The Evidence on Restructuring: How the Plan to Dissolve the Education Department Shifts K-12 to Labor
The administration has initiated the transfer of major K-12 and higher education programs to the Department of Labor using interagency agreements. The move aims to align schooling with workforce development, though logistical and legal challenges remain.
By Factlen Editorial Team
- Public Education Advocates
- Warn that dismantling the agency harms vulnerable students and removes specialized oversight.
- Devolution Advocates
- Argue that education is a state right and federal bureaucracy is redundant.
- Administrative & Legal Observers
- Focus on the logistical hurdles of grant migration and the constitutionality of bypassing Congress.
What's not represented
- · Local school district superintendents tasked with navigating the new multi-agency compliance landscape.
- · University financial aid officers managing the transition to Treasury and Labor systems.
Why this matters
This restructuring fundamentally changes how local schools and universities receive federal funding and oversight. By moving education programs to the Labor, Justice, and Health departments, the federal government is shifting its focus from specialized academic support to workforce preparation and legal compliance.
Key points
- The administration is using interagency agreements to transfer over 100 education programs to other cabinet agencies.
- K-12 and higher education management is shifting to the Department of Labor to align schooling with workforce readiness.
- Special education is moving to Health and Human Services, while civil rights enforcement shifts to the Justice Department.
- Critics argue the move is an illegal executive overreach designed to bypass Congress's authority to close cabinet agencies.
- State education agencies face significant technical hurdles in migrating complex formula grants to new federal payment systems.
The federal government has initiated the most sweeping reorganization of American education policy since the establishment of the U.S. Department of Education in 1979. Utilizing a series of newly signed interagency agreements, the administration is actively transferring the core functions, personnel, and grant-making authority of the education department to other cabinet-level agencies.[2]
This maneuver effectively reassigns the management of the nation's primary K-12 and higher education funding streams to agencies historically focused on entirely different mandates. For local school districts, universities, and families, this transition marks a fundamental shift in how the federal government interacts with local education systems, moving away from specialized educational oversight toward a decentralized model.[3]
The sheer scale of the reorganization involves moving over 100 distinct programs and tens of billions of dollars in formula grants across the federal bureaucracy. The centerpiece of this ambitious restructuring involves shifting both the Office of Elementary and Secondary Education and the Office of Postsecondary Education directly into the Department of Labor.
By moving these massive divisions, the administration is placing the bulk of federal education funding under the umbrella of an agency primarily tasked with workforce development, labor statistics, and worker protection. Staff in the Higher Education Programs division have already begun transitioning to Labor Department offices, marking the physical and administrative beginning of the end for the standalone education department.[1]

The primary rationale for moving K-12 and postsecondary programs to the Department of Labor is to structurally align American schooling with workforce readiness and state-level economic demands. Proponents of the restructuring, including the American Legislative Exchange Council, argue that housing education within the Labor Department eliminates the bureaucratic silo between classroom learning and employment.[2]
By integrating grant management under a single workforce-oriented umbrella, the administration asserts that states will experience reduced federal micromanagement, allowing them to tailor education to local industry needs. This devolution of power is designed to empower local districts and state legislatures to design educational pathways that lead directly to employment, aiming to close a national skills gap that currently includes hundreds of thousands of unfilled skilled positions.[2]
Administration officials have pointed to recent federal government shutdowns as evidence that local schools can operate seamlessly without day-to-day federal education oversight. During a recent 43-day lapse in federal funding, proponents noted that students continued attending class, teachers received their paychecks, and school buses ran on schedule, arguing this proves the federal education bureaucracy is largely redundant.
Because states and local municipalities provide the vast majority of school funding and control curriculum, graduation requirements, and teacher certification, advocates for the dissolution argue that the federal department merely adds unnecessary compliance burdens without improving student outcomes. However, the logistical execution of this massive transfer presents immediate technical and administrative challenges for state education agencies.[3]
The Office of Elementary and Secondary Education alone oversees major federal funding streams, including $18 billion annually in Title I funds dedicated to high-poverty schools. It also manages specialized support for English learners, homeless youth, and rural school districts. Migrating these complex, highly regulated formula grants to the Department of Labor's Grant Solutions and Payment Management System requires rewiring the financial infrastructure that connects Washington to every school district in the country.[1]
It also manages specialized support for English learners, homeless youth, and rural school districts.
Evidence from earlier, smaller-scale transfers suggests that migrating these complex formula grants to new federal systems is highly disruptive. When career and technical education funds were previously relocated to the Labor Department, the new grant portals did not initially recognize the established bank accounts of state education agencies, resulting in significant funding delays. State superintendents and financial aid administrators have expressed serious concerns about the Labor Department's capacity to absorb and manage these intricate educational grants without interrupting critical services.[1][3]

Beyond the Department of Labor, the administration's restructuring plan disperses other specialized educational functions across the federal government, assigning them to agencies deemed more structurally suited to their specific mandates. Special education programs, including those authorized under the Individuals with Disabilities Education Act, are slated to move to the Department of Health and Human Services.[2]
This shift frames disability support and rehabilitative services primarily as health and human services functions rather than strictly educational ones. Advocates for students with disabilities have voiced deep skepticism about this move, warning that healthcare administrators lack the specific pedagogical expertise required to enforce individualized education programs in classroom settings.[2]
Meanwhile, the critical function of civil rights enforcement in schools is being transferred to the Department of Justice. The Office for Civil Rights has historically been responsible for investigating complaints of discrimination, racial harassment, and Title IX violations regarding sexual misconduct on college campuses. Moving these investigators to the Justice Department aligns civil rights enforcement under the nation's primary legal agency, but critics argue it may change the nature of investigations from educational compliance to a more punitive, litigation-focused approach.[2]
The dispersal of the agency continues with the Office of Indian Education moving to the Interior Department, aligning Native American educational support with the Bureau of Indian Affairs. Additionally, international education and foreign language programs are being reassigned to the State Department, while the Child Care Access Means Parents in Schools program will join special education at Health and Human Services.
The legal mechanism driving this unprecedented reorganization—the use of interagency agreements—has become the subject of intense scrutiny, congressional pushback, and ongoing federal litigation. Because only Congress possesses the constitutional authority to formally abolish a cabinet-level agency, the executive branch is utilizing these agreements to bypass the legislative process. By delegating the administration of programs to other departments, the executive branch is emptying the Department of Education of its personnel and responsibilities without requiring a formal vote.[2]

Plaintiffs in federal court have amended ongoing lawsuits to argue that this strategy represents an illegal executive overreach that directly violates congressional intent. Lawmakers have noted that Congress recently authorized a $79 billion budget specifically for the Department of Education, signaling a clear legislative mandate for the agency to continue its operations as an independent entity. Democratic lawmakers are currently attempting to insert language into upcoming appropriations bills that would explicitly prohibit the department from offloading its statutory duties.[1][2]
Conversely, administration officials maintain that federal statutes permit the executive branch to delegate administrative duties to optimize government efficiency. They argue that the interagency agreements are entirely lawful mechanisms designed to reduce administrative bloat and align federal responsibilities with the agencies best positioned to support them. The Secretary of Education has stated that once these transfers are completed and proven successful, the administration will formally ask Congress to codify the changes.[2]
For the higher education sector, the transition introduces a distinct set of operational anxieties, particularly regarding the management of federal student aid and institutional compliance. While the massive $1.7 trillion student loan portfolio is being shifted to the Treasury Department, the programmatic oversight of universities—including accreditation standards and institutional eligibility for federal funds—will fall to the Department of Labor.[1]
Public education advocates and civil rights organizations warn that removing education programs from the hands of seasoned educational experts and spreading them across agencies with vastly different core missions will dilute specialized oversight. They argue that the Department of Labor's focus on workforce preparation may divert attention from the broader developmental, social-emotional, and civic roles of public education.[3]
As the transition proceeds, schools, universities, and families must navigate a fragmented federal landscape, adapting to new compliance systems, grant portals, and regulatory frameworks managed by agencies that are entirely new to the business of education. While the administration promises that formula funds will continue to flow without programmatic disruptions, the reality of rewiring the federal government's relationship with 13,000 local school districts suggests a turbulent period ahead.[1]
How we got here
1979
The U.S. Department of Education is established as a cabinet-level agency under President Jimmy Carter.
March 2025
An executive order is signed to initiate the elimination of the Department of Education.
November 2025
The administration announces the transfer of K-12 and higher education programs to the Department of Labor.
January 2026
Higher education agency staff begin physically relocating to Department of Labor offices.
June 2026
Special education and civil rights enforcement functions are officially moved to HHS and the Justice Department.
Viewpoints in depth
Devolution Advocates
State lawmakers and administration officials who argue education is a state right and federal bureaucracy is redundant.
This camp, heavily represented by organizations like the American Legislative Exchange Council, argues that the federal Department of Education has historically overstepped its mandate by micromanaging local schools. They point to the fact that states provide the vast majority of education funding and already control curriculum and graduation requirements. By moving federal grant administration to the Department of Labor, they believe states will have greater flexibility to align their educational systems with local workforce needs, eliminating bureaucratic silos that separate schooling from employment.
Public Education Advocates
Teachers' unions and child advocacy groups warning that the restructuring harms vulnerable students.
Organizations such as the National Education Association and First Focus on Children view the dissolution as a direct attack on public education and marginalized students. They argue that dispersing programs across multiple agencies dilutes specialized educational expertise and weakens federal oversight of civil rights and special education. This perspective emphasizes that education serves a broader civic and developmental purpose beyond mere workforce preparation, and warns that the logistical chaos of the transition will inevitably result in delayed funding for high-poverty schools.
Administrative Law Skeptics
Legal experts and lawmakers questioning the constitutionality of using interagency agreements to close a cabinet department.
This viewpoint focuses on the separation of powers, arguing that because Congress created the Department of Education in 1979, only Congress has the authority to abolish it. Skeptics view the administration's use of interagency agreements as an illegal executive overreach designed to bypass the legislative process. They point to the fact that Congress recently authorized a $79 billion budget for the department as evidence of clear legislative intent for the agency to continue its operations, setting the stage for protracted federal litigation.
What we don't know
- Whether Congress will successfully intervene in the upcoming appropriations cycle to block the interagency transfers.
- How long it will take the Department of Labor to fully integrate state education bank accounts into its grant systems.
- Whether federal courts will ultimately rule that using interagency agreements to effectively close a cabinet agency is constitutional.
Key terms
- Interagency Agreement (IAA)
- A written agreement between two federal agencies allowing one to perform services or administer programs on behalf of the other.
- Title I Funding
- A federal education program that provides financial assistance to local educational agencies and schools with high numbers or high percentages of children from low-income families.
- Office of Elementary and Secondary Education (OESE)
- The division within the federal government responsible for directing, coordinating, and formulating policy for K-12 education programs.
- Individuals with Disabilities Education Act (IDEA)
- The federal law that makes available a free appropriate public education to eligible children with disabilities and ensures special education and related services.
Frequently asked
Is the Department of Education officially closed?
Not officially. Only Congress can abolish a cabinet agency, but the administration is using interagency agreements to transfer its staff and programs to other departments, effectively emptying it.
Will my local school lose its federal funding?
No. The administration has stated that formula funds, such as Title I for high-poverty schools, will continue to flow to states, though they will now be administered by the Department of Labor.
What happens to federal student loans?
The massive $1.7 trillion federal student loan portfolio is being transferred to the Department of the Treasury, while the Department of Labor will oversee university accreditation and grant programs.
How will this affect special education (IDEA)?
Special education programs and rehabilitative services are being moved to the Department of Health and Human Services, shifting the focus toward a health and human services model.
Sources
[1]NASFAAAdministrative & Legal Observers
Administration Announces Next Steps to Transfer Higher Ed Programs to DOL
Read on NASFAA →[2]The 19thDevolution Advocates
Administration takes aggressive new steps to shut down the Department of Education
Read on The 19th →[3]First Focus on ChildrenPublic Education Advocates
Dismantling the Department of Education Puts Children at Risk
Read on First Focus on Children →
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