ELCA Guidance on Federal Grant Requirements for Congregations and Ministries

The U.S. Department of Homeland Security has released updated Fiscal Year (FY) 2025 Standard Terms and Conditions for federal financial awards, including the Nonprofit Security Grant Program, FEMA, HHS, and other awards that have historically supported ELCA ministries and congregations . Download the Guidance on Updated Federal Grant Terms & Conditions (PDF)

These newly revised terms include requirements that grant recipients certify cooperation with ICE and refrain from engaging in DEI (Diversity, Equity, and Inclusion) or DEIA (Diversity, Equity, Inclusion, and Accessibility) activities, or from participating in certain “prohibited boycotts” such as those relating to the Israeli–Palestinian conflict. Additionally, the HHS Grants Policy Statement requires recipients to submit an Assurance of Compliance affirming they will not promote what is termed “discriminatory equity ideology,” as defined by Executive Order 14190 (January 29, 2025).

While many of these restrictions may touch on rights otherwise protected by the First Amendment, it is not yet clear how those protections might apply when a ministry or congregation voluntarily accepts the conditions of a federal award.

What This Means for ELCA Ministries

Congregations and synods considering federal grants are urged to carefully review these new requirements and seek legal counsel before applying. It is critical to ensure that accepting a federal award will not interfere with the religious or ministerial activities of your congregation, or restrict with whom you may engage in ministry.

For full details, you may view the ELCA General Counsel’s guidance here:

👉 Download the Guidance on Updated Federal Grant Terms & Conditions (PDF)

If you have questions, you are encouraged to reach out directly to the ELCA Office of the General Counsel for support.