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How does the Department of Education’s 2025 delisting process compare to previous years’ actions?

Checked on November 21, 2025
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Executive summary

The 2025 delisting — a series of interagency agreements that move core Education Department program offices to Labor, Interior, State and HHS — represents a much broader, faster effort to strip functions out of the department than recent years’ actions, and administration officials frame it as efficiency while critics call it an illegal dismantling of the agency [1] [2] [3]. Reporting ties the moves to Project 2025’s blueprint and an earlier March executive order, and notes legal and practical questions about moving congressionally located offices without lawmakers’ approval [4] [5] [3].

1. What’s new in 2025: an organized “sell-off” of program offices

In November 2025 the Education Department announced interagency agreements to shift elementary and secondary and postsecondary education offices mainly to the Labor Department, Indian Education to Interior, international education to State and several program offices to HHS — a concentrated, coordinated move that administration spokespeople call a “soft launch” of reassignments and that officials say will be implemented over months [1] [2] [6].

2. How this differs from prior years: scale and explicit ties to Project 2025

Previous downsizings and policy shifts at Education typically meant budget cuts, regulatory rollback or reorganizations inside the agency; 2025 differs because multiple major program offices are being placed under other departments at once, and reporters link the specific configuration to Project 2025, the Heritage Foundation blueprint, whose authors now hold policy roles inside the department [4] [1].

3. Administration rationale vs. critics’ framing

The administration and Secretary Linda McMahon describe the changes as “efficiency” and a step toward returning control to states and streamlining services; critics — including Democratic lawmakers and education equity groups — call it a deliberate effort to dismantle or “sell off” the department that will weaken programs and harm vulnerable students [2] [7] [8].

4. Legal and congressional questions raised

Multiple outlets report that opponents say Congress explicitly located some offices inside the Education Department and that the White House cannot unilaterally relocate them; legal scholars and senators have questioned the administration’s authority to effect these transfers without congressional action [3] [1].

5. Practical risks flagged by reporting

Journalists and advocates warn that moving programs to agencies with different missions (e.g., Title I programs to Labor) could create confusion, weaken accountability and disrupt services such as reading programs and school-family partnerships that the Education Department currently administers [1] [8] [6].

6. Continuities with earlier 2025 moves: executive orders and staff changes

The delisting follows an executive order in March 2025 that began shifting functions and mandated programmatic changes (including conditions tied to diversity and inclusion in some accounts), and follows months of staffing changes and layoffs earlier in the year — a sequence that critics say signals an intentional campaign to hollow out the department [5] [9].

7. How quickly this is being pushed and what implementation looks like

Reporting describes the November announcements as the start of a “monthslong” implementation process involving multiple interagency agreements; officials say some staff have already been reassigned and more transfers and agreements are expected [1] [2].

8. Divergent stakes: higher ed, K‑12, and special education

Coverage highlights varied consequences: higher education oversight and K‑12 grant administration are being reassigned, while special education offices that recently suffered mass workforce reductions remain a focus of concern about capacity to manage statutory responsibilities [4] [9].

9. Political context and agendas at play

Reporting explicitly connects the plan to a political objective long-held by some conservatives to shrink or eliminate the department, pointing to Project 2025 and the Trump campaign commitment to close or repurpose Education — motives that shape both the administration’s public framing and its critics’ alarm [4] [5] [1].

10. What to watch next

Follow whether Congress sues or passes restraining legislation, whether transferred programs actually function under their new departmental homes, and whether legal challenges over offices “located” by statute proceed; current reporting notes both imminent implementation steps and explicit plans by opponents to contest the moves [3] [1] [6].

Limitations: available sources are contemporary news reports and advocacy statements about the November 2025 actions and link them to prior executive steps and Project 2025, but they do not yet include full legal filings, detailed implementation plans, or outcomes from Congress’ response — those items are not found in current reporting [3] [2] [4].

Want to dive deeper?
What specific criteria did the Department of Education use for delisting in 2025 versus prior years?
Which institutions were delisted in 2025 and how do their profiles compare to earlier delistings?
How did the 2025 delisting process affect federal student aid eligibility compared to past actions?
Were there changes in legal standards, guidance, or due-process protections for delisted schools in 2025?
How did stakeholder reactions (schools, advocates, states, Congress) to the 2025 delistings differ from previous years?