Does your public garden receive federal grant funding?

A new proposed “uniform guidance” rule change from the Office of Management and Budget seeks to rewrite the fundamental framework of how all federal grants issued by the federal government are administered. Read more from AAM here.

If your garden receives federal grant funding, these changes will likely affect you.

The proposed changes apply to future IMLS, NEA, and NEH grants, science related funding from NSF, NOAA, NASA, USDA, and others.

If your public garden does receive federal grant funding, please take a moment to tell the Association about them here: https://form.jotform.com/261723838758067

The proposed 400 pages of changes (Docket OMB-2026-0034-0001) include:

  • Cancellation of grants at any time, without notice (§200.340) – current guidelines require actual misconduct;
  • 90-day pauses in funding for “review” (§200.340) – can “recommend” changes;
  • Grants must conform to “Presidential priorities” and meet a loosely defined “Gold Standard” for research (§200.205) – these potentially change with every new administration or administrator;
  • All award decisions made by political appointees – peer review is made specifically secondary in influence;
  • DEI, Gender Research, and Related Topics Banned as Grant Conditions (§200.300);
  • Restrictions on ability to share information, fees excluded unless expressly approved for:
    • Publication (§200.461) – article processing and journal publications costs generally disallowed;
    • Conference/meeting (§200.432) – all charges must be approved in the initial application;
    • Membership (§200.454) – fees only allowable if required to fulfill award requirements.

This rule change removes many provisions which protected grants in last year’s Rhode Island v. Trump court decision restoring IMLS and other grants.

If your public garden might potentially be affected by these changes, the Association encourages you to consider submitting a public comment about the rule change. Comments are due by July 13, 2026. We have joined with many of our peer museum Associations and others in requesting an extension of the comment period. The Association plans to comment individually and/or with our peer Associations.

All comments are made public but you can submit comments with your name, on behalf of an organization, or anonymously.

The number of comments can attract Congressional attention while the quality of comments can influence final decision on the rule and help establish standing in any subsequent legal action. Filing a comment does not obligate you or your institution to participate in legal action.

SUBMIT PUBLIC COMMENT: https://www.regulations.gov/document/OMB-2026-0034-0001

Submitting Comments to a Federal Proposed Rule: 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. For additional tips, see the “How You Can Effectively Participate in the Regulatory Process Through Public Comment” document published on regulations.gov.

Comments are limited to 5000 characters (plus attachments).

AS AN INSTITUTION: be sure you are authorized to comment on behalf of your institution; be specific about the impact to your institution.

AS AN INDIVIDUAL: use your private contact information; speak from your professional experience (“As a 20 year public garden professional…”) not your institution (“As Director of Kiting at Franklin Public Garden…”); be specific about how the rule changes impact you as an individual professional.

We also encourage you to alert your member of Congress to make sure they are aware of these proposed changes. Share your public comments with them demonstrating the impact on your organization. Ultimately, Congress can overrule Executive rules like these in appropriations legislation.

You can find their contact information here: https://www.congress.gov/members/find-your-member