Appendix E › IV, VII, VIII Homeowners’ Association; Religious School; Religious Campus

How does FEMA treat a homeowners’ association, or a church with a school, chapel and residence?

FEMA term

PNP eligibility examples: homeowners’ associations and religious institutions

Short answer

FEMA evaluates each structure separately. A homeowners’ association providing critical services is an eligible nonprofit: its water, sewer, fire station and clinic qualify, but its lake, dam and park don’t. On a church campus, school buildings qualify as education, the church or chapel as a house of worship (with an SBA loan application), while a recreational dock and the pastor’s residence don’t.

What FEMA requires

Each facility or building is evaluated separately, even on the same campus.
A homeowners’ association that provides eligible critical services is an eligible nonprofit; each of its services is then judged on its own. Street work eligibility depends on whether streets have restricted access and the type of work. A community center must serve the general public outside the association.
Buildings used for secular or religious education at a state-certified private school are eligible educational facilities providing critical services, so no SBA loan application is needed for their permanent work.
Houses of worship are eligible but provide noncritical services, so an SBA loan application is required for permanent work.
Under Stafford Act Section 102(11)(B), no nonprofit facility is excluded because leadership or membership is limited to people who share a religious faith or practice.
Recreational structures and private residences are not eligible.

<table class="pt-table"><thead><tr><th>Facility</th><th>FEMA’s result</th><th>SBA loan needed for permanent work?</th></tr></thead><tbody><tr><td>HOA water and sewer systems</td><td>Eligible (utility)</td><td>No (critical service)</td></tr><tr><td>HOA fire station and medical clinic</td><td>Eligible (emergency and medical)</td><td>No (critical service)</td></tr><tr><td>HOA streets supporting its critical services</td><td>Eligible facility; work eligibility depends on access restrictions and type of work</td><td>Not addressed in the example</td></tr><tr><td>HOA community center</td><td>Eligible only if primarily a varied community gathering place that serves the public beyond the HOA</td><td>Yes (noncritical service)</td></tr><tr><td>HOA lake, dam and park</td><td>Not eligible (primarily recreational)</td><td>Not applicable</td></tr><tr><td>Church school buildings (secular and religious instruction)</td><td>Eligible (education)</td><td>No (critical service)</td></tr><tr><td>Chapel or church</td><td>Eligible (house of worship)</td><td>Yes (noncritical service)</td></tr><tr><td>Recreational dock</td><td>Not eligible</td><td>Not applicable</td></tr><tr><td>Pastor’s residence</td><td>Not eligible (private residence)</td><td>Not applicable</td></tr></tbody></table>

Documentation

A list of each structure and the service it provides, state certification for private schools, evidence of public access for community centers, and SBA loan applications for noncritical facilities such as houses of worship.

Watch out · Govstar practitioner advice

Limiting admission or membership to members of a faith does not disqualify a religious school or house of worship. But each building is judged on its own use, so map every structure on the campus to its primary service.

Govstar summarizes FEMA’s Public Assistance Program and Policy Guide in plain language and links to the official text. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.