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Background of the Shelter & Services Program
Over the past decade, a vibrant and supportive network of shelters, respite centers, community organizations, and local governments has come together in an organized effort to offer humane reception to asylum seekers at the southwest border. This network became especially critical in late 2018, as asylum seekers began arriving in increasing numbers, and many grassroots and faith-based volunteer efforts in border communities began to expand their services to ensure that migrants received a warm welcome and emergency shelter after being processed by the Department of Homeland Security (DHS).
In response to the increased need for support of newly arriving asylum seekers, the pivotal role of these shelters and border communities led to significant advocacy on behalf of humanitarian support in 2019. Spearheaded by Senator John Cornyn (R-Texas) and other border state Senators, bipartisan efforts successfully secured the authorization of federal funding through FEMA’s Emergency Food and Shelter Program - Humanitarian (EFSP-H), initially set at $30 million. As part of the FY 2023 Consolidated Appropriations Act, funding for ESFP-H transitioned into a new program under Customs and Border Protection (CBP) with administration by FEMA, named the Shelter and Services Program (SSP), and the 2023 budget was increased to $800 million—a small yet crucial portion of the over $20 billion annually allocated to DHS for immigration enforcement and border militarization.
EFSP-H and its successor, SSP, has become an essential financial support system for shelters and local communities providing vital services and shelter to new arrivals. Despite its challenges and opportunities for improvement, SSP has evolved into a lifeline for border communities, facilitating funding for essential services such as food, clothing, basic medical aid, legal information, and transportation coordination. These contributions are pivotal in enhancing the dignity and quality of life for migrants, reflecting our commitment to upholding human rights and fostering communities enriched by diversity and mutual respect.
How SSP Distributions Worked in FY2023
In an unexpected shift from the previous Emergency Food and Shelter Program - Humanitarian (EFSP-H), the Shelter and Services Program (SSP) moved away from a competitive grant process in FY2023. Funding was directly allocated to a set list of primary applicants based on a formula developed by the Department of Homeland Security (DHS), which considered previous funding allocations and data on the release and destinations of migrants. These primary applicants, while not mandated, were encouraged to further distribute funds as sub-awards to nonprofit organizations that had been beneficiaries under EFSP-H, in hopes of fostering a collaborative community spirit. In some regions, this framework hit serious obstacles and complications, resulting in some organizations being cut off from crucial funding for months.
In FY2023, SSP funding was dedicated exclusively to humanitarian assistance for migrants who had completed processing and had been released from DHS oversight, but the recipients were expanded to include select communities across the country receiving asylum seekers in need of medium to long term case management and services. For all recipient organizations, services had to be rendered to eligible individuals within 45 days of their release, a timeframe that met the needs of initial reception and emergency shelter, but fell short of the more complex needs once asylum seekers moved into the interior of the country to begin their anticipatory integration into their new communities. The range of services covered included shelter, food, and transportation—which was capped at 10% of the total funds—along with acute medical care, personal hygiene products, and necessary renovations to existing organization facilities (with a limit of $250,000 and excluding new constructions or real estate purchases). Other supported efforts included clothing provision, outreach initiatives, translation services, and the necessary labor and administrative costs associated with delivering these services, which was limited to 5% of the total funding received.
Recipients of SSP funds were held to a high standard of accountability, and required to submit detailed financial and programmatic reports. A critical part of this reporting was the collection and disclosure of A-numbers and/or evidence of DHS processing, ensuring transparency and availability for audit.
Recent Developments and Policy Changes for FY2024
The Shelter and Services Program (SSP) has undergone several updates and modifications in FY2024, intended to enhance its effectiveness and reach. The primary focus remains on offering support to non-federal entities that provide critical services to migrants who have been processed and released from Department of Homeland Security (DHS) custody.
Funding and Application Process
As of FY2024, SSP now includes two distinct funding opportunities: SSP-Allocated (SSP-A) and SSP-Competitive (SSP-C), aiming to facilitate a more structured and impactful distribution of resources. A total of $650 million has been allocated to these programs, an amount that is roughly 20% down from the previous fiscal years allocation, which as already raised concerns in underresources border communities.
SSP-Allocated (SSP-A) involves a predetermined list of recipients who are allocated funds based on historical data and current needs, with $300 million available.
SSP-Competitive (SSP-C), amounting to $340.9 million, is designed to provide funding through a competitive application process, encouraging a broader range of applicants and innovative service delivery models.
Eligibility and Service Provision
Eligibility for SSP funding has been broadened to include various entities such as local governments, tribal organizations, and non-profit organizations that have not previously received SSP funding. The services supported by SSP funding now extend beyond the immediate needs upon release from DHS custody, despite the allocated funding having been reduced by 20% compared to the previous year. Recognizing the varying needs of migrants, SSP now facilitates longer-term support services, such as extended shelter and integration assistance, particularly in non-border states experiencing an increase in asylum seeker arrivals.
Application Enhancements
The application process for SSP has been moved into the standard federal grants model in a bid to improve accessibility and efficiency. Applicants are encouraged to utilize the FEMA Grants Outcomes (FEMA GO) portal for submissions, with the registration process simplified to ensure timely and effective application submissions. It is worth noting that many of the border organizations providing initial triage services and emergency shelter have not previously managed federal grants, and may struggle with the application process. The latest Notice of Funding Opportunity (NOFO) outlines detailed criteria for both primary and secondary services, which now include extended medical care, limited legal assistance, and educational services to support migrants in their integration process.
Ongoing Challenges
Access and Transparency Issues
Despite reforms intended to streamline the SSP application and distribution processes, challenges persist, particularly for smaller, less established shelters and service providers. The current structure, while offering a clearer process to obtain competitive grants, still does not fully address the visibility or predictability of the funding formula used by DHS. This opacity can hinder the ability of potential recipients, especially new entrants and smaller organizations, to plan effectively or demonstrate their need for funding. There remains a critical need for enhanced transparency and direct communication with both primary recipients and sub-recipients to facilitate more equitable access to resources.
Interior/Border Dynamics
The ongoing demographic shifts and logistical challenges associated with migrant movements continue to stress the SSP framework. The increasing number of asylum seekers arriving without sponsors and the logistical complexities of busing migrants to interior cities necessitate a reassessment of resource allocation strategies. The program would benefit from a more flexible approach that considers the evolving geographic and temporal needs of migrants, potentially integrating SSP with broader federal initiatives like the Office of Refugee Resettlement services, the Case Management Pilot Program, or leveraging funds from the Immigration Emergency Fund to ensure a continuum of care that extends beyond immediate border areas.
Implementation
For Fiscal Year 2024, the SSP has seen some updates and changes that affect the caps on allowable expenses. It's important for organizations to review the specific guidelines in the latest SSP NOFO and other official FEMA documents for the current fiscal year to ensure compliance with the funding rules and to plan effectively for their budgetary allocations. These documents provide detailed information on allowable costs, caps, and other critical funding parameters. According to the most recent information available from FEMA:
Transportation Expenses
Previously, there was a cap that limited onward destination transportation expenses to 10% of the total funds awarded. This specific cap has been removed entirely to provide more flexibility, reflecting the evolving needs of organizations managing transportation logistics for migrants. Additionally, the required minimum capacity for charter bus transport has been reduced from 75% to 66% in FY2024.
Administrative Overhead
The cap on administrative costs traditionally limited these expenses to 5% of the total grant amount. This cap is typically intended to ensure that a maximum amount of funds are directed towards direct services rather than administrative overhead. This cap appears to remain consistent for FY2024, which has created challenges for eligible organizations that do not provide other grant-eligible services beyond asylum seeker reception.
Increasing Politicization
As the Shelter and Services Program (SSP) has increasingly become embroiled in political debates, its funding and operational stability have faced significant challenges. The bipartisan consensus that once bolstered SSP is eroding, with some factions within the Republican Party notably resisting approving any humanitarian support in recent legislative sessions. This contentious environment was highlighted by attempts to cut or even terminate SSP funding, as seen in legislative proposals such as the Secure the Border Act of 2023. These actions pose a real threat to the program’s sustainability and the continuity of services essential to migrants. It is imperative that immigration advocates continue to engage in vigorous advocacy and rally public support to protect, stabilize, and improve SSP funding.
While SSP remains an indispensable part of our national response to migration, it is crucial that the program adapts to the multifaceted realities of modern migration, shifting political climates, and administrative demands. We urge proactive adjustments and encourage a deeper dialogue among all stakeholders involved, especially frontline service providers and impacted asylum seekers. A firm commitment to transparency and flexibility in program administration are essential to overcome the prevailing challenges and enhance the effectiveness and scope of the Shelter and Services Program as an essential support mechanism for southwest border communities and all other communities providing humane reception to newly arrived asylum seekers.
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