Below are examples of private nonprofit (PNP) facility eligibility determinations that illustrate how the Public Assistance (PA) Program applies primary-use, shared-space, and structural evaluation criteria.
Parkland Hospital is an eligible PNP that owns a medical office building and leases a portion of it to doctors and laboratories that are providing for-profit services. The for-profit leases are for 70 percent of the floor space, excluding the common area floor space, as defined in this policy.
A parking garage is owned by an eligible PNP hospital to support its nearby hospital facility. The ground floor is leased to retail businesses and totals 15 percent of the total space of the garage.
The Woodlands Homeowners' Association is a PNP organization responsible for providing certain localized community services for a 200-home development. The Homeowners' Association is responsible for the neighborhood streets, a water system, a sewage system, a fire station, a medical clinic, a neighborhood park, a community center, and a recreational lake and dam.
The Homeowners' Association provides eligible critical services and therefore operates as an eligible PNP applicant, but the eligibility of each individual asset must be evaluated separately:
Public Access Prerequisite: The community center must be examined closely. If it is primarily used as a gathering place for a variety of social, educational enrichment, and community service activities, it is eligible as a noncritical but essential social service. To preserve eligibility, the facility must serve the general public outside the immediate Homeowners' Association development.
Recreation Exclusion: The neighborhood lake, dam, and park are completely ineligible PNP facilities because they provide primarily athletic or recreational services.
The PNP Springtown Recreation Center claims that it provides eligible essential social services in addition to its recreation activities. The organization notes that its services now include day care for elderly adults, senior citizen center programs, programs for families of domestic abuse, and shelter workshops. These programs are provided by the recreation center staff and offered 5 days a week. Recreational activities are limited to evenings and weekends, though the entire center is used for the eligible services.
Westover Recreation Center sponsors a variety of activities and is available for rental on Friday, Saturday, and Sunday evenings to companies, religious groups, clubs, and civic organizations for league parties, office parties, seminars, conferences, and holiday celebrations. The center has rooms set aside for seniors' bridge and occasional workshops for photography, pottery, ceramics, and art. However, the center is primarily oriented to athletics, featuring a large indoor pool, locker rooms, six squash/racquetball courts, a weight/exercise room, and a 9,200-square-foot gymnasium.
Somerset Community Center consists of several meeting rooms, a lending library, a social services room, a health services room, a dining room, an activity area with games and a wide-screen TV, a darkroom, pianos for practice, a ceramics lab, a woodshop, a computer room, sewing machines, an exercise room, and a large foyer. Outside are a fitness trail, garden plots, an outdoor basketball court, a softball field, a gazebo, and a picnic area. A nominal membership fee is charged, and classes are offered alongside numerous seniors' activities, a senior lunch program, health screenings, immunizations, and door-to-door transportation.
The Community Church operates a state-certified private school offering first through eighth grades. The teaching curriculum includes math, science, English, history, physical education, and religious doctrine. The school has an average attendance of 500 students. The campus consists of three distinct buildings: one used primarily for the secular curriculum, one used primarily for religious instruction, and a chapel primarily used for religious worship. Admissions to the school are restricted to members of Community Church.
FEMA evaluates the three campus structures independently:
SBA Permanent Requirement: Because houses of worship provide noncritical services, the applicant is required to apply for an SBA disaster loan and receive a determination for permanent work on the chapel before PA funding can be obligated.
Nondiscrimination Rule: The school's restricted admissions process does not affect its eligibility. Pursuant to Stafford Act Section 102(11)(B), no PNP facility is excluded from eligibility because leadership or membership in the organization is limited to people who share a religious faith or practice.
A religious institution owns multiple structures within its campus plot. One of the structures is a dock primarily used for recreation. The buildings include a church that provides routine worship services and a separate pastoral residence.
FEMA evaluates the campus elements as independent structures: