A change to the Nonprofit Security Grant Program application, which will measure the “social vulnerability” of the communities in which applicants are located, is raising questions from both lawmakers and members of the Jewish community.

The 2022 NSGP application provides a boost to nonprofits with a high score on the Centers for Disease Control and Prevention’s Social Vulnerability Index. Previously, SVI had not been taken into consideration in the grant process. The NSGP provides grants to religious groups, houses of worship and other nonprofits to upgrade their security.

A CDC fact sheet for the SVI explains, “A number of factors, including poverty, lack of access to transportation, and crowded housing may weaken a community’s ability to prevent human suffering and financial loss in a disaster. These factors are known as social vulnerability.”

A letter from House Homeland Security Committee Chair Bennie Thompson (D-MS) and Rep. Bill Pascrell (D-NJ) to Federal Emergency Management Agency Administrator Deanne Criswell questions the new application parameter.

“Concerns have been raised about FEMA’s plans to incorporate the Centers for Disease Control and Prevention’s social vulnerability index (SVI) in scoring NSGP applications,” the letter, sent May 27, reads. “It is our strong view that, with the $70 million funding increase Congress approved for FY 2022, FEMA should be able to bring at-risk nonprofits located in underserved and underrepresented communities into the program, while ensuring availability of funding to at-risk nonprofits not located in underserved or underrepresented communities.”

The program was funded with $250 million for 2022. Jewish community groups have, for several years, argued that $360 million is necessary to meet demand in light of rising incidents of antisemitism and other hate crimes. In 2021, fewer than half of all grant applications, which totaled nearly $400 million in requests, were approved.

Rep. Josh Gottheimer (D-NJ) called for the change to the application process to be “reconsidered” in his own letter to Criswell, dated June 1.

“While encouraging new applicants is a worthy goal, the SVI is not an appropriate measure to utilize when the purpose of the grant program is to protect vulnerable institutions that have a demonstrated active threat against them,” the letter, obtained by Jewish Insider, reads.

Gottheimer emphasized that the grants should be provided “to the most threatened institutions,” and called the SVI “a powerful tool for good” that is nevertheless “not relevant to the NSGP.”

A FEMA spokesperson emphasized to JI that “just being in a high vulnerability area is not enough to receive a grant.” 

According to a FEMA informational page, applicants in communities with a “high” SVI ranking will receive 10 bonus points on their applications, and those in communities with “very high” SVI will receive 15. First time-applicants will also receive 15 bonus points. 

Applicants can receive up to 40 points in the initial stage of their application, FEMA spokesperson Jaclyn Rothenberg told JI. A multiplier of three is applied for religious or spiritual institutions, for final scores of up to 120 points. Bonus points are added after the multipliers.

Rothenberg told JI the agency remains concerned about the increased risk to communities, “especially those that are experiencing any antisemitic or religious attacks” and that the agency is “expanding the program to attract more communities that have high SVI… to be able to reach communities that don’t have the funds to protect themselves.”

“However, we still remain dedicated to making sure that communities that did receive the funding are still able to apply,” she said. “And the bonus points are not enough to [receive] the funding unless there’s a clear security need. So at this point, we don’t see there being a huge barrier… The idea behind advancing this program to more high SVI communities is so that more apply to the program in general. It is not to take away from the communities that are reliant on these funds.”

She also said “we don’t know if there is or there isn’t” a correlation between SVI score and risk of attack, whether communities with high SVI will actually apply or whether consideration of the SVI factor will impact where grants are awarded this year.

Several of the most high-profile attacks at Jewish institutions in recent years have taken place in areas with low SVI scores. SVI is measured on a scale of 0 to 1, with 0 indicating lowest vulnerability and 1 indicating highest. 

Congregation Beth Israel in Colleyville, Texas, which had received a grant previously and was the site of a hostage situation earlier this year, is located in an area with an SVI score of .0129. The Chabad of Poway, Calif., where one person was killed and three were injured in 2019, is located in an area with an SVI score of .0714. The Tree of Life synagogue in Pittsburgh, where 11 people were killed and six wounded in 2018, is located in an area with an SVI score of .1752. Other attacks have taken place in areas with higher scores, and Jewish communities and institutions are located in areas with a range of SVI scores.

Responses to the change from Jewish community groups that have championed the NSGP have been mixed.

Nathan Diament, executive director of the Orthodox Union Advocacy Center, told JI that OU has had “candid conversations with people at the highest level of DHS” about the change. 

“We’re going to watch very closely how this year’s grant cycle plays out,” he said. “And if this factor does cause problems, then we expect we will be able to work with DHS leadership to correct those problems.”

Abba Cohen, Agudath Israel’s vice president for government affairs, told JI that the group supports “finding a methodology that will bring more people” into the program, but questioned the relevance of SVI — which he described as tailored to natural disasters and other incidents “of a different nature” — to NSGP.

“There’s no doubt that some of those issues would be applicable to the security situation, and to the extent that they’re applicable, we would think that it’s appropriate to include them,” Cohen said. “But the concern is that if you include more than that which is applicable, then we might be moving away from the original intent and purpose of the Nonprofit Security Grant Program, which is to guard against terrorist attacks directed to at-risk nonprofits.”

He also said that Agudath Israel has heard from institutions in close proximity to one another that have received significantly different SVI scores, despite facing presumably similar levels of terror threat.

Cohen said his organization has been communicating with FEMA to “see if there can be some kind of adjustment.”

The Anti-Defamation League’s director for national security, Ryan Greer, told JI that the ADL supports expanding access to the grants in communities that have not received them previously — particularly through increasing NSGP funding.

He added, “at a time of growing antisemitism across the country, it is critical that FEMA not create additional roadblocks to access for anyone trying to participate in the program, especially those in the Jewish community.”

Elana Broitman, The Jewish Federations of North America’s senior vice president for public affairs, told JI that the group has worked with local federations to “clarify” the process for this year’s funding requests.

“We… are grateful to Rep. Pascrell and Chairman Thompson for their oversight initiative,” Broitman said. “We have and will continue to work with diverse communities on outreach and training to help ensure that at-risk nonprofits in every community have increased access to coverage.”

At a Senate hearing in February, Christopher Logan, deputy assistant administrator for FEMA’s Grant Programs Directorate, said that the agency was reaching out to “underserved and marginalized communities” to provide both information and technical assistance about applications, as well as analyzing “where the grant program has not historically been awarded.”

The Jewish community has historically received the majority of NSGP grants.