funds to support inherently religious activities such as prayer, worship, religious instruction, or proselytization. Any inherently religious activities that the organizations may offer must be offered separately in time or location from services that receive federal assistance. FBOs cannot discriminate on the basis of religion when providing services (GAO 2006:13). Under Barack Obama President Barack Obama renamed the office and appointed Joshua DuBois as its head. He also established an advisory council, composed of religious and secular leaders and scholars from different backgrounds. Each member of the council was appointed to a one-year term. According to ABC News, the office would seek "to expand the role of this office as it relates to policy issues where religious and local leaders can be effective. DuBois would coordinate with faith-based and community organizations on social service outreach and work to utilize these organizations' efforts to advance the administration's policies, with a primary focus on poverty." Joshua DuBois resigned as director in February 2013 and was succeeded by Melissa Rogers in March. Under Donald Trump Following the election of President Donald Trump, the office remained without a director; the website was no longer available. In May 2018, Trump started the Faith and Opportunity Initiative, a new White House office to help faith-based organizations get equal access to government funding. Under Joe Biden On February 14, 2021, President Joe Biden reestablished the Office with Melissa Rogers again serving as executive director. Controversies The separation of church and state was noted as one of major issues with the Faith-Based Initiatives laws. Critics have claimed that millions in government grants have gone to ministries operated by political supporters of the Bush administration, or have been given to minority pastors who recently committed their support. In June 2006, U.S. District Judge Robert W. Pratt ruled that a faith based-program called InnerChange at a Newton, Iowa prison, operated by Charles Colson's Prison Fellowship Ministries, unconstitutionally used tax money for a religious program that gave special privileges to inmates who accepted its evangelical Christian teachings and terms. "For all practical purposes," Judge Pratt said, "the state has literally established an Evangelical Christian congregation within the walls of one of its penal institutions, giving the leaders of that congregation, i.e., InnerChange employees, authority to control the spiritual, emotional, and physical lives of hundreds of Iowa inmates." [See Americans United v. Prison Fellowship Ministries, 2006 U.S. Dist. LEXIS 36970, June 2,