Trump Administration Takes Steps to Dismantle Department of Education: What Higher Education Institutions Should Expect – JD Supra

Report on the Restructuring of the U.S. Department of Education and its Implications for Sustainable Development Goals

Executive Summary

The federal administration has initiated a significant reorganization of national education program administration, transferring key responsibilities from the Department of Education (DoED) to other federal departments via Interagency Agreements (IAAs). This report analyzes these changes through the lens of the United Nations Sustainable Development Goals (SDGs), particularly SDG 4 (Quality Education), SDG 8 (Decent Work and Economic Growth), SDG 5 (Gender Equality), SDG 10 (Reduced Inequalities), and SDG 16 (Peace, Justice, and Strong Institutions).

Interagency Realignment of Education Programs

The DoED has entered into six IAAs with four federal departments, shifting the administration of major educational programs. The stated objectives are to decentralize federal control and refocus education at the state and local levels. The receiving departments are:

• Department of Labor (DOL)
• Department of Health and Human Services (HHS)
• Department of State (DOS)
• Department of the Interior (DOI)

Analysis of Restructuring in the Context of Sustainable Development Goals

SDG 4 (Quality Education) & SDG 10 (Reduced Inequalities)

The administration’s long-term goal of eliminating the DoED and returning authority to the states presents a significant challenge to ensuring equitable and inclusive quality education for all (SDG 4, Target 4.5). A decentralized approach may increase disparities in educational outcomes between states, potentially undermining progress toward SDG 10. Previous actions, including the reduction of staff in the DoED’s Office for Civil Rights (OCR), weaken federal oversight mechanisms designed to enforce non-discrimination laws and guarantee equal educational opportunities.

SDG 8 (Decent Work and Economic Growth)

The transfer of postsecondary education programs to the Department of Labor explicitly links education to national workforce development. This strategic shift aims to address skilled labor shortages and aligns with SDG 8.

• The DoED-DOL Postsecondary Education Partnership will administer grant programs under the Higher Education Act of 1965.
• The DOL’s objective is to integrate these programs with existing workforce development initiatives, directly addressing SDG Target 4.4 (skills for employment) and Target 8.6 (reducing the proportion of youth not in employment, education or training).
• While the DoED retains statutory oversight, the DOL will manage grant competitions and provide technical assistance.

SDG 5 (Gender Equality)

The IAA with the Department of Health and Human Services establishes the Child Care Access Means Parents in School Partnership. This initiative directly impacts SDG 5.

• HHS will now administer grants for on-campus childcare, a critical support service that enables parents, particularly women, to pursue higher education.
• The effectiveness of this program under new administration is vital for achieving SDG Target 5.4, which recognizes the importance of public services and infrastructure in promoting shared responsibility and gender equality.

SDG 16 (Peace, Justice, and Strong Institutions) & SDG 17 (Partnerships for the Goals)

The unilateral nature of this executive branch reorganization raises questions regarding SDG 16, which calls for effective, accountable, and inclusive institutions. The move has been criticized on the grounds that only Congress can dissolve a federal department, and litigation is anticipated to challenge the legality of the IAAs. Furthermore, the IAA with the Department of State, creating the International Education and Foreign Language Studies Partnership, reconfigures a key component of global partnership (SDG 17). By placing the Fulbright-Hays Grant program under DOS administration, the focus shifts to aligning international education with national security and foreign policy, potentially altering its contribution to SDG Target 4.7 (education for sustainable development and global citizenship).

Strategic Recommendations for Higher Education Institutions

In response to this evolving federal landscape, higher education institutions should consider the following strategic actions:

1. Monitor Programmatic Shifts: Institutions must closely track changes to grant terms, program qualifications, oversight structures, and reporting obligations to ensure compliance and continued access to funding.
2. Strengthen State-Level Engagement: As authority devolves to the states, institutions should increase engagement with state education agencies and policymakers to understand and influence shifting funding flows and eligibility criteria in support of SDG 4.
3. Update Internal Compliance Processes: Financial aid, sponsored programs, and student support teams must adapt internal processes to meet the new oversight styles and data requirements of the DOL, HHS, and DOS.
4. Prepare for Litigation-Driven Uncertainty: The potential for legal challenges to the IAAs could lead to policy reversals. Institutions should develop contingency plans and maintain clear documentation to mitigate instability and ensure programmatic continuity.

Sustainable Development Goals (SDGs) Addressed

• SDG 4: Quality Education
• SDG 5: Gender Equality
• SDG 8: Decent Work and Economic Growth
• SDG 10: Reduced Inequalities
• SDG 16: Peace, Justice and Strong Institutions
• SDG 17: Partnerships for the Goals

Specific SDG Targets Identified

SDG 4: Quality Education

• Target 4.3: By 2030, ensure equal access for all women and men to affordable and quality technical, vocational and tertiary education, including university. The article is centered on the administration of postsecondary education programs, grant programs under the Higher Education Act of 1965, and support for parents enrolled in colleges and universities, all of which are directly related to access to tertiary education.
• Target 4.4: By 2030, substantially increase the number of youth and adults who have relevant skills, including technical and vocational skills, for employment, decent jobs and entrepreneurship. The article explicitly states that the partnership with the Department of Labor (DOL) will address a “labor shortage of over 700,000 skilled jobs” and integrate education with workforce development to “ensure Americans are prepared for the jobs of today and the future.” This includes moving responsibility for career and technical education to the DOL.

SDG 5: Gender Equality

• Target 5.4: Recognize and value unpaid care and domestic work through the provision of public services, infrastructure and social protection policies. The “Child Care Access Means Parents in School Partnership” is a social support initiative aimed at improving on-campus childcare. This directly addresses a significant barrier, often disproportionately affecting women, to accessing higher education.

SDG 8: Decent Work and Economic Growth

• Target 8.6: By 2020, substantially reduce the proportion of youth not in employment, education or training. The initiative to move postsecondary education programs to the Department of Labor is designed to “streamline education programs” and “integrate with federal workforce development programs,” directly aiming to connect education with employment outcomes and address labor shortages.

SDG 10: Reduced Inequalities

• Target 10.3: Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies and practices. The article mentions that the Department of Education’s Office for Civil Rights (OCR) “enforces certain nondiscrimination laws aimed at ensuring equal educational opportunities for students.” The firing of many employees in this office raises concerns directly related to the capacity to ensure equal opportunity in education.

SDG 16: Peace, Justice and Strong Institutions

• Target 16.6: Develop effective, accountable and transparent institutions at all levels. The article discusses a “significant unilateral reorganization of the Executive Branch,” the legality of which is expected to be challenged in court. It also highlights changes in “oversight structures, and revised reporting obligations,” which are core components of institutional accountability and effectiveness.

SDG 17: Partnerships for the Goals

• Target 17.14: Enhance policy coherence for sustainable development. The entire plan is built on establishing “six interagency agreements (IAAs)” to link education policy with workforce development (DOL), social support (HHS), and foreign policy (DOS), representing an effort to create policy coherence across different government departments.

Indicators for Measuring Progress

Workforce and Skills Development (SDG 4 & 8)

• Indicator: The article implies a key indicator by mentioning the goal to address the “annual labor shortage of over 700,000 skilled jobs.” Progress could be measured by the reduction in this specific labor shortage figure over time as a result of the new education-workforce partnership.

Access to Education (SDG 4 & 5)

• Indicator: The “Child Care Access Means Parents in School Partnership” implies an indicator related to the number of student-parents who are able to enroll in or complete higher education due to access to on-campus childcare grants administered by HHS.

Equal Opportunity (SDG 10)

• Indicator: The article’s focus on the firing of staff in the Office for Civil Rights (OCR) implies that the capacity of this office, potentially measured by the number of staff or the volume of nondiscrimination cases it can process, is a key indicator for ensuring equal educational opportunities.

Institutional Change (SDG 16 & 17)

• Indicator: The article explicitly states the establishment of “six interagency agreements (IAAs) with four other departments.” The number and scope of these agreements serve as a direct indicator of the implementation of this new partnership-based governance model. It also advises institutions to monitor “revised reporting obligations and processes,” which are measurable changes in institutional practice.

Summary Table of SDGs, Targets, and Indicators

Source: jdsupra.com