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AGB Policy Alert: Department of Education Interagency Transfers

By AGB November 21, 2025 AGB Alerts

This AGB Policy Alert is based on policy developments current as of the date posted. Given the evolving nature of legislative and judicial activity, content may become outdated. For the most recent updates and guidance, please refer to the latest AGB Policy Alerts available at AGB.org/Advocacy/Policy-News.

On November 18, 2025, the U.S. Department of Education (ED) announced a sweeping set of interagency agreements (IAAs) transferring administration of dozens of higher education and student-support programs to the Departments of Labor (DOL), Health and Human Services (HHS), Interior (DOI), and State. ED asserts that it is retaining statutory and policy authority, but it is rapidly shifting program operations, staffing, and fiscal management to outside agencies.

These moves come as part of U.S. Secretary of Education Linda McMahon’s broader initiative to “dismantle” the department through structural fragmentation rather than congressional authorization.

The changes will have immediate implications for institutions, particularly Minority-Serving Institutions (MSIs) and those reliant on programs that affect access to federal funding, student support, and international education.

What Board Members Need to Know

Programs covered by the IAAs include TRIO, GEAR UP, Title III MSI programs, Transition and Postsecondary Programs for Students with Intellectual Disabilities (TPSID), Child Care Access Means Parents in School (CCAMPIS), Fulbright-Hays, Title VI international programs, Tribal Colleges and Universities (TCUs) initiatives, and more. Key details are outlined in the fact sheets accompanying each agreement with ED.

While ED maintains that statutory responsibilities for these programs will remain unchanged, these agreements are expected to impact institutions in the following ways:

  • Increased political and operational uncertainty around programs, including delays in the issuance of grant funding, and consolidation or elimination of funding.
  • Staffing shortages and changes in points of contact.
  • Changing workforce and mission realignments at DOL, HHS, DOI, and State as they assume programs for which they have not historically been responsible.
  • Evolving compliance frameworks based on agency-specific priorities (workforce outcomes at DOL, national security at State, service delivery metrics at HHS).

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Key Program Transfers and Implications for Institutions


ED→Department of Labor Postsecondary Transfer

Programs affected: TRIO (all components), GEAR UP, Title III MSI programs, TPSID, Howard University appropriations, FIPSE, GAANN, community project funding, HEP/CAMP

Board Implications

  • Revenue Concentration Risk: Institutions relying on TRIO, Title III, or GEAR UP face new financial risks, including delays or changes in funding during the transition to DOL’s systems and priorities.
  • Shift to Workforce-Centric Metrics: DOL may integrate labor market outcomes into grant administration. Academic affairs, student success, and compliance units will need to prepare for new alignment.
  • Strategic Differentiation: Institutions with strong employer partnerships and nondegree/workforce pathways may gain competitive advantage under DOL-administered competitions.

 


ED→HHS Child Care Access Means Parents in School (CCAMPIS) Transfer

Programs affected: CCAMPIS campus child care grants

Board Implications

  • Impact on Student-Parent Success: Interruption of CCAMPIS grants could disproportionately affect low-income and first-generation learners.
  • Need for Bridge Funding Planning: Boards should expect scenarios where institutional or philanthropic funds must temporarily sustain child care services.

 


ED→HHS Foreign Medical Accreditation and Health Workforce Programs Transfer

Programs affected: Foreign medical education accreditation processes and related data/regulatory responsibilities

Board Implications

  • International Medical Programs: Institutions partnering with or hosting international medical education pathways may see delays or re-vetting under HHS frameworks.
  • Compliance Adjustments: HHS oversight could mean new reporting and accreditation expectations affecting clinical training pipelines and graduate medical education partnerships.

 


ED→Department of State Transfer of Fulbright-Hays & Title VI International Programs

International and Foreign Language Education (IFLE) programs affected: NRCs, FLAS, LRCs, UISFL, BIE, FRA, DDRA, Seminars Abroad, AORCs, CIBEs

Board Implications

  • National Security Reorientation: State is likely to emphasize geopolitical and security priorities, which may alter funding criteria and program viability for area studies centers.
  • Research and Graduate Program Risk: Institutions with Title VI centers or FLAS fellowships may face increased scrutiny and possible realignment of academic priorities to fit State’s strategic agenda.
  • Institutional Funding Stability: These programs support language instruction, graduate fellowships, and research centers that may require institutional backstopping if federal funding becomes less predictable.

 


ED→Department of Interior Transfer of Tribal and Native-Serving Programs

Programs affected: American Indian/Alaska Native programs, Tribal Colleges and Universities (TCUs), Native education initiatives

Board Implications

  • TCU Funding Pathways: Institutions serving Native communities (including non-TCU partners) may face significant administrative changes under DOI and the Bureau of Indian Education.
  • Cultural Mission Alignment: DOI’s tribal sovereignty mission may produce new expectations for engagement, consultation, and reporting.
  • Grant Administration Complexity: Institutions should prepare for new system integrations and potential delays as DOI absorbs unfamiliar programs.

Key Issues for Governing Boards

These interagency transfers represent the most significant reorganization of federal education functions in decades. They introduce new risks and strategic shifts, as well as opportunities, for institutions.

  1. Institutional Finance and Federal Grant Stability
  • Delays or disruptions in TRIO, GEAR UP, Title III, or CCAMPIS funding could directly affect operating budgets and student support infrastructures. Agencies that will be administering these programs do not necessarily place education as a top priority.
  • Boards must assess new and evolving risks for programs essential to institutional mission.
  1. Academic Strategy and Program Sustainability
  • International education, graduate fellowships, area studies centers, TCUs, and teacher prep pipelines now depend on agencies with different priorities where education programs are not the first or second priority.
  • Boards should request scenario analyses for programs whose access to federal support may change.
  1. Equity and Access Commitments
  • Programs central to supporting low-income, first-generation, parenting, Indigenous, and multilingual learners may be restructured, narrowed, or defunded.
  • Boards must monitor how these changes affect institutional commitments, demographic goals, and mission fulfillment.
  1. New Compliance and Administrative Requirements
  • Each agency shift brings new compliance requirements, including workforce reporting at DOL, service delivery metrics at HHS, geopolitical vetting at State, and sovereignty and consultation protocols at DOI.
  • Boards should expect increased administrative costs and potential need for staffing adjustments.

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Call to Action: Prepare and Advocate

Engage Leadership and Governance Structures
Boards, presidents, and senior leaders should immediately evaluate program-by-program exposure across the newly transferred portfolios. Coordination among academic affairs, finance, government relations, and student success is essential to minimize impacts.

Assess Direct Institutional Impact
Using internal data, institutions should quantify:

  • Reliance on TRIO, Title III, GEAR UP, TPSID, CCAMPIS, Title VI/FLAS, or TCU-related grants.
  • Student populations and retention metrics tied to these programs.
  • Operational dependencies (e.g., campus child care, language instruction, area studies pipelines).

Prepare for Transitional Funding and Program Changes
Boards should consider:

  • Strategies to bridge funding if federal funds are expected to be delayed or disrupted.
  • New strategic investments in programs vital to mission and accreditation.
  • Partnerships or philanthropic support to sustain vulnerable student services.

Communicate with Federal Policymakers
Board members, in alignment with institution leadership, should advocate and share specific impacts with congressional delegations and transition teams at DOL, HHS, State, and DOI.

Points to highlight:

  • Time-sensitive risks (delays in recompeting or renewing grant cycles and delays in grant funding availability).
  • Consequences for regional inclusiveness, workforce development, and economic vitality.
  • The need for continuity and clarity during agency transitions.
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