The U.S. Department of Homeland Security (DHS) released its initial guidance today. The New York Department of Homeland Security and Emergency Services (DHSES) hopes to have the necessary approvals and release their Request for Applications sometime next week. We’ve begun to update our webpage www.jcrcny.org/securitygrants with the 2014 material.
The application package for New York nonprofits will be due around the end of April, possibly as late as May 9th. DHS should announce the results at the end of July. The DHS materials are available here. Remember: The “applicants” referred to in the links on the DHS page are the state agencies. All organizations are bound by the requirements of and dates set by New York DHSES. The New York materials will be available at http://www.dhses.ny.gov/grants/nonprofit.cfm when they are approved.
The big change this year is that 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-qualification
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/.
- First steps.
- Fill out the Registration Form for Administrator, have it notarized.
- Create an organization chart that shows the head of your organization. The state has some samples here. JCRC-NY created a sample for religious schools here. Be sure to fill in the appropriate names in the boxes.
- New applicants must request an SFS ID. Do so by completing a copy of Substitute W-9.
- Mail the notarized Registration Form, Substitute W-9 and Organizational Chart to: Division of Budget – Grants Reform, Agency Building 1 – 5th Floor, Empire State Plaza, Albany, NY 12224.
- Tutorial. Watch the video on completing the Pre-Qualification process here.
- 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 firstname.lastname@example.org 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:
- Certificate of Incorporation or equivalent document.
- 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.Prequalification Audit Change.
- Previous Audit Requirement – CPA reviewed audit with management letter for organizations with revenues over $250K.
- New Audit Requirement (3/25/2014) – Entities that are exempt by Executive Law § 172-a from submitting financial disclosure materials to the Attorney General’s Charities Bureau (such as religious organizations involved in exclusively non-secular activities) should, regardless of their annual revenue, provide their most recent internal financial report reviewed by the board. This is the same financial disclosure requirement for prequalification that applies to organizations with revenues of less than $100,000.
- 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 CHAR500 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. If you have any questions about prequalification, please go to the Grants Reform website at http://www.grantsreform.ny.
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.