
A Timely Warning About a Projected Rise in Charity Fraud
06.19.2025 | Linda J. Rosenthal, JD
“These days, there are few issues on which average Americans as well as lawmakers with diverse political affiliations can find common ground.”
That was the opening sentence of our April 3, 2025 post: Nonprofit Security Grant Program: Bipartisan Push to Unfreeze It. We tacked on: “There is a strong consensus, though, that messing around with FEMA is a terrible idea.”
That was true until Inauguration Day 2025 when the second Trump administration initiated a full-throttle effort to pull the rug out from under this important federal agency with a rich and distinguished history that “can be traced as far back as 1803.”
Suddenly, there were executive orders issued and other directives put in place to dismantle the “federal core” of the Federal Emergency Management Agency and to freeze “funds desperately needed for disaster relief and so much more.” Over the next month or so, federal courts intervened to unfreeze some of the FEMA money but that has not been the end of the story, as we explained in the April 3rd post.
Americans are most familiar with FEMA in connection with the rapid-response efforts when natural disasters or extreme weather events occur. The modern-day FEMA “was officially created in 1979 through an executive order by President Jimmy Carter” for the dual purposes of disaster relief and civil defense. Congress then passed statutes authorizing the expanded scope of FEMA.
The agency became part of the new Department of Homeland Security on March 1, 2003, in a series of administrative shuffles triggered by the September 11, 2001, attacks on the World Trade Center.
An activity under FEMA’s jurisdiction that is lesser known than disaster relief is the Nonprofit Security Grant Program (NSGP). It was “enacted in 2005 to address the “threat of terrorist attacks on nonprofit entities and institutions” and to be a “key component of FEMA’s strategy to improve the readiness of nonprofits—as well as state, local, tribal, and territorial governments—to anticipate, prevent, and defend against the threats posed by malicious actors intent on causing harm.” These needs include “target hardening and other physical security enhancements and activities” to help “nonprofit organizations that are at high risk of terrorist attack.”
As is the case in so many of the day-to-day decisions and actions by Trump 2.0, there was an abrupt change of course in mid-March 2025. Suddenly, the spigot for already allocated funds from the Nonprofit Security Grant Program was shut off. Slowly, information filtered down from Washington, D.C. that FEMA officials had embarked on a review of NSGP to evaluate its alignment with administration goals and beliefs, and to determine which previously approved awards to continue.
When word floated over to Congress about this development, a bipartisan group of 79 House members wrote a letter to the acting director of FEMA, demanding answers. “We are writing to express our concern following the Administration’s recent decision to immediately pause the drawdown of funding for federal grant programs supported by the Federal Emergency Management Agency (FEMA) to conduct an additional review of projects, including the Non-Profit Security Grant Program (NSGP)….” See: Amo Co-Leads Bipartisan Letter of 78 Colleagues to Reverse Funding Pause on Nonprofit Security Grant Program (March 21, 2025) Press Release & Letter.
The representatives’ letter continued: “At a time when hate and violence against faith-based communities across this country are at historic levels, the NSGP has provided life-saving funding to protect” them. The Administration has made clear its goal to protect Americans from terrorist threats both foreign and domestic, as well as to respond to the rise in hate crimes. Supporting the NSGP is critical to fulfilling that goal. The program has long enjoyed bipartisan support…. It is critical that those institutions that have already been awarded an NSGP grant are allocated the expected funding.”
The lawmakers closed their letter by calling on the administration to explain its rationale for the funding pause. They also asked to be briefed by officials by April 1st and before any firm decisions were made.
Did these members of Congress expect a timely reply? Who knows.
By the first week or so of May 2025, however, word spread that the spigot was back on. “After a months long pause, FEMA has once again started reviewing applications and reimbursing nonprofits already approved for the funds.” The FEMA website section was back up and running: Nonprofit Security Grant Program (NSGP) (97.008) (last updated May 6, 2025).
There is, of course, the matter of appropriations for the coming fiscal year. Reportedly, early in May, a bipartisan group of about “130 House members put forward the highest-ever request for nonprofit security funding for 2026”: namely, $500-million, which is nearly double the current funding level. Despite the substantial bipartisan support, the Trump administration’s “big beautiful bill” proposals included “significant cuts to the Federal Emergency Management Agency’s non-emergency grants — a category that includes NSGP.”
We mentioned in the April 3rd post that “California has its own state-funded security-grant program to augment (or partially replace) the federal program if FEMA becomes marginalized due to shifts in federal priorities.” The program is called the California State Nonprofit Security Grant Program available to 501(c)(3)s.
Several other states have such nonprofit security grant programs as well, but California’s is the largest.
Administered by CalOES, the Governor’s Office of Emergency Services, the “purpose of the CSNSGP is to provide funding support for physical security enhancements and other security-related activities to nonprofit organizations that are at high risk for violent attacks and hate crimes due to ideology, beliefs, or mission. The CSNSGP seeks to integrate the preparedness activities of nonprofit organizations with broader state and local preparedness efforts. The CSNSGP also promotes emergency preparedness coordination and collaboration activities between public and private community representatives ….”
Funds are available which “directly support physical security measures such as reinforced doors, gates, high-intensity lighting, access control systems, development and enhancement of security plans and protocols.”
Decisions on amounts available for this state program are part of California’s annual six-month budget process that begins each January 10th for the upcoming fiscal year starting July 1st. See CA Budget Time Again: Small Surplus is Back But Catastrophic Needs Ahead (January 11, 2025) FPLG Blog. Negotiations among Assembly members, Senators, and Governor Gavin Newsom must result in a balanced budget approved by lawmakers and signed into law on or before June 15th.
The most important period of budget deliberations has already begun with the publication on May 14, 2025, of the governor’s Mid-May Revision. That’s when the governor and his finance chief look at the actual revenue numbers from the first months of 2025, and disregard the early January figures which were estimates only.
Despite: (1) unexpectedly high Medi-Cal costs (attributable to a brand-new extension of benefits to undocumented persons) that turned a small surplus in January to a deficit now; and (2) the projected economic turbulence (nationally) ahead, Governor Newsom has proposed a generous amount for the security needs of the state’s nonprofits. The May Revision “… maintains $80 million one-time General Fund to implement the California State Nonprofit Security Grant Program, consistent with the two-year funding commitment in the 2024 budget agreement.” See Budget Summary from the Department of Finance at ebudget.ca.gov.: specifically, under “Office of Emergency Services.”
And that’s on top of the announcement from two months ago about the “largest-ever funding award of $76 million to 347 community groups and nonprofit organizations to protect them from hate-motivated violence.” See Governor Newsom announces record-breaking $76 million to safeguard local faith communities and nonprofits (March 24, 2025), gov.ca.gov.
Of course, the final numbers going forward will not emerge until completion of the negotiations that result in the constitutionally required balanced budget.
The tragic shooting on May 21, 2025, in downtown Washington D.C., leaves no doubt – if ever there was – as to the existence of persistent security threats against sectarian nonprofit institutions. The need is clear for vigilance as well as robust financial support for “target hardening.”
We’ll save for another day and another post a discussion about faith-based organizations sometimes being too trusting – too welcoming – of strangers. Not only had the shooter easily purchased a ticket to the event a few hours earlier, but – after the crime – he wandered inside the building. Other patrons reported thinking he was a “distressed bystander” to the attack. They comforted him, offering a glass of water.
Consider similar circumstances at the Emanuel African Methodist Episcopal Church on June 17, 2015, or at Congregation Beth Israel in Colleyville, Texas, on January 15, 2022.
There are no easy answers.
– Linda J. Rosenthal, J.D., FPLG Information & Research Director