Operational Resilience for Head Start and NGO Leaders

Executive Order 14151, titled "Ending Radical and Wasteful Government DEI Programs and Preferencing," triggered a list of banned or forbidden words on federal grant applications.

A report by Straight Arrow News noted court filings in which the U.S. Department of Health and Human Services (HHS) instructed Head Start programs to remove nearly 200 terms, including "disability," "women," "Black," and "tribal"—from grant applications, or risk denial of potential funding. The legal challenge stipulates that this removal and ban of words directly conflicts with federal law, which mandates that Head Start programs serve children with disabilities and provide culturally appropriate and sensitive care.

On the website www.grantwritingandfunding.com, grant writers can access a "trigger word replacement checklist" and take actionable steps for completing requests for proposals under these new constraints. One of the most significant operational challenges for Head Start is balancing compliance with the mission's conflicting objectives. Head Start is legally required to serve children with disabilities and provide culturally and linguistically appropriate services. However, with the banned-word list in place, providers find it increasingly difficult to accurately describe legally mandated services without risking funding. Program directors report that applications are being denied or returned with instructions to scrub banned terms, forcing organizations to self-censor descriptions of inequity, trauma, or victimization—even when these terms are central to the populations they serve.

For example, a non-governmental organization (NGO) receiving federal funding that specifically works with victims of domestic violence may no longer use the term "victim" or "victims" in federal reviews, grant proposals, or reports without triggering additional scrutiny or denial. This creates an impossible bind: how do you describe your mission and impact truthfully while navigating a politically determined vocabulary?

On August 7, 2025, President Trump signed another executive order titled "Improving Oversight of Federal Grantmaking". This order emphasizes the need to "strengthen oversight and coordination of agency grantmaking to streamline the process to address alleged problems, prevent their recurrence, and ensure greater accountability for the use of public funds". The problems cited as justification for this order include the promotion of "Marxist class warfare propaganda" and other "anti-American ideologies" in classrooms, as well as non-governmental organizations providing services to undocumented immigrants. As a result, the Trump Administration has tightened the grant-writing and review process for NGOs and placed political appointees in positions to review funding opportunity announcements and grant awards for alignment with administration priorities.

How NGOs Can Move When Filing RFPs for Government Grants

For NGOs and Head Start providers, navigating this new grant environment is less about finding the "perfect synonym" and more about building operational resilience into the grant process itself. Organizations that survive policy shocks like these are the ones that have governance structures, compliance playbooks, and cross-functional response capacity already in place.

Here's what that looks like in practice:

1. Align tightly with RFP language.

Study the specific RFP, the agency's strategic plan, recent press releases, and any updated guidance documents, and mirror their exact phrasing for goals, populations, and outcomes. When a concept is essential but a word carries risk, use outcome-based or statutory language that still accurately describes the work—for instance, "persons impacted by intimate partner violence" instead of "victims of domestic violence." Grant-writing best practices have always encouraged matching funder language, but in this environment, it's no longer optional.

2. Use a trigger-word strategy.

Draw on tools like the Federal Grant Trigger Word Replacement Checklist and similar workbooks to identify high-risk terms and develop pre-agreed alternatives. Build an internal "language grid" that distinguishes: words required by law or regulation (must use), terms that can be reframed without losing meaning (replace or pair), and phrases that signal fundamental misalignment with the funder (do not apply here). This grid becomes your team's shared reference and reduces the risk of inconsistent or reactive word choices across multiple proposals.

3. Engage legal and compliance early.

Nonprofit legal advisories recommend conducting privileged risk audits of your programs and language to understand where your work might be treated as "DEI" or "ideological" under current executive orders. Before submitting any proposal, route key sections—statement of work, target population, equity or inclusion language, and training components—through counsel or a compliance lead who is tracking DOJ, OMB, and agency-level guidance implementing EO 14151 and related directives.

4. Funding Diversification.

Grant law and nonprofit advisors are explicitly telling organizations not to depend solely on federal grants in this environment. Intentionally expand foundation, corporate, and individual-donor revenue streams so that a delayed federal review, a stop-work order, or a denied continuation under these executive orders does not immediately trigger layoffs or program collapse. This is classic operational resilience: diversify funding streams and manage evolving policies to ensure mission continuity.

5. Document decisions and prepare for disputes.

Legal experts stress that agencies now have greater discretion to restrict or terminate awards "for convenience," particularly where they believe DEI-related conditions or "ideological" activities conflict with the executive orders. Keep meticulous records of how language and design choices were made, which guidance you relied on, and all communications with program officers. This documentation is critical if a grant is frozen, terminated, or challenged, or if your organization joins or supports litigation, as seen in the Head Start cases.

6. Leverage AI to automate compliance review and funding diversification.

Operational resilience is about having the right tools to execute those processes at scale, with speed and consistency. Two emerging AI applications can significantly reduce risk and expand capacity for NGOs navigating this environment:

AI-powered RFP compliance review: NGOs can use AI tools (such as custom GPTs, Claude Projects, or enterprise compliance platforms) trained on trigger-word lists, agency guidelines, and specific RFP language requirements to scan draft proposals before submission. These tools can flag high-risk terms, suggest vetted replacements from your internal language grid, and verify alignment with the exact phrasing in the funding opportunity announcement. This reduces the risk of manual oversight, speeds up internal review cycles, and creates a documented compliance trail, especially critical when programs span multiple grants with different language constraints.

AI for non-federal funding discovery: Rather than relying solely on manual searches or expensive subscription databases, NGOs can work with AI developers or use advanced web-scraping and natural language processing tools to identify foundation, corporate, and state/local grant opportunities that align with their mission. These tools can be configured to monitor new funding announcements, track application deadlines, and surface opportunities from sources that may not appear in traditional grant directories. This accelerates the diversification strategy and reduces over-reliance on federal dollars.

Moving Forward

Operational resilience means adapting to evolving policy changes. To develop operational resilience in your NGO means diversifying funding before you are forced to, and using technology to streamline work. The rules are shifting faster than capacity.

What are you seeing in your sector? Are you navigating restricted language, frozen awards, or compliance uncertainty? How are leaders adapting in real time?

This article was also published on LinkedIn on December 18, 2025. Read the original article there for additional discussion and comments.