The White House Office of Management and Budget (OMB) recently proposed changes that would overhaul the federal grantmaking process and hinder the work of the history field. This message highlights the implications of OMB’s proposal and how you can speak up in response.

OMB recommends revising long-standing guidance on federal grants, cooperative agreements, and other financial assistance that would fundamentally transform the solicitation, administration, and reporting of initiatives supported by federal funding. If finalized, these new OMB regulations would operate with the force of law, which would create a binding one-size-rules-all regulation that federal agencies must follow.

The bottom line: These changes would enable far greater influence by presidential administrations on federally funded efforts, undermining the long-established merit-review process for grants, reducing flexibility and stability for grantees, and limiting Congress’s constitutional authority over spending.

Read on to learn about major potential effects of OMB’s proposal and what you can do about it.

What would OMB’s new rules do?
The document detailing OMB’s proposed changes is long and complex. We’ve pulled from analysis led by the Association of Science and Technology Centers, National Council of Nonprofits, American Alliance of Museums (AAM), and others to identify major provisions and implications most relevant to the AASLH community.

Demote independent experts in favor of political hires

  • Political appointees (or their designees) would be required to approve all awards, with nonpartisan, merit-based peer review of grants by historians and other experts reduced to advisory roles. Decisions would be based on whether an application “demonstratively advance(s) the President’s priorities” and does not “facilitate” the “promotion of anti-American values.” 2 CFR 200.205(b)(1)-(2)

Limit whole history

  • The new rules prohibit DEI and gender ideology from grant applications, creating uncertainty and anxiety for organizations seeking federal funding and undermining a major source of support for our field’s work in building a more complete, accurate, and widely shared understanding of our nation’s history. § 200.300
  • They also bar awards that “fund, promote, encourage, subsidize, or facilitate” practices where “race or intentional proxies for race will be used as a selection criterion for employment or program participation.” 2 CFR 200.300

Burden local institutions

  • Fixed grants would be banned, a serious impact to smaller and more rural organizations, the primary user of these grants. § 200.1, § 200.102, § 200.201
  • The new rules prioritize lower indirect costs, which reduces grantees’ ability to cover the total cost of administering a funded program and may limit the competitiveness of AASLH members who have higher indirect costs because they are part of a larger operating unit, such as a city or county government agency. 2 CFR 200.205 (b)(3)

Create logistical headaches and instability

  • The new rules provide agencies with wide discretion to cancel awarded grants at any time, with no required mechanism for objections, hearings, or appeals. This means that a federal award would no longer be guaranteed, compromising fundraising and budgeting efforts. 2 CFR 200.340(a)(2)
  • Agencies would be allowed to change terms during the grant award period and, potentially, temporarily pause a grant for up to 90 days. 2 CFR 200.340(e)

Undermine collaboration

  • Grantees would be required to ensure that subrecipients have not taken or do not take “actions that could significantly damage the reputation” of the grantee or the federal government. This would increase risk for AASLH members to partner with other organizations in their federally funded work. 2 CFR 200.322(i)
  • The rules add new restrictions against “issue advocacy” and engagement with state governments, which could jeopardize efforts to align or combine state and federal funding. 2 CFR 200.450

What can we do?

Ask your member of Congress to ensure that federal grants continue to provide vital support for their communities and to uphold Congress’s authority to direct funding. Encourage your representative to add a provision to this year’s appropriations bill preventing OMB or any federal agency from enacting the proposed changes.

Submit a comment on OMB’s proposal by July 13. Before it can finalize the proposed changes, OMB must receive and consider public comments on the proposal. You can help challenge the proposed changes by submitting a comment, ideally one highlighting the concrete impact the revised rules would have on your work. AAM offers examples here.

Now is the time for the history field to make our voices heard. Please join AASLH in speaking up for history and protecting the integrity and stability of the federal funding landscape.

AASLH’s efforts to champion the history field are made possible by the generous support of the history community. Become a member of AASLH or donate to our annual fund today.