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NSGP Appendix | 2023 Page C-6 <br />NSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified <br />as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. § <br />5196(j)(9), which cross-references Davis-Bacon). Grant recipients must ensure that their contractors or <br />subcontractors for construction projects pay workers no less than the prevailing wages for laborers and <br />mechanics employed on projects of a character similar to the contract work in the civil subdivision of the <br />state in which the work is to be performed. Additional information regarding compliance with the Davis- <br />Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following <br />website: https://www.dol.gov/whd/govcontracts/dbra.htm. <br />Training <br />Nonprofit organizations may use NSGP funds for the following training-related costs: <br />•Employed or volunteer security staff to attend security-related training within the United States; <br />•Employed or volunteer staff to attend security-related training within the United States with the <br />intent of training other employees or members/congregants upon completing the training (i.e., <br />“train-the-trainer” type courses); and <br />•Nonprofit organization’s employees, or members/congregants to receive on -site security training. <br />Allowable training-related costs under the NSGP are limited to attendance fees for training and related <br />expenses, such as materials, supplies, and/or equipment. Overtime, backfill, and travel expenses are not <br />allowable costs. <br />Allowable training topics are limited to the protection of critical infrastructure key resources, including <br />physical and cybersecurity, facility hardening, and terrorism/other extremism awareness/employee <br />preparedness such as Community Emergency Response Team (CERT) training, indicators and behaviors <br />indicative of terrorist/other extremist threats, Active Shooter training, and emergency first aid <br />training. Additional examples of allowable training courses include: “Stop The Bleed” training, <br />kits/equipment, and training aids; First Aid and other novice level “you are the help until help arrives” <br />training, kits/equipment, and training aids; and Automatic External Defibrillator (AED) and AED/Basic <br />Life Support training, kits/equipment, and training aids. <br />Training conducted using NSGP funds must address a specific threat and/or vulnerability, as identified in <br />the nonprofit organization’s Investment Justification (IJ). Training should provide the opportunity to <br />demonstrate and validate skills learned as well as to identify any gaps in these skills. Proposed <br />attendance at training courses and all associated costs using the NSGP must be included in the <br />nonprofit organization’s IJ. <br />Contracted Security Personnel <br />Contracted security personnel are allowed under this program only as described in the NOFO and Manual <br />and comply with guidance set forth in IB 421b and IB 441. NSGP funds may not be used to purchase <br />equipment for contracted security. The subrecipient must be able to sustain this capability in future years <br />without NSGP funding, and a sustainment plan will be required as part of the closeout package for any <br />award funding this capability. <br />Additionally, NSGP recipients and subrecipients may not use more than 50% of their awards to pay for <br />personnel activities unless a waiver is approved by FEMA. For more information on the 50% personnel <br />cap and applicable procedures for seeking a waiver, please see IB 421b, Clarification on the Personnel <br />Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of 2008 (Public <br />Law 110-412 – the PRICE Act).