On May 29, 2026, the Office of Management and Budget released a proposal to revise the Guidance for Federal Financial Assistance. The proposal was extensive, with profound implications for any entity that receives federal grants or contracts, including humanities organizations and higher ed institutions.
NHA’s first step was to sign on to a broader letter requesting an extension on the comment period. With comment periods usually set at 90 working days, 45 days for a revision of this breadth was highly unusual. NHA also submitted a comment on July 10 that discusses how the revisions would affect humanities funding.
NHA’s comment is specifically addressed to the National Endowment for the Humanities (NEH), as a cosigner of the proposed revision. Our comment addresses how several provisions of the proposed rule could significantly modify the manner in which the National Endowment for the Humanities carries out responsibilities specifically assigned by Congress in the National Foundation on the Arts and the Humanities Act. An overbroad interpretation of those provisions could impede Congress’s objective of strengthening the nation’s humanities infrastructure through sustained support for scholarship, preservation, publication, education, and public engagement and substantially harm the humanities infrastructure and the institutions, scholars, and organizations Congress directed the NEH to support in 20 U.S.C. § 953.
NHA’s concerns fall into four areas: the proposed § 200.205 merit review requirements and the role of the statutorily established National Council on the Humanities; the proposed §§ 200.300 and 200.218 nondiscrimination provisions and Congress’s definition of the humanities and directions to the NEH; the proposed § 200.340 termination authority and Congress’s long-term investment in the nation’s humanities infrastructure and scholarly independence; and the proposed §§ 200.454 and 200.461 requiring pre-approval for publication costs and scholarly exchange and Congress’s direction to the NEH to support publication, dissemination, and scholarly exchange.
The full comment is available here.
Posted on: July 14, 2026