Key Points at a Glance

• The Department of Education is still in place. No legislation has been passed to eliminate it.
  
  • Core federal laws such as IDEA, FAPE, Section 504, and Title I remain fully intact.
  
  • Most reorganization efforts are at an early stage and have not changed day-to-day school operations.
  
  • Some programs are shifting to other agencies through administrative agreements, not  congressional action.
  
  • The 43-day shutdown showed that early childhood programs are highly sensitive to federal delays, while K–12 remained mostly stable.
  
  • Special education oversight remains uncertain due to staffing changes and possible shifts in monitoring and enforcement responsibilities.
  
  • New student loan rules will end Grad PLUS for new borrowers in July 2026 and introduce borrowing caps that may affect educator and clinician pipelines.
  
  • Legal challenges are ongoing and could influence how far program transfers can go.
  
  • State-level budgets and capacity will shape the real impact more than federal headlines.
  
  • Headlines have outpaced actual changes, contributing to confusion and emotional strain for educators and clinicians.
  
  • The most important point: rights for students and obligations for districts have not changed.

Why This Conversation Looks Different in Late 2025

When we first explored the idea of closing the Department of Education earlier in 2025, the conversation was mostly theoretical. Much of the focus was on what could happen if federal oversight shifted and how states, districts, and educators might feel those changes. Only a few months later, the landscape looks different, not because large structural changes have taken effect, but because the events of late 2025 have shown how complex and uneven this process is. Headlines have accelerated, new proposals have emerged, and agencies have begun early-stage reorganization work, yet most of these shifts remain in motion rather than completed.

Several events have shaped the current moment. A 43-day federal shutdown disrupted grant cycles, delayed reimbursements, and pushed some early childhood programs into temporary closures, as reported by Reuters and Education Week. After the shutdown, Federal News Network documented significant staff reductions across the Department of Education, raising questions about long-term capacity. At the same time, multiple interagency agreements began moving selected programs to agencies such as Labor, Interior, State, and HHS, according to reporting from Education Week and K-12 Dive. Alongside these shifts, Inside Higher Ed reported new proposals to redefine what counts as a professional degree, which would change federal student loan limits and affect fields like teaching, social work, nursing, and school-based clinical practice. Also throughout the year, states and advocacy groups continued to challenge the administration’s reorganization authority in court.

These developments have generated steady headlines, but the reality on the ground looks much quieter. Despite strong political rhetoric and high public attention, the pace of actual structural change has been slow. Nearly a year of debate has produced more questions than answers, and many schools report that day-to-day operations feel largely unchanged. As the year wraps up, a pattern emerges. The conversation has moved quickly, while the actual changes have unfolded far more gradually.

This article focuses on what has shifted, what remains uncertain, and what still holds. The goal is to present the current facts, outline the potential benefits and risks raised by different stakeholders, and help readers sort through the competing claims. We pay particular attention to special education, where changes to oversight could have significant implications for IDEA and FAPE, and to the proposed loan rules that may affect graduate programs for educators and clinicians.

One point remains stable through all the discussion. Federal laws such as IDEA, FAPE, and Section 504 are still in effect. Unless Congress takes action, the rights they guarantee do not change. What may change, and what this article examines closely, is how those laws are overseen, enforced, and supported at the federal level.

Where Things Stand Now: Is the Department of Education Actually Closing?

From “Could It Happen?” to Active Reorganization

In early fall, much of the conversation about closing the Department of Education focused on whether it could even happen. The idea was rooted in campaign promises to return more education authority to states, but there were few concrete steps in motion. Since then, a series of administrative actions has pushed the conversation from hypothetical to active reorganization, even though Congress has not passed any legislation to eliminate the department.

Part of the shift comes from the ripple effects of the 43-day federal shutdown earlier this year. There were widespread delays in grant approvals, disrupted timelines for early childhood programs, and slower processing across key offices. Once the shutdown ended, the department entered a period of internal restructuring and staff reductions, which has been one of the most significant downsizing efforts in recent decades.

As of December 2025, the Department of Education still exists. Congress has not voted to abolish it, and federal education laws remain in place. What is happening instead is a piecemeal process in which certain programs are being transferred to other agencies through interagency agreements. This is the mechanism driving most of the change. It is administrative, not legislative.

Even so, the impact in schools has been limited. Districts report that day-to-day operations look much the same as they did before. Many of the proposals generating national headlines remain in draft form. Others have begun moving through agencies but have not yet changed what teachers, principals, or families experience. It goes without saying that the tension between political messaging and practical realities is one of the defining features of the current moment.

Programs Already Moving to Other Agencies

Several program shifts are underway. These transfers are framed by the administration as a way to streamline federal functions and reduce duplication, while critics warn that the moves could fragment oversight or make some programs harder to track.

One major transition involves Perkins career and technical education programs, along with selected K–12 grants, which are moving to the Department of Labor. We have also tracked the movement of Native and tribal education programs to the Department of the Interior. Title VI international and foreign language programs have been reassigned to the Department of State, reflecting the administration’s belief that these initiatives better align with foreign policy and diplomatic priorities. Additionally, the CCAMPIS program, which supports child care access for student-parents, is shifting to the Department of Health and Human Services. This transfer pattern suggests an emerging structure where education-related services are scattered across multiple agencies rather than housed within a single department.

These changes raise new questions for states and districts. Supporters argue that relocating programs may reduce redundancy, lower administrative costs, and align services with agencies better suited to oversee them. Critics worry that funds could lose their visibility within much larger agencies. They also note that the promised reduction in paperwork has not yet been felt at the state level, and many state agencies report that compliance and reporting expectations have remained essentially unchanged.

Legal and Political Pushback

The reorganization has also triggered a growing legal response. It was reported that several states and advocacy groups have expanded their lawsuits, arguing that the administration does not have the authority to dismantle core functions of the Department of Education through outsourcing alone. These groups point to the 1979 law that established the department and argue that Congress intended federal education oversight to remain centralized.

Critics also emphasize the connection between staff reductions and the enforcement of IDEA. Both Education Week and K-12 Dive have highlighted concerns that shrinking the federal workforce responsible for special education monitoring could weaken compliance efforts, slow corrective action, and reduce support for states that rely on federal technical assistance.

None of these cases have been resolved. All remain in progress, creating uncertainty about how far the administration can go before courts intervene, and whether some transfers could ultimately be paused or reversed.

What Has Not Changed: Core Federal Education Laws

Despite the movement happening around the edges of federal oversight, the foundational federal education laws remain untouched. IDEA, FAPE, Section 504, and Title I are still fully in effect. States must continue to meet the same legal requirements they met before. Districts must continue to provide the same services to students. Families continue to have the same rights.

What could change in the future is the structure that supports and enforces these laws. Agencies may shift. Processes may look different. Program staff may sit in different offices. But the legal obligations themselves have not changed, and they do not change unless Congress rewrites the laws.

 

Potential Benefits and Risks of Downsizing the Department of Education

Arguments Supporters Raise

Supporters of the administration’s reorganization efforts often frame the changes as a chance to rethink how federal education programs are organized, highlighting several perceived advantages.

One central argument is the potential for greater state flexibility. Proponents believe that shifting authority away from Washington gives governors, state agencies, and local districts more room to make decisions that reflect regional priorities rather than federal mandates. Some see this as a return to a system in which states carry more responsibility for curriculum, accountability, and school improvement.

Another common point is the possibility of reducing administrative burden. Moving programs into agencies that already manage related responsibilities, such as the Department of Labor for workforce initiatives or the Department of Health and Human Services for early-childhood programs, is described by supporters as a way to streamline oversight. This realignment, they argue, could reduce duplication, consolidate similar grant structures, and create clearer pathways for schools and families.

Supporters also frame the shift as a way to better match certain programs with the agencies that have the strongest expertise. International and foreign-language programs, for instance, may fit more naturally within the Department of State, while labor-focused pathways and technical-education grants might benefit from closer alignment with national workforce priorities. Finally, some argue that reducing the Department of Education’s footprint could cut federal-level waste, though these claims are often made without specific fiscal estimates.

Concerns Raised by Critics

Critics view the reorganization with caution, noting that reducing the federal role could affect civil rights enforcement, create uneven implementation across states, and complicate how education programs fit together.

A primary worry is the potential loss of centralized civil rights enforcement. The Department of Education’s Office for Civil Rights plays a unique role in monitoring compliance with federal nondiscrimination laws, and critics warn that redistributing responsibilities across agencies could dilute this function or create inconsistent enforcement.

Another major concern is uneven state capacity. States vary widely in how well they monitor IDEA, manage corrective actions, and provide technical assistance to districts. Critics caution that shifting responsibilities without equivalent staffing or funding may widen these gaps, particularly in states already struggling with compliance workloads.

Staff reductions are also a point of tension. As positions remain unfilled or are phased out, some experts worry that reviews, monitoring visits, and technical-assistance cycles could slow significantly. This could affect timelines for districts awaiting guidance or corrective-action approvals, creating bottlenecks in an already complex system.

Finally, there is concern that moving programs into multiple agencies could make funding harder to track. Critics argue that fragmentation across Labor, HHS, Interior, and State could reduce transparency for districts and families. They note that even well-intentioned reorganizations can lead to confusion about where grants originate, how they are monitored, and how decision-making authority is distributed.

Additional Context: What States and Communities Are Experiencing

Alongside the formal arguments for and against the restructuring, new dynamics are shaping how the changes are being interpreted on the ground.

Despite rhetoric emphasizing increased state control, the expectation that states would significantly expand their own education budgets has not materialized. This is particularly relevant as states assume a larger share of oversight responsibilities for programs previously anchored at the federal level. Several states are reporting flat or limited growth in education funding for 2025. This appears to be driven more by state-level budget pressures than by federal restructuring, but it remains part of the larger environment in which these shifts are occurring.

At the same time, public schools continue to function as community anchors. Even in places where federal structures are shifting, local stakeholders have repeatedly mobilized to protect public schools, maintain core services, and safeguard student supports. This pattern suggests that while governance structures may change, community investment in public education remains strong and steady.

Together, these factors complicate the picture. Supporters emphasize flexibility and efficiency, while critics warn of weakened safeguards and fragmentation. On the ground, states face fiscal constraints, and communities continue to rely on schools as central institutions, regardless of how federal responsibilities are redistributed.

What the 2025 Shutdown Revealed About Federal Education’s Role

Head Start and Early Childhood Programs as a Case Study

The 2025 federal shutdown offered one of the clearest examples of how early childhood services depend on federal timelines. Several Head Start centers in California and other states began reducing hours or temporarily closing because their grant renewals were delayed during the shutdown. Reports from The 74 and EducationCounsel noted that these disruptions happened quickly and were difficult for programs to absorb.

Even after the government reopened, the effects lingered. Programs needed time to process backlogged renewals, reorganize staffing, and respond to families who had already experienced gaps in care. This case shows how early childhood systems that rely on ongoing federal approvals are especially vulnerable when those approvals pause. While many centers were able to resume operations, the shutdown highlighted how even short delays can interrupt services that families depend on daily.

Broader Lessons for K–12

K–12 systems experienced the shutdown differently. Most school operations continued because state and local funds cover the bulk of daily expenses like staffing, transportation, and instructional time. Education Week’s shutdown tracker confirmed that schools stayed open and basic functions moved forward.

However, several federally supported activities slowed or stalled. Districts relying on the Department of Education for grant drawdowns, technical assistance, McKinney-Vento homelessness supports, and reimbursement paperwork reported delays. There are documented instances where districts had to use local cash flow or temporarily pause certain activities while waiting for federal processes to restart.

Taken together, these patterns suggest that while K–12 schools can maintain short-term stability during a shutdown, the programs that depend on federal funding, guidance, or renewal cycles are more sensitive to interruptions. Vulnerable student groups, particularly those served by McKinney-Vento or specialized grant programs, experience the impact first. The shutdown ultimately provided a clearer view of which parts of the system function independently and which rely heavily on federal infrastructure, timelines, or staffing.

Implications for Special Education If Federal Oversight Shifts

As discussions about reorganizing federal education functions continue, one of the most closely watched areas is special education. IDEA is uniquely dependent on federal oversight, data systems, and technical assistance, so even small structural changes can create outsized ripple effects for states and districts. The following themes reflect what current reporting and advocacy groups are watching most closely.

OSEP’s Changing Role and Capacity

K–12 noted that the Office of Special Education Programs and the Office of Special Education and Rehabilitative Services are experiencing staffing shifts, open positions, and organizational uncertainty. These changes come at a time when districts are already seeking clarity about future federal monitoring.

Disability organizations have emphasized that IDEA implementation benefits from keeping oversight within a single, specialized department, and they continue urging the administration to maintain a centralized structure. For now, however, officials have not confirmed what OSEP’s final role will be within a reorganized federal landscape. That ambiguity is shaping how states plan for the year ahead.

Oversight, Data, and Accountability for IDEA

Because IDEA compliance relies on dedicated federal systems, any realignment could affect how information flows between states and Washington. There are several scenarios under consideration, including moving certain monitoring, enforcement, or civil rights responsibilities to the Department of Justice or the Department of Health and Human Services.

These possibilities raise practical questions. IDEA Part B data collections, EDFacts submissions, and state determinations operate on well-established timetables. If these systems are shifted or re-bid under a different agency, states may face new expectations at a time when many are already managing tight budgets. Families and advocates also worry that breaking apart oversight could lead to inconsistent guidance or blurred communication channels.

Early Childhood Special Education and Head Start

Early childhood is another area where timing matters. Reporting on the recent shutdown illustrated how sensitive early childhood programs are to federal delays. When grant renewals stalled, some Head Start centers temporarily reduced hours or closed, interrupting services for families.

Because IDEA Part C and 619 depend on coordinated referrals and early intervention timelines, even small disruptions can have long-term developmental consequences. If oversight becomes spread across multiple agencies, leaders caution that early childhood programs could face additional administrative steps and more variability in how services start or continue.

What This Could Mean Day-to-Day for District SPED Teams

For districts, the core legal obligations do not change. IDEA, FAPE, timelines, and procedural safeguards still apply regardless of where oversight ultimately sits. What may shift is the day-to-day experience of how districts receive guidance, technical assistance, and compliance expectations.

Teams are watching for concrete answers to questions such as which agency will issue annual state determinations, what dispute resolution processes will look like, and how federally funded technical assistance centers will operate if their grants move under new management.

As states prepare for possible transitions, differences in local capacity may become more pronounced. States with strong internal infrastructure may adapt more easily, while others that rely heavily on OSEP’s assistance could experience more uncertainty during the transition period.

How New Federal Loan Caps Could Affect Teachers and Clinicians

Separate from the federal oversight changes unfolding across K–12 education, the Department of Education has concluded negotiated rulemaking on a major overhaul of graduate student lending. These changes implement loan provisions of the One Big Beautiful Bill Act and reshape how graduate education is financed for future teachers, special educators, and school-based clinicians. Because most school-based professional roles require advanced degrees for licensure, changes to federal borrowing structures have direct implications for the educator and clinician pipeline.

Under the new framework, Grad PLUS loans will be eliminated for new borrowers beginning July 1, 2026, and replaced with capped federal loan limits that distinguish between “professional” and general graduate degrees. Most master’s-level licensure programs in education, special education, and school-based clinical fields would fall outside the professional designation, resulting in lower borrowing caps despite similar training and licensure requirements. Supporters argue the changes reduce excessive debt and federal financial exposure, while critics warn they could restrict access to graduate preparation in fields already facing workforce shortages. A full breakdown of what this means for teachers and clinicians is explored in a separate article linked here.

 

What We Still Don’t Know

Even with multiple announcements, negotiated-rulemaking summaries, agency transfers, and ongoing public statements, several major questions remain unresolved. These uncertainties span legal authority, higher-education rulemaking, special education oversight, and the practical realities of how states will respond.

Legal Questions About Reorganization Authority

There are also unresolved legal questions about the federal government’s authority to shift or scale down programs within the Department of Education without explicit approval from Congress. Several challenges have already emerged, and additional lawsuits are possible as agencies continue to transfer responsibilities and restructure offices. Until courts issue clearer guidance, it remains uncertain how far the administration can go in reassigning or consolidating federally mandated education functions.

Whether the Final Professional Degree Rule Will Be Expanded

Inside Higher Ed and the Department of Education’s own press release confirm that the negotiated rulemaking session has concluded, but the full regulatory text has not yet been released for public comment. This means the definition of “professional degree,” which determines which graduate students receive the higher borrowing cap, could still change. It is not known whether fields currently excluded, such as education, nursing, social work, and allied health, will be added or whether the definition will remain narrow. The final determination will have direct implications for the teacher and clinician pipeline.

How States Will Adjust IDEA Oversight and Workforce Pipelines

With questions still unresolved about where special education monitoring will ultimately reside and how transitions will be managed, it is difficult to predict how states will respond. Some states may build internal capacity to manage oversight responsibilities formerly supported by the federal Office of Special Education Programs. Others may rely heavily on external consultants or regional service agencies. It is equally unclear whether states will expand “grow-your-own” pipelines, offer new tuition support, or continue to operate under constrained budgets that limit workforce development.

Whether Promised Paperwork Reduction Will Materialize

Federal officials have emphasized that one goal of the reorganization and the loan-system overhaul is to reduce unnecessary administrative burden for states, districts, and higher-education institutions. However, whether these reductions will take shape is still unknown. Consolidation can streamline processes, but transitions between agencies often create new layers of documentation in the short term. It remains to be seen whether states, school systems, and colleges actually experience the paperwork relief that has been promised.

Whether States Will Increase Funding or Maintain Current Cuts

Many of the reforms assume that states will invest more heavily in oversight systems, workforce pipelines, and educator preparation. Yet several states have recently reduced budgets for higher education, special education, or support services. It is unclear whether states will reverse course and increase funding, maintain current cuts, or shift resources in ways that strengthen or weaken their ability to adapt to federal changes.

 

Questions for District Leaders, SPED Directors, and Clinicians to Consider

As federal and state policies continue to shift, local leaders will need to evaluate how these changes intersect with staffing, budgets, early childhood services, and long-term planning. The landscape is still evolving, but the following questions can help guide strategic conversations.

What updated guidance is coming from the state?

Because states are interpreting and implementing changes at different speeds, district teams will need to track new memos, compliance reminders, and interim instructions from state education agencies. This includes updates on IDEA monitoring, data reporting requirements, early childhood funding streams, and any changes tied to reorganized federal programs. Staying connected with state-level webinars, office hours, and technical-assistance networks will help districts respond proactively rather than reactively.

How are federal early childhood program changes impacting families?

Head Start, early intervention (Part C), and preschool special education (619) remain especially sensitive to disruptions in federal timelines. Delayed grants or shifted oversight can ripple into reduced hours, paused enrollments, or slower referral pathways for families. District leaders and early childhood coordinators may want to monitor how local providers are coping, whether waitlists are growing, and how transitions into preschool special education are being affected.

Will loan changes affect educator and clinician recruitment?

Graduate-level loan caps may influence who enters or completes programs in teaching, special education, speech-language pathology, occupational therapy, physical therapy, school psychology, and social work. Districts facing persistent shortages may want to assess whether loan-limit changes could shrink applicant pools or make certain specialties harder to fill. This may also be a moment to evaluate tuition-support partnerships, onboarding incentives, or grow-your-own initiatives that help reduce financial barriers for prospective hires.

What local partnerships can buffer instability?

In periods of policy transition, strong local partnerships can help maintain continuity for students and families. Districts may benefit from strengthening relationships with regional service agencies, higher-education institutions, community mental-health providers, early childhood organizations, and family-support networks. These partnerships can offer shared resources, pooled staffing solutions, and additional stability when federal and state systems are in flux.

Are we monitoring state-level budget decisions, not just federal headlines?

Many of the most immediate impacts on districts will stem from state budget choices, not federal announcements. Shifts in state appropriations for early childhood, special education funding formulas, educator preparation programs, and mental-health services can shape district capacity just as much as federal reorganizations. Leaders may need to track legislative sessions, governor’s budget proposals, and potential cuts or reinvestments that affect staffing, services, and compliance obligations.

 

Navigating the Emotional Impact of Headlines

Alongside shifting policies and rapid announcements, the education community is also facing the emotional weight of headlines that often move faster than the actual story. Across media outlets and political perspectives, coverage tends to prioritize speed and attention over nuance. Headlines are written to capture clicks, not to reflect the slow and detailed nature of state and federal decision-making. For people who work in education or school-based clinical fields, roles that require deep emotional investment, these headlines can feel personal.

When stories highlight cuts, layoffs, or reductions to programs that support children, families, or vulnerable populations, it is understandable to have an immediate and strong reaction. Educators, clinicians, and early childhood professionals often choose their fields because of their commitment to care and service. Seeing those areas presented publicly as targets for reduction can be discouraging, even when the policy details are more limited or still in development.

This emotional response also appears in the debate over professional degree classifications. When degrees held largely by teachers, nurses, social workers, and allied-health practitioners are categorized as non-professional, the language alone can feel devaluing. These fields are often dominated by women and centered on nurturing work, and labels that seem to diminish their status can feel demoralizing, regardless of the technical policy intention.

For mental well-being, it may help to pause and recognize the gap between early announcements and actual implementation. Over the past year, public communication has often outpaced operational change. Agencies have announced program transfers before systems were ready, proposed rules before full details were available, and timelines before processes were finalized. Headlines have amplified these early signals more than the slower and quieter updates that follow.

Focusing on what has truly changed, and what is still in draft, transition, or litigation, can provide clarity. This approach may not remove the emotional impact entirely, but it can help ground reactions in fact rather than in the urgency of fast-moving stories. The landscape is still evolving, and even after a year of announcements, many of the most dramatic headlines have not translated into day-to-day shifts in schools or services. Holding both truths at once, the emotional weight and the factual reality, can help leaders, educators, and clinicians move through this moment with steadiness and perspective.