Page 1 GAO-06-663R Homeland Security Assistance for Nonprofits 

May 22, 2006 

The Honorable Judd Gregg 

Chairman 

The Honorable Robert C. Byrd 

Ranking Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

United States Senate 

The Honorable Harold Rogers 

Chairman 

The Honorable Martin Olav Sabo 

Ranking Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

House of Representatives 

Subject: Homeland Security Assistance for Nonprofits: Department of Homeland Security 

Delegated Selection of Nonprofits to Selected States and States Used a Variety of Approaches to 

Determine Awards

The fiscal year 2005 Department of Homeland Security (DHS) appropriation1

 set aside 

$25 million, of the $885 million appropriated for the Urban Areas Security Initiative (UASI), for 

grants to eligible nonprofit organizations that the Secretary of Homeland Security determined to 

be at high risk of international terrorist attack.2

 This letter responds to the conference report that 

directed GAO to review the validity of the threat and risk factors used by DHS to allocate 

discretionary grants to nonprofit organizations in fiscal years 2003, 2004, and 2005.3

 Based on our 

review of DHS’s risk methodology for fiscal year 2006, the criteria in the fiscal year 2005 grant 

application kit, and conversations with your staff about the conference report, we addressed the 

following objectives: (1) DHS’s methodology for determining risk for urban areas and the 

nonprofit grant program, and DHS implementation of the program; (2) states’ efforts to 

implement the nonprofit grant program in fiscal year 2005, and (3) whether subgrants were made 

to nonprofits in fiscal years 2003 and 2004, when funds were not specifically set aside for 

 1

 Pub. L. No. 108-334, 118 Stat. 1289, 1309 (2004). 

2

 Nonprofits are those organizations described by 26 U.S.C. §501(c)(3). 

3

 H.R. Conf. Rep. No. 109-241, at 65 (2005). 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-06-663R Homeland Security Assistance for Nonprofits 

nonprofits. On May 3, 2006, and May 8, 2006, we briefed your offices on the results of our review. 

This letter, and the accompanying slides, transmits information provided during those briefings. 

Summary 

To implement the fiscal year 2005 nonprofit grant program, DHS used a two-tiered approach, first 

determining the urban areas in which nonprofits would be eligible to apply for the funds and then 

providing guidance to the states on how to allocate the funds to applicants. In the first stage, 

DHS determined that in the absence of information from federal law enforcement about risk to 

specific nonprofit organizations, those nonprofits that were located in the highest risk urban 

areas were most at risk of international terrorist attack. DHS used a model based on five factors 

to determine the urban areas that would receive fiscal year 2005 UASI grants and the grant 

amount for each area. Using this model, fifty urban areas were determined to be at high risk. Of 

those 50, the top 18—located in 13 states and the District of Columbia4

—were selected to receive 

portions of the $25 million set aside for nonprofit organizations (nonprofits in urban areas that 

did not receive a nonprofit allocation could still apply for subgrants from the State Homeland 

Security and UASI grant programs). The amounts allocated were based upon each area’s 

contribution to the overall risk in the 18 areas. In the second stage of the process, DHS delegated 

to the states the authority to make subgrants to organizations, but required them to use six risk 

criteria provided by DHS to determine organizations at high risk of international terrorist attack. 

According to DHS, it made this delegation because it had no information about credible threats 

against nonprofits by international terrorist organizations, and it believed that state and local law 

enforcement might have credible information and that states and urban areas might be in a better 

position to assess threats within their areas. DHS then provided programmatic guidance to the 

states along with the six risk criteria that states were to consider in determining eligibility and 

selecting nonprofits for subgrants. These criteria addressed the three elements of risk--threat, 

vulnerability, and consequences. The criteria did not require actual threats against facilities 

within the United States. Individual awards were not to exceed $100,000 and were for target 

hardening only. DHS retained responsibility for managing the grant program and for monitoring 

the awards it made to the states with the nonprofit funding. 

The 13 states and the District of Columbia implemented the program using differing approaches. 

They interpreted the DHS guidance as providing flexibility in implementing the program. They 

used several approaches in working with their urban areas and required nonprofit applicants to 

provide varying amounts of risk-related information and organizational capacity information. The 

threat information provided by the nonprofit applicants varied in specificity and the degree to 

which it referred to threats from international terrorist groups; none provided reports of threats 

 4

 The District of Columbia received funding for the National Capital Region (NCR). The District of Columbia, the 

counties of Montgomery and Prince George’s, Md.; the counties of Arlington, Fairfax, Prince William, and Loudon, Va.; 

the cities of Falls Church, Manassas, Manassas Park, Fairfax, and Alexandria, Va., comprise the NCR. 
Page 3 GAO-06-663R Homeland Security Assistance for Nonprofits 

or attacks by international terrorist organizations against the specific facilities of the nonprofit 

applicants that were located within the United States. The vulnerability information included 

some professional assessments. Some applicants claimed proximity to critical infrastructure; 

others cited the presence of particular individuals as indications of vulnerability. Information on 

potential consequences generally related to the size of the organization and included number of 

employees or persons served as indicators of potential consequences. The states and urban areas 

generally relied on law enforcement to assess threat and vulnerability. Some of the states and 

urban areas developed formal methods for assessing the nonprofit organizations’ risk and 

capacity to implement the proposed projects. About 400 awards were made, out of 600 

applications. Most recipients were religious organizations. Medical and social services were the 

second and third largest categories. The average amount awarded was about $62,000. State and 

urban area officials reported a range of views about target hardening for nonprofit organizations. 

For example, some stated that the subgrants met a need, but that nonprofits, relative to other 

critical infrastructure, were a comparatively low priority for funding, and most said they had not 

received inquiries from nonprofits about the availability of funding for target hardening prior to 

the fiscal year 2005 allocation. Others said that the $100,000 limit on target hardening subgrants 

was insufficient to address need. Some officials also noted that target hardening funds were 

already allowable under the State Homeland Security and UASI grant programs and that a 

specific allocation for nonprofits constrained their ability to address the security issues of other 

types of organizations. Finally, officials reported that they generally lacked the capacity to 

conduct the type of vulnerability assessments needed to determine the relative risk to nonprofit 

organizations within their areas and that in implementing the nonprofit grant program, they 

needed additional guidance and support from DHS; implementing the program added additional 

unreimbursable administrative costs; and they varied in the degree to which they could 

determine that the program reduced the overall risk of terrorist attack to their area. 

About 18 UASI subgrants were made to nonprofits in fiscal years 2003 and 2004. No funding was 

set aside specifically for nonprofits in the DHS appropriations for those years. Nonprofits were 

eligible for subgrants, but many states were unaware that they could make subgrants to 

nonprofits. The subgrants that were made to nonprofits were generally for citizen preparedness 

and capability enhancement for emergency response organizations. None were for target 

hardening. 

Scope and Methodology 

To review the DHS methodology for determining risk for urban areas and the nonprofit grant 

program and the decision to delegate the selection of nonprofit subgrantees to the states, we 

interviewed officials and reviewed documentation from DHS. To address the remaining 

objectives, we interviewed officials from the 18 urban areas that received fiscal year 2005 

nonprofit allocations; reviewed solicitations for applications; reviewed copies of applications, 

where available; interviewed officials from 17 additional urban areas that did not receive fiscal 

year 2005 nonprofit allocations; and reviewed DHS data and documentation. We assessed the 

reliability of the data and determined that it was sufficient for our purposes. 
Page 4 GAO-06-663R Homeland Security Assistance for Nonprofits 

We conducted our work in accordance with generally accepted government auditing standards 

from February 2006 through April 2006. 

We provided the Department of Homeland Security with a draft of this report. It provided 

technical comments that have been incorporated into this report. 

As agreed with your office, we will send copies of this report to relevant congressional 

committees and subcommittees and to the Secretary of the Department of Homeland Security. 

Copies of this report will also be made available to others upon request. In addition, this report 

will be available on GAO’s Web site at http://www.gao.gov. 

If you or your staff have questions regarding this report, please contact me at (202) 512-8757 or 

by e-mail at jenkinswo@gao.gov or William Sabol at (202) 512-3464 or by e-mail at 

sabolw@gao.gov. Key contributors to this report were David Alexander, Frances Cook, Kathryn 

Godfrey, Daniel Kaneshiro, Doris Page, and Nettie Richards. 

William O. Jenkins Jr. 

Director, Homeland Security and Justice Issues 

Enclosure—2 
Enclosure I: Fiscal Year 2005 UASI Nonprofit Allocations, Number of 

Applications and Nonprofit Grants Awarded 

Page 5 GAO-06-663R Homeland Security Assistance for Nonprofits 

Nonprofit organizations applying, 

awarded, and not funded 

State Urban area 

Amount 

allocated to 

nonprofit 

organizations

Number of 

organizations 

applying

Number 

funded

Number 

not funded 

Number of 

solicitations

Amount of 

nonprofit 

allocation 

not awarded 

as of March 

31, 2006

Anaheim $114,490 0 0 0 2 $114,490 

San Francisco 935,551 7 6 1 2 394,141 

Los Angeles 3,750,000 88 46 42 1 0 

California 

San Diego 320,885 8 6 2 1 0 

District of Columbia National Capital Region 4,500,000 38 37 1 2 c 1,706,527 

Florida Miami 402,110 28 18 10 1 0 

Georgia Atlanta 216,068 15a15 0 NA 0

Illinois Chicago 3,000,000 41 38 3 2 73,000

Maryland Baltimore 132,160 45 38b7 1 0

Massachusetts Boston 2,075,000 43 25 18 1 0

Michigan Detroit 516,028 6 6 0 1 0

New Jersey Newark 181,298 8a 7 1 NA 0

New York New York City 6,311,701 203 113b90 1 0

Oregon Portland 100,000 4 2 2 1 0

Pennsylvania Philadelphia 1,347,598 76 29 47 1 0

Texas Dallas 261,148 5 2 3 1 0

Houston 681,984 13 13 0 1 0

Washington Seattle 153,978 7 3 4 1 0

Total $24,999,999 635 404 231 $2,288,158

Source: GAO analysis of DHS data and interviews with state and urban area officials. 

a

UASI regions selected applicants and awardees rather than issuing solicitations. 

b

Additional DHS funds were used to supplement the initial UASI nonprofit allocation to enable funding this number of applicants.

c

Awards for the second solicitation had not been made at the time of our review. 

Enclosure I: Fiscal Year 2005 UASI Nonprofit 

Allocations, Number of Applications and 

Nonprofit Grants Awarded 
Enclosure II: Presentation 

Page 6 GAO-06-663R Homeland Security Assistance for Nonprofits 

Enclosure II: Presentation 

1

Homeland Security Assistance for Nonprofits: DHS 

Delegated Selection of Nonprofits to Selected States 

and States Used a Variety of Approaches to 

Determine Awards

Briefing to the Subcommittees on 

Homeland Security 

House and Senate Committees on 

Appropriations

May 3, 2006 and May 8, 2006
Enclosure II: Presentation 

Page 7 GAO-06-663R Homeland Security Assistance for Nonprofits 

2

GAO Directed to Study Risk Factors Used in Nonprofit 

Grant Program

• FY 2005 DHS appropriations act provided:

– $25 million of the $885 million appropriated for the Urban Areas Security 

Initiative (UASI) grant program to be set aside for grants to eligible 

nonprofit organizations.

– Eligible nonprofit organizations were:

• Private, nonprofit, and tax-exempt as described by 26 U.S.C. § 501(c)(3).

• Those the Secretary of Homeland Security determined were at high risk of 

international terrorist attack.

• No similar provisions for nonprofit organizations in FY 2003 or FY 2004 

DHS appropriations.

• Conference Report 109-241 accompanying FY 2006 DHS appropriations 

directed GAO to study:

– The validity of the threat and risk factors used to allocate discretionary grants, 

including a project-by-project analysis of grants to nonprofit organizations, in 

fiscal years 2003, 2004, and 2005.
Enclosure II: Presentation 

Page 8 GAO-06-663R Homeland Security Assistance for Nonprofits 

3

Objectives for This Briefing

• Based on our review of DHS’s risk methodology for fiscal year 2006, the criteria in the fiscal year 2005 grant application kit, and conversations with 

your staff about the conference report, this briefing covers: 

– DHS methodology for determining risk for urban areas and the nonprofit 

grant program and the decision to delegate the selection of nonprofit 

subgrantees to the states;

– States’ efforts to implement the nonprofit grant program:

• how states organized their efforts to identify and fund eligible organizations and 

what information they required from the applicants;

• how many nonprofits applied and what information they provided about the risk of 

international terrorist attack;

• how states and urban areas assessed the information provided and how many 

nonprofits were funded; and

• officials’ views about the fiscal year 2005 nonprofit grant program.

– Whether subgrants were made to nonprofits in fiscal years 2003 and 

2004 when funds were not specifically set aside for nonprofits.

Note: A subgrant is an award of financial assistance made under a grant by the grantee to 

an entity that is eligible to receive some or all of the grant funds.
Enclosure II: Presentation 

Page 9 GAO-06-663R Homeland Security Assistance for Nonprofits 

4

Scope and Methodology

• To determine DHS risk methodology and assess the delegation decision, 

we interviewed officials and reviewed documentation from DHS.

• To address the remaining objectives, we

– interviewed officials from the 18 urban areas (in 13 states and the District of 

Columbia) that received fiscal year 2005 nonprofit allocations, including 

representatives from State Administrative Agencies (SAA), Urban Area Working 

Groups (UAWG), and the Urban Areas Security Initiative (UASI) program;

– reviewed solicitations for applications;

– reviewed copies of applications, where available; 

– interviewed officials from the 17 additional urban areas that received UASI funds 

in at least 1 fiscal year 2003-2005, but did not receive fiscal year 2005 nonprofit 

allocations; and

– reviewed DHS data and documentation.

• We assessed the reliability of the data and determined that it was sufficient 

for our purposes.

• We conducted our work in accordance with generally accepted government 

auditing standards from February 2006 to April 2006.

Note: The District of Columbia received funding for the National Capital Region (NCR). The District of Columbia, counties of 

Montgomery and Prince George’s, Md.; the counties of Arlington, Fairfax, Prince William, and Loudon, Va.; the cities of Falls Church, 

Manassas, Manassas Park, Fairfax, and Alexandria, Va., comprise the NCR.

Note: SAAs are the state administrative agencies responsible for allocating funds to the urban areas. Points of contact from local 

jurisdictions within the defined urban areas comprise the UAWGS, which are responsible for determining the eligibility and selection 

criteria for nonprofits in coordination with the SAA.
Enclosure II: Presentation 

Page 10 GAO-06-663R Homeland Security Assistance for Nonprofits 

5

For FY 2005, DHS Used a Two-Tiered Approach to 

Determine Risk to Nonprofit Organizations of International 

Terrorist Attack

• To implement the nonprofit grant program according to the FY 2005 

appropriations act, DHS used a two-tiered approach:

– Tier 1: DHS determined that in the absence of information from federal law 

enforcement about the risk* to specific nonprofit organizations, those nonprofits 

that were located in the highest risk urban areas, as determined by its methodology for determining high-risk urban areas, were most at risk of 

international terrorist attack. 

– Tier 2: DHS delegated to states the selection of nonprofit organizations for subgrants located in the 18 highest risk urban areas and required that states use six criteria that it provided to them in determining risk to nonprofit organizations.

• DHS viewed its role under the FY 2005 appropriations act as one of allocating the $25 million nonprofit set aside among urban areas on the 

basis of the overall risk of attack to these areas and to provide risk-related 

criteria to guide states in selecting nonprofit subgrantees.

• DHS provided guidance to states and retained responsibility for managing 

the grant program and for monitoring the awards it made to the states with 

the nonprofit funding.

*DHS officials stated that, according to federal law enforcement and the federal intelligence community, there were no 

known credible threats against 501(c)(3) nonprofit organizations. Credible threat means information or knowledge derived 

from a source with direct access to sensitive information, having an established reporting record or whose past reporting 

has been corroborated by other sources and has or is capable of responding to collection taskings for information 

regarding terrorist plans, activities or intentions regarding an attack against the United States. 
Enclosure II: Presentation 

Page 11 GAO-06-663R Homeland Security Assistance for Nonprofits 

6

Tier 1: DHS Used a Model Based on Five Variables to 

Determine FY 2005 UASI Locations and to Allocate the 

Funding for Nonprofits

• 50 of 303 urban areas were determined to be high-risk urban areas 

based on a model that used five variables to create an index of risk.

Variables were:

– Credible threat.

– Law enforcement investigative and enforcement activity.

– Presence of critical public and private infrastructure weighted by 

vulnerability of attack and consequences of loss.

– Population and population density.

– Existence of formal, written mutual aid agreements. 

• Data analyzed included law enforcement data on threats, key 

assets, vulnerability, and loss assessments.

• Allocation of the $885 million in UASI funds among the 50 areas 

was proportionate to each area’s contribution to the overall relative 

risk index.
Enclosure II: Presentation 

Page 12 GAO-06-663R Homeland Security Assistance for Nonprofits 

7

Tier 1: Allocations to Nonprofits in 18 Areas

• In absence of information about specific threats to nonprofit organizations, DHS determined that the nonprofits in the highest risk urban areas were most at risk of international terrorist attack.

• 18 urban areas at highest risk of international terrorist attack, based on UASI allocation model, were selected to receive portions of the $25 million set aside for nonprofit organizations (see encl. I).

• DHS limited the nonprofit funding to 18 areas to increase the dollar amount 

of awards.

• Nonprofits in urban areas that did not receive a nonprofit allocation could apply for funds from State Homeland Security and UASI grant programs.

• Method to allocate portions of the $25 million nonprofit set aside among urban areas presumes that the risk to nonprofit organizations in different 

areas equals the overall risk to the urban areas:

– Amounts for nonprofit grants allocated to each area were based upon each area’s contribution to the overall risk to the 18 areas, as

determined by the methodology used to identify the 50 highest risk 

urban areas in FY 2005.

– DHS methodology for determining high-risk urban areas did not include specific measures for the presence of or risk to nonprofit organizations 

within urban areas.
Enclosure II: Presentation 

Page 13 GAO-06-663R Homeland Security Assistance for Nonprofits 

8

Tier 2: DHS Delegated to States the Selection of Nonprofit 

Subgrantees in the 18 Highest Risk Areas and Required 

States to Use Six Criteria in Determining Risk

• DHS delegated to the states the authority to make subgrants to 

organizations, but required them to use six criteria provided by DHS to 

determine organizations at high risk of international terrorist attack.

• DHS reasoned: 

– It had no information from federal law enforcement about credible 

threats against specific nonprofits by international terrorist 

organizations.

– State and local law enforcement might have credible information about 

threats against nonprofits.

– States and urban areas may be in a better position to assess threats 

within their areas because

• States have their own homeland security strategies.

• States know their own assets and localized threats better than DHS.

• States are in a better position to work with state and local law enforcement 

officials to evaluate local risk to nonprofits.
Enclosure II: Presentation 

Page 14 GAO-06-663R Homeland Security Assistance for Nonprofits 

9

Tier 2: DHS Provided Programmatic and Risk-Related 

Guidance to the States for the Nonprofit Grant Program

• Guidance on the nonprofit grant program to states was in 

the fiscal year 2005 Homeland Security Grant Program 

guidelines and application kit, issued in December 2004.

• Programmatic guidance:

– Funding to be made through the UASI program.

– States to coordinate with their UAWGs to determine 

eligibility and selection criteria.

– States required to issue solicitations within 60 days.

– Subgrant awards limited to target hardening

• DHS believed this to be consistent with purpose of the 

program—to deter and mitigate terrorist attacks.

– Individual awards were not to exceed $100,000.
Enclosure II: Presentation 

Page 15 GAO-06-663R Homeland Security Assistance for Nonprofits 

10

Tier 2: DHS Risk-Related Guidance (cont.)

• DHS provided six risk criteria that states were to consider in determining 

eligibility and selecting nonprofits:

– Threats from U.S. Department of State designated international terrorist 

organizations against any group of U.S. citizens who operate or are principal 

beneficiaries or users of the nonprofit organization.

– Prior attacks, within or outside the U.S., by international terrorist organizations 

against the nonprofit organization or entities associated with or similarly 

situated as the nonprofit organization.

– Symbolic value (highly recognized national cultural or historical institution).

– Role of the nonprofit organization in response to international terrorist attack.

– Previously conducted threat and/or vulnerability assessments.

– Increased threats to specific sectors and/or areas.

• Criteria address threat, vulnerability, and consequences elements of risk

• First two criteria did not require threats against nonprofit facilities within 

the United States

– DHS viewed international threats and attacks against similar organizations or people as indicating the possibility of domestic attacks. 
Enclosure II: Presentation 

Page 16 GAO-06-663R Homeland Security Assistance for Nonprofits 

11

States Used Different Approaches in Implementing the 

Nonprofit Grant Program

• Most urban area officials we contacted viewed DHS guidance as providing 

them with flexibility in implementing the program.

• States used several approaches in working with urban areas to develop 

criteria and make selections, including:

– SAA and UAWG worked collaboratively in developing criteria and 

reviewing applications,

– The UAWG reviewed applications and made funding decisions, or 

– SAA implemented the grant program without major UAWG involvement.

• 16 of 18 urban areas issued general solicitations; 2 solicited applications by 

invitation to specific organizations

• Some states required nonprofit applicants to provide risk-related information 

and some organizational capacity information:

– Risk information requested included threat, vulnerability assessments, 

role of the nonprofit in responding to attacks, and prior efforts to 

enhance security.

– Organizational capacity included project plan, management, and budget 

information.
Enclosure II: Presentation 

Page 17 GAO-06-663R Homeland Security Assistance for Nonprofits 

12

States Requested Varying Amounts of Detail about Risk 

and Capacity

• Amount of information requested ranged from relatively little to very 

detailed:

– Little: Select which of DHS 6 risk criteria best apply to the applicant and 

provide a short narrative on how the funds would enhance the 

applicant’s overall readiness in the event of a terrorist attack. Five of the 

18 urban areas requested this information from nonprofits.

– Detailed: Extensive description of the applicant’s current security 

capabilities and planned upgrades; description of how each of DHS risk 

criteria apply, the role of the nonprofit in responding to international 

terrorist attacks, the potential consequences of an attack, detailed 

descriptions of threats and prior attacks against the organization, and 

examples of collaboration with law enforcement. Eleven of the 18 urban 

areas requested detailed information from nonprofits.
Enclosure II: Presentation 

Page 18 GAO-06-663R Homeland Security Assistance for Nonprofits 

13

Nonprofit Applicants Provided a Range of Risk Information: 

Threats Generally Covered Domestic Threats or Criminal 

Actions

• About 600 nonprofit organizations applied for target hardening funds:

– Number of applications ranged from 0 (zero) in Anaheim to 203 in New 

York City; 

– 4 urban areas had not obligated entire nonprofit allocation, by the time 

of our review, and each of these areas issued a second solicitation for 

additional applicants. (See encl. I.)

• Threat information provided by nonprofit organizations varied in specificity 

and the degree to which it referred to threats from international terrorist 

groups:

– Some threat information referred to criminal incidents at facilities, 

including vandalism and burglary;

– Other threat information related to threats or attacks by terrorist groups 

against groups or persons in other countries that were similar or 

comparable to those served by the nonprofit; and

– No reports of threats or attacks by international terrorist organizations 

against the specific facilities of the nonprofit applicants that were located 

within the United States.

– Threat assessments generally covered domestic threats.
Enclosure II: Presentation 

Page 19 GAO-06-663R Homeland Security Assistance for Nonprofits 

14

Nonprofit Applicants Provided a Range of Risk Information: 

Vulnerability and Consequences

• Nonprofit organizations provided varying degrees of information about their 

vulnerability to attack:

– Some provided professional assessments. 

– Some claimed proximity to critical infrastructure. 

– Some cited the presence of particular individuals as indications of 

vulnerability.

• Consequences of attack generally related to size and type of organization.

– The total number of employees or persons served by nonprofits 

generally was given as an indicator of potential consequences of attack.

– The type of service provided by the organization, for example, hospitals 

and other medical services, was also given as an indicator.
Enclosure II: Presentation 

Page 20 GAO-06-663R Homeland Security Assistance for Nonprofits 

15

States and Urban Areas Generally Relied on Law 

Enforcement to Assess Threat and Vulnerability

• Some state and urban area officials reported having limited capacity or 

limited need to conduct assessments and limited access to threat

information:

– Did not have the resources to conduct assessments of risk to a specific 

organization within the entire urban area;

– Some had too few applications to necessitate making choices among applicants 

based upon their relative risk and funded all applicants with available funds; and

– Some reported limited access to threat information.

• Officials in all but two states collaborated with law enforcement agencies to 

assess risk and threat information about nonprofit organizations and:

– Sought assistance from local or state law enforcement or Joint Terrorism Task 

Force (JTTF) to assess applicants’ threat and vulnerability information;

– Relied upon independently conducted or ongoing threat assessments by law 

enforcement to determine organizations at highest risk; and

– Officials in one state accepted the threat and vulnerability information reported by 

nonprofits as valid and in another, officials used information about nonprofit 

organizations’ relationship with law enforcement agencies to make their 

assessment.
Enclosure II: Presentation 

Page 21 GAO-06-663R Homeland Security Assistance for Nonprofits 

16

Some States and Urban Areas Developed Formal Methods 

for Assessing Nonprofit Organizations’ Risk and Capacity 

to Implement Projects

• Ten urban areas developed methods to score applications to be ranked 

based on their composite score on risk and capacity-related criteria:

– Number of risk criteria scored varied.

– Organizational capacity measures included: description of the organization, 

current efforts; the proposed objectives and project plan; budget and 

management.

– Two urban areas funded all applicants and did not use the scoring systems that 

they developed.

– Three urban areas used a scoring system to adjust the amount of funds given to 

applicants rather than to reject applicants who still presented a need.

• Two urban areas performed their own risk assessments to determine 

eligibility of nonprofit organizations and invited specific groups to request 

funding based on their assessments.
Enclosure II: Presentation 

Page 22 GAO-06-663R Homeland Security Assistance for Nonprofits 

17

Some States and Urban Areas Developed Formal Methods 

for Assessing Nonprofit Organizations Risk and Capacity to 

Implement Projects (cont.)

• Officials in other urban areas generally relied upon law enforcement officials 

to assess nonprofit organizations’ risk:

– In several urban areas, law enforcement agencies used their own 

information about threats to corroborate applicants’ information. 

– In one urban area, the JTTF reviewed applicants and found that while 

none were at risk of international terrorist attack and none had been 

attacked, applicants’ information about burglary and vandalism incidents 

was accurate. 

– In one urban area, the SAA planned to utilize the JTTF for assessing 

risk, but did not due to the low number of applicants.

– In one urban area, law enforcement officials performed site visits of the 

applicants’ facilities.
Enclosure II: Presentation 

Page 23 GAO-06-663R Homeland Security Assistance for Nonprofits 

18

Within Areas that Received an FY 2005 Nonprofit 

Allocation, about 400 Nonprofits Received Awards

• Within areas that received a nonprofit allocation in FY 2005, about 400 

awards were made, ranging from 113 in New York City to 3 in Seattle (encl.

I).

• Average amount of award was about $62,000.

• Categories of recipients:

– Most recipients were religious organizations.

– Medical and social services were the second and third largest 

categories.

• Within the states that did not receive a specific allocation for nonprofit 

grants in FY 2005, only one (Nebraska) reported awarding subgrants to 

nonprofit organizations:

– A total of $216,779 of FY 2005 UASI funds were used to fund the Red 

Cross, United Way, and Citizen Corps (this amount is exclusive of the 

$13,485,710 that was awarded to all States and territories specifically 

for the Citizen Corps Program), and these funds were for training, 

exercises, and medical kits, but not for target hardening.
Enclosure II: Presentation 

Page 24 GAO-06-663R Homeland Security Assistance for Nonprofits 

19

Within Areas That Received an FY 2005 Nonprofit 

Allocation, About 400 Nonprofits Received Awards (cont.)

• In the 10 urban areas that developed formal methods for assessing risk and 

capacity, 2 did not use their methods to score and rank applicants because 

they had sufficient funds within their nonprofit allocation to fund all 

applicants. 

• In one urban area that did not develop a formal method for assessing risk 

and capacity, all applicants received the funds they requested.

• In three urban areas, the results from the scoring of applications were used 

to determine amounts of funding, as applicants with lower scores generally 

received less funding.

• In several urban areas, there were more qualified applicants than available 

funding.
Enclosure II: Presentation 

Page 25 GAO-06-663R Homeland Security Assistance for Nonprofits 

20

State Officials Reporting a Range of Views about Target 

Hardening Grants for Nonprofit Organizations

• Some state and urban area officials made the following comments on the 

need for target hardening subgrants for nonprofit organizations.

Comments included:

– The subgrants met a need, as some states had more qualified 

applicants than they could fund;

– Relative to other critical infrastructure within urban areas, nonprofit 

organizations were a comparatively low priority for funding;

– Some nonprofits had inquired about future funding. One official

indicated that nonprofits had not expressed a need for target 

hardening prior to this grant program;

– In some cases, the $100,000 limit on target hardening subgrants per 

organization was insufficient to make improvements that could mitigate 

a terrorist attack; and 

– Target hardening funds are allowable under other grant programs and 

a specific allocation for nonprofits limited states’ flexibility in 

addressing security issues of other types of organizations.
Enclosure II: Presentation 

Page 26 GAO-06-663R Homeland Security Assistance for Nonprofits 

21

State Officials Reporting a Range of Views about Target 

Hardening Grants for Nonprofit Organizations (cont.)

• Officials also reported that they : 

– Needed, requested, but generally did not receive much additional

guidance and support from DHS;

– Implementing the program added additional and high administrative 

costs, not all of which were reimbursable; and 

– Varied in the degree to which they could conclude that the program 

reduced the overall risk of terrorist attack to their areas.
Enclosure II: Presentation 

Page 27 GAO-06-663R Homeland Security Assistance for Nonprofits 

22

Few UASI Subgrants Made to Nonprofits in Fiscal Years 

2003 and 2004

• No funding for nonprofit organizations was set aside in the fiscal year 2003 

and 2004 DHS appropriations.

• DHS issued guidance in June 2004 clarifying the eligibility of 

nongovernmental organizations, which included nonprofit organizations:

– Many states were unaware that they could make subgrants to 

nonprofits.

• For fiscal year 2003: 1 state to about 12 hospitals; for fiscal year 2004, 3 

states to 6 nonprofits: 

– Subgrants awarded to nonprofits generally were for citizen 

preparedness and capability enhancement for emergency response 

organizations.

– Most subgrants identified as nonprofit in DHS’s data system in FY 2004 

actually were made to government agencies.

– None were for target hardening.

(440478) 
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