NSGP funding is not a blank check for security spending. FEMA ties every award to a set list of allowable cost categories published in the annual Notice of Funding Opportunity (NOFO), and a budget line that doesn’t fit cleanly into one of them gets flagged before it’s ever scored.
The short answer: current NSGP funding recognizes seven categories of allowable spending. Two of them, Maintenance and Sustainment, and Construction and Renovation, are the ones applicants most often don’t realize exist. This guide walks through all seven ways NSGP funding can be used, in plain terms, along with the handful of costs people commonly assume are covered but aren’t.
Not sure how NSGP funding applies to your organization’s project? Book a free consultation with SGA
The Seven NSGP Funding Categories at a Glance
- Planning
- Equipment
- Training and Exercises
- Maintenance and Sustainment
- Construction and Renovation
- Contracted Security Personnel
- Management and Administration (M&A)
Each category has its own rules, and some carry a percentage or dollar cap. Here’s what NSGP funding actually covers in each one.
1. Planning
Planning covers the documents and assessments an organization needs before it spends a dollar of NSGP funding on equipment or guards. That includes developing or updating a security plan, writing an emergency contingency plan, building an evacuation or shelter-in-place plan, and coordinating with local fusion centers on information sharing. It can also include a risk assessment of the facility’s physical and connected systems.
Planning has to be tied to protecting the facility and the people in it, including people with access and functional needs and those with limited English proficiency. Other planning activities are allowable with prior approval from FEMA, so it’s worth asking your State Administrative Agency (SAA) before assuming something outside this list qualifies.
Related: [How to Write a Security Plan for Your NSGP Application](INTERNAL LINK → /your-security-plan-blog-slug/)
2. Equipment
Equipment is the category most applicants think of first when they picture NSGP funding, and usually the largest line in the budget. NSGP ties every equipment purchase to FEMA’s Authorized Equipment List (AEL). If an item isn’t on the list, it isn’t fundable, no matter how directly it addresses a real vulnerability.
Common allowable equipment includes:
- Physical hardening: reinforced doors, ballistic-resistant film, bollards, fencing, and gates
- Access control: card readers, electronic locks, video intercoms, and visitor management systems
- Surveillance: camera systems, video management software, and supporting lighting
- Alarms and sensors that flag when a security system is failing or has been tampered with
- Screening equipment such as walk-through magnetometers
One detail worth flagging because it surprises people: the AEL specifically excludes license plate reader software and software that automatically identifies individuals from video footage. Neither is fundable under the current list, even though both are widely marketed as security tools.
Equipment must be installed on property the organization owns or leases, and it has to be justified by a documented vulnerability, not by the age of what’s currently in place.
Related: [Which Security Equipment Actually Qualifies for NSGP Funding](INTERNAL LINK → /your-equipment-blog-slug/)
3. Training and Exercises
The current NOFO treats training and exercises as one combined category, which is why it doesn’t show up as two separate line items on some budget worksheets.
Training covers attendance fees, materials, and instruction for staff, volunteers, and congregants. Topics are limited to security-related subjects: active shooter response, Stop the Bleed and basic first aid, indicators of extremist threats, and similar preparedness training. Overtime, backfill pay, and travel costs are not allowable, even when the training itself is.
Exercises are the drills that test what the training and planning produced. This includes tabletop exercises, functional exercises, and full-scale exercises, along with the facilitation, meeting space, and materials that go with them. Exercises have to follow Homeland Security Exercise and Evaluation Program (HSEEP) methodology and produce an after-action report with an improvement plan. An exercise that doesn’t produce that documentation isn’t reimbursable.
4. Maintenance and Sustainment
This is the category most applicants don’t know NSGP funding covers, largely because it’s easy to assume equipment funding stops the day it’s installed.
Maintenance contracts, warranties, repair costs, replacement costs, upgrades, and user fees are all allowable. If a warranty or sustainment plan is purchased as part of the original equipment purchase, it can extend past the grant’s period of performance. If an organization is instead buying a stand-alone warranty or extending an existing maintenance contract later, that coverage can’t run past the period of performance for the award that’s paying for it.
In practice, this category is what keeps a funded camera system or access control system working in year three, not just year one.
5. Construction and Renovation
This category exists, but it’s tightly conditioned. NSGP funding cannot be used for construction or renovation without prior written approval from FEMA, and the total cost of any approved construction or renovation cannot exceed the greater of $1,000,000 or 15% of the award.
Some equipment installations can technically count as construction or renovation depending on scope, so it’s worth checking with your SAA or FEMA Preparedness Officer before assuming a project falls outside this category or before assuming it needs no approval at all. Either mistake, assuming it’s automatically covered or assuming it’s automatically off-limits, can slow an application down.
6. Contracted Security Personnel
NSGP funding can pay for contracted security personnel from a licensed third-party vendor, including off-duty law enforcement officers contracted through their agency. This has to comply with FEMA’s Information Bulletin 441.
There is no percentage cap on this category federally. An organization can direct up to 100% of its NSGP funding award to contracted security personnel if that’s what its vulnerability assessment supports. What NSGP funding cannot cover is equipment for that contracted security team. Equipment for contract guards has to come from the Equipment category and follow the AEL, or be provided by the vendor itself.
It’s worth noting this is a place where federal rules and state program rules genuinely diverge. Several state security grant programs — including [California’s CSNSGP](INTERNAL LINK → /your-csnsgp-page-slug/) and [Connecticut’s CT-NSGP](INTERNAL LINK → /your-ct-nsgp-page-slug/) — cap contracted security at a set percentage of the request. Federal NSGP does not.
7. Management and Administration (M&A)
M&A covers the administrative cost of managing NSGP funding itself: preparing and submitting required reports, maintaining an equipment inventory, documenting expenditures, and responding to oversight requests from the SAA or FEMA. Both the SAA and the individual nonprofit subrecipient can use up to 5% of their respective award for M&A purposes.
M&A is a separate line from indirect costs. Indirect costs, the shared overhead a nonprofit allocates across multiple funding sources, are handled through a different process under 2 CFR Part 200 (Uniform Guidance for federal awards) and are not simply folded into the 5% M&A figure. Organizations that plan to charge indirect costs to an NSGP award should talk to their SAA early, since the process depends on whether the organization already has a negotiated rate.
What NSGP Funding Does Not Cover
Even with seven categories, several costs applicants often assume NSGP funding includes are not actually eligible:
- In-house staff salaries. Security directors, facilities managers, and other employees on the organization’s own payroll are not funded outside the narrow M&A direct charge for documented grant management time.
- Equipment not on the AEL. This includes license plate reader software and facial identification software, regardless of the vulnerability it’s meant to address.
- General construction beyond the approved category. Roof replacement, footprint expansion, or renovation unrelated to security cannot be bundled into a hardening project, and any construction still requires prior FEMA approval.
- Fundraising and matching costs. NSGP funding cannot be used as matching funds for another federal grant, and staff time spent on fundraising is not allowable.
- Lobbying and legal claims against the government. These are excluded under standard federal grant cost principles, not just NSGP-specific rules.
- Contract security equipment. As noted above, the personnel contract is fundable; the gear for that contractor is not, under this category.
What This Means for Your Organization
The seven-category structure of NSGP funding is more forgiving than a lot of applicants assume, particularly once Maintenance and Sustainment and Construction and Renovation are accounted for. It’s also stricter in specific spots, like the AEL’s exclusion of certain surveillance software, that can quietly sink a budget line if no one catches it before submission.
The practical takeaway is to build a budget against the current year’s NOFO category by category, not against last year’s approved budget or a state program’s rules. Categories, caps, and even what counts as allowable equipment change from cycle to cycle.
Not sure how these categories apply to your organization’s specific project? We’re happy to help you think it through. Book a free consultation with SGA.
Official Sources
Every claim in this guide traces back to a primary federal source. Confirm the current cycle’s allowable cost categories, percentage caps, and AEL contents at the official sources below before assembling a budget.
- FEMA Nonprofit Security Grant Program (NSGP)
- Grants.gov opportunity portal
- 2 CFR Part 200 (Uniform Guidance for federal awards)
- U.S. Department of Homeland Security
