Grassroots Action Center

On March 20, President Trump issued an executive order initiating a process to dismantle the U.S. Department of Education, advancing a long-standing policy goal but creating uncertainty for the nation's public education system, student borrowers, families, and providers. 

The directive instructed the Education Secretary to initiate department closure procedures and transfer authority to individual states while simultaneously maintaining continuity of essential educational services and programs that serve the American public.  

Though such a significant change would require congressional action and face numerous hurdles, counselors, students, and educational institutions should understand the potential implications of such a structural reorganization. 

Functions of the Department of Education  

The Department of Education, established in 1980 as a cabinet-level agency, has served as the federal government's primary entity for education policy and administration. With approximately 4,400 employees and an annual budget of around $70 billion, the department fulfills several key functions: 

• administers the federal student loan program (over $1.7 trillion in outstanding loans)
• ensures equal access to education through the Office for Civil Rights
• gathers comprehensive education statistics through the National Center for Education Statistics
• collaborates with states on educational standards implementation
• administers the Individuals with Disabilities Education Act (IDEA)
• supports education for homeless children and youth
• provides resources for rural and lower-income communities

NBCC’s analysis reveals potential ripple effects of the Department of Education's closure, beginning with significant restructuring, which may impact your practice, students, and the counseling profession. 

Implications for School Counselors 

Federal Guidance and Standards 

• School counselors may experience shifts in federal guidance regarding best practices and legal compliance.
  • The challenge would be maintaining consistent standards across states if federal coordination diminishes, particularly for trauma-informed practices.
  • Crisis response protocols in educational settings have been developed with Department of Education guidance; counselors should proactively engage with schools to ensure these protocols remain intact. 
     

Individuals with Disabilities Education Act (IDEA) Implementation 

• School counselors would continue to have legal obligations to provide services under IDEA, regardless of which agency oversees compliance.
  • IDEA services involving school counselors include Individualized Education Programs (IEPs), counseling services, transition planning, and early intervention.
  • If the Department were eliminated, IDEA oversight would likely transfer to the Department of Health and Human Services (HHS), potentially changing implementation guidance. 
     

Documentation and Advocacy 

• School-based mental health professionals should continue documenting the effectiveness of their interventions thoroughly during any transition period.
  • This documentation is particularly important for services to twice-exceptional students, who need both academic and mental health support.
  • The Department of Education coordinates data systems tracking mental health workforce needs in schools; fragmentation could affect resource allocation.
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Implications for Counselor Educators 

Accreditation Considerations 

• The Department of Education currently recognizes accrediting bodies that evaluate counseling programs.
  • This function would need to be preserved through transfer to another federal agency, an independent commission, or increased state-level oversight.
  • Maintaining clear accreditation standards is essential for ensuring licensure eligibility and professional mobility for graduates. 
     

Workforce Development Programs 

• The Graduate Assistance in Areas of National Need program has been vital for addressing shortages of PhD-level counselor educators.
  • Without dedicated education oversight, these targeted programs may be deprioritized.
  • The Department of Education and the National Institute of Mental Health (NIMH) collaboration has been crucial for translating mental health research into educational settings. 
     

Student Financial Aid Impacts 

• Federal student loans would continue, potentially under Small Business Administration (SBA) management.
  • Existing loan agreements would remain legally binding, and repayment programs would continue.
  • Public Service Loan Forgiveness would likely persist, though eligibility requirements may change.
  • Counseling programs should prepare for potential disruptions in student financial aid processing during the transition
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Implications for Students 

Financial Aid Access and Processing 

• Student loans would continue to exist, though potentially under SBA management.
  • The FAFSA process would remain but may undergo modifications that could affect application timing and requirements.
  • During the transition period, students may experience delays in financial aid processing, verification, and customer service.
  • Students should keep personal copies of all financial aid documentation and communication during this transition. 
     

IDEA Services and Accommodations 

• Students with disabilities would maintain their rights under IDEA, as the law exists independently of the Department of Education.
  • Interpretation and implementation guidance will likely shift to HHS.
  • Students transitioning between education levels may face additional challenges navigating changing oversight structures. 
     

Mental Health Service Access 

• Students accessing mental health services through educational institutions may experience changes in service delivery models.
  • Campus-based mental health services that rely on Department of Education grants or guidelines may undergo restructuring.
  • Students from underserved populations who benefit from specialized programs may need to navigate changing eligibility requirements.
  • Continuity of care could be disrupted during transitional periods, particularly for students with complex needs. 
     

Career Development and Loan Forgiveness 

• Students pursuing careers in counseling should monitor potential changes to Public Service Loan Forgiveness eligibility requirements.
  • Those planning to work in high-need areas through federal incentive programs should consider how those programs may be restructured.
  • Students nearing graduation should verify how licensing requirements may interact with changing accreditation oversight.
  • Long-term career planning may need to accommodate shifting federal priorities for mental health workforce development.

Implications for Practicing Counselors  

College Counseling Centers 

• College counseling centers could see changes in how mental health services integrate with disability accommodation requirements.
  • The FAFSA process would likely remain but with potential modifications that may affect students' access to mental health services.
    • Transitioning FAFSA processing to a different agency could create processing backlogs.
    • Students awaiting financial aid verification may experience gaps in health insurance coverage.
    • These insurance gaps could interrupt ongoing mental health treatment and medication access.
    • Campus-based counselors should monitor changes in federal guidance on accommodations and service integration. 
       

Community-Based Practitioners 

• Practitioners may encounter clients with disrupted educational services during any transition period.
  • The current system allows synchronization between education and mental health systems; fragmentation could complicate these interactions.
  • Specialized programs for underserved populations often rely on coordination between education and health departments.
  • Counselors serving vulnerable communities should pay close attention to how coordinated programs may be restructured. 
     

Financial and Record-Keeping Considerations 

• Mental health professionals should maintain their records of loan payments and forgiveness program participation.
  • The transition period could temporarily disrupt loan processing, verification, and customer service.
  • Counselors working with education-based programs should document program effectiveness to justify continued funding.

Advocacy Priorities 

• Contact your member of Congress through our Grassroots Action Center or call the congressional switchboard at (202) 224-3121.
  • Focus on preserving specific programs rather than only departmental structure.
  • Identify programs that directly impact vulnerable populations the most.
  • Document how federal coordination benefits the consistent implementation of mental health services.
  • Document the effectiveness of current programs that rely on federal coordination.

Navigating the Path Forward 

Federal education policy decentralization may cause both immediate and long-term program administration disruptions. Though some states may gain implementation flexibility, many lack sufficient resources to manage these newly transferred responsibilities, effectively creating a potential gap between federal withdrawal and state capacity to assume these functions. 

Though the Department of Education's potential dismantling represents a significant challenge, counselors can navigate this transition through preparation and collective advocacy. Though federal functions will continue under different agencies, maintaining service continuity for vulnerable populations requires vigilance. By leveraging professional networks, documenting effectiveness, and fostering cross-system collaboration, counselors can ensure mental health services remain accessible throughout this transformation. 

NBCC will continue to monitor developments closely and provide updated guidance to counselors as the situation evolves. The coming months will bring greater clarity about specific Department of Education reorganization plans.