WASHINGTON, DC.- On March 24, 2025, members of the National Museum and Library Services Board sent a letter to Keith E. Sonderling, the newly appointed Acting Director of the Institute of Museum and Library Services (IMLS), outlining the agency’s statutory obligations in light of recent directives from Executive Order 14238. Signed by 19 board members, representing both Libraries and Museums, the letter emphasizes the board’s advisory role and the legal mandates that the IMLS must continue to fulfill despite the executive order’s call for significant operational reductions.

The IMLS, an independent federal agency responsible for providing federal support to the nation’s 35,000 museums and 123,000 libraries, has been under scrutiny since President Donald Trump issued Executive Order 14238 on March 14, 2025. Titled “Continuing the Reduction of the Federal Bureaucracy,” the order, published in the Federal Register on March 20, 2025, directs federal agencies, including the IMLS, to reduce “non-statutory components and functions” to the maximum extent allowed by law and to minimize the performance of statutory functions and associated personnel. This directive has raised concerns among library and museum communities about the potential loss of critical funding and services.

In their letter, members of the National Museum and Library Services Board, established under 20 U.S.C. § 9105a and operating pursuant to the Federal Advisory Committee Act, reaffirmed its role in providing advice and recommendations on the IMLS’s policies, programs, and interagency coordination. The board highlighted its commitment to working with Sonderling to support the agency’s mission during this transitional period. “This is an important moment of transition for the agency, and we look forward to working with you to support and strengthen its mission,” the letter stated.

The members of the board detailed several core statutory obligations under the Museum and Library Services Act of 2018 (MLSA) that the IMLS is legally required to maintain. These include the Grants to States for Library Services (§9141), Native American Library Services (§9161), National Leadership Grants Program (§9162), State Plan Requirements (§9134), and Statutory Disbursement of Funds (§9133). Additionally, the board noted that all current-year and multi-year grants, contracts, and awards authorized by Congress—such as those under the Laura Bush 21st Century Librarian Program (§9165), Support for Digital Literacy and Emerging Technologies (§9121, §9162), and Museum Services Activities (§9173)—are non-discretionary and must be honored.

The letter also outlined structural requirements mandated by the MLSA, including the existence of both an Office of Library Services and an Office of Museum Services (§9102), ongoing research and data collection (§9108), policy development by the Director (§9103), and the board’s obligation to meet at least twice per year to advise the Director (§9105a). Beyond the MLSA, the IMLS is also bound by other statutes, such as the National Museum of African American History and Culture Act (20 U.S.C. § 80r-5(b)) and the National Museum of the American Latino Act (20 U.S.C. § 80u(f)(2)).

The members of the board emphasized that these statutory obligations cannot be discontinued or delayed by executive action. “Sections 9133 and 9176 of the Act affirm IMLS’s duty to obligate and disburse funds to grantees, subject only to the availability of appropriations, not to executive discretion,” the letter stated. It warned that failing to meet these mandates or reducing operations below the minimum required would place the IMLS in noncompliance with Congressional intent.

Sonderling, who was sworn in as Acting Director on March 20, 2025, after being appointed by President Trump, has stated his intention to align the IMLS with the administration’s goals, focusing on efficiency, innovation, and a renewed emphasis on patriotism. However, the board’s letter urges him to carefully consider these legal obligations as the agency prepares its response to the executive order. The board expressed its readiness to convene and assist Sonderling in navigating these challenges, underscoring its commitment to the lawful operation of the IMLS.

The letter comes at a time of heightened tension for the IMLS, as supporters, including the American Library Association and the American Alliance of Museums, have voiced strong opposition to the executive order, citing its potential to harm rural and underserved communities by cutting essential funding for libraries and museums.