School districts nationwide are assessing how the dismantling of the U.S. Department of Education (ED), including workforce cuts and interagency agreements (IAAs), could affect school transportation service and funding. While full closure requires full congressional approval, which hadn’t occurred at this publication, a majority of its core duties have been reassigned to other federal agencies.
Civil rights and student privacy functions have moved to the U.S. Department of Justice (DOJ), while special education functions tied to the Individuals with Disabilities Education Act (IDEA) have shifted in part to the Department of Health and Human Services (HHS). Prior to the formation of ED by Congress in 1979, the precursor to IDEA, the Education for All Handicapped Children Act, as well as other federal education initiatives operated within the Department of Health, Education and Welfare.
Rosalyn Vann-Jackson, the chief support services officer for Broken Arrow Public Schools in Oklahoma and NAPT Region 4 director, said the impact is difficult to predict. But it could disrupt continuity of services and increase existing challenges.
Transportation as a related service under IDEA is already severely underfunded, she said, even as the number of students requiring specialized transportation continues to increase locally and nationally while specialized transportation gets expensive.
The IAAs “may cause us to not focus on ramping up that service that is needed in an existing challenge we have in funding,” Vann-Jackson said, adding the same is true of the McKinney-Vento Homeless Assistance Act, which continues to operate within ED.
School transportation is a significant indicator of educational outcomes regarding equity for students, Vann-Jackson noted, adding “attendance is critical for our families in light of the economy and challenges we are experiencing.
While there may be a loss of institutional knowledge, there are opportunities through a new set of eyes and lens to those challenges and a greater opportunity to engage industry experts, Vann-Jackson said.
Industry experts Vann-Jackson cites include School Transportation News’ Transporting Students with Disabilities & Special Needs conference, the National Association for Pupil Transportation, the National School Transportation Association, and the National Association of State Directors of Pupil Transportation Services.
“Many of these organizations have political or organizational advocacy committees tied into legislative efforts at the federal level,” she said, noting the best approach for districts is to stay engaged and diplomatically voice concerns.
Special education attorney Julie Weatherly observed it is difficult to assess the impact moving the Office for Civil Rights (OCR) to the DOJ will have on students with disabilities, given significant staffing reductions as well as the closure of seven OCR regional offices with no specific plans as to how the changes will work.
“While OCR has allowed for significant backlogs in complaint resolution to accumulate over time, my experience working with OCR in the Section 504 complaint process has traditionally involved a more administrative and collaborative approach focused on resolution and remedies for a specific student, rather than the more litigious and broader approach often utilized by DOJ,” said Weatherly, who keynotes next month’s TSD Conference.
She emphasized transportation departments serving students with disabilities may face DOJ investigative procedures examining systemic violations of the Americans with Disabilities Act (ADA) and Section 504 complaints referred by OCR and filed more like a class-action lawsuit.
“DOJ traditionally will ask for all kinds of district-wide information through deposition-style interviews, extensive records, data review requests and on-site visits and observations during its investigations with a much more heavy-handed approach,” she explained. “Transportation departments should conduct internal audits of their practices, policies and procedures regarding transportation of students with disabilities to ensure they are aligned with the nondiscrimination requirements of the ADA and Section 504.”
Departments should be prepared to respond to student and staff safety issues, discipline, appropriate supervision, student and staff-based bullying and harassment, service animal transportation, and the provision of equitable, timely, and appropriate and required accommodations and transportation services to students with disabilities in accordance with their IEPs and 504 plans, she added.
“They also need to ensure documentation of compliant practices, policies and procedures and implementation thereof exists and is ready if ever requested,”
Weatherly said, sharing that legal counsel should be sought to assist in an internal review as well as if an OCR complaint is filed in order to prepare for addressing and responding appropriately to DOJ’s enforcement process.
Glenna Wright-Gallo, a former assistant secretary of the Office of Special Education and Rehabilitation Services at ED and current vice president of strategic research and policy for adaptive technologies provider Everway, noted while the entitlement doesn’t change, the June 2026 IAA moving IDEA Parts B, C, and D operations from ED’s Office of Special Education and Rehabilitation Services (OSERS) to HHS introduces “real friction risk on the administrative side.”
Under the IAA, HHS is supporting specified IDEA administrative functions including grant administration, monitoring-related work, data functions and fund drawdowns, she noted.
“ED retains statutory authority and ultimate responsibility for IDEA oversight, policy and enforcement functions,” Wright-Gallo added. “For districts, that means a new point of contact and a new system learning curve at exactly the point where transportation directors need fast answers on allowable uses, reimbursement timing and compliance questions.”
There is recent precedent for this kind of disruption. The Career and Technical Education and adult education programs Perkins V and Workforce Innovation and Opportunity Act (WIOA) Youth Program Title II moved to the Department of Labor (DOL) in the first pilot IAA in May 2025 and again when Every Student Succeeds Act Title I, Title II-A, and Title IV-A followed in November 2025, Wright-Gallo noted.
“Rural school leaders reported receiving funds roughly two months late because DOL’s grant system did not recognize state education agencies’ existing bank accounts, which was a basic onboarding failure,” she added. “That same category of risk applies to the fiscal year 2027 transition of IDEA grants into HHS’ GrantSolutions and Payment Management System. Fiscal year 2026 awards remain in ED’s G5 system for now, so delays are not imminent.”
She noted three compounding factors raise the odds of delay or confusion, including reduced technical assistance capacity, mixed federal messaging and staffing shortages, including among school bus drivers.
While the legal right to transportation as a related service hasn’t changed, Wright-Gallo said the risk is delay through a slower drawdown of IDEA funds, a teacher’s aide request backlog, or a rocky fiscal year 2027 systems transition. That could push back the purchase of adapted vehicles, hiring and training of aides, or approval of specialized routes tied to a student’s IEP.
Wright-Gallo noted while federal restructuring has changed the operational home of programs, federal staffing, and the movement of grant systems and guidance for some non-students with disabilities, those changes do not alter IDEA, Section 504 or McKinney-Vento requirements.
She noted the McKinney-Vento Education for Homeless Children and Youth (EHCY) program was not transferred by any IAA. A separate proposal to fold it into an 18-program block grant and reduce funding from $6.5 billion to roughly two billion dollars was not adopted during the fiscal year 2026 appropriations process, but it may emerge in fiscal year 2027 negotiations.
The open question is whether the agencies now responsible for grant administration and oversight can maintain the same pace and consistency ED built up over time, particularly during the fiscal year 2027 systems transition, Wright-Gallo noted.
“For transportation and special education staff, that translates into a practical planning task of confirming current federal contacts and grant-system requirements, rather than a change in what students are entitled to,” she added.
Wright-Gallo said states carry independent IDEA monitoring responsibilities regardless of federal restructuring, adding it gives states “a natural role in backstopping any reduction in direct federal oversight, although how well that works in practice depends on each state agency’s staff capacity.”
Addressing where documentation gaps actually occur, Wright-Gallo noted the recurring pattern is information loss at handoff points, not generally due
to gaps in the law itself.
Wright-Gallo said there are six funding streams beyond the standard pupil transportation budget that districts may consistently leave on the table, thus an eligible student may not receive a transportation support for which they
otherwise qualify.
They include state-administered reimbursement for health-related services delivered to Medicaid-eligible students, which requires billing infrastructure most districts haven’t built specifically for transportation.
Others include 21st Century Community Learning Centers, vocational rehabilitation, WIOA Title I, Part A and Impact Aid, Elementary and Secondary Education Act (ESEA) Title VII.
Wright-Gallo suggested districts confirm allowability with the relevant administering entity before obligating funds.
“Administrative oversight for several of these programs has moved to new federal agencies as part of ongoing restructuring at the Department of Education,” she said. “Program eligibility and allowable uses for students have not changed as a result.”
Wright-Gallo noted there are 15 funding sources that can support transportation a district provides to get students to and from school or school-related services and can be used alongside the district’s transportation cost data to identify which streams are already captured and which may be worth exploring for students who currently lack an adequate transportation solution.
They include IDEA Part B Section 611, the McKinneyVento Homeless Assistance Act, the U.S. Environmental Protection EPA Clean School Bus Program, the EPA Diesel Emissions Reduction Act, and the Federal Highway Administration Safe Routes to School/Transportation Alternatives Program.
Others include ESEA Title I Part A, ESEA Title II Part A, ESEA Title IV Part A, 21st Century Community Learning Centers (Title IV-B), Impact Aid (ESEA Title VII), Medicaid School-Based Services, IDEA Travel Training (34 CFR §300.39) / VR / WIOA Youth, state categorical funding, state funding formula inclusion, and state reimbursement of district costs.
Alexandra Robinson, president of A. Robinson Consulting and a former NAPT president, noted the most obvious issue is that HHS focuses on a medical perspective.
“When we are educating and transporting students with disabilities, we want to focus on an educational perspective,” said the TSD Conference Tenured Faculty member. “We’ve been lucky enough to have a team of people at the [ED], in the office of special education programs, whose expertise is education, instructional interventions, and assisting states and local entities with technical assistance.
“This will either not exist in that same way or be extremely lacking. For large urban school districts and in states where there is strong accountability and oversight, things may be okay. But in those places where we already have issues with equitability and numerous cases of IEP and IDEA violations, there will be no incentive for any ongoing accountability, especially if the Office of Civil Rights does not exist as it does now.”
Robinson noted McKinney-Vento is now covered under the Every Student Succeeds Act.
“In those states and districts where there is a strong liaison dealing with students who are homeless or temporarily housed, it should be business as usual,” she said, adding the unfunded mandate and reduced federal oversight may mean students are missing necessary, instructional minutes and classroom time because of lack of ownership, responsibility and a sense of urgency at the local levels.
“It’s easy to let administrative noise stand in for a change in obligation when it isn’t one,” added Wright-Gallo. “Our responsibility, professionally, is to hold that line: To keep documentation, training and coordination tight enough that a shift in who processes a grant never becomes a gap in what a student actually receives.
“It’s a reminder of why this work matters in the first place,” she continued. “The bus that shows up on time, the aide who knows a student’s behavior plan, the ride that gets a homeless student back to the only school that still feels like home, aren’t abstracts of policy. They’re the daily, unglamorous proof that the laws are doing what they were written to do.”
Editor’s Note: As reprinted from the October 2026 issue of School Transportation News.
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