Mass Layoffs at the U.S. Department of Education: Impacts on Higher Education
Institutions May Experience Substantial Delays in Federal Student Aid Matters
At a Glance
- On March 11, 2025, the Department of Education announced a significant reduction in force (RIF), dismissing almost half of its 4,133 employees and closing most regional offices nationwide. These layoffs affect a broad range of departmental offices, including substantial cuts to staff levels at the Office of Federal Student Aid (FSA), the Office for Civil Rights (OCR), and the Institute of Education Sciences. Employees impacted by the RIF will be placed on administrative leave as of Friday, March 21.
- The layoff notification followed other recent and sweeping changes at the Department, including a shift — documented in its February 14 Dear Colleague Letter — in the Department’s interpretation of antidiscrimination laws as they pertain to diversity, equity and inclusion (DEI) initiatives in education programs and campus life.
- A coalition of attorneys general from 20 states and the District of Columbia sued the administration following the layoffs, arguing that the dismissals were unconstitutional (on grounds of separation of powers as well as ultra vires action outside the scope of executive or agency authority) and also violated the Administrative Procedure Act. A second lawsuit has also been filed by two parents and a parent advocacy organization, arguing that the OCR will be unable to fulfill its statutory obligations because of the RIF. Absent judicial intervention, the effects of the layoffs on postsecondary institutions and other stakeholders will become clearer in the coming weeks.
Overview
On March 11, 2025, the Department of Education (ED or the Department) effectively fired a substantial portion of its employees, marking a significant step in what Secretary Linda McMahon has called the Department’s “Final Mission.” The Department announced the closure of most of its regional offices, laid off more than 300 full-time staff members at FSA, and fired the vast majority of staff at the Institute of Education Sciences. Accounting for both the March 11 layoffs and the “deferred resignations” submitted by some staff during the first weeks of the administration, the Department’s workforce has been reduced by nearly 50% — decreasing from 4,133 workers at the beginning of the administration to 2,183 following the layoffs, according to the Department. Employees impacted by the reduction in force will be placed on administrative leave beginning on Friday, March 21.
The Department has stated that it “will continue to deliver on all statutory programs that fall under the agency’s purview,” such as formula funding, student loans, Pell Grants and competitive grantmaking. In a March 14 letter addressed to “Education Stakeholders,” Acting Under Secretary James Bergeron sought to assure institutions that “continuity of operations for [FSA] is both a statutory and critical function of the Department” and no employees working on “core functions” of the Free Application for Federal Student Aid (FAFSA) or student loan servicing were impacted by the RIF. The letter also stated that staff at the Office of Policy, Planning, and Innovation, which oversees negotiated rulemaking and accrediting agency recognition processes, were not impacted by the RIF, nor were “critical functions” for career and technical education offices.
Nonetheless, many divisions within the Department were significantly impacted by the RIF, likely affecting the ability of the Department to operate effectively in many key areas. In particular, the operations of FSA, which oversees the administration of all federal student aid programs under Title IV of the Higher Education Act of 1965 (Title IV Programs) including Federal Direct Loans and Pell Grants, may be significantly and negatively impacted by staffing reductions across program review units. FSA’s School Eligibility and Oversight Group, more commonly referred to as the School Participation Division (SPD) — which handles all institutional applications related to Title IV participation, including initial certification, recertification, mergers and changes in ownership or control, financial oversight matters including composite score determinations, letters of credit and other financial monitoring, and Title IV program reviews — was reportedly reduced from nearly 200 to less than 30 persons. Additionally, the regional FSA-SPD teams in Atlanta, Boston, Dallas, Denver, Kansas City, New York, San Francisco and Seattle were shuttered, as was the Multi-Region and Foreign Schools team. Only the Chicago and Philadelphia teams remain. In an electronic announcement (EA) released late on March 14, the Department stated that FSA will be “centrally responding” to all questions related to institutional applications and school eligibility matters. The EA directs postsecondary institutions to send such correspondence to a new email address (CaseTeams@ed.gov) and notes continued availability of the FSA Partner Connect helpdesk.
Many cuts within FSA also reportedly focused on technical support staff, a decision which may limit ED’s capacity to support the FAFSA for student aid applicants, the FSA Partner Connect system used by institutions to submit required information, the eZ-Audit system, call centers and other systems.
Other units experiencing significant staffing cuts include OCR and the Institute of Education Sciences (IES). OCR offices in Chicago, Philadelphia, New York, Dallas, San Francisco, Boston and Cleveland have been closed, resulting in the firing of nearly half of the OCR workforce in total. As of January 14, those seven offices had over 6,000 open investigations, which raises questions about how pending cases will be resolved. Meanwhile, the IES, which tracks college and university data that serves as the basis for broader education policy research, also experienced significant cuts, potentially making it more difficult to monitor and assess academic program quality and impacts across the country. These cuts to IES follow earlier contract terminations led by the administration’s “Department of Government Efficiency,” thereby multiplying the eventual impact on ED’s research grants and contracts.
At an individual level, the most-affected roles at ED were attorneys, management and program analysts, institutional review specialists, and information technology professionals. As referenced above, longstanding departmental functions associated with these roles, such as program oversight, enforcement, research and technical support, will likely be affected by these layoffs, including potentially extensive impacts on how students and institutional administrators engage with the Department regarding financial aid matters and other frequent areas of inquiry or reporting.
Implications for Educational Institutions
Institutions of higher education may experience the most acute interruptions as a result of substantial staffing losses at FSA. Section 498 of the Higher Education Act governs the institutional eligibility and certification procedures associated with Title IV program participation, specifically directing the Secretary of Education to determine an institution’s legal authority to operate within a state, its accreditation status, and its administrative capability and financial responsibility. As institutions know, that oversight has historically been executed through deep involvement with, and individual contact from, FSA officials at both national and regional levels. Yet, as described above, FSA experienced some of the most severe cuts as a result of the RIF, including the complete termination of all but two of SPD’s school participation teams.
Institutions therefore should anticipate significant delays in FSA’s processing of all institutional applications and other matters within its purview. We understand, for instance, that the RIF included all of FSA’s financial reviewers, creating significant uncertainty as to how FSA will be able to assess the annual financial statement submissions made each year by each Title IV-participating institution. With reportedly less than 30 staff remaining in the SPD to handle all recertification applications, mergers and changes in ownership or control, financial reviews, letters of credit, and numerous other more routine matters, there undoubtedly will be impacts on institutions and their day-to-day operations. Additionally, staff cuts within OCR may impact ongoing claims and investigations, raising questions for institutions currently interacting with the Department on case management issues or OCR resolution agreements.
Notably, because there has been no revision of the pertinent underlying statutes or their implementing regulations, the compliance obligations of postsecondary institutions remain unchanged. Institutions should be prepared to meet all federal regulatory reporting and other compliance requirements, and to comprehensively document such submissions (and all attempts to timely make such submissions), regardless of the Department’s evident reduction in overall capacity.
What’s Next?
A coalition of attorneys general from 20 states and the District of Columbia sued the administration following the RIF, arguing that the dismissals were unconstitutional and violated the Administrative Procedure Act. A second lawsuit has also been filed by two parents and a parent advocacy organization, seeking injunctive relief to “restore the investigation and processing capacity of OCR and to process complaints from the public promptly and equitably in accordance with OCR’s statutory and regulatory obligations.” Any judicial actions arising from these lawsuits could potentially affect the reduction in force as well as this Department’s policy priorities. Educational institutions should engage with legal counsel to evaluate how they might be affected by the recent reduction in force and should actively track their existing compliance obligations.
For More Information
We continue to review the impact of this RIF, new ED guidance, and agency directives, and are available to answer any questions.
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