9. Agency for International Development · Notable
Issue OGC guidance on faith-based organizations' funding eligibility
Printed page 272 9. Agency for International Development
“Within weeks of Inauguration Day, OGC should issue clear guidance on the eligibility of faith-based organizations for USAID funding.”
What has happened
- Not started
Moved nearby. Congress wrote the same direction into statute: P.L. 119-75 §7011(a)(2)(D) requires the Secretary of State's multi-year foreign-assistance effectiveness strategy to analyze "increasing partnerships with local organizations, including faith-based organizations, as appropriate, including specific plans to provide grants, cooperative agreements, and other awards of not more than $2,000,000".
- Not started
Moved nearby, at the successor. The first documented application of that policy to foreign assistance: a five-year bilateral health memorandum of understanding with Nigeria with "a strong emphasis on promoting Christian faith-based health care providers" and "significant dedicated funding to support Christian health care facilities", reaching the 900 faith-based clinics and hospitals that serve more than 30 per cent of Nigerians. A funding decision, not a legal opinion: the eligibility question the Quote wanted settled on paper has been settled in practice, by presidential directive plus award decisions, while the OGC guidance itself was never issued and OGC no longer exists.
- Not started
Moved the other way. The office the Quote addresses is gone, and so is the funding stream the guidance would have been about: USAID ceased implementing foreign assistance on 2025-07-01, and USAID's own Federal Register notice records "the ongoing reorganization of USAID operations in 2025, including the transition of certain foreign assistance functions to the Department of State and a reduction-in-force of nearly all USAID personnel". Guidance from a named agency's Office of the General Counsel on eligibility for that agency's funding is something the body does within itself, so abolishing the body defeats this ask rather than delivering it (playbook 3b, an ask addressed to a body that no longer exists).
- Not started
Moved nearby. Executive Order 14205 established the White House Faith Office and set the policy that faith-based entities, community organizations and houses of worship compete "on a level playing field for grants, contracts, programs, and other Federal funding opportunities", directing the Office to coordinate with agencies on identifying and promoting grant opportunities "especially [for] those inexperienced with public funding" and on religious-liberty exemptions. Government-wide and presidential: it names neither USAID nor any legal office, and no eligibility guidance followed within weeks of Inauguration Day.
Research log
What was searched, and what didn’t count as evidence
Research notes
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Re-leveled partial → not started on 2026-09-01 under the rule for an ask addressed to a body that no longer exists. The ask is for one specific document from one specific legal office — USAID’s Office of the General Counsel — about eligibility for USAID’s own funding, and neither the office nor the funding stream can be in the asked-for state with USAID gone, so the abolition defeats the ask. The directive (EO 14205), the Nigeria award decision and the FY2026 statutory language are real, dated and Primary but satisfy neither limb, so they carry their Evidence on the not started events as action nearby. The earlier reading read the object as the eligibility question rather than the guidance document.
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Negative search: the Federal Register full text for the window carries no faith-based partnership rule from State or USAID — the only in-window “Partnerships With Faith-Based and Neighborhood Organizations” document is USDA’s correction of 2026-04-17 (FR 2026-07525). The three Promoting Human Flourishing in Foreign Assistance rules of 2026-01-27 bind Department foreign assistance on abortion, gender ideology and equity ideology and say nothing about faith-based eligibility.
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EO 14332 grant-process sweep (2026-09-29). Executive Order 14332 (2025-08-07) puts every agency’s funding announcements and discretionary awards under senior-appointee review and a test of the President’s priorities. Under the rule we settled on 2026-09-29, it counts only where an ask’s object is review, clearance or priority-alignment of an agency’s awards. This Quote’s object is guidance from USAID’s Office of the General Counsel, which is gone. Status unchanged.
- Action
- issue
- Object
- OGC guidance on faith-based organization eligibility for USAID funding
- ID
- 732