Issue Brief: Contingency Planning for State Budgets for IMLS Funding Uncertainty

Immediately following President Trump's March 14, 2025, Executive Order directing the Institute of Museum and Library Services to “reduce the performance of [its] statutory functions and associated personnel to the minimum presence and function required by law”, the EveryLibrary Institute issued a Brief that outlined and discussed the statutory obligations and discretionary functions of the Institute in order to help inform our sector about a viable framework for advocacy and Congressional engagement.

Since that Brief on March 15, numerous state library associations and stakeholder groups have sent letters concerning the statutory obligations of IMLS to their congressional delegations, particularly members who serve on committees of jurisdiction or are key Senate and House library leaders. Notably, both the Institute of Museum and Library Services Advisory Board letter of March 20 and a joint letter by Senators Reed, Collins, Gillibrand, and Murkowski on March 26 have framed their advice or oversight within this statutory obligations framework.

While Congress is conducting its critical legislative oversight role and the IMLS Advisory Board is continuing to inform the acting director of agency responsibilities, it remains to be seen how the Office for Management and Budget will implement President Trump’s Executive Order. The IMLS situation remains extremely fluid. The current fiscal year 2025 payments to grant recipients, as well as the future makeup of the agency, remain uncertain. Congress cannot repeal an Executive Order, and the outcome of any possible lawsuit is uncertain. It is important for state-level libraries, museums, and archives stakeholders to understand that the next phase of this campaign needs to be conducted within their state’s budget processes and to not exclusively focus on Congress or the Administration. 

Prudent state-level stakeholders should be engaging with their state legislators, particularly on appropriations, finance, budget, or ways and means committees, about federal FY2025 IMLS funding contingencies. The federal fiscal year runs through September 31, 2025. Aside from New York, Alabama, Michigan, and Texas, states will begin their 2026 fiscal years on July 1. Any disruption or discontinuance of federal FY2025 funding would immediately impact state agency budgets and grant recipients in significant ways. This would include funding to state libraries through the Grants to States program as well as funding to numerous agencies, non-profits, and academic institutions across the museums, archives, and libraries sectors. The window for FY2026 budget advocacy in some states has already closed. In others, negotiations are ongoing, and contingencies may yet be enacted. 

While we are confident that state library associations will continue to advocate strongly for the stability and full funding of IMLS, we must recognize the importance of contingency planning within each state budget should it be necessary to shift cost centers to the states in order to ensure the continuity of library services.

Two Triggers: Budget Policy Options for Contingency Planning about Federal FY2025 Funding

This Policy Brief introduces a budget strategy that state library associations can use in conversations with their appropriations, budget, finance, or ways and means committees about the future stability and constancy of IMLS funding. We recommend developing and supporting a “fiscal trigger” mechanism within your state budget appropriations language that allows state funds to be allocated or released if federal FY2025 IMLS funding thresholds or conditions are not met. These mechanisms provide a prudent, responsive approach to preserving library services and safeguarding the public interest in times of fiscal uncertainty.

Historically, state legislatures have a variety of fiscal trigger mechanisms at their disposal to respond to uncertainties in federal funding. The term “fiscal trigger” is used in a variety of contexts, including automatic spending, ending a state program, or even implementing an automatic change to the tax code. While budget triggers have often included healthcare, transportation, and infrastructure settings, they have not, to the best of our knowledge, ever been applied to state libraries or other IMLS obligations. In this setting, the context of a trigger - where a shortfall to current FY2025 IMLS funding would hazard a state agency or recipient - is more important than the term of art used. These are unusual times. 

Below are two adaptable models of contingent state budget appropriation triggers that could be applied in practice should federal FY2025 IMLS funding be disrupted or discontinued:

1. Set up a “Federal Reduction Trigger” that would authorize a conditional state budget appropriation that is released if FY2025 federal IMLS funding falls below a prior-year benchmark. It should require that the governor or state OMB certify the shortfall on the advice of the state library agency. 

Illustration: “If federal FY2025 IMLS funding is reduced below FY2024 levels, $X is appropriated from the General Fund to the State Library Agency, contingent upon certification by the Budget Director.”

2. Create a “Federal Elimination or Inaction Trigger” that would allow an appropriation to be made if IMLS is eliminated or rendered non-functional by executive action. This trigger could be tied to a fixed date or legislative session milestone.

Illustration: “If the federal Office for Management and Budget withholds FY2025 federal funding  from IMLS, $X from the State Reserve Fund shall be released to the State Library Agency to preserve essential library services.”

Any trigger mechanism should allow the director of the state library agency to notify a designated executive official that a mid-FY2025 reduction, disruption, or elimination to IMLS funding has occurred and authorize that designated executive official (e.g., Governor or Budget Director) to certify that a reduction or program disruption has occurred. This certification should include a legislative reporting requirement.

Illustration: “If the director of the state library agency is unable to draw down on federal FY2025 IMLS funds because of mid-year actions by the Institute of Museum and Library Services, the director shall notify the [executive officer]. Upon certification by the [executive officer] that IMLS funding has been reduced or eliminated, $X is released from the General Fund to the State Library Agency to be used solely to maintain programs and services previously supported by IMLS funding, and a report is submitted to the Joint Legislative Budget Committee within 30 days.”

Policy Recommendations and Legislative Language

This Brief introduces state-level library, museums, and archives stakeholders to fiscal triggers, an unusual but germane policy strategy that they can use in conversations with their appropriations, budget, finance, or ways and means committees. We recommend developing and supporting a trigger-based appropriations language that will allow state funds to be allocated or released if certain federal funding thresholds or conditions are not met. These mechanisms will provide a prudent, responsive approach to preserving services and safeguarding the public interest in this time of fiscal uncertainty.

When meeting with legislators and their staff, it's essential to approach the conversation about trigger-based funding policies with a strategic narrative. Start by leading with shared values, affirming your commitment to maintaining strong and stable public services alongside sound fiscal management. It's important to establish common ground from the outset, as this sets a collaborative tone for the discussion. Next, position the trigger as a current fiscal year "safety valve." Make it clear that this would act as a temporary response to current volatility and uncertainties. Stress that this is a pragmatic solution designed to address uncertainties in a responsible manner.

It is important to position a trigger as part of a broader risk-mitigation strategy. Be ready to share potential impacts to paint a true picture of the situation should federal FY2025 IMLS funding disappear mid-year. Offer concrete local examples that illustrate what services or support might be jeopardized without this contingency fund. Illustrative scenarios can help legislators understand the real-world implications of inaction.

Messaging Checklist:

• Frame your fiscal trigger as a safeguard, not as a pre-determined outcome. Be sure to pro-rate your funding request within the timeframe of both your state and federal fiscal years.
• Align with state fiscal norms by using terminology and mechanisms already familiar to your legislature (e.g., “certification,” “contingency,” “reserve funds”).
• Link the funding back to the continuity of core services and emphasize the risk to local libraries, museums, archives, and grant recipients. 
• Provide reassurance about controls by using legislative language that ensures a trigger is only activated under defined federal funding conditions.

Beyond Federal FY2025 Planning

IMLS is authorized, and its statutory obligations are set by the Museum and Library Services Act, which is up for reauthorization at the end of FY2025. It is possible that the Act could be reauthorized by Congress without many changes and that IMLS could continue as-is or with only minor modifications to its statutory obligations. However, given the administration’s overarching approach to repositioning cultural agencies like the NEH, NEA, PBS, the Smithsonian, and the Kennedy Center in relation to its priorities about patriotism, American exceptionalism, and social norms, it is unlikely that the next iteration of IMLS will look or behave like it has since it was first created in 1996. State-level IMLS stakeholders should be planning for a future where the administration and Congress could impose significant changes to IMLS grant rubrics or even set conditions and qualifications on IMLS funding that may make it uncomfortable or even impossible for current grant recipients to reapply. 

State legislators, particularly appropriators, will benefit from timely engagement about current FY2025 IMLS funding and a reasonable landscape assessment of future fiscal years. If the administration’s mandates severely limit the use or scope of FY2025 federal funds, the effects will cascade quickly across our ecosystems. If the nature and character of IMLS and other cultural grant programs change in future fiscal years, new state funding priorities will need to follow. Given the administration's approach to other federal departments and agencies, it is not out of the question to contemplate the end of federal funding for libraries, museums, and archives through IMLS. In any case, for states to take up some or all of the funding obligations from IMLS, deliberate engagement by library, museums, and archives stakeholders is required in order to succeed.