Schools & early intervention

Six reasons why the Department of Education should not be dismantled

On November 18th, the Department of Education (ED) announced new interagency agreements transferring many of the functions of six offices in ED to other federal agencies. Under these agreements, the Department of Labor (DOL) would assume responsibility for administering the majority of K–12 general education programs under the Every Student Succeeds Act (ESSA), including Title I programs. While administration of the Individuals with Disabilities Education Act (IDEA) will remain at ED, AOTA believes it is critical that general education not be separated from special education. K-12 programs should be administered by a department dedicated to student education.

Here are six reasons why we believe ED should remain a unified agency:

1. Education programs work best together

For decades, Congress has intentionally aligned general and special education laws to promote integration and inclusion. Congress has made it clear that general education is not separate or distinct from special education and that the purpose of special education services is to support access to their basic education. Moving general education, K–12 programs to DOL, while special education remains at ED, would fracture this alignment, making it harder to coordinate services and undermine efforts to ensure all students, especially those with disabilities, receive a free and appropriate public education.

2. ED provides essential expertise

Staff at ED have decades of experience administering education programs and understanding how schools and classrooms function. Shifting general education programs to DOL, an agency focused primarily on workforce issues rather than education, would create a steep learning curve and dilute the educational mission of supporting student success.

3. Changes would weaken OT practitioners’ ability to support all students

As mentioned, policymakers and advocates have spent decades working to align federal special and general education laws to create a seamless continuum of services, including occupational therapy, for students, educators, and families. Congress intentionally included the same IDEA-related services in general education laws that define Specialized Instructional Support Personnel (SISP) to make clear that the goal of both laws is to provide students with the support they need to thrive across educational environments. For example, many schools use occupational therapy practitioners to help create inclusive school environments or provide early intervening services under ESSA programs. Splitting the administration of the Office of Elementary and Secondary Education and the Office of Special Education Programs (OSEP) into different agencies threatens the progress made in using related service professionals, such as occupational therapy practitioners, to support all student learning and reduce the need for special education services.

4. Separating offices creates new administrative burdens for states and schools

State and local education agencies manage general and special education programs together because these systems are deeply interconnected. Moving general education programs to the Department of Labor would force states and districts to establish new processes, reporting structures, and compliance relationships with a federal agency with no history of working with schools. This would create delays, confusion, and unnecessary administrative burdens—pulling time and resources away from students.

5. Dismantling ED creates uncertainty for schools and families

School systems operate on long planning cycles, with staffing, budgeting, curricula, and compliance frameworks designed around the Department of Education. Shifting K–12 and ESSA programs to DOL would create significant uncertainty as states and districts navigate new rules, new agency contacts, and new interpretations of long-standing laws. This instability diverts schools from their core mission and ultimately disrupts support for students, educators, and families.

6. Accountability would be weakened, risking decades of progress

For decades, ED has ensured that states meet minimum education standards set by Congress so every student, including students with disabilities, can access a high-quality public education. Splitting responsibility for oversight of these standards between two agencies would weaken accountability and make it harder to enforce the civil rights protections Congress intended. In addition to being a bureaucratic headache for agencies and schools, it threatens the hard-won progress that moved our country from excluding students with disabilities entirely to building systems that identify needs early, support struggling learners, and foster student success and independence into adulthood. While education should be left to state and local communities, the federal government cannot abdicate its role in protecting all students. Such an abdication would undermine ED’s vital role, reversing years, even decades, of that progress.

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