In October 2025, the U.S. Department of Education executed one of the most consequential reductions-in-force (RIF) in its history—466 positions eliminated, including nearly all staff from the Office of Special Education Programs (OSEP) and Rehabilitation Services Administration (RSA). The Office of Special Education and Rehabilitative Services (OSERS)—the federal backbone for IDEA oversight—was effectively dismantled during a government shutdown.

IDEA Still Exists, but Its Infrastructure Doesn’t

The Individuals with Disabilities Education Act (IDEA) and Section 504 remain fully intact in law. The people and systems that ensure compliance, however, have been gutted. With OSEP and RSA staff gone, the flow of guidance, technical assistance, and enforcement has slowed to a crawl. Civil-rights investigations through the Office for Civil Rights (OCR) are also delayed, leaving schools without timely answers to pressing questions.

But let’s be clear: no reduction-in-force can eliminate IDEA. The law is a federal statute enacted by Congress. It cannot be dismantled by an administrative action, executive order, or agency downsizing. Only Congress can amend or repeal IDEA, and doing so would require full legislative action—hearings, votes, and a presidential signature. What’s happening now is not the end of IDEA; it’s the erosion of the federal infrastructure that helps schools uphold it.

Ripple Effects: From Washington to the Classroom

The immediate fallout is striking:

• Fewer Dear Colleague letters, longer response times, and stalled corrective action plans.
• State agencies forced to fill the void, producing uneven and sometimes conflicting guidance.
• Districts absorbing compliance responsibilities once managed federally.
• Teachers becoming de facto compliance officers—logging every accommodation, service minute, and parent contact while instructional time shrinks.

Yet amid this disruption, one thing has not changed: what goes on in classrooms. Teachers are still teaching, students are still learning, and districts are still obligated to deliver a free appropriate public education (FAPE). The scaffolding around IDEA may have weakened, but the legal duty to serve students with disabilities remains as strong as ever.

What It Looks Like on the Ground

Educators are already feeling the strain:

• Delayed evaluations and expired IEPs.
• Behavior supports (PBIS/MTSS) paused, leading to increased incidents.
• Transition services disrupted as RSA partnerships vanish.
• Funding bottlenecks for IDEA Part B and related service contracts.
• Erosion of inclusion, with more restrictive placements and fewer co-teaching models.

The brunt falls hardest on rural and high-poverty districts, widening existing inequities for students of color and those in under-resourced systems.

Budget Uncertainty, but Some Hope

While the RIF has crippled administrative capacity, it does not automatically defund IDEA. The budget picture for FY2026 remains unsettled, with funding tied up in broader federal negotiations. However, several congressional proposals aim to keep IDEA funding at current levels, ensuring that dollars continue flowing to states even if federal staff are not there to manage oversight.

That’s an important distinction: Congress controls appropriations, and as long as IDEA remains law, states and districts should continue receiving funding—though likely with delays and less guidance on how to use it. The uncertainty lies in timing and implementation, not in the existence of IDEA itself.

Legal and Emotional Fallout

With weakened oversight, due process filings are expected to rise, and teachers—already stretched thin—may find themselves named in hearings. Compliance now depends on individual vigilance: teachers logging every session, administrators conducting internal audits, and parents monitoring timelines more closely than ever.

What Leaders Can Do Now

A ten-point survival plan for special education administrators:

1. Start an evidence log of delays and missing guidance.
2. Identify federal dependencies and find state-level backups.
3. Audit timelines for all IEPs and evaluations.
4. Stabilize services and verify that related service minutes are delivered.
5. Reinforce documentation and communication protocols.
6. Prepare family communication templates for service changes.
7. Reaffirm to staff that FAPE and timelines still apply—federal chaos is no defense for noncompliance.
8. Double-check local discipline and shortened-day procedures.
9. Coordinate with finance for contingency planning.
10. Mobilize advocacy channels—CEC, CASE, NASDSE, and others—to press for federal stabilization.

Holding the Line on IDEA

The message is stark but essential: IDEA endures because Congress wrote it into law. Federal staffing cuts may delay oversight and blur accountability, but they do not erase obligations. Teachers, administrators, and advocates now carry the responsibility of keeping the promise of FAPE alive until Washington restores its capacity.

 “When federal scaffolding thins, it’s the teachers who hold the system together.”