Arlington, VA–Today, the American Alliance of Museums submitted a public comment in the Federal Register to the White House Office of Management and Budget regarding the proposed rule: Regulation for Federal Financial Assistance.

The public comment was submitted jointly with nine other museum associations, the Association of African American Museums, the Association of Science and Technology Centers, the Association of Children’s Museums, the American Insittue for Conservation, the Association of Science Museum Directors, the Association of Art Museum Directors, the American Association of State and Local History, the Association of Zoos & Aquariums, and the American Public Gardens Association.

Following is the letter submitted for the public record:

July 10, 2026

The Honorable Russell Vought Director
Office of Management and Budget
725 17th St NW Washington, DC 20503

RE: Public Comment on OMB-2026-0034

Dear Director Vought:

The American Alliance of Museums and the following organizations are writing regarding our concerns about OMB Docket OMB-2026-0034. Museums, zoos, science centers, children’s museums, public gardens, aquariums, historic sites and other vital organizations utilize federal grant programs to further their mission to educate the public, strengthen America’s leadership position in STEM education and innovation, showcase our culture, present art from across the country and around the world, and engage Americans with our shared history. If implemented, this proposed rule would limit access to critical programs at IMLS, NEA, NEH, NASA, NSF and more. We ask that OMB reconsider the key points laid out in our comments regarding the unprecedented changes to the federal government grant process.

The United States became a global leader in science, the arts, medicine, higher education, and other areas by following a simple principle: federal funding should support the best work, as judged by independent experts—not by politicians. This proposed rule would dismantle that standard across every federal agency, and places undue burden on grantees due to lack of consistency and constant threat of termination.

Expansion of Federal Government
Overall, these changes would enable much greater influence by current and future presidential administrations over federally funded initiatives, undermining the long-established merit-review process for grants, restricting flexibility for grantees, and further reducing Congress’s constitutional authority over spending.

Alignment with Administration Priorities (§ 200.202)
This provision could lead to significant instability as grantees would have to constantly respond to shifting environments due to the likelihood that each new administration would make significant, substantive changes to their priorities. Federal law is clear that the executive branch does not have the authority to add new programmatic requirements beyond what Congress has authorized.

Agency Discretion (§ 180.25, § 200.101)
Turning OMB guidance into a formal regulation could prevent federal agencies from exercising their statutory authority and carrying out their missions independently, instead requiring them to conform to OMB’s political priorities. Combined with a mandate that agencies submit reports identifying specific recipients of federal awards during any given period, this change could further centralize control within OMB and increase political oversight of agency funding decisions. (§180.25, § 00.101).

Replacing competitive, merit-based grantmaking with political/policy considerations

Political Appointees Control Grant Awards (§200.205, §200.205(d)) Nonbiased, peer reviewed grantmaking decisions are the cornerstone of providing necessary and merit-based grants to museums and other organizations. The proposed changes will erode this foundation of support and add a significant level of uncertainty by requiring that senior political appointees preapprove all top proposals before awards are finalized.

Peer review has always been the bedrock of grantmaking in the historical and scientific communities. It should be preserved and not reduced to an advisory role. Political appointees should be encouraged to defer to peer reviewers, who are experts in their fields, and to routinely ratify their recommendations.

Museums and cultural institutions should be able to trust that funding will be provided once a Notice of Funding Opportunity (NOFO) is issued and finalized. The new clause, stating that agencies are not required to provide that funding, creates unnecessary uncertainty and undermines confidence in the grantmaking process.

Creates Uncertainty and Undermines Trust

Active Grants Can Be Terminated at Will (§ 200.211, § 200.340, § 200.341, § 200.342, § 200.343)
If adopted as written, the threat of termination at any time places undue burden and creates significant financial and operational uncertainty for grantees. Institutions develop long-term plans, budgets, and programs based on the expectation that awarded granting funding will remain available. The proposed rule would undermine trust in the granting process and jeopardize the financial and operational stability of grantees. This change in OMB policy also eliminates the opportunity to appeal or schedule a hearing on the termination. This would leave grantees with no meaningful opportunity to understand, challenge, or respond to an unjustified cancellation of funding.

Also problematic is the proposed authority to immediately “temporarily suspend” any award activities or funding potentially disrupting grantees’ operations without adequate notice or an opportunity to respond in whole or in part, for up to 90 days if it is “in the interest of the federal agency.” This provision could leave grantees in prolonged uncertainty while an administration weighs potential political consequences or gauges the intensity of public opposition before deciding whether to continue or terminate an award.

The addition of further oversight of subrecipients adds more pressure and unpredictability on grantees, who must monitor the work of their partners to maintain federal funding. There is significant time and cost associated with in ensuring that subrecipients have not taken or do not take “actions that could significantly damage” the “reputation” of the grantee or the federal government. (§ 200.322(i))

Claimed ability to change rules midstream (§ 200.208)
It is unclear the full intent of this policy, however we are concerned that it appears to allow any administration to unilaterally add or modify grant terms and conditions long after an award is issued. This could jeopardize receipt of awarded funds or timely reimbursement, if a grantee does not rapidly comply with altered terms. As worded, significant power would be granted to political appointees and subsequent administrations to change the parameters of the grant, at will far into the future. We ask that this provision be removed or clarified.

Ban on fixed grants (§ 200.1, § 200.102, § 200.201)
Cutting the fixed grant awards will have a serious impact on smaller institutions. Smaller, more rural museums and related organizations are the primary users of these programs, and terminating fixed grants will jeopardize the viability of these institutions. We ask that OMB maintain these programs.

Impacts on conferences, membership and advocacy (§ 200.450)

As written, the proposed rule places more stringent regulations on grantees’ use of funds for conference attendance, professional organizations, and publications by requiring that agencies grant permission to applicants before a grant is awarded. However, since the rule also would allow an agency to change the criteria at will, museums and others could not rely on federal funding. This section also places significant restrictions on how museums and other grantees could use federal funds to communicate with the public, including through voter registration activities. Many museums offer on-site voter registration to their audiences as an important part of their civic mission, often in collaboration with their local government.

Ensuring Museums Remain Highly Respected Places of Knowledge
Furthermore, the addition of the prohibition of DEI and gender ideology from grant applications (§ 200.300) would create additional uncertainty and discourage museums and cultural institutions from seeking federal funding. These organizations are uniquely positioned to help build a widely shared understanding of our nation’s history, including by highlighting multiple perspectives, and to reflect the full scope of the American experience in all its depth and complexity. This provision would disproportionately burden and undermine civil rights museums, Indigenous museums, and other institutions dedicated to preserving and interpreting culturally specific histories.

Finally, the wording of §200.205(d) as it refers to Executive Order14332 on “anti American” values should be removed due the lack of clarification and potential problematic implications. People trust museums because they rely on independent scholarship and research, uphold high professional standards, and embrace open inquiry. When any directive dictates what should or should not be displayed, it risks narrowing the public’s window into scientific evidence, ideas, and a full range of perspectives.

Courts have already found some of the proposed changes, with respect to termination of grants based on viewpoint discrimination, to be illegal and/or unconstitutional. While we do not offer legal analysis, it seems fair to observe that the proposal only adds to the uncertainty that the proposals will cause in prospective applicants.

If implemented, this proposed rule sets unpredictable financial, legal, and reputational risks that increase the perils of applying for and accepting federal monies overriding any potential benefits. We anticipate that a significant percentage of museums and related organizations would not be able to accept these risks, which would produce increased financial pressure in already challenging times. Therefore, we ask OMB to reconsider the proposed rule and delay any further implementation.

Sincerely,

American Alliance of Museums
American Association for State and Local History
American Institute for Conservation
American Public Gardens Association
Association of African American Museums
Association of Art Museum Directors
Association of Children’s Museums
Association of Science Museum Directors
Association of Science and Technology Centers
Association of Zoos and Aquariums