Policy Alert: The De Facto Dismantling of the U.S. Department of Education
- The Policy Stack
- Nov 19, 2025
- 3 min read
Date: November 19, 2025
To: Education Stakeholders
From: The Policy Stack LLC
High Level Summary (Non-Partisan) Analysis
The Trump administration has bypassed the legislative requirement to formally "abolish" the Department of Education (ED) by executing a series of sweeping Interagency Agreements (IAAs). As of this week, the ED is effectively operating as a shell agency. The administrative authority for over $30 billion in grants—including Title I and major postsecondary funding—has been transferred primarily to the Department of Labor (DOL), with other portfolios shifting to the Department of the Interior, HHS, and State.
For State Education Agencies (SEAs), this is not merely a political headline; it is an immediate operational pivot. The federal "front door" for compliance, technical assistance, and funding draws has moved.
1. The Structural Shift: "Partnership" as a Loophole
While the President cannot shutter the ED without an act of Congress, the administration is using the Economy Act and other executive authorities to "partner" with other agencies. This allows the ED to retain its statutory name while offloading its statutory duties.
The New Reality: The Department of Labor is now the primary federal regulator for K-12 and Higher Education funding.
Other Transfers:
Interior: Indian Education programs.
State Dept: International and Foreign Language education.
HHS: Campus childcare and foreign medical school accreditation.
Analysis for States: This "hollowing out" strategy creates a legal gray zone. While the authorizing statutes (like ESSA) haven't changed, the interpretation of those statutes now rests with agencies that view education through a different lens (e.g., Labor views education as "workforce preparation," not "pedagogy").
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