Between July 25 and Aug. 1, the Department of Homeland Security’s (DHS) Federal Emergency Management Agency (FEMA) released almost two dozen Notices of Funding Opportunities (NOFOS), totaling approximately $2.2 billion, to help state, local and tribal partners improve emergency preparedness. FEMA released these funding opportunities to help partners respond to natural disasters like floods, fires, tornadoes and hurricanes, as well as terrorist attacks and cyberattacks. Several of these funding opportunities are grants that tribal entities may apply for, although they have varying requirements and conditions that must be met to be eligible for an award.
Tribal Homeland Security Grant Program
On Aug. 1, FEMA announced a funding opportunity for the Fiscal Year 2025 (FY25) Tribal Homeland Security Grant Program (THSGP). This grant program offers $13,500,000 to assist tribal governments in preventing, protecting against and responding to acts of terrorism. The THSGP is authorized by Section 2005 of the Homeland Security Act of 2002 (Homeland Security Act) as a carve-out of the State Homeland Security Program (SHSP).
The application deadline is Aug. 15, 2025. The agency expects to award 19 applicants, with the expected award range between $40,000 and $2,000,000, no later than Aug. 23.
In FY25, applicants are asked to focus their requests on the following national priorities:
- Enhancing the protection of soft targets and crowded places,
- This includes faith-based organizations and election sites;
- Supporting Homeland Security Task Forces and fusion centers;
- Enhancing and integrating cybersecurity resiliency;
- Enhancing election security; and
- Supporting Border Crisis Response and Enforcement.
- Example activities under border crisis response and enforcement support may include:
- Participation in the DHS and Immigration and Customs Enforcement’s (ICE) 287(g) training program, which allows certain state and local law enforcement officers to enforce federal immigration laws;
- Cooperation with ICE detainers; and
- Other jurisdictional responsibilities.
It should be noted that the agency also asks that applicants address safety gaps identified in communities’ Threat and Hazard Identification and Risk Assessments (THIRAs) and Stakeholder Preparedness Reviews (SPRs).
Eligibility
To initially qualify for the THSGP, the applicant must be a federally recognized tribe that meets the Homeland Security Act’s definition of a “Directly Eligible Tribe.” Pursuant to this definition, a “Directly Eligible Tribe” is one that is located in the continental United States, operates a law enforcement or emergency response agency with the capacity to respond to law enforcement or emergency services calls, and is able to certify that a state has not provided funds to the tribe for the purpose for which the funding is sought.
In addition to the other criteria, the tribe must meet one of the following requirements:
- The tribe is located on or within 100 miles of an international border, the ocean (including the Gulf of Mexico) or international waters;
- The tribe possesses or is within 10 miles of critical infrastructure included on DHS’ prioritized critical infrastructure list;
- The tribe is located within or contiguous to one of the 50 most populous metropolitan statistical areas in the United States; or
- The tribe possesses a jurisdiction with at least 1,000 square miles of Indian country.
Allowable Activities
Projects authorized under this funding opportunity are sorted under each of the national priority areas.
Priority Areas
Allowable Activities
Enhancing and Integrating Cybersecurity Resiliency
- Cybersecurity risk assessments
- Cybersecurity training and planning
- Projects to address vulnerabilities identified in the cybersecurity risk assessments
Enhancing the Protection of Soft Targets and Crowded Places
- Physical security enhancements:
- Security cameras;
- Security screening equipment;
- Lighting;
Access controls
- Fencing, barriers and gates
Supporting Homeland Security Task Forces and Fusion Centers
- Information sharing with all DHS components and fusion centers
- Cooperation with DHS on threat assessments and recognition
Enhancing Election Security
- Site security measures
- Cyber and general election security navigator support
- Testing through the Voting System Test Laboratories (VSTL)
Supporting Border Crisis Response and Enforcement
- Staffing support to expand 287(g) screening
- Development of information sharing platform between ICE and tribal law enforcement
Previous Awardees
In FY24, FEMA awarded $13,500,000 across the following tribes:
- Agua Caliente Band of Cahuilla Indians
- Blue Lake Rancheria
- Cher-Ae Heights Indian Community of the Trinidad Ranch
- Cherokee Nation
- Chitimacha Tribe of Louisiana
- Little Traverse Bay Bands of Odawa Indians
- Mashantucket Pequot Tribal Nation
- Muscogee (Creek) Nation
- Oneida Nation
- Osage Nation
- Pascua Yaqui Tribe
- Quapaw Nation
- Soboba Band of Luiseño Indians
- Twenty-Nine Palms Band of Mission Indians
- Viejas Band of Kumeyaay Indians
Other Funding Opportunities for Tribes
FEMA announced more than 20 grants aimed at improving local, state and tribal emergency preparedness;, however, of those 20 grants, only the THSGP allows tribes to apply directly. The FY25 Emergency Management Performance Grant, the State and Local Cybersecurity Grant Program and the Homeland Security Grant Program only allow tribal governments to receive funding either through State Administrative Agencies (SAAs) or a state’s Emergency Management Aency (EMA) as subrecipients. Further, tribes may not directly apply for FEMA’s Tribal Cybersecurity Grant Program (TCGP), a funding opportunity established by the Bipartisan Infrastructure Law (BIL) to assist tribal governments with managing and reducing the risk of cyberattacks.
Despite announcing the TCGP as an available funding opportunity for interested applicants on Aug. 1, FEMA has already selected the tribes that will receive funding for this year’s award cycle. This is because the agency determined that it would not have sufficient time to solicit, receive and review new applications before the TCGP’s statutory authorization under the BIL expires on Sept. 30, 2025.
During the FY22/23 TCGP award cycle, FEMA elicited interest from tribes that exceeded $100 million in funding requests, far exceeding the approximately $18 million in obligated funding for the cycle. After awarding tribes $18.2 million, approximately $12 million remained to obligate over FY24 and FY25. FEMA and CISA chose to combine FY24 and FY25’s remaining funding into a single NOFO and award meritorious tribal applicant projects that did not receive funding during the FY22/23 award cycle, given that the agencies had already received their application materials years earlier.
Accordingly, FEMA and CISA selected the following tribes to receive the remaining $12,164,971 in outstanding TCGP funding:
- Blackfeet Tribe
- Chippewa Cree
- Confederated Tribes of the Colville Reservation
- Inupiat Community of the Arctic Slope
- Kickapoo Traditional Tribe of Texas
- Little Traverse Bay Bands of Odawa Indians
- Metlakatla Indian Community
- Mohegan Tribe of Indians of Connecticut
- Native Village of Kluti-Kaah
- Nottawaseppi Huron Band of the Potawatomi
- Paskenta Band of Nomlaki Indians
- Prairie Band Potawatomi Nation
- Quapaw Tribe of Oklahoma
- Saint Regis Mohawk Tribe
- San Carlos Apache Tribal Council
- Seminole Tribe of Florida
- Southern Ute Indian Tribe
- Swinomish Indian Tribal Community
How to Apply for the THSGP
To access any of the applications outlined in this alert, an interested tribe must submit an application package through the FEMA Go system. To apply for an award under the THSGP, interested applicants must take the following steps:
- Verify or obtain a Unique Entity Identifier (UEI) number and Employer Identification Number (EIN) from the Internal Revenue Service (IRS)
- Access or obtain an account with login.gov
- Verify or create an account with the System for Award Management (SAM)
- Register with FEMA GO if one has not done so already and add one’s organization into the system
- Submit the complete application, including:
- Standard Form (SF)-424, Application for Federal Assistance
- Grants.gov Lobbying Form, Certification Regarding Lobbying
- SF-424A, Budget Information (Non-Construction)
- If the applicant intends to use funds for construction, it must submit SF-424C, Budget Information (Construction), in addition to or instead of SF-424A
- SF-424B, Standard Assurances (Non-Construction)
- If the applicant intends to use funds for construction, it must submit SF-424D, Standard Assurances (Construction), in addition to or instead of SF-424B
- SF-LLL, Disclosure of Lobbying Activities
In addition, THSGP requires program-specific application documents:
- THSGP Investment Justification
- Self-certification form stating a tribe’s eligibility under the Homeland Security Act
Next Steps
Interested applicants should read FEMA’s guidance thoroughly to understand whether they are eligible for any federal funds and if their desired emergency preparedness improvements meet the criteria for allowable activities. DHS will also be hosting a webinar to answer questions on these programs on Aug. 7. Questions for the Q&A must be submitted by Aug. 5 by 3 p.m.
In FY24, FEMA granted applicants more than 60 days to submit the necessary application materials for the THSGP. However, this year, the agency is offering just 14 days to submit all documentation. Given this tight deadline, Brownstein can assist applicants in preparing, writing and finalizing grant application materials and assisting tribes with FEMA GO’s submission requirements. Please contact the authors for additional information and assistance.
