You may already be aware of proposed changes to guidance for the Office of Management and Budget (OMB) that have raised concerns from colleagues across the cultural heritage landscape. Amidst an already uncertain federal funding landscape, the proposed changes would exacerbate existing issues by expanding the authority of political appointees.
Our colleagues at the American Alliance of Museums (AAM) have outlined some of the most relevant issues:
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Political appointees must review all award proposals and relegate peer reviewers to an advisory role.
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Political appointees will review all award proposals to ensure they align with “national interests” and Presidential policy priorities. (This will likely impact anything deemed DEI-related.)
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Any active grant can be cancelled by a political appointee with no chance of appeal.
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A grant can be put on a temporary hold for up to 90 days.
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Agencies can change the terms of the award at any time.
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Adds restrictions on voter registration drives, issue advocacy, and engaging with state governments.
Most of our membership and our community are familiar with the expert review provided through the federal grant making process and have benefited from funding provided through agencies like the Institute of Museum and Library Services (IMLS), National Endowment for the Arts (NEA), and National Endowment for the Humanities (NEH). Several key FAIC programs are directly funded by federal funding, such as the Collections Assessment for Preservation (CAP) Program, Connecting to Collections Care (C2C Care), and our emergency programs. The instability that would be created by the proposed changes would make seeking federal funding virtually impossible for many organizations, especially small historical societies, tribal organizations, libraries, archives, and other collecting institutions.
AIC will be joining many other allied organizations in heritage, education, and science fields in submitting a comment on this proposed guidance to express how these changes would negatively impact the conservation profession and care of cultural heritage in the United States.
Anyone is welcome to review the proposed changes and offer commentary on Regulations.gov. Please be advised that specific, individualized comments are most effective! AAM advises: "If you decide to submit a comment to a Federal Proposed Rule, make sure your comments are specific about your concerns and provide insights on how the rule impacts you/your organization. Public comments on proposed rules are more about quality over quantity. Provide impact data if you have it. The comments should be unique. The comments are made public but you can submit comments with your name, on behalf of an organization, or anonymously. For additional tips, see the “How You Can Effectively Participate in the Regulatory Process Through Public Comment” document published on regulations.gov."
We also encourage those of you who can to contact elected representatives about the executive overreach created by these proposed changes. Explain how these proposed changes would affect conservation, collections care and public access to our shared cultural heritage. Our colleagues at AAM have set up an easy form to contact your representatives to let them know how you would be impacted by these changes: https://www.congressweb.com/aam/102/
Comments are open through July 13.