Two weeks ago, we took one (more) step towards a future in which the risks of government funding might outweigh the benefits.

On May 29, the Office of Management and Budget (OMB) released a new proposed rule for the Regulation for Federal Financial Assistance. The rule, aka Uniform Guidance, would apply to all government agencies, including the Institute of Museum and Library Services, the National Endowment for the Arts and the National Endowment for the Humanities and affect funding for arts, culture, health, science, housing and transportation. As written, the regulations would:

• De-emphasize the role of peer review in screening applications and awarding grants.
• Give political appointees the authority and responsibility for reviewing grant applications to ensure they “align with presidential priorities.”
• Prohibit funding for activities that advance DEI, as well as certain activities related to gender ideology, gender-affirming care, abortion-related activities and voter registration efforts.
• Restrict the ability of grant recipients to engage in some kinds of advocacy.
• Give agencies the authority to restrict eligibility for certain categories of nonprofits.
• Establish that any grant could be cancelled at any time if the agency providing the funding decides the grant is no longer in the national interest.
• Discourage international collaboration.

Of particular concern to the museum sector is the fact that these draft regulations direct that grants could not be used to “promote anti-American values.” This suggests the possibility of a future in which political appointees evaluate whether a museum exhibit or program aligns with how the administration wishes to depict our country.

How can museum people respond?

This is a draft regulation, open to public comment until July 13 (OPM plans to publish the final rule in October).  AAM’s June Advocacy Alert encourages museum people to submit comments via regulations.gov. Individuals can add comments by name, or anonymously, up to 5,000 characters, with the option of uploading attachments. As of time of writing of this post, over ten thousand comments had been received, with 35 days to go before the comment period closes. (I encourage you to read some of the submitted comments to get a feeling for public reactions to the proposal.)

AAM joins a growing number of professional associations voicing concerns about the impact these regulations would have on their sectors, including nonprofits overall (National Council of Nonprofits), science (AIBS, AAAS, American Astronomical Society, higher education (APLU and NACUBO), and  K-12 education (AASA). We will be submitting comments ourselves and are consulting with our counterparts to determine best next steps as a collective nonprofit sector. Watch for additional analysis and guidance from AAM’s advocacy staff in coming weeks.

How can foresight help your museum prepare and respond?

Strategic foresight can help your museum anticipate, prepare, and respond to this and other disruptions in the policy landscape in coming years.

First, monitor political news and commentary to ensure you are not taken by surprise. However unwelcome, this proposed rule was foreshadowed in recent years:

• It aligns with policies advocated in Project 2025, which served as a blueprint for the current administration.  (OMB Director Russell Vought, co-author of that report, has long advocated that OMB serve as the keeper of “commander’s intent,” moving power away from Congress and towards the executive branch.)
• The executive order Restoring Truth and Sanity to American History, issued in March 2025, made it clear that museum content is on the administration’s radar.
• Last year, AAM’s Impact of Executive Actions resource flagged the potential for funding to be tied to presidential priorities and asked, “in the future, might government funding shift from being a reliable pillar of museum income to a source of supplementary funds that comes with significant risks?”  

Second, use these implications to stress-test your museum planning. Even as we, as a sector and as individuals, advocate for changes to this proposed rule, as organizations we should budget and plan for a future in which government funding is precarious at best. Your planning team might ask:

• What programs and initiatives in our plans depend on federal funding, and how would we adapt to loss of these funds?
• Would we be willing to change our plans to meet expectations or limitations around content?
• How would we manage the risk that grants already awarded might be cancelled?

Third, ask “what’s next?

• If the rule is enacted, it will almost certainly be challenged in court. Would it be wise to wait until the courts weigh in before applying for new government funding, or proceed with the hope the rule will be struck down?  
• Whether or not this rule is approved as written, revised, or abandoned, many states are taking their cues from federal proposals. Might your state propose similar constraints on state funding?
• Whether or not this rule is enacted, it demonstrates how future administrations might attempt to use grantmaking to advance particular values or objectives. In such a future, what guard rails might your museum erect around the risk that even existing grants might be used as a mechanism of control?

Finally, envision the way you want the future to play out, and take actions that help put us on that path. The opposite of apathy is advocacy, and right now advocacy our most effective tool for pushing back against the forces trying to constrict and constrain government grant-making. Working together, we have already won notable victories—restoring cancelled grants, defending the budgets of IMLS, NEA, and NEH. If you want a future that includes robust, non-partisan federal funding of arts and culture (not to mention science and health), that means speaking up now, individually and together with the field.

Please make your voice heard, most importantly via public comments on the proposed rule, but also in the AAM community, via discussion on Museum Junction, and in comments here on the blog. It is good to remind ourselves that we face this challenge together, supporting and encouraging each other as we navigate difficult times.

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