Review Federal Grant Terms Carefully

If your ministry has received a grant this year or is planning to accept or apply for a grant, GCFA encourages you to review all the terms and conditions, taking special care with any grants involving federal funds. Since March of 2025, The United States Department of Homeland Security (“DHS”) has been amending their standard terms and conditions applicable to all grants issued by DHS and its constituent agencies, including FEMA and the Nonprofit Security Grant Program, the Public Assistance Grant (Disaster Recovery), the Emergency Food and Shelter Program, and the Hazard Mitigation Grant Program.   

Some of the changes to the grant terms relate to immigration enforcement participation, prohibitions against diversity, equity and inclusion, and compliance with all other Presidential Executive Orders. If your application occurred before March of this year, please know the date of the actual award controls, not the date of the grant application.  

Some aspects of these terms were challenged by some states in court in the case Illinois v. FEMA. On September 24, 2025, The US District Court in Rhode Island issued a permanent injunction related to some terms, but the outcome of that case will only impact those in the lawsuit. Those states include: Illinois, California, New Jersey, Rhode Island, Colorado, Connecticut, Delaware, Hawaii, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Mexico, New York, Oregon, Vermont, Washington, Wisconsin, and the District of Columbia.  An appeal is possible. This means terms might be different in different places, and change depending on the issuing agency.  

United Methodist ministries should exercise discernment and caution when accepting grants, especially when dealing with new terms and conditions like these. Ministries should thoroughly evaluate whether any grant terms might, explicitly or implicitly, dictate or restrict religious activities or determine the scope of ministry. Ministries are therefore encouraged to seek guidance from legal counsel and to reflect on how the terms of the grant could impact ministry.

While GCFA does not advise individual churches, we do want to issue information that may be helpful. As always, we encourage individual ministries to rely upon their own legal counsel.