A Future of “Uniform Guidance”

Category: Center for the Future of Museums Blog
Checking the fine print

ForesightInsightAction

That’s the framework the Institute for the Future uses to navigate uncertainty with concrete, tactical action.

Last week’s museum foresight: flagging the Office of Management and Budget’s new proposed funding regulations. In that post, I summarized the provisions of highest significance to our sector. Quick recap of some key points: the new regs would direct senior political appointees to review all grant proposals, ensure that funding demonstrably advances the President’s political priorities, give federal agencies explicit authority to terminate any active grant at any time, and ban use of federal funds to promote, encourage or subsidize DEI.

This week I’m working on insight. What are the implications of this proposal for museums? 

Here are some vignettes I’ve sketched of a future shaped by these rules being enacted in their current state:

  • A science museum in the mid-west must choose between including content on climate change in their newly renovated galleries and applying for federal funding for support. Their grant writing staff has warned that the exhibit, as planned, is likely to be flagged as “not aligned with presidential priorities.”
  • For the past two decades, a natural history museum has relied on a steady stream of grants from NSF and IMLS to fund their work documenting the biodiversity of the Gulf Coast and the impacts of industry and climate change. Noting that federal grants can now be cancelled at any time, if the agency providing the grant decides it is “no longer in the national interest,” the museum decides to seek funding only from non-government sources, even though that means cutting back on research and on improvements to collections care.
  • A Jewish history museum in the northeast has generated much-needed income from renting its lecture hall and reception area. Museum staff are concerned by the provision in the new regulations that recipients of Federal assistance “not discriminate on the basis of the viewpoint, content, or subject matter of speech—including on the basis of political, ideological, or religious affiliation or perspective—in providing services for events, meetings, or other expressive activities.” They had planned to apply to IMLS for funding to rehouse their archives—but would this provision mean they had to provide access to their rental facilities to groups that espouse antisemitic viewpoints, or to Holocaust deniers?
  • Half-way through the implementation of an NEA-funded project highlighting local artists engaged in social activism, a California museum learns that the grant is cancelled. A newly appointed Chairman of the agency, after implementing a review of all existing grants, determined that the museum’s project “subsidizes radical political ideologies.”

Next up: Action. I encourage you to study the proposed regulations, think about the implications for your organization, and submit input that reflects the impact they would have on your organization and the services you provide to your community via the call for public comments (closing on July 13). For tips on crafting effective input, see AAM’s June Advocacy Alert, and “How You Can Effectively Participate in the Regulatory Process Through Public Comment” at regulations.gov.

The proposed rules are over 400 pages long. If you have limited time (or emotional capacity) to read the whole document in depth, I recommend you explore key sections via the table of contents. For example, Section 200.343—Effects of Suspension and Termination—which seeks to further limit how funds might be spent on existing obligations should a grant, once awarded, be cancelled. It may also help to study summaries of the regulations such as those released by NACUBO and the 2025 Report Card for America’s Infrastructure. Sign up for AAM Advocacy Alerts and watch the AAM newsletters for more information in coming weeks.

Yours from an uncensored future enriched by federal funding,

Elizabeth Merritt, Vice President, Strategic Foresight and Founding Director, Center for the Future of Museums, American Alliance of Museums

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