Trump's War on Nonprofits

I’ve been wanting to start this thread for a while.

I wanted to dedicate a space to articulate and complain about the ongoing saga between Trump’s administration and nonprofit organizations. I’m a federal grants writer and administrator (I also do corporate and foundation grants) for an agency that serves survivors of intimate partner violence and sexual assault. I’ve been in the field for approximately 15 years, with three years managing federal grants. I can only speak to my experience within the narrow field of services for victims of crime. I’m currently administering grants from the Office on Violence Against Women as well as about thirteen grants from MDHHS’ Division of Victim Services as federal pass-through funding - which includes VOCA (Victims of Crime Act) funding.

I plan to update this thread regularly because it seems like a new drama every week and it’s exhausting trying to keep up with it and it would help to have a void to scream into.

While there has been a lot in the news about federal grants being paused and rescinded, I wanted to dive into the broader context and complexities of what’s actually happening, because this administration is clearly making a concerted effort to destroy nonprofit organizations - particularly those that don’t fall in line with the government’s ideology, but with knock-on effects for all of them. At a time when services for marginalized communities, including poor communities, are being slashed, when access to medical services are being cut, when we’re in the midst of a housing crisis, I think it’s important to draw attention to the fact that these people are going to have very little to fall back on. Nonprofits even in our heyday were unequipped to address all the need. Well, it’s going to get a lot worse.

Here’s what’s going on:

  1. Within the field of victim services in particular, we are facing significant cuts to VOCA, by about 75%. I cannot blame this on Trump, it’s been an ongoing issue for years, and VOCA hit a new low during COVID because these funds are based on the prosecution of white collar crime. Assuming nothing is done to compensate VOCA funds, victim service providers are looking at cuts of half of our workforce, across the country. (The state of Michigan, at least, thanks to aggressive legislative advocacy by victims service providers, has allocated $35m in the state budget for victims of crime, which helps, but does not erase the problem.)

  2. The rules for securing federal funding have radically changed, but the current administration will not tell us what the new rules are. They use vague terminology like “illegal DEI” which inevitably has a chilling effect, but according to the many experts I’ve heard talk about this issue, it has no real meaning. That doesn’t mean it won’t be used to weed us out of the selection pool, though. Furthermore, these unallowable expenses now cover “illegal DEI” activities that are not implemented using federal funding. The new rule is that agencies cannot even spend their own money to fund DEI activities. This is of course a massive free speech violation.

  3. According to other grant professionals in my network, all agency contacts with federal funders are now under surveillance, recorded, and flagged for keywords that could trigger a Civil Rights investigation. I’ve looked at lists with hundreds of words used to filter applications, some of which make no sense. Not being able to use the word “justice” for example, when applying to the Department of Justice and discussing victims of crime.

  4. The language in grant applications has changed to include what read to me as blatantly illegal definitions of unallowable activities. Perhaps the most concerning of these is language in domestic violence and sexual assault grant applications that require us to agree to cooperate with DHS in immigration proceedings. The problem with this is that it is illegal. We are required by federal and state law to keep the names and identities of clients confidential. We’re not even allowed to ask them their full name.

  5. Department of Justice funding priorities (which used to be things like, “serving underserved populations” and “addressing human trafficking”) are now focused on “serving AMERICAN victims of crime,” but there has been no communication about how we are to determine the immigration status of our clients given federal and state law. We wouldn’t do it anyway, because it’s unethical, and is a safety risk to the client. As a general commentary on this, there’s been a radical shift in the language away from serving victims and toward prosecuting criminals, with special emphasis on illegal criminal cartels, which generally have nothing to do with this issue.

  6. We now have to jump through an extra administrative hoop every time we draw down funds. In the past, we submitted a budget, the budget was approved by the federal agency, and we drew down funds for those specific purposes after we spent the money (it’s important to keep this in mind - we only get reimbursed after we spend the money.) The new rules require a “Defend the Spend” written justification every single time we draw down funds, on top of the budget approval process. What this means is they can deny funds to us after we’ve already spent them. I’d like to underscore here that the people deciding whether or not we get reimbursed have zero expertise in running a domestic violence or sexual assault services program.

  7. Recent executive order stated that from now on there will be a “Presidential appointee” reviewing federal grant applications who will have final say over subject-matter expert review. They have also announced they are going to rewrite 2 CFR Part 200, the 200-page Uniform Guidance document that governs all federal grant recipients. I can only imagine what that will contain.

  8. Executive Order released this week declared that from now on, legal expenses for “removable aliens” are now unallowable. This may or may not affect us, as we provide legal advocacy to survivors who may or may not be documented, we don’t know because we can’t legally ask.

  9. Yet another Executive Order released this week declared renewed scrutiny on nonprofits believed to be funding domestic terrorist activity and “radicalizing” people. I presume this means agencies that vocally support LGTBTQ communities and undocumented people. The nastiness is just getting started.

  10. Here’s something people don’t really know about: The assault on federal grants is not the only way that Trump’s administration is attacking nonprofits. The One Big Beautiful Bill revised corporate tax law to create a 1% floor for the deduction of charitable contributions made by corporations. Think tanks estimate this will reduce corporate giving to nonprofits by trillions of dollars. So when we lose all that federal funding, what will we fall back on?

Oh, is that everything? I’m sure I’m missing things. Here is a link to a link to a full analysis of relevant Executive Orders.

The biggest issue I’ve been having personally is trying to figure out how the hell the federal government wants us to write these applications now. We’re supposed to pander to their right-wing ideology while somehow also convincing subject-matter experts we know what we’re doing. It’s crazy-making. The idea of a “Presidential appointee” determining what an effective victim services program looks like makes me nauseated. Considering the President doesn’t even think domestic violence should be a crime, I’m not optimistic.

I got into this field because I wanted to make a difference on a systemic level. At that time, people like me were dismissed as “do-gooders,” maybe unrealistic in our idealism, but we were not characterized as radicals or terrorists. And the irony is that a lot of the people who voted for this guy are going to need the services we won’t be able to provide them.

I’m not sure, entirely, how applicable this is but, first, I’d note that words are fictions.

Like, a homeless man can be “a person to care for” or “a terrorist”, just depending on who the speaker is. Both words reference the same thing. Likewise, “a grant” is no different than “a bribe” or “a gratuity” or “a mechanism for compliance”. If you write that you “want to deal with terrorists through iterative mechanisms of compliance”, on paper that sounds awesome. In practical reality, it means “Give money to homeless people.”

Secondly, I’d note that some people have little to no mind of their own, desperately want to please their boss, and would gladly accept any solution that you offered that ticked all the boxes.

So, I can easily imagine a strategy doc that explains a non-DEI strategy for aid that uses a 5 point grading system to decide who to prioritize for “investment” and who to prioritize for “sanctions”. Said grading system could, for example, rely strongly on “expectations of positive impact”, “past performance”, etc.

Ultimately, if you’re the one who decides how to square the peg, then it gets squared in the way that sounds right on paper to the people above you, and achieves the goals that you feel would best work for your non-profit.

For us, personally, I’ve been trying to emphasize the role we play in bringing perpetrators to justice, which is pretty robust. In addition to medical forensic examinations, expert testimony, suspect exams and legal advocacy, we have strong relationships with local police departments, courts, prosecutors, etc. so I feel like that one’s a little easer for us to pitch.

Federal grants have always been onerous, but at least the expectations were clear. That’s just not the case anymore.

OK, that’ll be disqualifying. The people running the government now don’t want perpetrators brought to justice, because they are the perpetrators.

I’d make a stab that the expectation is that you make #1 look good and don’t do the DEI.

Slap the guy’s face on the wall, give the Roman salute each morning, pray an offensive joke, and you’ll be gold.

Yeah, but they don’t believe they’re the perpetrators. “Criminal behavior” is whatever someone else is doing. They want to look tough on crime. The only ethical priority area is “combatting violent crime,” so I’m trying to respond to that one.

You know, there’s what they want to hear and there’s what you’re willing to say and still be able to sleep at night.

When you say the One Big Beautiful Bill creates a 1% floor for the deduction of charitable contributions, are you saying that there will be a 1% ceiling that makes it so no more than 1% of a corporation’s income can be donated to charity (and then deducted from income)? I’m a little confused because floor usually means a minimum rather than a maximum.

If that is the case, do we know how that line got slipped into the bill? Is it just someone trying to maximize federal revenue by preventing corporations from lowering their income taxes? I’ve never thought of Republicans as being against charities (they usually advocate for charities to do things instead of the Federal Government), but I suppose if the budget problem is bad enough, they may be desperate enough to get the money from anywhere. Are there any loopholes? Is there some sort of religious exemption so their pet causes won’t be hurt or do they figure religious organizations get their donations in small dollar form from religious people and won’t be in danger?

I’m no expert, but from googling

How Will Non-Profits Be Impacted by the Big Beautiful Bill? Your Guide to Key Changes Affecting Charitable Giving, Excise Taxes, and More | Fisher Phillips.

For context, corporate giving is about 1/6 of our current budget. It’s going to be much higher for smaller non-profits who don’t have the capacity to manage federal grants.

As if this isn’t fun enough, many corporations are still heavily weighing funding priority by whether we are implementing DEI initiatives. They expect us to be doing it while the government is telling us not to do it.

They intentionally put it in there to raise revenue for their ridiculous spending bill.

Those times have passed, not that it was ever anything but lip service anyway. Non-profits are now being framed as hotbeds of leftist extremism. The Sept. 25th Executive Order is chilling.

This political violence is not a series of isolated incidents and does not emerge organically. Instead, it is a culmination of sophisticated, organized campaigns of targeted intimidation, radicalization, threats, and violence designed to silence opposing speech, limit political activity, change or direct policy outcomes, and prevent the functioning of a democratic society. A new law enforcement strategy that investigates all participants in these criminal and terroristic conspiracies — including the organized structures, networks, entities, organizations, funding sources, and predicate actions behind them — is required.

In case you had any doubt what they are talking about, the DOJ has opened an investigation into the progressive grantmaking entity Open Society Foundations.

Also, this:

The Department of Justice (DOJ) confirmed this week that it will be using the False Claims Act (FCA) to investigate recipients of federal funds that the agency determines have certified compliance with federal non-discrimination laws “while knowingly engaging in racist preferences, mandates, policies, programs, and activities, including through diversity, equity, and inclusion (DEI) programs that assign benefits or burdens on race, ethnicity, or national origin.”

According to a memo addressed to DOJ attorneys, the agency is standing up a new “Civil Rights Fraud Section” to be co-led by DOJ’s Civil Division’s Fraud section and its Civil Rights Division, and engage with DOJ’s Criminal Division and other federal agencies with civil rights enforcement authority (such as the Departments of Education, Health and Human Services, Housing and Urban Development, and Labor). The “Civil Rights Fraud Initiative” also intends to establish partnerships with state attorneys general and local law enforcement to share information and coordinate enforcement actions.

The False Claims Act exists to reward whistleblowers who report misappropriation of government funds. The DOJ has now decided that any agency conducting DEI activity is defrauding the federal government. I’m not sure if this is going to be retroactive, but if it is, a lot of nonprofits are screwed. The overwhelming trend, even at the federal level, was for many years to fund initiatives that identified specific underserved populations, demonstrated cultural competence, or otherwise promoted DEI. Now it looks like nonprofits could be punished for responding to previous administrations’ funding priorities.

Make sure they know that.