This bill amends Section 323 of the Higher Education Act of 1965 to broaden what HBCU strengthening grants may fund. It adds five new permissible uses tied to arts and cultural programs — from student financial support and wraparound services to conserving Black art collections and funding apprenticeships — and authorizes partnerships with the National Endowment for the Arts.
The change is procedural rather than appropriative: HB2664 does not create a new pot of money; it expands how existing Section 323 grant dollars can be spent. For HBCUs with arts programs or collections, the amendment creates a federal policy pathway to direct previously restricted grant funds toward arts workforce development, museum stewardship, and paid experiential learning at historically Black institutions.
At a Glance
What It Does
The bill inserts five new allowable uses into the list of permissible activities under Section 323(a) (Strengthening Historically Black Colleges and Universities) and adds two short subsections: one permitting partnerships with the National Endowment for the Arts, and one defining 'arts.' It leaves the existing grant program structure and eligibility intact.
Who It Affects
Eligible HBCUs that receive Section 323 strengthening grants, campus grant administrators, arts and museum staff at those institutions, and external arts organizations that might serve as internship or preservation partners (including the NEA). It does not change which institutions qualify for the grants.
Why It Matters
By changing allowable uses, the bill gives HBCUs more flexibility to invest federal strengthening dollars in creative workforce pipelines and cultural stewardship—areas that previously faced funding barriers. The NEA partnership language signals an intent to knit higher education grants to federal arts infrastructure without creating a new funding stream.
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What This Bill Actually Does
HB2664 begins with a set of findings that link the arts to economic and educational value and highlight underrepresentation of Black artists and underinvestment at HBCUs. Those findings provide the policy rationale for the change that follows: expanding the list of activities Section 323 grants may support.
Practically, the bill reworks Section 323(a) by inserting five specific new activities into the statute’s enumerated permissible uses. Those activities allow institutions to use strengthening grant money for direct financial aid to arts students, to build outreach and development capacity for arts units, to deliver wraparound student supports (mentorship, career advising, and work-based learning), and to care for and exhibit Black art collections.
The statute also explicitly permits funding for paid apprenticeships, internships, and fellowships arranged through nonprofit arts partners.HB2664 adds a short subsection permitting institutions to enter into partnerships with the National Endowment for the Arts to carry out these newly authorized activities. It also defines 'arts' broadly — covering performance, literary, visual, graphic, plastic, and decorative arts — to reduce interpretive ambiguity.
Importantly, the bill does not appropriate new funds or alter how awards are made; it simply clarifies that existing Section 323 grant dollars may be used for these arts-related purposes.For campus administrators and compliance officers, the practical takeaway is twofold: first, institutions can reallocate existing strengthening grant funds to support arts programs and cultural preservation where those activities align with their grant proposals and reporting; second, they must track and justify such expenditures under the Section 323 reporting regime and coordinate with external partners where applicable. The legislation will therefore tighten the link between grant accounting, program outcomes, and partnerships with arts organizations without changing eligibility criteria or award formulas.
The Five Things You Need to Know
The bill amends Section 323 of the Higher Education Act (20 U.S.C. 1062) by inserting five new permissible uses for HBCU strengthening grants.
New allowable uses explicitly include direct financial and other assistance to students enrolled in arts, arts education, and cultural programs.
The statute permits institutions to use grant funds to exhibit, maintain, monitor, and protect Black art collections both on display and in storage.
HB2664 authorizes HBCUs to form partnerships with the National Endowment for the Arts to implement the newly permitted activities.
The bill adds a statutory definition of 'arts' (performance, literary, visual, graphic, plastic, and decorative arts) and authorizes 'well‑paid' apprenticeships, internships, and fellowships without setting a federal wage level.
Section-by-Section Breakdown
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Policy rationale linking arts investment and HBCU capacity
This opening section provides the bill’s justification: it cites analyses of arts-sector diversity gaps and historic underfunding of HBCUs to support the change. While nonbinding, these findings frame the amendment as addressing both workforce development and cultural preservation needs tied to HBCUs’ missions.
Five new allowable uses for HBCU strengthening grants
The core change is textual: the bill inserts five numbered paragraphs into the list of permissible activities under Section 323(a). The new entries authorize (1) student financial and other assistance for arts programs, (2) outreach and development capacity for arts units, (3) comprehensive wraparound services for arts students, (4) stewardship and protection of Black art collections, and (5) paid experiential learning through apprenticeships, internships, and fellowships. Because the change is to the statute’s enumerated list, grant recipients can claim these activities as legitimate uses when they design budgets and report on awards.
NEA partnership authority
This new subsection allows institutions to enter into partnerships with the National Endowment for the Arts to carry out the activities newly authorized in the statute. The text is permissive rather than prescriptive: it authorizes collaboration but does not specify the terms, matching requirements, or administrative arrangements for such partnerships, leaving those details to agencies and institutions to work out.
Definition of 'arts'
The bill adds a statutory definition encompassing multiple art forms (performance, literary, visual, graphic, plastic, and decorative arts). The definition narrows room for interpretive disputes over eligible activities, but it remains broad enough to include a wide array of campus programs and museum practices.
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Explore Education in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- HBCU arts departments and museum collections — They gain a new, legally sanctioned revenue source for instruction, conservation, exhibitions, and development activities that previously struggled to compete for limited institutional funds.
- Students in HBCU arts programs — The statute authorizes direct financial assistance, wraparound services, and paid experiential opportunities that can lower barriers to participation and support career entry.
- Nonprofit arts organizations and cultural partners — The NEA partnership authorization opens pathways for funded collaborations with HBCUs, including co‑sponsored fellowships, internships, and joint stewardship projects.
- Black artists and cultural heritage stewards — Explicit support for exhibiting and protecting Black art collections increases institutional capacity to preserve and display works that might otherwise remain uncatalogued or in poor storage conditions.
Who Bears the Cost
- HBCU grant administrators — They must implement new budget categories, update compliance and reporting practices, and demonstrate allowable uses under Section 323, increasing administrative workload.
- Other campus programs competing for finite Section 323 dollars — Because the bill does not add funding, reallocating grant dollars to arts activities may reduce resources available to other authorized uses (e.g., infrastructure, faculty development).
- Department of Education and NEA staff — Agencies will need to coordinate guidance, oversight, and potentially memoranda of understanding without an explicit appropriation for new administrative work.
- Smaller HBCUs with limited arts capacity — Institutions lacking museums, development offices, or established arts programming may struggle to absorb or justify redirected funds, creating uneven uptake across institutions.
Key Issues
The Core Tension
The central dilemma is a trade-off between flexibility and capacity: broadening allowable uses empowers HBCUs to invest in arts, preservation, and paid experiential learning, but because the bill does not add funding or detailed implementation rules, it forces institutions and agencies to reconcile competing priorities, administrative burdens, and unclear standards for partnerships and compensation.
Two implementation realities shape the bill’s practical effect. First, HB2664 expands what Section 323 funds can pay for but does not appropriate new dollars or alter award formulas; any shift toward arts and cultural uses must come from within each institution’s existing grant allocation.
That means the measure creates flexibility but not guaranteed new capacity, and reallocation decisions will pit arts priorities against other campus needs.
Second, the statute leaves several operational questions unresolved. The NEA partnership authorization is permissive and silent on matching, procurement, intellectual property, or stewardship responsibilities for transferred or jointly conserved collections.
Similarly, terms like 'well‑paid' apprenticeships are policy‑forward phrasing without a defined wage floor, leaving institutions and agencies to set standards. These gaps could produce uneven implementation, compliance ambiguity, and potential litigation or audit risk if stakeholders disagree on permissible spending or compensation standards.
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