We expect the U.S. Department of Homeland Security to release the guidance on the program to the states on or about March 18th. We don’t expect any major changes in the requirements. New York DHSES will secure the necessary approvals and release their Request for Applications the following week.

This year’s budget includes $13 million in federal funding to help protect high-risk non-profit institutions from terrorist attacks. This is a $3 million increase over the fiscal year 2013 funding levels for the Nonprofit Security Grant Program. New York nonprofits must pre-qualify (see below), which may take several weeks (see below). While completing the pre-qualification process, organizations should assemble the materials for their Investification Justification (see here). Get started now!

New York’s new requirement

Pre-qualify with NY State. Applications from New York nonprofit organizations that have not “pre-qualified” will not be considered, so we recommend that you start this process immediately. Your pre-qualification package cannot be approved overnight – don’t wait until the last minute.

See the Grants Gateway at http://grantsreform.ny.gov/.

• Written resources. The Grants Gateway website contains the definitive information. Be sure to check the required list of documents at Documents and Questions. More information can be found at the FAQs About Prequalification and the full manual.
• Assistance. Any organization unsure about how to respond to the questions should contact the Statewide Grants Reform office at grantsgatewayhelp@budget.ny.gov or (518) 474-5595. While we try to learn as much as we can, the advice given by the Statewide Grants Reform office is definitive.
• Documents. The Grants Gateway website has lots of information. You should consider their requirements and answers as the final word. A short list of the documents that organizations are required to submit include:

1. Certificate of Incorporation or equivalent document.
2. IRS 501(c)(3) determination letter. As long as your organization is seeking tax exempt status and can show that it
   has applied for a 501(c)(3) tax exemption from the IRS, then the uploading of a copy of your application form or a copy of the receipt letter from the IRS, is sufficient. They also recognize that some tax exempt organizations are not required to file for IRS 501(c)(3) recognition.Your organization will not be penalized if you do not submit its determination letter, if:

• you are not required to have one; and
• you write a letter attesting to the fact. For example, houses of worship and organizations incorporated pre-1969 are not required to file for 501(c)(3) recognition . Religious organizations need only provide a statement, including their official name, stating that they are a religious corporation and exempt from IRS recognition.

• IRS 990. Houses of worship and some other religious corporations are not required to file an IRS 990. If your organization is not required to file an IRS 990, Religious organizations need only include a statement, including their official name, stating that you are a religious corporation and exempt from the requirement to file an IRS 990. If you do file, please include your latest IRS Form 990.
• Audit/Reviews and Findings. In NY, organizations with revenues greater than $250,000 must provide an independently audited financial statement. Organizations with revenues of less than $250,000 but greater than $100,000, must provide a financial statement reviewed by a CPA. Organizations with revenues of less than $100,000 need only provide a copy of the most recent internal financial report.

• Exceptions.
  • Religious organizations pursuing religious activity are exempt from the financial filing requirements regarding audit/reviews and findings.
    If you are a religious organization pursuing religious activity, you need only include a statement, including your official name, stating that you are a religious corporation pursuing religious activity and not required to report or file financial information with the New York State Attorney General.
  • However, religious organizations that engage in any form of secular activity (i.e. food bank, daycare, social justice advocacy, secular education, job training, conservation, after school athletics, etc.) must file through the Grants Gateway their audit/reviews or findings, consistent with their level revenues .
  • JCRC has inquired whether certain schools, exempt from filing with the New York State Attorney General, are required to file audit/reviews or findings.
• NY State Attorney General Charities Bureau Form CHAR500 or CHAR410. Most not-for-profit organizations must file either a CHAR 410 (for newly formed entities within the first year of operations) or a recent CHAR 500 with the NY State Charities Bureau. Religious organizations, as well as educational corporations that confine solicitations to their student body, alumni, faculty and trustees and their families; need only include a statement, including their official name, stating that they are a religious or an educational corporation and exempt from registration with the New York State Attorney General.
• Board of Directors Profile. A sample profile template can be found here. This document should include board member names and affiliations, a list of the board committees and chairs, and a list of board officers.
• Senior Leadership Resumes.
  Not-for-profits must upload the resumes or CV’s of their Senior Leadership team. The positions included should be Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Executive Director, President, or other high ranking officials. Individuals should upload their own resume or CV.
• Corporate Bylaws

There are also questions covering organizational policies supporting good governance, etc. The Grants Gateway (especially the manual) website has the rationale, samples and links to other sites with further information.

The Grant itself

Vulnerability assessment. We expect that the “Investment Justification” will again be based on a “previously conducted vulnerability assessment.” See Getting a vulnerability assessment for more details and suggestions.

• Read and understand the Investment Justification. Download the Investment Justification from last year here. There will be some changes, but they are usually minor. You can find JCRC-NY’s guidance on each section on the “Security Grants” webpage (and below). Note: many applicants lost points last year because they did not properly respond to the questions.

• Applicant Information
• Background
• Risk: Threats, Vulnerabilities & Potential Consequences
• Target Hardening
• Milestones
• Project Management
• Impact