Project 2025 and changes at the US Department of Education
Could the US be witnessing a turn away from its long-standing support of special education for students with disabilities?
In 2025, the United States has entered an unprecedented phase in the history of federal education policy. The Heritage Foundation’s Project 2025: Mandate for Leadership—long viewed as a conservative wish list—has begun to materialize in real time. The core education chapter in Project 2025, authored by Lindsey M. Burke, outlined a comprehensive blueprint for dismantling the U.S. Department of Education, decentralizing control of K–12 schooling, and redirecting federal special education funds through flexible, market-oriented mechanisms.
I described the implications of Project 2025 for special education in a post on Special Education Today on 7 November 2024.1 This post reviews what has happened in federal special education policy since that time.
Once dismissed as aspirational rhetoric, Project 2025 has rapidly transformed into an operational roadmap. In early 2025, the administration of President Donald J. Trump initiated sweeping structural changes within ED, implementing major staff reductions and signaling an intent to devolve authority to states and localities. Many of those changes correspond with the recommendations of Project 20205. These developments mark a dramatic departure from the 50-year federal commitment to ensuring equity, accountability, and access for students with disabilities under the Individuals with Disabilities Education Act (IDEA).
The Executive Order to Dismantle the Department of Education
In March 2025, President Trump issued an executive order directing the Department of Education to “close to the maximum extent permitted by law.” Within weeks, nearly half of ED’s workforce was eliminated or reassigned following a Supreme Court decision allowing the administration’s downsizing plan to proceed.
The result has been a hollowing out of the agency’s capacity to provide oversight, monitoring, and technical assistance—especially in critical areas like special education, civil rights compliance, and fiscal accountability. Although Congress alone can formally abolish the Department, the executive branch has made clear its determination to reduce federal involvement to a symbolic presence.
For students with disabilities, this means the very infrastructure built to protect their rights—through programs like the Office of Special Education Programs and the Office of Special Education and Rehabilitative Services—is being systematically dismantled.
From Compliance to “Flexibility”: The Shift to Block Grants
At the heart of Project 2025 is the belief federal education programs should be consolidated and simplified through block grants, giving states and local agencies near-total discretion over spending. In the administration’s FY 2026 budget proposal, most IDEA funding streams were merged into a single “Special Education Support Grant” distributed directly to LEAs, bypassing state-level coordination and oversight.
Proponents argue this model reduces bureaucracy and empowers local decision-making. However, critics note it strips IDEA of its accountability mechanisms—the very features that ensure equitable service delivery, data collection, and due process protections for students with disabilities. Without federal consistency, special education risks devolving into a patchwork of local interpretations, where eligibility, services, and supports depend more on ZIP code than student need.
Funding Portability and the Rise of IDEA “Savings Accounts”
Another core element of Project 2025 is the idea of funding portability—allowing families to take their child’s share of IDEA funding and spend it on private tuition, tutoring, therapies, or specialized programs. Similar to programs in Florida and Arizona, often called “education savings accounts,” the proposal reframes IDEA entitlements as personal financial benefits rather than guaranteed public services.
The appeal of portability is clear: more control for families, greater customization, and potential for innovation. Yet, the per-pupil federal IDEA allocation averages around $1,8002—far below the cost of specialized instruction or related services such as occupational therapy, speech, or behavioral support. For students with significant or complex needs, these funds are grossly inadequate.
In practice, portability risks entrenching inequities. Affluent families may supplement these funds but lower-income families are left without sufficient means to access equivalent services. Districts could also face fiscal instability if funding follows students out of the public system.
Transferring Disability Rights Enforcement to the Department of Justice
One of the most consequential structural changes is the proposal to transfer IDEA and Section 504 oversight from the Department of Education’s OSERS and Office for Civil Rights to the Department of Justice (DOJ). Advocates within Project 2025 frame this as streamlining: consolidating all civil rights enforcement under one agency.
However, this realignment represents a fundamental shift in philosophy. The Department of Justice is primarily a law enforcement agency—it does not house the educational expertise required to monitor compliance, interpret IEP implementation, or evaluate the instructional impact of policy decisions.
As a result, special education enforcement would likely become more reactive—triggered by formal complaints or lawsuits—rather than proactive, preventive, and educationally focused. This shift could delay interventions, reduce guidance to states and districts, and weaken the federal government’s ability to ensure consistent application of IDEA’s procedural safeguards nationwide.
Targeted Cuts to Special Institutions
In addition to systemic restructuring, Project 2025 calls for the gradual elimination of earmarked federal funding for specialized institutions, including the National Technical Institute for the Deaf, the American Printing House for the Blind, and programs associated with Special Olympics.
Although these cuts have not yet been implemented as of fall 2025, they remain active policy goals. The potential consequences are significant. These institutions serve students with low-incidence disabilities—those with sensory impairments or multiple disabilities—for whom individualized support is essential. Removing these targeted funds would dismantle decades of infrastructure built specifically to promote accessibility, academic competence, and workforce readiness.
Consequences for Equity, Accountability, and Civil Rights
The cumulative effect of these changes cannot be overstated. Together, they represent a dramatic shift from federally guaranteed rights to localized discretion.
Equity risks: The shift to block grants and portability will amplify disparities between affluent and under-resourced districts. Families with means can navigate complex choice systems; those without may lose access to the very services IDEA was designed to guarantee.
Erosion of accountability: Without federal monitoring or uniform standards, local compliance will vary dramatically. Students requiring costly supports risk being underfunded or excluded entirely.
Weakened civil rights enforcement: With OSERS downsized and potential jurisdiction transferred to DOJ, specialized educational oversight is waning precisely when IDEA noncompliance complaints are surging.
In short, the Project 2025 proposals that have and are being implemented in the first nine months of the Trump administration dismantle the connective tissue that has bound IDEA’s promise of equity and access to federal oversight. The changes may seem minor in some ways, but they are foundational modifications in other ways.
Beyond Bureaucracy: What’s at Stake
Supporters of Project 2025 argue federal downsizing is long overdue—Washington’s role has become too intrusive and local control will restore efficiency and parental authority. But this framing overlooks what ED was created to do: ensure national consistency in opportunity.
The dismantling of ED threatens to turn back decades of civil rights progress for students with disabilities. For over 50 years, federal law has guaranteed a free appropriate public education to every eligible child. The Department of Education served as both the guarantor and the enforcer of that promise.
If changes in policy and practice at the federal level continue to correspond with Project 2025’s proposals, the nation may soon return to a pre-IDEA landscape. The US may have special education defined by fragmented policies, uneven access, and children with disabilities left to the mercy of local discretion and limited funding.
Conclusion
The events of 2025 make one thing clear: Project 2025 is no longer a theoretical exercise in conservative policymaking—it is a live experiment in deconstructing federal authority over education. The executive order to dismantle the Department of Education, combined with the restructuring of IDEA funding and oversight, signals a shift in how the nation defines its responsibility to students with disabilities.
What was once a coordinated national commitment to access, accountability, and equity now teeters on fragmentation. Whether states and local districts can—or will—uphold the spirit of IDEA in the absence of strong federal leadership remains to be seen.
For millions of students with disabilities, the stakes could not be higher.
Reference
Dans, P., & Groves, S. (Eds.). (2025). Mandate for leadership; The conservative promise Project 2025. Heritage Foundation.
Footnote
Special Education Today also published other examinations of Project 2025 in the Special Education Today newsletter 4(2) published 8 July 2024 and the post Another view on Project 2025 published 23 July 2024,
The $1800 is not predicated on “full funding” of IDEA. Congress originally planned for the federal government to contribute 40% of the extra costs state and local agencies incurred in providing special education, but it hasn’t done so over the 50-year history of US laws.