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How interagency agreements are reshaping the Department of Education’s role

Education shifts program management to other agencies, raising oversight and investor concerns

The U.S. Department of Education has moved management of several key programs to other federal agencies through a series of interagency agreements. Those agreements assign daily administration to the State Department, the Department of Health and Human Services (HHS) and the Department of Labor, while Education often retains a coordinating role.

Officials who support the transfers say the changes will streamline service delivery and place programs under agencies with relevant technical expertise.

Critics argue the approach risks fragmenting authority, creating additional bureaucratic layers and exposing programs to new legal challenges.

From an ESG perspective, the reassignments could affect program continuity and stakeholder accountability. Sustainability is a business case when policy stability matters to investors and service providers, and sudden administrative shifts can complicate long-term planning for both public and private partners.

The moves also pose operational questions for interested investors and civic actors. Who will hold final responsibility for compliance, procurement and performance measurement? How will interagency oversight affect the speed and cost of program delivery?

Leading companies have understood that consistent regulatory structures reduce execution risk. Market participants tracking federal program funding and contracts should monitor which agency issues solicitations and sets compliance standards under each agreement.

This article opens a series examining the scope of the transfers, the legal and fiscal implications, and practical steps for stakeholders to adapt to the new administrative landscape.

Education officials say the recent moves have largely been administrative and temporary. Many transfers involve functions and budgets rather than permanent reassignments of staff. Previously, the department detailed more than a dozen employees to another agency and issued layoff notices to hundreds during disputes over federal funding. Those steps prompted union objections and prompted litigation. The shifts have intensified debate about which agency will exercise long-term control over significant education funds and program oversight.

What programs are moving and why officials say it helps

The department has shifted management of rules enforcement, grant administration, and technical assistance for several programs to other federal entities. Officials describe the changes as a way to streamline operations and reduce duplication of effort. They argue that moving program management to agencies with existing infrastructure can accelerate implementation and improve service delivery.

Critics counter that transferring responsibilities between agencies may fragment accountability for program outcomes. From a fiscal perspective, observers note potential complications in budget execution and reporting. Legal experts have flagged questions about statutory authority and the need for clear memoranda of understanding to define responsibilities.

For stakeholders, the practical effects vary by program. States and grantees may see new points of contact, altered application procedures, or changes in compliance monitoring. Education providers could face short-term administrative burdens as systems and records are realigned.

From an operational standpoint, officials say safeguards are planned to maintain continuity of services. Those safeguards include transitional staffing arrangements, shared data protocols, and phase-in timelines. Implementation details remain subject to interagency agreements and possible judicial review.

Investors and market observers interested in education-related financial flows should track which agency receives final spending authority. That allocation will influence contracting opportunities, funding predictability, and compliance risk for private partners.

State department to oversee foreign funding reports for colleges

Federal agreements assign the State Department assistance with oversight of foreign gift and contract reporting for colleges and universities. The function is congressionally mandated under the 1965 Higher Education Act.

Officials say the department will ensure reported data are accessible to national security experts and provide diplomatic channels for interpreting overseas funding. The move reflects the department’s existing international networks and liaison capabilities.

The shift follows administrative transfers of functions and budgets among agencies. That allocation will influence contracting opportunities, funding predictability, and compliance risk for private partners.

From an ESG perspective, the reassignment could prompt universities and vendors to strengthen due diligence and transparency practices. Sustainability is a business case when reputational and regulatory risks affect access to capital and partnerships.

Universities will face new operational requirements, including faster information sharing with federal national security units and clearer ties to diplomatic inquiries. Private contractors should anticipate increased scrutiny of foreign-sourced funds and tighter reporting timelines.

Leading companies have understood that integrating compliance into procurement and grant management reduces disruption. Practical steps include revising contract clauses, updating internal controls, and mapping foreign funding across scope 1-2-3 risk frameworks.

Federal officials declined to release implementation timelines but said the State Department will coordinate with education agencies and university compliance offices. Observers expect detailed guidance and interagency protocols to follow.

Observers expect detailed guidance and interagency protocols to follow. The department has partnered with HHS to manage programs addressing school safety, mental health, and family engagement.

Those programs cover emergency response to traumatic events, community school models and family engagement centers. Education officials say HHS brings decades of disaster response and public health experience that could strengthen crisis preparedness and student well‑being interventions in schools.

Concerns from advocates, unions and lawmakers

Advocates, teacher unions and several lawmakers warned the partnership could expand federal influence in local education decisions. They expressed particular concern about student privacy, data sharing and the scope of medical or behavioral interventions in schools.

Unions argued that expanding crisis and mental health programs without parallel investment in school staff would increase workloads for teachers and counselors. Labor representatives said implementation must protect collective bargaining rights and staffing ratios.

Advocacy groups also warned about potential resource diversion. They said funds and attention devoted to new federal programs could reduce spending on classroom instruction and support services that directly affect learning outcomes.

Some lawmakers questioned whether public health frameworks are the optimal model for school safety. They asked for clear limits on federal authority, transparent data safeguards and measurable outcomes before programs scale up.

From an ESG perspective, proponents point to potential benefits. HHS involvement could standardize response protocols and integrate public health metrics into school planning. Sustainability is a business case for resilient school systems, and leading organizations have understood that cross‑sector coordination can reduce long‑term costs and risks.

Implementation experts urged concrete operational steps: defined data governance policies, independent oversight, dedicated funding for school personnel, and phased rollouts tied to evaluation metrics such as reduced response times and improved student wellness indicators.

Federal officials said they would consult stakeholders as guidance is drafted. Observers expect the agencies to release detailed protocols and funding rules in subsequent guidance documents.

Concerns rise over interagency transfers and program effectiveness

Federal unions, education advocates and many school leaders warned that recent interagency transfers could create confusion for grant recipients. They said the moves risk duplicating work and increasing administrative costs for local grantees. Observers expect agencies to publish detailed protocols and funding rules in follow-up guidance.

The American Federation of Government Employees argued that shifting responsibilities to agencies without specific educational expertise would undermine program effectiveness. The union also said the transfers could represent an unlawful attempt to erode the Department of Education’s statutory mission.

Members of Congress have repeatedly debated appropriations language meant to limit the use of interagency agreements as a mechanism to strip authority from the department. Those debates underscore continuing legislative concern about accountability and statutory responsibility.

From an ESG perspective, stakeholders flagged governance risks tied to fragmented program management. Leading companies have understood that clear lines of authority reduce operational risk; public programs may require the same discipline.

Officials supporting the transfers say they enable cross-agency coordination on issues such as school safety and mental health. Critics counter that coordination should not replace domain-specific expertise or add costs for school districts already managing tight budgets.

Guidance documents now expected from the agencies will be critical to resolving disputes over roles, compliance and funding flows. Analysts said those documents will determine whether the transfers streamline services or impose new burdens on grantees.

Analysts said those documents will determine whether the transfers streamline services or impose new burdens on grantees. Local districts and nonprofit grantees described immediate, measurable disruptions following the shifts.

Grantees reported funding cancellations and difficulty accessing replacement grants. Staff layoffs followed, reducing capacity for family outreach and school-based social supports. When funding tied to programs such as Full-Service Community Schools or educational media was cut or reassigned, districts sometimes lost the ability to retain social workers, parent engagement staff, and afterschool coordinators. Those roles have documented effects on attendance and student supports.

Legal and fiscal implications

Legal counsel for several districts said transfers raise questions about grant terms and compliance. Agencies must clarify whether previously obligated funds remain available and how reporting requirements will change. Uncertainty has delayed spending decisions and complicated audits for some grantees.

From a fiscal perspective, shortfalls have forced program reductions and reallocation of local funds. Smaller nonprofits reported cash-flow stress that limited their ability to apply quickly for alternative funding. Municipal budget officers warned that one-time replacements do not compensate for the loss of multi-year commitments tied to staffing.

From an ESG perspective, funding stability is a governance issue that affects service continuity. Sustainability is a business case when interruptions to social programs produce measurable downstream costs, including higher absenteeism and increased demand for crisis services. Leading companies have understood that predictable funding and clear accountability frameworks reduce operational risk for partners and beneficiaries.

Practical remedies cited by stakeholders include clearer transition guidance from federal agencies, bridge funding for grantees during administrative transfers, and multi-year grant structures that protect staffing lines. Observers said adoption of established reporting frameworks could help align fiscal transparency with program outcomes.

Officials and grantees now await the publication of guidance documents. Those documents will influence whether affected programs recover, adjust, or contract further.

Court challenges and oversight questions have emerged over whether interagency transfers exceed departmental authority and harm beneficiaries. Plaintiffs and judges are scrutinizing both personnel moves made during funding disputes and the substance of agreements that shift program administration into unfamiliar bureaucratic territory. Congressional appropriators have warned these changes could produce inefficiencies and higher administrative costs. Some lawmakers nevertheless declined to add binding prohibitions to recent funding bills.

Operational complexity for states and schools

States and local school systems report immediate operational strain as responsibilities move across agencies. New reporting lines require rewritten memoranda, revised grant terms and additional training for staff. Many districts face duplicated processes and incompatible data systems that slow payments and complicate budgeting. That can reduce service continuity for the students and families the programs serve.

From an ESG perspective, governance and accountability risks are rising. Sustainability is a business case for resilient service delivery; weak coordination undermines institutional stewardship and stakeholder trust. Leading companies have understood that clear roles, standardized agreements and transparent performance metrics reduce transition risk.

Practical steps suggested by administrators include centralized transition offices, standardized memoranda of understanding, phased handovers and mandated interoperability standards for data systems. Enhanced monitoring and contingency funding can protect beneficiaries during change. States and districts are preparing contingency plans while litigants and courts resolve the scope of the transfers.

States and districts are preparing contingency plans while litigants and courts resolve the scope of the transfers. Routine interactions now often require contact with multiple federal partners, increasing administrative complexity for local officials.

What to watch next

Watch for updates to federal guidance that clarify grant rules and reporting responsibilities. Clear guidance could reduce confusion; ambiguous guidance will prolong uncertainty.

Monitor the Education Department–Labor portal for expanded functionality and consolidated reporting. The portal aims to reduce duplicative queries, but its rollout pace and usability will determine whether it eases or complicates compliance.

Pay attention to how agencies designate points of contact and case-management protocols. Multiple contacts without unified case records will raise transaction costs for smaller districts and community organizations.

Track congressional oversight and further litigation. Court rulings or congressional directives could narrow or affirm the transfers and affect funding stability for vulnerable recipients.

Expect administrative churn to disproportionately affect entities with limited grant-management capacity. Contingency planning, cross-agency memoranda of understanding, and streamlined portals are practical steps that could mitigate disruption.

Key developments to watch as federal transfers proceed

Federal education officials, courts and lawmakers will shape whether personnel shifts become permanent. Key actions include whether the Department of Education initiates permanent staff transfers, how courts rule on consolidated lawsuits challenging layoffs and interagency agreements, and whether Congress adopts more prescriptive measures during upcoming appropriations cycles.

These decisions will directly affect schools, grantees and state administrators. At stake is whether interagency transfers yield measurable improvements in service delivery or function as a de facto reduction of a cabinet-level agency without formal legislative change. Stakeholders will weigh claimed efficiencies against potential risks to accountability and program integrity.

Practical governance steps remain central. Contingency planning, cross-agency memoranda of understanding and consolidated portals can reduce disruption. From an ESG perspective, transparency on staff roles, performance metrics and reporting lines will be essential to preserve public trust.

Policymakers and program managers will monitor near-term indicators: court rulings that clarify legal authority, the scope of any permanent reassignments, and whether appropriations language introduces binding constraints. These developments will determine whether operational gains materialize or whether oversight gaps create new vulnerabilities for federal education programs.

The outcome will depend on agencies’ ability to align on data systems, grant management and technical assistance. Coordination will determine whether affected communities sustain uninterrupted support for students during the transition.

From an ESG perspective, continuity of services is also a risk-management issue for public-sector stakeholders. Leading companies have understood that clear governance and measurable metrics reduce operational fragility; similar practices can limit disruption in federal program delivery. Sustainability is a business case when continuity preserves human capital and reduces long-term remediation costs.

The interagency approach remains a live experiment in federal administration. Implementation milestones and active oversight mechanisms will reveal whether operational gains materialize or create new vulnerabilities. Expect scrutiny from courts, funders and service providers as those mechanisms are tested and refined.

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