NEA: A Federal Seal on Someone Else's Code

Methodological Framework

Research objective: to trace the history of the National Endowment for the Arts as a sequence of cultural code shifts: to establish when and why each code emerged, how the agency transmitted it to the arts sector and the public, whether re-fusion occurred, and what destroyed or transformed it.

Unit of analysis: the binary code of the organization and its performance through the grant ritual. NEA is examined here not as a budget line or an arena of partisan struggle, but as a cultural institution that produces the definition of the sacred on behalf of the state. NEA does not create cultural objects (Disney), does not consecrate them (AMPAS), and does not directly fund their creators (Ford Foundation since 2016). NEA places a federal seal on a definition of quality produced by someone else. Financial data (budget, appropriations dynamics) are used as a verifiable indicator of the code's condition. A Gramscian analysis of the institutional mechanisms of capture and positional entrenchment is presented in the companion report [NEA: How Private Ideology Becomes a Federal Standard]; the present text references those findings where necessary for understanding the sociological dynamics.

Analytical Specificity: A Government Grantmaker Is Not a Private One

NEA occupies a unique position in the CulturalBI series. Disney produces a cultural object. AMPAS consecrates it. Ford Foundation funds the creator and defines the criterion. NEA does something fourth: it places a state seal on a definition of quality produced by the private sector. This is a special type of consecration. A Ford grant carries the symbolic capital of one (albeit the largest) private foundation. An NEA grant carries the symbolic capital of the federal government. For an arts organization, this means access to additional private funding: foundations and donors treat an NEA grant as a signal of reliability. For an artist, it is a line on the resume that no private foundation can provide.

The key analytical distinction follows: NEA does not produce the definition of the sacred (Ford), does not transmit it to a mass audience (Disney), and does not build a ceremony around it (AMPAS). NEA legitimizes someone else's definition on behalf of the state. Whoever produces that definition controls the content of federal consecration. The production mechanism: expert panels.

De-fusion cannot be detected through box office, ratings, or subscriber attrition. NEA has no mass audience. The grant ritual addresses a professional community: arts organizations, state arts agencies, panelists, partner foundations. The general public learns about the agency's internal dynamics only through the political process (congressional hearings, budget wars, presidential directives). The primary verifiable indicators of de-fusion are: budget dynamics, executive orders, legislative decisions, and the comparative behavior of peer federal cultural agencies (NEH, IMLS, CPB).

A fifth type of code visibility in the CulturalBI series. Disney displayed the code on screen. Netflix hid the mechanism. AMPAS published the mechanism but concealed the results. Ford concealed the audience entirely. NEA concealed the source of the code: the agency performs someone else's code while presenting it as its own federal standard.

Conceptual Apparatus

Binary codes (Alexander): culture divides the world into sacred and profane poles. The pair is emotionally and morally charged; it is through this pair that participants interpret everything happening around them.

Performance (Alexander): a social action whose outcome is determined not by the quality of content, but by whether the audience believed the performer genuinely believes in what is being performed.

Ritual (Alexander): a recurring performance that has become institutionalized. The audience knows what will happen, knows its role, knows how to respond. Participation in the ritual is itself an act of belonging to the code.

Re-fusion (Alexander): the moment when the boundary between performer and audience dissolves: the participant ceases to be an observer and becomes part of the process, emotionally and symbolically.

De-fusion (Alexander): the moment when the boundary is restored: the audience is outside again, seeing the seams and the construction.

Cultural Diamond (Griswold): four poles through which any cultural object exists: creator, object, receiver, social world. De-fusion is always a rupture along a specific axis.

Habitus (Bourdieu): a system of perception and action internalized through socialization, operating automatically; it explains why people from the same professional milieu make similar decisions without explicit coordination.

Consecration (Bourdieu): an institutional act of sanctification through which an agent possessing symbolic capital confers it upon an object or person. An NEA grant functions as consecration: the recipient does not merely receive a resource but enters the category of "recognized by the state." Other donors, foundations, and institutions accept this classification as a signal of quality.

Settled culture (Swidler): habitus works, no one notices it, the question "why do we do it this way" does not arise.

Unsettled culture (Swidler): habitus is broken or under threat; manifestos, declarations, and reforms appear. Explicitly regulated ideology: always a signal of instability.

Cultural trauma claim (Alexander & Eyerman): the successful appropriation of someone else's real suffering as a source of one's own moral authority.

Carrier groups (Alexander & Eyerman): specific social groups that carry and transmit a narrative within an institution.

Framing (Snow & Benford): a ready-made interpretation that answers the questions: who is to blame, what is to be done, and why action is needed now.

Boundary work (Lamont): the mechanism of drawing boundaries: who is inside, who is outside, and along which axes (moral, cultural, socioeconomic).

Civil sphere (Alexander): an autonomous sphere with its own binary code: democratic/anti-democratic, open/secretive, autonomous/dependent. Presence within it grants an institution legitimacy beyond the cultural field.

Sources

Primary: National Foundation on the Arts and Humanities Act of 1965 (20 U.S.C. § 951 et seq.), NEA Strategic Plan FY 2022–2026, NEA Equity Action Plan (April 2022), GAO Report GGD-91-102FS (1991) on the expert panel procedure, NEA Appropriations History (arts.gov), NEA FY2025 and FY2026 Congressional Budget Requests, Supreme Court decision NEA v. Finley (524 U.S. 569, 1998), Executive Orders 14151, 14168, 14173 (January 2025), chair biographies (arts.gov), public remarks by Chairman Jackson (Edinburgh International Culture Summit, August 2022), public statements by Chairman Carter (arts.gov). For verification of de-fusion and political dynamics: Wikipedia/NEA (verified against primary sources), Chronicle of Philanthropy, Inside Philanthropy, NPR, Artnet News, Americans for the Arts.

Known Limitations

Expert panel meeting minutes are closed. The substance of individual decisions is unavailable. Procedure has been verified through GAO 1991 and official regulations. The causal link between a shift in the private consensus and a change in NEA's strategic plan is reconstructed from the chronology of public decisions, not from internal correspondence. Attribution of intent is prohibited: only the sequence of verifiable facts.

Chronological Code Map

I. The Original Code: The Cultural Cold War (1965–~1977)

Founding as a Geopolitical Performance

On September 29, 1965, President Lyndon Johnson signed the National Foundation on the Arts and Humanities Act in the White House Rose Garden [1]. The law created NEA as an independent federal agency. The context was not cultural but geopolitical. Section 2(8) of the Act stated directly: U.S. world leadership "cannot rest solely upon superior power, wealth, and technology." Two years earlier, in October 1963, Senator Claiborne Pell (D-RI) opened hearings on the future legislation with the argument that America's cultural life "projects itself into the world beyond our shores" [2]. America needed cultural infrastructure not because art is beautiful. It needed it because the USSR was building its own.

The first chairman, Roger Stevens (1965–1969), a Broadway producer and Kennedy's cultural adviser, received a skeletal budget and a few dozen grants. NEA's first budget was $2.5 million [3]. Stevens focused on rescuing financially distressed elite institutions and on establishing state arts agencies.

Binary Code

Cultural leadership / Soviet threat. The sacred was: American culture as a soft-power instrument, free creativity, independent knowledge. The profane was: cultural insularity, authoritarian censorship, the absence of government support for the arts (i.e., losing the cultural competition with the USSR). The code is identical to the Cold War code of the Ford Foundation under Hoffman. The difference: Ford funded from a private endowment; NEA funded from the federal budget. State consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) added a dimension Ford lacked: an NEA grant carried not merely the symbolic capital of an institution but the symbolic capital of the nation.

The funding criterion intended to ensure cultural leadership: "artistic excellence and artistic merit." The law provided no definition for either term [1]. The NEA website still describes the grant standard as "equal weight assigned to artistic excellence and artistic merit." Two synonyms in place of one definition. The normative vacuum was built into the foundation.

Nancy Hanks: Democratization as Code Expansion (1969–1977)

Nancy Hanks, the second chairman (appointed by Nixon in October 1969), is the key figure of the entire NEA story, not merely a line in a list [4]. She built the infrastructure through which all subsequent codes would be transmitted. Hanks came from the Rockefeller Brothers Fund. Her connection to Nelson Rockefeller dated to 1954, when she worked on his team at the Department of Health, Education, and Welfare. Hanks was the first woman to chair the agency. She understood politics no less than culture. She manipulated congressmen through flattery. She took control of the National Council on the Arts: under Stevens, the council and the chairman were equal partners; under Hanks, the council reported to her. She established the panel rotation system that remains in place to this day [4].

Over eight years, the budget grew from $8 million to $114 million [4]. A fourteenfold increase. The number of grant categories expanded from a few dozen to 115 by the 1990s. Hanks created the system of state arts agencies, which receives 40% of the NEA budget and transmits the federal standard to the state level. This infrastructural decision would outlast every subsequent culture war: the map that Gioia deploys in 2003 was built by Hanks in the 1970s.

Hanks did not change the question the code answered ("what is quality art?"). She changed the perimeter of the answer: quality art exists not only in New York. The criterion of distinction: the question remains the same, but the answer includes new objects. The recipients of excellence expanded geographically and socially.

But Hanks accomplished something greater than code expansion. She built two mechanisms that would define the next fifty years. First: expert panels with rotation. Second: the federal-state partnership (state arts agencies). Both mechanisms appear procedural. Both are architectural: they determine who will decide what quality means for the next half-century. Hanks is not Bundy (Ford Foundation), who changed the content of the code. Hanks is the architect of invisibility: she built a system in which the content of the code is determined by panels, and panels are staffed from a sector funded by private foundations. In the 1970s, the architecture worked as intended: depoliticization through delegation of decisions to experts, democratization through geographic expansion. The long-term effect (the transfer of code control to the private sector) did not manifest immediately. It became visible fifty years later, when the private sector itself synchronously shifted its criteria. The architecture did not change. The input changed: panelists began arriving from institutions that in 2020 had restructured their own definition of quality. Hanks designed the channel, not the content.

Hanks's connection to the Rockefellers was not incidental. The Rockefellers were building cultural infrastructure (Lincoln Center, MoMA, Council on the Arts). Hanks transferred this logic to a federal agency. Private capital built institutions. The government institution (NEA) legitimized those whom private capital had cultivated. The closed loop began operating under Hanks, long before anyone described it.

SettledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) Culture

By the mid-1970s, the code had become invisible. No one asked why NEA funded what it funded. The answer seemed self-evident: because it is quality work. The question "who defines quality?" did not arise, because the answer was embedded in procedure. Panels of professionals evaluated applications. Professionals knew what was good. This is settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture in the precise Swidlerian sense: habitus works, no one notices it.

Arbiters of quality. NEA program officers and panelists: people with advanced degrees, connections in universities and major cultural institutions. The boundary was drawn along the cultural axis (educated/uneducated) and the professional axis (expert/amateur). Boundary workMechanism of drawing boundaries: who is inside, who is outside, along which axes (Lamont) was invisible: it was embedded in the panelist selection procedure.

Carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman). Code bearers: the professional class of arts administrators, curators, and academics. The same people funded by Ford, Mellon, and Rockefeller through universities and MFA programs. The habitus of carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) aligned with the agency's code not because anyone coordinated them, but because they received their education at the same universities, completed their dissertations under the same advisers, and worked at museums and arts centers funded by the same foundations. The institutional pathway produces aligned judgments without the need for coordination.

By the Cultural DiamondFour poles of a cultural object: creator, object, receiver, social world (Griswold): alignment of all axes. The creator (NEA and its panels) believes the code. The object (the grant) embodies the code through professional excellence. The receiver (the arts community) accepts the code. The social world (Cold War America, then Great Society America) provides ideal conditions for the code.

Iconic consciousnessFusion of form and meaning: the object carries meaning without context (Alexander). The NEA grant achieved iconic status in the arts sector. The phrase "NEA grant" required no context. This is not a visual icon (like Mickey Mouse) or a material one (like the Oscar statuette). It is a procedural icon: an act of federal consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) that moved the recipient from the category of "applicant" to the category of "recognized by the state."

II. The Normative Vacuum and Its Judicial Codification (1989–1998)

Culture War: The Code Becomes Visible

In 1989–1990, settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture collapsed. Two events made the invisible code visible. An exhibition of Robert Mapplethorpe's photographs (indirectly funded through an NEA grant to the Institute of Contemporary Art in Philadelphia) and Andres Serrano's photograph "Piss Christ" (a $15,000 grant through the Southeastern Center for Contemporary Art) became the subject of congressional hearings [5]. Senator Jesse Helms (R-NC) demanded a ban on funding "obscene" art.

This is a classic transition from settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) to unsettledHabitus broken or threatened; manifestos and declarations signal instability (Swidler) culture. The code of "professional excellence" worked as long as it went unnoticed. The moment an external actor (Congress) asked, "Who decided this is excellence?", invisibility was destroyed. Habitus ceased to be habitus and became an object of contestation.

NEA Four: Performance as a Collision of Codes

In June 1990, Chairman John Frohnmayer vetoed grants to four performance artists: Karen Finley, Tim Miller, John Fleck, and Holly Hughes. All four had passed peer review. The veto was imposed on substantive, not procedural grounds [5]. This was the first time in NEA history that a chairman overruled a panel decision. The artists won in court in 1993; the grant amounts were reimbursed.

Jane Alexander: An Actress on the Front Lines of the Culture War (1993–1997)

On October 8, 1993, Supreme Court Justice Sandra Day O'Connor swore in Jane Alexander as the sixth NEA chairman [6]. The first professional artist to hold the post. Alexander came from Broadway: a Tony Award for "The Great White Hope" (1969, alongside James Earl Jones), four Academy Award nominations, two Emmys. Her early career was a direct product of the NEA grant system: "The Great White Hope" was developed with an NEA grant at Arena Stage in Washington [6].

Alexander arrived without political experience and immediately faced a hostile Congress. At her first meeting on Capitol Hill, Senator Strom Thurmond asked: "Are you going to fund pornography?" [6]. Her chairmanship coincided with the 104th Gingrich Congress and a campaign for the agency's total elimination.

In her memoir "Command Performance: An Actress in the Theater of Politics" (2000), Alexander described her four years as a battle for survival [6]. The book is structured as a theatrical production: "Audition," "Rehearsal," "Curtain." This is performance in the literal sense: an actress describes politics as theater in which she found herself involuntarily. The key scene of the memoir: Speaker Gingrich tells a supporter of NEA, "Arthur Murray never needed a grant to write a play." The interlocutor restrained herself from replying that the famous ballroom dancer might have wanted to apply to the dance program [6].

Over four years, the budget was cut nearly in half ($170 → $99.5 million). Direct grants to individuals were eliminated permanently. Alexander convened Art 21 (1994), a national conference on the role of art in the twenty-first century. She visited all 50 states and over 200 cities. It was these trips, she said, that saved the agency: "The American people told their congressmen: hands off NEA" [6]. Congressman Pat Williams (D-MT) told her after the vote to preserve funding: "It's bulletproof now. You won the big war. It's part of the system now" [6].

Alexander identified the paradox that would define everything that followed: the agency survived, but at the cost of "democratization"—her successors focused on community art and large-scale projects for broad audiences. "Let's say Picasso could no longer apply with his erotic art. And if he did, he wouldn't get funded" [6]. Survived but diminished. The institution weathered the crisis by losing the ability to fund precisely what made it culturally significant: risky individual creativity.

Congress Attempts to Fill the Vacuum (1990)

In 1990, Congress added to the excellence criterion the requirement to consider "general standards of decency and respect for the diverse beliefs and values of the American public" [7]. This was the first attempt to legislatively fill the normative vacuum of 1965. Four artists challenged the amendment.

NEA v. Finley (1998): The Supreme Court Legalizes the Void

The case reached the Supreme Court. The decision in NEA v. Finley (524 U.S. 569, 1998) merits analysis as a founding text, because the three opinions formulated three competing answers to the question of the nature of state consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) [7]. No previous case in the series has an analogue: the court did not merely describe the code; it prohibited defining it.

Majority opinion (O'Connor, 8–1). The terms of §954(d)(1) are "undeniably opaque." But opacity is permissible: "in the context of selective subsidies, it is not always feasible for Congress to legislate with clarity." To accept the vagueness argument would "cast doubt on the constitutionality of many valuable government programs in which the weights assigned to various selection criteria are left to the discretion of panels of experts acting under broad mandates to promote, for example, 'excellence'" [7]. O'Connor legalized the vacuum: the state may fund on the basis of an undefined criterion, because any definition of the criterion would be worse. This opinion became the constitutional shield for the entire expert panel system.

Concurrence (Scalia, joined by Thomas). Scalia opened with: "The operation was combated combative. The operation was successful, but the patient died." The majority saved the statute by eviscerating it. Scalia held that the statute does establish viewpoint-based criteria. And this is perfectly constitutional. "It is the very business of government to favor and disfavor points of view on innumerable subjects—which is the main reason we combative that we combative elect those who run the government" [7]. Scalia legitimized state taste: the government has the right to decide which art to fund, and this is not censorship, because denial of a subsidy is not suppression.

Dissent (Souter). The sole voice that named the mechanism for what it was: "the decency standard mandates viewpoint-based decisions in the allocation of public subsidies." The First Amendment prohibits viewpoint discrimination in the exercise of public authority over expressive activity. Souter saw what O'Connor obscured and Scalia endorsed: the state funds a viewpoint under the guise of funding quality [7].

The three opinions form three positions that are reproduced in every subsequent conflict over NEA. O'Connor (2022: the strategic plan as a vague priority, compatible with Finley). Scalia (2025: EO 14151 as the lawful right of the president to determine what to fund). Souter (2025: the ACLU lawsuit as an attempt to establish viewpoint discrimination). The 1998 decision did not close the question. It constitutionally enshrined three possible answers, among which the institution oscillates to this day.

This is the pivotal moment for the entire CulturalBI series. Neither Disney, nor AMPAS, nor Ford Foundation underwent judicial codification of their normative vacuum. NEA is the only institution in the series whose code (or rather, absence of code) has been legitimized by a Supreme Court decision.

Budgetary Capitulation (1996)

Parallel to the court proceedings, NEA's budget was cut from $170 million to $99.5 million [3]. Direct grants to individuals were eliminated permanently. Money would henceforth go only to organizations. The individual artist as a recipient of federal consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) ceased to exist.

Culture war framingA ready-made interpretation: who is to blame, what to do, why act now (Snow & Benford). Helms and Gingrich deployed all three dimensions. Diagnostic: NEA funds obscenity with taxpayer money. Prognostic: either control the content or eliminate the agency. Motivational: every taxpayer has the right to know what their money pays for. The frame appealed to the civil sphereAutonomous sphere with a democratic/antidemocratic code; presence grants legitimacy beyond the cultural field (Alexander): democratic accountability against elitist autonomy.

The arts community's counter-frame. Diagnostic: politicians are interfering with professional judgment. Prognostic: protect the independence of expert review. Motivational: censorship kills creative freedom. This frame also appealed to the civil sphereAutonomous sphere with a democratic/antidemocratic code; presence grants legitimacy beyond the cultural field (Alexander): free speech against state control.

The collision of the two frames was not resolved. Both sides retained their positions. The compromise was procedural: the budget was cut, direct grants were abolished, but the agency survived. Expert panels remained intact.

Carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman). During the unsettledHabitus broken or threatened; manifestos and declarations signal instability (Swidler) period, code bearers split. Inside NEA: program officers defending professional autonomy. Outside: arts organizations, artists, the ACLU. The opposing carrier groupSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman): conservative congressmen, the American Family Association, religious organizations. Neither side won.

By the Cultural DiamondFour poles of a cultural object: creator, object, receiver, social world (Griswold): rupture along the receiver ↔ social world axis. The professional receiver (the arts community) accepted the excellence code. The social world (the American voter, as represented by conservative congressmen) did not accept specific manifestations of that code. De-fusion occurred between audiences: the professional audience of NEA and the political audience of Congress existed within different codes.

III. Pseudo-Settled:Habitus works invisibly; the question "why do we do it this way" never arises (Swidler) Four Chairs Without a Code (1997–2016)

The portrait of Jane Alexander (1993–1997) and the culture war of that period are presented in Section II. For the purposes of this section, one point matters: Alexander won the battle for the agency's survival but lost the war over its substance. Her successors inherited an institution that had weathered the crisis at the cost of abandoning funding for risky individual creativity. Congressman Williams told her: "It's bulletproof now." Williams said this in 1996. In January 2025, a presidential executive order undid in a single day what Alexander had built over four years. Williams was wrong by exactly twenty-nine years.

Bill Ivey: A Folklorist Without Political Ambitions (1998–2001)

Bill Ivey, the seventh chairman, was appointed by Clinton in 1998. Before NEA, he headed the Country Music Foundation in Nashville. A folklorist by training, Ivey had neither political nor ideological ambitions for the agency. His principal initiative: Challenge America, a grant program for expanding access to the arts in economically depressed areas [8]. Challenge America became the mechanism that, under the next chairman, would ensure national reach.

Ivey posed the question that defined the next decade: can the NEA chairmanship become nonpartisan? He tried to answer it by personal example. Appointed by Democrat Clinton, Ivey stayed on after Republican Bush took office in January 2001, expecting the new administration to reconfirm him. It did not. For nine months, Ivey served without White House support and resigned in September 2001, six months before his term expired [9]. The Bush administration did not find a replacement immediately: the post remained vacant for over a year. The brief chairmanship of Michael Hammond (2002) ended within a week: he died of a heart attack. The episode exposed a structural constraint: the NEA chairmanship remains partisan because it is filled by the president, not by Congress. Any code established by one administration is vulnerable to a change in power.

Dana Gioia: A Poet Builds a Defense Through the Map (2003–2009)

Dana Gioia, the eighth chairman, was appointed by George W. Bush. Poet, literary critic, author of the essay "Can Poetry Matter?" (1991), former vice president of General Foods [8]. Gioia combined two worlds: the literary and the corporate. It was he who made the strategic move that would determine the agency's survival for the next twenty years.

Gioia became the first chairman to set a goal: at least one grant in each of the 435 congressional districts [8]. The logic was not cultural but political. Any congressman voting to eliminate NEA would be voting against money in his own district. Gioia recounted how he convinced one congressman by inviting him to a gathering where the congressman discovered that many of his major donors were passionate supporters of the arts [8]. The Challenge America program ensured national reach. "Art Works" had not yet become a slogan (that would happen under Landesman), but the infrastructure was laid.

Under Gioia, the budget began to recover: $99.5 million in 1996, $124.4 million by 2005 [3]. Shakespeare in American Communities, NEA Big Read, and Poetry Out Loud were scaled up. All three programs shared a single logic: transmitting professional art into schools and communities. This is neither the equity code nor the excellence code. It is an access code: art should be everywhere. The philosophical question "which art?" remains unanswered.

Rocco Landesman: A Broadway Producer Asks the Forbidden Question (2009–2012)

Rocco Landesman, the tenth chairman, was appointed by Obama. Broadway producer, owner of the five Jujamcyn theaters, producer of "Angels in America" (Tony 1993, 1994) and "The Producers" (Tony 2001). A PhD in dramatic literature from the Yale School of Drama, where he taught before moving into business [10]. His wife: Debbie Landesman, former executive director of the Levi Strauss Foundation, a consultant to foundations on philanthropic strategy.

Landesman entered office with a bang. In an interview with the New York Times: "I don't know if there's theater in Peoria, but I bet it's not as good as Steppenwolf or Goodman" [10]. Scandal. A trip to Peoria with apologies. But behind the scandal lay a principled question no previous chairman had asked. Landesman demanded that grants go on the basis of merit and quality, not because an organization exists in a particular location. This was a direct attack on Gioia's geographic strategy. Not "a grant in every district," but "a grant to the best."

Then Landesman asked an even more dangerous question. In 2011, at a conference on new theater development: "You can increase demand or reduce supply. Demand won't grow, so it's time to think about reducing supply" [10]. His own agency's survey (SPPA 2008) had found that attendance at live arts events had declined by 5 percentage points, while the number of nonprofit arts organizations had grown by 23%. Landesman said out loud what many were thinking: the sector is overproducing.

The reaction was furious. The arts community accused him of "organizational euthanasia." But Landesman was the first to articulate the problem that explains why the normative vacuum causes no scandal in a settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) period: when there is enough money for everyone, no one asks by what criterion it is distributed. Landesman demanded a criterion. He did not get one, but he forced the question.

Landesman also launched "Art Works" as a slogan with a triple meaning: works of art (art works), art works (for the economy), and jobs in the arts (art works as employment). The slogan reframed NEA's rationale: not "art is beautiful" but "art creates jobs." Interagency partnerships: with the Department of Transportation (LaHood), with HUD. Landesman called his strategy the "cuckoo bird": laying NEA eggs in the nests of other agencies [10].

Yosi Sergant, NEA's director of communications, had been transferred to the agency from the Obama presidential campaign team. In August 2009, he conducted a series of conference calls with artists and arts organizations, urging them to use art to support the White House's legislative agenda (healthcare, energy, education). Recordings of the calls leaked to the press. The scandal lasted several weeks: Republicans accused the administration of turning NEA into a propaganda organ; the ACLJ demanded an investigation. Sergant was removed in September 2009 and soon dismissed. Landesman publicly stated that Sergant had acted "without approval or authorization" [10]. The incident demonstrated a structural constraint: a government institution cannot establish a code without risking the charge of partisanship. Any attempt to set a substantive direction is perceived as politicization. This explains why no NEA chairman before Jackson attempted to publicly articulate the agency's code: the cost of trying exceeds the benefit.

Jane Chu: The Quiet Transition to Equity (2014–2018)

Jane Chu, the eleventh chairman, was appointed by Obama in 2014. Before NEA: president and CEO of the Kauffman Center for the Performing Arts in Kansas City. A pianist who grew up in a Korean immigrant family in Oklahoma. Her father died when she was nine. Chu recalled: art gave her a language for experiences she could not express in words [11].

Under Chu, a quiet, imperceptible lexical shift occurred. The word "equity" began appearing in NEA documents. Not as a central concept, but as one among several priorities. This was not a manifesto (Walker at the Ford Foundation) or a programmatic statement (Landesman with his "supply and demand"). It was infiltration: new language entered documents slowly, together with new staff who carried it as habitus.

Chu received two Emmy nominations for NEA (Outstanding Short Form Nonfiction, 2016 and 2017). She expanded programs for HBCUs (Historically Black Colleges and Universities), Native communities, and folk arts. Under her leadership, NEA received a Special Tony Award (2016) [11]. Chu's public performance was soft, non-confrontational. The equity code was not yet declared. It was germinating.

Analytical Diagnosis of the Entire Period

Four chairs, zero codes. Ivey: nonpartisanship and access. Gioia: the map and defense through geography. Landesman: merit, quality, "supply and demand." Chu: a quiet shift toward equity. None of them established a code comparable to Walker's at the Ford Foundation. Each answered the philosophical question partially, situationally, not institutionally. This is a pseudo-settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) period: no external signals of instability, but no re-fusion either.

SettledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture without a code differs from settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture with a functioning code. No one asked "why does NEA exist?" The answer consisted not in a definition of the sacred but in a gesture toward the map: "we fund art in all 435 districts." Defense through procedure, not through meaning. The analogy is with Ford Foundation 1979–2013: the institution exists, the budget grows, the philosophical question goes unasked.

But there is a critical difference between Ford and NEA. At Ford, the codeless period ended with the hiring of Walker: one person brought a ready-made answer to the philosophical question and institutionalized it through BUILD, Social Bond, and the closed JustFilms loop. At NEA, the codeless period ended differently. By 2020, three external processes converged, none of which explains the code's establishment on its own, but together they made it inevitable.

First process: the five largest private foundations (Ford, Mellon, MacArthur, Kellogg, Doris Duke), with a combined endowment of ~$33 billion, in June 2020 synchronously announced a shift in grantmaking criteria from artistic quality to social justice. This redefined what counts as "quality" in the sector from which NEA draws its experts.

Second process: EO 14035 of the Biden administration (June 2021) required all federal agencies to develop DEIA plans. This was a direct top-down directive, legally binding on NEA as a federal agency.

Third process: the murder of George Floyd (May 2020) and the wave of protests created a moral backdrop that transformed DEIA language from a debatable position into the minimum condition of professional acceptability in the arts sector.

These three processes are examined in detail in the next section. What matters here is one thing: none of them was controlled by NEA. The private foundations acted on their own logic. The executive order came from the White House. The social backdrop was shared across the entire country. The agency found itself at the convergence of three vectors, none of which it had set in motion.

This is the fundamental difference from Ford. Walker, too, brought a code from outside: the Urban Institute, the Rockefeller Foundation, Harlem's Abyssinian Development Corporation. The difference lies not in the source (both codes were produced by the same professional milieu) but in the mechanism of establishment. Walker institutionalized the code personally: manifesto, restructuring, BUILD, Social Bond. NEA institutionalized the code impersonally: through three parallel external processes, none of which the agency had initiated. Ford Foundation chose its code. NEA's code was established before the agency had a chance to choose.

Landesman as diagnostician. His "supply and demand" was not a code at all and made no claim to be one. It was an empirical observation about the state of the sector: a 23% increase in arts organizations alongside a 5% decline in audience (SPPA 2008). There is no code in the Alexanderian sense here: no sacred/profane pair, no moral charge, no ritual performance. There is a statement of fact. But that statement is valuable in its own right. Landesman is the only chairman to have publicly articulated the problem that explains why NEA's normative vacuum causes no scandal: as long as there is enough money for everyone, no one asks by what criterion it is distributed. When there is no longer enough (i.e., when the sector overproduces to the point where allocation becomes fiercely competitive), the question of criterion becomes unavoidable. Landesman saw that moment and named it. He did not propose a code to replace the void. He showed that the void would soon become a problem.

Arbiters of quality. Expert panels operated without change. GAO 1991 described the procedure: 6–16 panelists, 77% annual rotation, "knowledgeable laypersons," closed sessions [12]. The excellence criterion remained undefined. Panelists applied it through internalized professional reflexes. By the 2010s, those reflexes had begun to shift: the Kresge Foundation (where future Chairman Jackson spent a decade) funded "equitable communities" programs; Mellon invested in diversity at universities; Ford launched JustFilms (2011). NEA panelists arriving from institutions funded by these foundations carried an updated habitus. The code was not yet declared. The habitus had already shifted.

There were no code bearers, because there was no code. Professional arts administrators carried competence but not ideological identity. By the Cultural DiamondFour poles of a cultural object: creator, object, receiver, social world (Griswold), this is a rupture along the creator ↔ social world axis: NEA produced grants, but those grants carried no message. The social world did not know why the agency existed, except to distribute money across districts. A quiet de-fusion without scandal, analogous to Disney 1966–1984 and Ford Foundation 1979–2013. It was precisely the absence of identity that made the agency vulnerable to a political moment that would bring a ready-made answer to the philosophical question.

Landesman began the return to the civil sphereAutonomous sphere with a democratic/antidemocratic code; presence grants legitimacy beyond the cultural field (Alexander): interagency partnerships positioned NEA as an actor in urban development, economics, and healthcare (Creative Forces). But this was a utilitarian argument ("art works as economic engine"), not a moral one ("art carries justice"). A utilitarian argument does not produce re-fusion. It produces a budget justification.

Bridge to the equity code. The quiet lexical shift under Chu (2014–2018) proved to be not a dead end but an incubator. The word "equity" entered NEA documents during the same period when the Kresge Foundation (where future Chairman Jackson worked) was developing its "equitable communities" program, when Mellon was doubling its investments in diversity in the humanities, when Ford was launching JustFilms (2011) and BUILD (2016). NEA panelists arrived from institutions funded by these foundations. Their habitus was shifting faster than the agency's language. By 2020, the agency had not yet declared a new code. But the people sitting on the panels were already carrying it.

SPPA: Who Defines What Counts as Participation

NEA possesses an instrument not found in any previous case in the series. The Survey of Public Participation in the Arts (SPPA) is the only federal survey that systematically measures Americans' participation in the arts. SPPA is conducted through the Census Bureau. SPPA 2008 recorded a 5-percentage-point decline in live attendance (the data Landesman cited). SPPA 2012 showed a further decline in traditional participation but growth in "arts through electronic media" [13].

SPPA is not a neutral instrument. The definition of "participation" determines what counts as art. If SPPA includes streaming and digital consumption, the numbers rise. If only live attendance, they fall. Whoever defines the methodology defines what the sector's condition looks like. Under Jackson, NASERC (National Arts Statistics and Evidence-based Reporting Center) was launched to monitor four domains: artists, arts participation, arts assets, and arts and education [14].

This is a third loop, but of a different type. The first and second loops are distributional: they determine who receives a grant and who decides. The third loop is reflexive: it determines how the agency reports on the results of its own activities. Disney measures by box office. AMPAS measures by ratings. NEA measures by a survey whose methodology it controls itself. No other institution in the series simultaneously possesses the instrument of consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) and the instrument for measuring its own effectiveness.

IV. Establishing the New Code: Inclusive Justice (2016–2025)

Synchronous Shift: Private Capital, the Federal Mandate, and a Shared Environment

The new code was not established by a single decision or a single person (unlike the Ford Foundation, where Walker publicly announced the shift in October 2015). NEA's code shifted gradually, through three parallel processes.

First process: the private grantmaking consensus. In June 2020, the five largest American foundations (Ford, Mellon, MacArthur, Kellogg, Doris Duke), with a combined endowment of ~$33 billion, issued $1.7 billion in bonds and synchronously announced a change in grantmaking criteria: from artistic quality to social justice and DEIA [15]. Mellon announced a "major strategic evolution." MacArthur launched "The Just Imperative" ($125 million in bonds). The combined grantmaking of the five foundations (~$1.5 billion/year) exceeded NEA's entire budget ($207 million) sevenfold.

Second process: the federal mandate. EO 14035 of the Biden administration (June 2021) required all federal agencies to develop DEIA plans [16]. As a federal agency, NEA was legally obligated to comply.

Third process: the shared environment. The murder of George Floyd (May 2020) and the wave of protests triggered a synchronous shift as an autonomous sector response. NEA's leadership and the leadership of the major foundations belonged to the same professional circle. The synchronicity was explained by a shared environment, not by a direct command.

All three processes are compatible and mutually reinforcing. Each was part of the mechanism, not an alternative to it.

Maria Rosario Jackson: Biography as Code Performance

In January 2022, following Senate confirmation, Maria Rosario Jackson took office as NEA chairman. The first African American and the first Mexican American to lead the agency [14]. Her biography functioned as a performance of the new code, structurally analogous to Walker's biography at the Ford Foundation. Jackson had spent ten years at the Urban Institute (Washington), where she founded the Culture, Creativity and Communities program. She served roughly ten years as a senior adviser on arts and culture at the Kresge Foundation. From 2017, she taught at Arizona State University, where she led the Studio for Creativity, Place and Equitable Communities [14]. In 2012, she was appointed by Obama to the National Council on the Arts.

The keyword in her professional biography: "equitable." Not "excellent," not "innovative," not "creative." "Equitable communities," "equitable opportunities," "equitable access." Jackson's habitus was formed by institutions that had already shifted the definition of quality toward equity.

This is the sixth type of code establishment in the CulturalBI series. Walt Disney created the code personally (authorial). Hastings established the code through a culture memo (corporate). Chernik/Hudson at AMPAS established the code through a vote (collegial). Walker at Ford established it through a manifesto and restructuring (programmatic). Trump attacked the code through an executive order (directive). Jackson established the code by none of these methods. She did not write a manifesto. She did not restructure the agency. She did not create a new program on the scale of BUILD. NEA's code was established by the environment, not by a person. Jackson was not the code's author but its aggregator: she articulated what her carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) already carried as habitus. This is an authorless code. It is less vulnerable than an authorial one (there is no one to replace in order to make the code disappear) but also less controllable (there is no one to guide its evolution).

Strategic Plan 2022–2026 and Grant Criteria: How Equity Became a Federal Standard

In 2021, NEA developed a strategic plan for 2022–2026, with public consultations concluding in September 2021 [17]. DEIA was codified for the first time as a cross-cutting standard for all agency operations. In April 2022, the Equity Action Plan was published [18].

The strategic plan merits analysis as a performance analogous to Walker's "New Gospel of Wealth." The draft contained such formulations as: "help rebuild the U.S. economy," "heal individuals and communities," "bridge social divides," "positive, life-enhancing experiences for Americans of all backgrounds" [17]. Each of these formulations extends the agency's mandate beyond "artistic excellence." NEA is no longer only about art. NEA is about healing, communities, bridges. The logic is the same as what Landesman initiated with "Art Works," but taken to its logical limit: art is declared an instrument of social change.

The criteria for Grants for Arts Projects (GAP), NEA's largest grant program, formally retained the dual formula: "equal weight assigned to artistic excellence and artistic merit" [19]. But the elements through which these criteria were operationalized changed. "Artistic excellence" was elaborated as "quality of the artists and other key individuals, creative process, works of art... and their relevance to the audience or communities the project aims to serve" [19]. The word "relevance" presumably performs the same work as the 30 points for "power analysis" in Ford Foundation's JustFilms: it allows evaluation not only of quality but of the project's alignment with a particular social framework. Panel minutes are closed, and direct verification is impossible. But the structural logic points in this direction: a criterion that includes "relevance to communities" cannot avoid considering which communities the project addresses.

"Artistic merit" was elaborated through "evidence of direct compensation to artists, art collectives, and/or art workers" [19]. The phrase "art workers" is a marker of a specific habitus: this is the language of labor organizing, not aesthetics. For FY2023, NEA worked with more than 340 expert reviewers [20]. The press release on the first round of FY2023 results contained a statement by Chairman Jackson: "strengthening our arts and cultural ecosystems, providing equitable opportunities for ar[tists]" [20]. "Equitable opportunities" in an official press release about grants.

Challenge America, the second major program, was even more explicit: $10,000 grants were directed "primarily to small organizations for projects to reach historically underserved communities" [19]. The definition of "underserved": "those whose opportunities to experience the arts are limited relative to: geography, ethnicity, economics, or disability" [19]. At minimum, one of these characteristics must be "evident in the proposed project." This is formalized boundary workMechanism of drawing boundaries: who is inside, who is outside, along which axes (Lamont): the selection criterion defines who is inside (underserved community) and who is outside (everyone else).

Comparison with the Ford Foundation. JustFilms: 30 points for power analysis, 25 for intersectional identity, 25 for narrative innovation. NEA: "relevance to the audience or communities," "underserved communities," "equitable opportunities." The difference: Ford assigned numerical weights in a published document. NEA embedded the same meaning in prose without numbers. The effect is identical: a project that does not address equity scores lower on both criteria. But NEA's formulations are legally invulnerable: they contain no words like "racial," "gender," or "intersectional." Only "underserved," "equitable," "relevance."

This explains why Trump's attack in 2025 targeted not the specific wording of grant criteria (which is hard to cite as discriminatory) but the strategic plan and Equity Action Plan, where DEIA is written out explicitly. The directive level (strategic documents) is vulnerable. The reflexive level (the language of grant criteria) is legally protected.

A federal document reproduced the vocabulary that private capital had established a year earlier. NEA did not invent a new standard. The agency formalized through a federal document a consensus that was already the norm in the sector from which it draws its experts.

Binary Code

Inclusive justice / exclusion and inequality. The sacred was: work to expand access to the arts for historically excluded communities. The profane was: the status quo—an elitist art world that reproduces inequality. The code is structurally identical to Walker's code at the Ford Foundation (structural justice / systemic inequality). The difference: Walker established the code through his own manifesto. Jackson received the code from the environment through which she had passed.

Cultural Trauma ClaimAppropriation of someone else's real pain as a source of one's own moral authority (Alexander & Eyerman): A Mediated Subtype

The murder of Floyd (May 2020) became a source of moral authority for the institutional shift. But NEA did not appropriate the trauma directly. At Ford Foundation, Walker did so explicitly: the book "From Generosity to Justice," his biography as performance. At Disney, Karey Burke declared: "as a mother of a queer child." At AMPAS, April Reign created #OscarsSoWhite. In each of these cases, a specific individual transformed collective suffering into an institutional justification.

NEA acted differently. The federal mandate (EO 14035), the synchronous sector shift, and the appointment of Jackson constituted a trauma claim without a single author. This is not the absence of a claim but a new subtype: an institutional trauma claim in which the appropriation of trauma is distributed among three actors (president, sector, chairman) and none of them bears it in full. The analytical consequence: a distributed claim is less vulnerable (there is no one to accuse of appropriating someone else's suffering) but less powerful (there is no biography-as-performance, no emotional center). This explains why NEA's code lacks a protagonist: the trauma was real, the claim was collective, the performance was impersonal.

FramingA ready-made interpretation: who is to blame, what to do, why act now (Snow & Benford)

Diagnostic: the arts sector has historically excluded racial minorities, people with disabilities, and rural communities. Prognostic: make DEIA a cross-cutting requirement of all grant programs. Motivational: NEA, as a federal agency, bears a special responsibility for equitable access to public resources. The frame appealed to the civil sphereAutonomous sphere with a democratic/antidemocratic code; presence grants legitimacy beyond the cultural field (Alexander): the agency's democratic mandate requires inclusion. Jackson's address to the Scottish Parliament (August 2022): "In strategies of devaluation, the first thing that is suppressed is the ability to create meaning, to ask questions, to have an aesthetic, to express oneself through creativity" [14].

Carrier GroupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman)

Bearers of the new code: NEA program officers (hired under Jackson and earlier), panelists from Ford/Mellon/MacArthur/Kresge institutions, state arts agencies (40% of NEA's budget, transmitting the federal standard to the state level), and Jackson herself as a bearer of the equity habitus. NEA's carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) are not employees of the agency but external experts recruited through panels. This makes the code more durable: panelists do not depend on NEA for employment and cannot be dismissed by directive. But also more vulnerable: the agency does not directly control their selection, and the 77% annual rotation means that three-quarters of the roster is renewed each year from the same sector.

UnsettledHabitus broken or threatened; manifestos and declarations signal instability (Swidler) Culture as a Permanent Mode

Throughout 2020–2025, NEA operated in unsettledHabitus broken or threatened; manifestos and declarations signal instability (Swidler) mode. The strategic plan, the Equity Action Plan, Jackson's public appearances, and the interagency working group on arts and health (with HHS, involving over 20 federal agencies). The code did not become invisible habitus. It was declared, explained, and institutionalized through documents. SettledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture does not need strategic plans.

By the Cultural DiamondFour poles of a cultural object: creator, object, receiver, social world (Griswold): Re-Fusion Without External Verification

All four axes are formally aligned: the creator (Jackson) believes the code, the object (the Equity Action Plan) embodies it, the receiver (arts organizations) accepts it as a condition of funding. But the social world is split. Re-fusion occurs only within the sector: panelists, state arts agencies, and recipients form a closed audience where the code operates. Beyond the sector, re-fusion is not merely unverified. It is inherently unverifiable. At Disney, box-office revenue signifies re-fusion. NEA has no analogous indicator. This renders the 2022–2025 period analytically opaque: we do not know whether re-fusion occurred, because we have no instrument to measure it outside the professional circle. SPPA could serve as such an instrument, but SPPA measures participation, not acceptance of the code.

V. The Moment of De-Fusion: EO 14151, EO 14168, and the Directive Rupture

A Special Type of De-Fusion: Initiated by the State

In all previous cases in the series, de-fusion was initiated by the audience. Disney: the viewer does not buy a ticket. AMPAS: the television audience does not watch the ceremony. Netflix: employees stage a walkout. Ford: HHMI closes its program. NEA presents a unique case: de-fusion is initiated not by the audience but by the founder. The state that created the agency rejects the code the agency performs.

Chronology of De-Fusion

On January 20, 2025, President Trump signed EO 14151 and EO 14168: a ban on federal funding for DEI programs and "gender ideology" [21]. In March 2025, NEA updated application criteria in accordance with the orders. On May 3, 2025, the agency revoked dozens of grants for noncompliance. On the same day, Trump proposed eliminating the agency [22]. In July 2025, the House of Representatives recommended cutting the budget to $135 million (the lowest since 2007) and banning funding for CRT and DEI training [23]. In August 2025, NEA abolished individual fellowships for writers (Creative Writing Fellowships) [5]. On December 18, 2025, the Senate confirmed Mary Anne Carter as the new chairman [24].

Mary Anne Carter: A Performance of the Alternative Code

Carter had previously served as NEA chairman under Trump I (2019–2021). Her biography functions as a performance of a different code. Carter is not an artist or an academic. Her professional background: public policy analysis, issue tracking, communications [24]. During her first term, she expanded Creative Forces (art therapy for veterans), held National Council on the Arts meetings outside Washington (Charleston, Detroit), and positioned art as "an economic asset for states and communities" [24].

The key difference from Jackson: instead of "equitable communities," Carter uses "arts belong to all Americans," "expand opportunity," "support the creative spirit" [24]. A lexical shift from equity to opportunity. The same words, a different habitus. Jackson saw barriers that needed dismantling. Carter sees access that needs expanding. The difference appears subtle. It is fundamental: the first code demands a diagnosis of systemic inequality; the second code demands only increased reach.

The Competing Frame

EO 14151 and 14168 contain their own frame. Diagnostic: DEI programs are discriminatory preferences. Prognostic: restore merit-based opportunity. Motivational: defending equality before the law. Both frames (Jackson's and Trump's) appeal to the civil sphereAutonomous sphere with a democratic/antidemocratic code; presence grants legitimacy beyond the cultural field (Alexander). The clash is structurally identical to the culture war of 1989–1996, with one difference: in the 1990s, the attack targeted the content of specific grants (obscenity). In 2025, the attack targets the selection criteria (DEI). The second argument is structurally stronger: it is aimed not at a specific grant but at the panel mechanism itself.

The 1996 Pattern

The pattern is reproduced in precise detail. 1996: threat of elimination, budget cut ($170 → $99.5 million), abolition of direct grants to individuals, agency survives [3]. 2025: threat of elimination, budget cut ($207 → $135 million), abolition of Creative Writing Fellowships, agency survives [22, 23]. The defense mechanism is the same: grants are distributed across all 435 congressional districts. Every vote for elimination is a vote against money in one's own district.

Within the sector, the pattern is not unique. The Corporation for Public Broadcasting was eliminated in September 2025 ($1.1 billion). IMLS was proposed for elimination. NEH faced a proposed 35% cut [22]. Three of the four largest federal cultural agencies were attacked simultaneously. But they responded differently. CPB, lacking geographic distribution across districts, was eliminated. NEH, whose grants go predominantly to universities (not community organizations), is more vulnerable than NEA: NEH has no equivalent of Challenge America, no map of 435 districts. NEA survives precisely because Gioia in 2003 converted the agency from an elite institution into a geographic one. The NEH counterexample confirms: the map protects; philosophy does not.

The ACLU Lawsuit (March 2025)

Four arts organizations (Rhode Island Latino Arts, National Queer Theater, The Theater Offensive, Theatre Communications Group), with ACLU support, filed suit against NEA, challenging the requirement not to use grants to "promote gender ideology" [25]. The lawsuit attacks the directive level: published application criteria that can be cited. A court can restore specific grants. It cannot protect the agency's budget in the next congressional appropriations cycle.

By the Cultural DiamondFour poles of a cultural object: creator, object, receiver, social world (Griswold): A Double Rupture

Rupture along the creator ↔ object axis: the new leadership (Carter) carries a different code from the one codified in Jackson-era documents (the 2022–2026 strategic plan formally remains in effect). Rupture along the object ↔ social world axis: the presidential directive declares the codified criteria unlawful. The receiver (arts organizations) is in a state of uncertainty: old criteria have been revoked, new ones have not been established.

Carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) in conflict. Jackson's panelists and program officers carry the equity code as habitus. Carter has brought a different professional class. The two carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) do not coexist (as they do at Ford Foundation under Goerken). The question is resolved by directive: the executive order overrides the output of the prior habitus. But the habitus of the panelists themselves cannot be altered by executive order.

VI. The Grant Ritual: The Mechanism of ConsecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu)

Expert Panels as Ritual

NEA's grant ritual merits separate analysis because it is the only case in the CulturalBI series in which state consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) is produced through a closed mechanism into which private habitus is embedded.

Procedure. NEA program staff compile lists of panelist candidates. The list is approved by the deputy chairman. Panels of 6–16 members evaluate applications in closed sessions. Composition: artists, arts administrators, state arts agency representatives, "knowledgeable laypersons" (the GAO 1991 formulation, retained without change) [12]. Term of service: one year, three consecutive years maximum. 77% of panelists rotate annually. Panel recommendations are transmitted to the National Council on the Arts (25 members, 18 appointed by the president), then to the NEA chairman for the final decision.

Formal Rotation, Substantive Reproduction

Each year, 77% of the expert panel roster is replaced. On paper, this is a safeguard against monopoly and groupthink. In practice, the rotation changes names without changing the institutional profile of the membership.

What the FY2023 lists reveal. Panelist lists are published on arts.gov via the FACA database. A sample by discipline [26]:

What follows from this. Three patterns are immediately visible.

First: research universities dominate. Michigan State, Columbia, Johns Hopkins, UNC, University of Georgia—five universities out of thirteen positions. Add university museums (Weatherspoon, Lunder Institute) and university affiliates (Wilma Theater), and the share rises to eight out of thirteen. The majority of NEA experts work in an academic environment funded in significant part by the same foundations (Mellon, Ford) that synchronously shifted their criteria in 2020.

Second: equity language is embedded in institutional names. African Diaspora Consortium, "Justice & Rights" in the job description of Masum Momaya. This is not an ideological filter at the point of entry. It is a career signal: the organizations where potential panelists work add equity language to their own missions because their donors require it.

Third: "knowledgeable laypersons" are not always from the arts sector. Natasha White on the music panel: Chief of Staff at the Equity and Inclusion Cabinet, City of Boston. Not a musician, not a curator, not an arts administrator. A specialist in inclusion policy at city hall. This is a formally permissible layperson under GAO 1991 rules [12]. But her professional expertise belongs to a different domain.

This is not a conspiracy. It is career logic. One becomes an NEA expert by passing through the institutions that produce experts: an arts department at a research university, an MFA program, a university-affiliated museum, a major-foundation grantee. No alternative candidates exist in the system, because no alternative system for producing them exists.

The key consequence. The panel receives the "excellence" criterion without a definition. It applies the criterion through its own habitus. When in 2020–2021 the largest private foundations synchronously change the definition of quality, they do not change NEA's rules. They change what is considered normal in the sector from which NEA draws its experts. An executive order can rewrite application criteria. It cannot replace the habitus of 340 reviewers, because there is no one to replace them with.

The Grant Ritual in Alexanderian Terms

NEA's ritual is recurring (the annual grant cycle), institutionalized (regulated by the Federal Advisory Committee Act), and participation in it is an act of belonging to the code. An organization applying for an NEA grant accepts the agency's criteria as a condition of participation. A panelist who accepts the invitation accepts the role of arbiter of quality. A grant awarded to an organization is an act of federal consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu): the state declares the recipient worthy.

Two Nested Loops: Why a Directive Does Not Change Habitus

The Ford Foundation has been described through a single closed loop: Ford → recipients → SMU DataArts → Ford cites the results → Ford continues. NEA is embedded in two loops nested inside each other. This explains why the habitus of the panels is not changed by a presidential directive.

Outer loop. Ford/Mellon/MacArthur/Kresge fund universities, MFA programs, museums. These institutions produce people with a specific habitus. Those people sit on NEA expert panels. The panels affix the federal seal. The federal seal attracts additional private funding from the same foundations (the NEA grant as a signal of reliability). The cycle is closed.

Inner loop. NEA funds 56 state arts agencies and six regional arts organizations (40% of the budget, ~$66 million). State arts agencies run their own grant competitions using criteria harmonized with NEA. Recipients of state agency grants cultivate the next generation of arts administrators. Those administrators become NEA panelists. The cycle is closed.

The two loops reinforce each other. The outer loop determines the content of habitus (what quality is). The inner loop ensures geographic reproduction (quality is defined the same way in New York and in Montana). To change the habitus of the panels, both loops must be disrupted simultaneously. A presidential directive can change application criteria. It cannot change the habitus of 340+ reviewers (outer loop) and 56 state arts agencies (inner loop). This is where NEA fundamentally differs from the Ford Foundation, where it suffices to replace program officers and close BUILD.

Boundary WorkMechanism of drawing boundaries: who is inside, who is outside, along which axes (Lamont): Who Is Inside, Who Is Outside

The boundary is drawn through the panelist selection procedure. Inside: people with credentials from recognized institutions (MFA, major museums, arts departments at research universities). Outside: everyone who lacks such credentials. The boundary is drawn along the cultural axis (educated/uneducated) and the institutional axis (recognized/unrecognized). There is no third arbiter: NEA does not recruit philosophers of aesthetics, critics, or independent scholars unaffiliated with the grant ecosystem.

This is a closed loop, structurally analogous to the Ford Foundation. Foundations fund institutions. Institutions produce experts. Experts sit on NEA panels. Panels reproduce the consensus of the institutions. No external point of verification exists.

VII. Comparative Framework: NEA in the CulturalBI Series

Five Types of Institutions, Five Types of ConsecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu)

NEA is unique on two parameters. First, the source of the code is concealed: the agency performs the private sector's consensus while presenting it as its own federal standard. Second, de-fusion was initiated not by the audience but by the founder (the state).

NEA and the Ford Foundation: Mirror Institutions

The Ford Foundation produces the definition of the sacred for the arts sector. NEA legitimizes that definition on behalf of the state. The difference lies not in content (the codes are nearly identical) but in the nature of consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu). A Ford grant carries the symbolic capital of a private foundation. An NEA grant carries the symbolic capital of the federal government. When the state changes its position (EO 14151), consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) ruptures. The Ford Foundation can continue funding under the old criteria. NEA cannot: it is subject to the presidential directive.

This exposes the fundamental vulnerability of state consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu). A private foundation depends on its endowment and carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) (Ford: Social Bond through 2070). A government agency depends on the political cycle. Ford Foundation's code survived a change in the foundation's president (Walker → Goerken), because Social Bond and carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) provide inertia. NEA's code did not survive a change in the country's president (Biden → Trump), because the agency has neither an endowment, nor financial lock-in, nor protection from a directive from above.

VIII. Structural Conclusion: Six Patterns

Sections I–VII described the history, mechanism, and place of NEA in the series. Six patterns summarize what follows from this.

First pattern: a normative vacuum does not remain empty. The 1965 Act created an agency without a definition of quality. The Supreme Court in 1998 legalized the void. The content of an empty criterion is determined by whoever controls the evaluation system. Control over the system is not seized. It is exercised through the production of experts. Foundations fund institutions. Institutions produce people. People sit on panels. Panels affix the federal seal on the consensus of those who produced them. The process takes a generation, not a political cycle.

Second pattern: state consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) is fragile in the face of the political cycle. Disney depends on the viewer (box office). Ford depends on the endowment (Social Bond). NEA depends on Congress (budget) and the president (directives). This makes state consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) the most powerful instrument (the federal seal has no private equivalent) and the most vulnerable (four years, not fifty). The paradox: the greater the symbolic capital of consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu), the lower its durability.

Third pattern: de-fusion without an audience. In all previous cases, de-fusion was registered through audience reaction: box office, ratings, walkout, foundation retreat. NEA's audience has no voice: arts organizations cannot "unsubscribe" from a federal agency. De-fusion was initiated by the founder. The state that created the agency for the consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) of one code rejects that code and demands the consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) of another. This is the only case in the series where the ritual is not de-fused but seized.

Fourth pattern: survival through geography and personal advocacy. NEA survives not because of its code but because of its map and specific defenders. Grants across 435 districts create a political cost of elimination for every congressman. The pattern has been confirmed three times: 1996, 2017–2018, 2025–2026. Congressman Sidney Yates (D-IL), chairman of the Appropriations Subcommittee on Interior, held NEA's budget for twenty years (1975–1995) [27]. After his departure, the budget was cut. His successor, Ralph Regula (R-OH), did not share his priorities. The personalization of advocacy shows: the map works as long as there is someone who defends it.

A second survival instrument: the National Medal of Arts, established in 1984 (signed by Reagan). The medal is awarded by the president annually (up to 12 medals). Recipients range from Ella Fitzgerald to Steve Martin [28]. The medal functions as second-order consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu): it is not the agency that consecrates the artist but the president through the agency. The paradox of 2025: the same president who proposes eliminating the agency is the only person authorized to award its highest honor. The map protects the institution, not the code. The medal binds the president to the institution, not to the code.

Fifth pattern: split settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture. The 1965–1989 period demonstrates settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture structurally analogous to the Ford Foundation under Hoffman. Habitus operated invisibly for carrier groupsSocial groups that carry and transmit the narrative within an institution (Alexander & Eyerman) (panelists, program officers, arts administrators). But for the architects (Pell, Stevens, Hanks), the code was a conscious instrument. SettledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) for the performers, instrumental for the architects. This is the same pattern as the Ford Foundation with CCF: settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture can be both genuine and instrumental simultaneously, provided that architects and bearers operate at different levels of awareness.

Sixth pattern: the normative vacuum may be an inevitability, not a flaw. The Gramscian report on NEA poses a question that undermines the central thesis: if neither a government institution nor private capital is fundamentally competent to define what artistic quality is, then the void in the 1965 Act is not an architectural error. The philosophy of aesthetics is two and a half thousand years old. Congress and foundations acknowledge that this is not their level of competence. The court in 1998 fixed this juridically.

The Finley decision poses the question more sharply than any previous case in the series. Disney knows what "magic" is (box-office success). AMPAS knows what "mastery" is (a vote of professionals). The Ford Foundation knows what "structural justice" is (Walker defined it). NEA does not know what "excellence" is, and the court has forbidden it from finding out. The vacuum is not filled by a definition. It is filled by people: those who agree to play by the rules. A serious philosopher of aesthetics will not join an NEA panel: bureaucratic procedure and intellectual honesty are incompatible. The evaluation system is structurally severed from the source of competence. This is not a bug, not a feature. It is a property of NEA that likely extends to analogous government institutions (Arts Council England, Canada Council for the Arts), though confirming universality would require a comparative analysis beyond the scope of this report.

All six patterns point in the same direction. NEA is in a transitional state: the equity code has been revoked by directive, but the habitus of the panelists who produce the definition of quality has not changed. The new chairman carries a different code, but the expert infrastructure that produces panelists remains untouched. To change who sits on NEA panels, one must change who is considered an expert in the sector. To change who is considered an expert, one must change which institutions produce expertise. A top-down directive changes the outcome of one cycle. The network remains. The network is formed by three loops: outer (private foundations → institutions → experts → panels → federal consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu)), inner (NEA → state arts agencies → recipients → new panelists), and reflexive (SPPA/NASERC: NEA itself determines what the condition of the sector it funds looks like). Breaking one loop is not enough. Breaking all three simultaneously is impossible within a four-year presidential term.

Open Questions

First. If an authorless code is less vulnerable (there is no one to replace in order to make the code disappear), why did it collapse within three months from a single executive order? Possible answer: an authorless code is resilient against internal pressure (a board of trustees, a leadership change) but fragile against external pressure (a presidential directive), because it has no one capable of mobilizing resistance. Walker at Ford could write a book, give interviews, appeal to the board. NEA had no voice.

Second. Is Gioia's geographic strategy (a grant in every district) a form of second-order settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture? No one asks why NEA distributes by the map. The answer is self-evident: money in the district. This is invisible habitus operating not within the arts sector but within Congress. If Congress ever asks, "why do we give money to every district instead of to the best?", the settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture of the map will collapse just as the settledHabitus works invisibly; the question "why do we do it this way" never arises (Swidler) culture of excellence collapsed in 1989.

Third. The Ford Foundation established its code through a single person; NEA received its code from the environment. Is there an intermediate variant: a code established by a small group of insiders without a public manifesto? If so, it may explain how Chu (2014–2018) conducted a quiet infiltration of equity language: not authorlessly (there was a specific person) but not authorially either (there was no manifesto). A seventh type of code establishment? Or a variant of the authorless type?

IX. Operational Conclusion: Three Scenarios

NEA's current state is determined by the intersection of three variables: 1) the habitus of expert panels (shaped by institutions funded by private foundations); 2) the presidential directive (DEI ban, compliance requirement); 3) budgetary pressure ($207 → $135 million). Two extreme scenarios follow from their combination. Between them lies a middle path. Caveat: Carter has not delivered a programmatic statement beyond her biography on arts.gov. The scenarios are reconstructed from the pattern of her first term (2019–2021) and structural variables.

Scenario B: Ideological Reset (Extreme Conservative)

The Trump administration goes beyond budgetary pressure. Carter restructures the National Council on the Arts (18 members appointed by the president). The new council changes the panelist selection procedure. The excellence criterion receives a substantive definition through administrative regulation: "artistic merit" is defined through "broadly shared American values," "national heritage," "community impact." Creative Forces and Shakespeare in American Communities are scaled up as flagship programs. DEIA language is removed from all documents.

Mechanism: Carter uses the same instrument Jackson used (strategic plan, equity action plan) but with the opposite sign. Documents are replaced. Application criteria are rewritten. A new type of panelist is recruited from institutions not dependent on Ford/Mellon/MacArthur: community arts organizations, veteran programs, folk and traditional arts.

Risk: habitus does not change by document. Panelists from universities and major museums continue to carry the equity code even when formal criteria have been changed. Two habitus systems within a single procedure. If panel stacking becomes overt, it will register as de-fusion along the creator ↔ receiver axis: the arts community will cease to regard an NEA grant as a signal of quality. Federal consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) will lose its symbolic capital.

Verifiable signals: 1) replacement of more than 50% of National Council on the Arts membership; 2) publication of a new strategic plan with lexical removal of DEIA; 3) replacement of program directors; 4) decline in application volume from major institutions (if they begin boycotting an "ideologized" agency).

Scenario C: De Facto Elimination Through Devaluation (Extreme Progressive)

The budget is cut to $135 million. Creative Writing Fellowships are abolished. Grants are revoked for noncompliance. Major arts organizations (Met Opera, Lincoln Center, large university arts programs) begin declining NEA grants in order to avoid accepting the compliance conditions of EO 14151/14168. Federal consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) loses symbolic capital: an NEA grant ceases to be a signal of quality and becomes a signal of compliance.

Mechanism: the private sector substitutes the function. Ford Foundation, Mellon, and MacArthur increase their grantmaking. Their combined budget ($1.5 billion/year) exceeds NEA's reduced budget ($135 million) tenfold. Private consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu) replaces state consecrationInstitutional act of consecration: an agent endows an object or person with symbolic capital (Bourdieu). NEA formally exists, but its grant ceases to carry symbolic capital for those who define the sacred in the arts sector.

Risk for the progressive side: loss of the federal seal. A private grant does not provide what an NEA grant provided: legitimization on behalf of the state. For organizations in 435 districts, especially in conservative states, a federal grant is the only signal that local donors and politicians recognize as "official." The private sector cannot replicate this function.

Verifiable signals: 1) major institutions declining NEA grants; 2) growth in private foundation grantmaking in niches previously funded by NEA; 3) decline in application volume; 4) public statements by arts organizations about the impossibility of compliance.

Scenario A: Procedural Compromise (Middle Path)

Between ideological reset and devaluation lies a third path. Carter does not attempt a radical restructuring of the panels. She shifts emphases: from DEIA to "arts and healing," "national heritage," "creative placemaking," "economic impact." The lexicon changes. Grant content shifts gradually. DEIA is removed from documents, but the excellence criterion remains undefined. Panelists continue to arrive from the same institutions. Habitus slowly adapts to the new language.

Mechanism: the same as in 1996–2003. After the budget crisis, NEA recovered through the geographic argument and the Challenge America program. Carter already demonstrates this approach: National Council meetings outside Washington (Charleston, Detroit), an emphasis on "arts in every corner of the nation" [24]. The code is not replaced. It is diluted: equity dissolves into wider access, justice dissolves into opportunity.

Verifiable signals: 1) budget recovery from $135 million back to $170–180 million within 2–3 years; 2) no radical change in panel composition; 3) a new strategic plan without DEIA language but also without rigid ideological content; 4) stable application volume.

What Determines Which Scenario Is Realized

The key variable: the November 2026 midterm elections. If Democrats win a majority in at least one chamber, pressure eases and Scenario B becomes impossible. If Republicans retain control, Scenario B gains political resources.

Second variable: the behavior of private foundations. If Ford, Mellon, and MacArthur increase direct funding to arts organizations in NEA's niches, this signals Scenario C. If the foundations maintain current levels, Scenario A stabilizes.

Third variable: judicial. The ACLU lawsuit (March 2025) may result in a court injunction on the compliance conditions of EO 14168. If the court prohibits the restrictions, the administration loses its directive instrument, and Scenario A is realized faster.

Observation horizon: the FY2027 grant portfolio (published on arts.gov) and the presence or absence of a new strategic plan by 2027.