Scenario Planning Insights and Recommendations
Already, the White House has issued a memorandum accusing many nonprofits of engaging in “actions that actively undermine the security, prosperity, and safety of the American people” and is directing agencies to “stop funding NGOs that undermine the national interest.”[1] They have also begun criminal investigations into groups for allegedly conducting a “conspiracy to defraud the United States.”[2] The arbitrary slashing of funding for federal grant recipients has created immeasurable uncertainty throughout civil society, from museums to research institutions to housing organizations to food pantries.
For the vast majority of organizations, the assumptions that were utilized to inform previous strategic plans are almost certainly flawed. Organizations facing funding cuts are in a state of panic, leading them to make across-the-board cuts instead of methodically restructuring and strategically reallocating resources – to allow for future rebuilding and regrowth. Instead, they should take the time to think about their current strategic posture, the risks they face, and how to maximize their resources given the new reality – and make resource and programmatic decisions carefully and thoughtfully. To that end, we also encourage funders to provide bridge funding to give organizations room to reassess and restructure their plans, and to consider additional flexible operations funds for organizations to use to strengthen infrastructure, security, and legal defense in this unprecedented time.
This memo describes the unprecedented threats that now originate from the federal government – threats that are only just beginning – and outlines in detail the key insights and recommendations gathered from our work. We hope this resource can inform the steps that civil society organizations and their funders can take to address the challenges.
THE CURRENT LANDSCAPE
The pace with which the administration is moving has caught most by surprise, however many of the specific challenges could be anticipated. Throughout the election, we stressed that Project 2025 is not an aberration, but the culmination of the work of over 120 groups — the entire conservative industrial complex.[1] Therefore, reports about the number of policy steps the new administration has taken that can be found in Project 2025 are not surprising. The handbook’s recommendations will remain closely adhered to and should be studied.
In addition to federal regulatory and legislative attacks, we also anticipate a coordinated movement of the Project 2025 playbook into the states. Nonprofits working in conservative states have already faced heightened risks and will see those challenges replicated in the federal government. Despite efforts to organize a “blue wall,” we also anticipate that the Trump administration will target states with Democratic governors for cuts and other retribution, which will also affect social justice organizations in blue states.
[1] https://www.project2025.org/about/advisory-board/
INSIGHTS AND RECOMMENDATIONS: GOVERNMENTAL THREATS
Federal Funding Cuts: In addition to the DOGE efforts to make across-the-board, government-wide cuts, the Republican Congress is also poised to significantly cut and eliminate federal programs.
Recommendation: Groups that receive government funding – either directly from the federal government or federal dollars that pass through states or cities – should be prepared to see those dollars cut, if not eliminated. Budget re-forecasting and programmatic modifications should be considered immediately, and organizational restructuring options should be explored.
Regulatory Scrutiny: Organizations need to be prepared for increased scrutiny from regulators like the IRS, U.S. Department of Justice, state attorneys general, and secretaries of state. Often, this kind of scrutiny is designed to intimidate and interfere with the work of organizations.
Recommendation: Groups should conduct a detailed risk assessment to ensure they are in full compliance with the law and preserve their 501(c)(3) status. They should be prepared to defend their specific use of government funds if investigated or audited.
Oversight and Investigations: Congress is poised to aggressively use its oversight and investigations power to target organizations that work on disfavored issues. For groups on the receiving end of these inquiries, there is little understanding of the distinction between a political inquiry and a legal inquiry. Again, these tactics are designed to send organizations on paper chases, intimidate both individual organizations and movements by making “examples” of others, depress their supporters, and broadly distract organizations from executing their missions.
Recommendation: Groups should not rush to comply with an oversight request. Instead, we recommend they engage their members of Congress (or state legislators, depending on the origin of an inquiry) and other elected officials to respond on their behalf. We also recommend that groups engage directly with their allies on committees of jurisdiction to help them understand the context and status of investigations.
Criminalization of Services: Draconian enforcement measures should be anticipated that are designed to intimidate and criminalize those working with vulnerable populations, for example undocumented immigrants or caregivers to trans youth. The Department of Justice has already begun to use its prosecutorial discretion to enforce obscure and anachronistic laws to bring cases against organizations that serve marginalized communities.
Recommendation: Organizations that serve targeted communities should be prepared to defend staff and clients engaged in that work. Having legal support, whether pro bono or otherwise, can help organizations conduct a risk assessment and respond to prosecution and law enforcement actions. Collaborations with strategic litigation organizations will also be critical here.
INSIGHTS AND RECOMMENDATIONS: OTHER THREATS
Physical Safety and Cybersecurity: The risk of targeted protests and cybersecurity threats is high, and too few groups have the resources or knowledge to design and implement security plans.
Recommendation: Organizations should evaluate potential vulnerabilities in their physical and digital infrastructure and ensure those gaps are addressed.[1] We recommend that organizations be wary about partnering with law enforcement or governmental agencies that may be hostile to their work.
Staff Burnout: The breadth, speed, and recklessness of the actions of the new administration have already contributed to a sense of powerlessness, crisis, and overwhelm.
Recommendation: Organizations need to foster a culture of resilience, emphasizing the need for staff to maintain their well-being to sustain high performance over the next four years. For their part, leadership should communicate available internal resources and support systems, and the importance of self-care while also underscoring that staff are essential frontline advocates for the mission. We also recommend organizations consider cross-training, utilizing fractional leadership models, and creating continuity plans to provide flexibility for staff that need to take leave for self-care.
[1] Penchina Partners has been developing a list of vendors in this space who share our values.
OTHER RECOMMENDATIONS
Coalitions and Coordination
Coordination within national movement work has become diffuse and fragmented, particularly over the past two years. This has been driven partially by (real or perceived) competition for resources and partially because of strategic disagreements and uncertainty over who should take a leadership position, and thus has weakened movements’ collective efforts. This is not sustainable given the breadth and depth of challenges ahead; organizations will need to choose a lane, lean into their areas of excellence and expertise, and focus on what they can control. Now is also an excellent time to consider mergers and other models of collaboration, resource sharing, and alignment.
Collaboration with Elected Officials
Groups should engage with their representatives, appointed officials, and with allies. Working closely with elected and appointed officials can provide a protective buffer against government inquiries, intimidation, and hostility. Building these relationships can help ensure that organizations’ interests are defended at the local, state, and national levels.
CONCLUSION
We strongly encourage organizations to conduct a sober analysis of the threats they face and put plans in place to confront them as soon as possible. We also strongly encourage groups to evaluate their existing strategic plans to take into account the new political reality; to reevaluate and reset their 2025 plans with the above in mind; and to consider that the 2026 elections will be the next time they can reasonably anticipate changes in the environment. Finally, we encourage funders to quickly provide funding to allow panicked organizations the time to assess and restructure their plans and identify and secure resources to navigate the legal, financial, and other challenges to come.
