Trump Administration Play-by-Play

2025 and Beyond

  • It lays out the potential timing and process for Administration actions to implement education priorities and highlights opportunities for disrupting those plans. It also offers additional resources for anyone who wants to learn more about these anticipated policy actions and their impact on public schools, as well as how public school advocates are preparing and responding. By demystifying the federal actions and process the Administration might follow and identifying resources, we hope to support partners in developing strategies to protect public education in local communities, cities, and states.


    This resource is being developed in real-time and is intended to cover the first two years of the Trump Administration, traditionally the most productive years of a president’s term. It is structured in parts: actions the Administration could take during the first 100 days, the first six months, the first year, and over the first eighteen months. The initial version of this document focuses on policies that could be implemented in the first 100 days to six months of the Trump Administration. As a living document, it will be updated with information on policies that have been enacted, policies that have been delayed or dropped, as well as other emerging administration priorities or on-the-ground changes. It also will be updated to include additional resources and information on partner responses. We welcome your contributions on resources and planned actions. Please share those with us at info@futureforlearning.org.

Public education has long been under attack in the U.S. Now, the players leading that attack will be directing federal education policy and they have not hidden their plans for public schools. To the contrary, they’ve published them for everyone to see. This Administration Play-by-Play looks under the hood of those plans to explore how President Trump and his appointees might accomplish their goals.

THE FIRST 100 DAYS (JANUARY 20TH - APRIL 30, 2025)

Administration Priority

Weaponizing the Office for Civil Rights (OCR)

The Office for Civil Rights is responsible for enforcing federal civil rights laws in schools, colleges, and universities, and other entities receiving federal education funds. Under the Trump Administration, this office may use that power to target states, districts, and schools that do not adhere to the Administration’s policy agenda, ultimately threatening to withhold federal funding.

  • The Department of Education’s Office for Civil Rights (OCR) is charged with ensuring that all students have equal access to education and vigorously enforcing federal civil rights laws prohibiting discrimination based on race, nationality, gender, sex, disability status, and age by schools, districts, states, or other recipients of federal funds found to have violated these laws. OCR determines whether a violation has taken place through a complaint and investigation process. Anyone with knowledge of a potential violation of civil rights law may file a complaint with OCR. OCR may decide to open an investigation in response to a complaint or it may initiate an investigation independently based on its own data or information about potential violations. As part of the resolution of investigations, OCR can require a wide range of remedies up to and including withholding federal funding.

  • Officials in the Trump Administration have already indicated their intention to use this enforcement mechanism to punish schools, states, and districts that  do not adhere to their policy agenda. This tool is so critical to advancing Trump’s agenda that it may be reason enough to slow walk efforts to dismantle the Department of Education. The groundwork for this type of action has already been laid. Thousands of complaints have already been filed by Trump allies against schools, districts, as well as colleges and universities that permitted affinity groups, scholarships for underrepresented minorities, mentorship programs for girls and young women entering traditionally male-dominated fields, and so on. The Trump Administration is likely to direct OCR to investigate these complaints, as well as others relating to DEI, culturally affirming curricula, and policies supporting transgender and nonbinary students, and to require harsher remedies to resolve them. President Trump has already threatened to withhold federal funding in some of these instances, a remedy that has rarely, if ever, been enforced.

  • The White House: The Administration’s priorities on civil rights enforcement may or may not be publicly communicated. However, President Trump has already made clear his views on issues related to equity and inclusion. The White House is expected to appoint staff to OCR who share these views and will develop policy guidance that interprets the law in their favor.

    The Department of Education (ED): Staff appointed to lead the Department of Education, including those appointed to lead OCR, are expected to hew closely to President Trump’s priorities. That means they are likely to look skeptically on certain programming, such as that related to underrepresented minorities, and to prioritize opening and resolving investigations in a manner that supports their policy agenda. Even if these investigations do not result in a finding of violation, this level of scrutiny is likely to have a chilling effect, discouraging schools and districts from engaging in activities related to equity and inclusion regardless of whether they actually violate federal law.

  • Advocate for states and districts to strengthen their own civil rights reporting and oversight procedures.

    Ensure that schools and districts understand their rights and responsibilities, including what is required to comply with the law and what constitutes a violation. Although the Trump Administration may interpret facts differently, they cannot change laws or regulations outside of specific, and often lengthy, procedures. 

    The Pennsylvania WInS Coalition provides support for districts schools so they know their rights and can protect historically marginalized students.

    Develop plans to protect the programming and staff most likely to be targeted by changes in OCR policy (e.g. inclusive state or district policy prohibiting discrimination)

  • Trump on DEI And Anti-Discrimination Law from the ACLU

    Can Trump Force Schools to Change Their Curricula? By Alyson Klein

    How the Trump Team Plans to Dismantle Civil Rights from the Chicago Teachers Union

    Inside Trump’s ominous plan to turn civil rights law against vulnerable Americans by Zack Beauchamp

Administration Priority

School-to-Deportation Pipeline

The Trump Administration will likely remove the protected status from schools, churches, hospitals, and other critical service providers that have enabled them to serve undocumented children and families and ensure access to essential resources. This could occur in the early weeks of the Administration by rescinding existing agency guidance.

  • President Trump has stated that immigration will be a key focus of his second term. During his first term, he moved swiftly to issue executive orders related to immigration and the US southern border that directed the building of the wall and threatened to withhold federal grant money from Sanctuary Cities that refused to enforce immigration laws. However, the first Trump Administration left guidance in place from the Department of Homeland Security that designates hospitals and schools as protected spaces. In accordance with that guidance, immigration arrests or detentions at or near schools, hospitals, or churches may only be conducted under a limited set of circumstances.

  • Officials close to the Trump transition team indicated an intention to target the “protected spaces” policy as one of the Administration’s first steps. On his first day in office, President Trump signed an Executive Order requiring DHS to rescind the policy and on Jan. 21, 2025, DHS issued a release announcing that the “protected spaces” policy had been terminated, making it more likely that students or their parents will be detained after a disciplinary infraction that leads to an encounter with the school law enforcement.

    • The White House: Because the protected spaces policy is not enshrined in legislation or regulation, the President can change it unilaterally. For example, he could issue an executive order calling for its review and/or rescission, or he could address the guidance in a new executive order on immigration more broadly.

    • Department of Homeland Security (DHS): As the agency issuing the guidance, DHS would be responsible for actually rescinding the policy. It could do so without issuing a policy to replace it. DHS would simply need to publish notice in the Federal Register of the withdrawal of the policy along with the rationale for the change. While this second step could not be completed on President Trump’s first day in office, it could be accomplished in the first few weeks.

    • Potential obstacles to this agenda: Rescinding the protected spaces policy does not strip immigrant students of their right to equal access to public education. First, while states cannot prevent federal law enforcement from enforcing federal immigration law, the federal law enforcement cannot force states or municipalities to enforce or assist in enforcing federal immigration law. In addition, according to longstanding Supreme Court precedent, students are guaranteed equal access to public education regardless of their immigration status. The ruling in Plyer v. Doe has been interpreted to prohibit both the exclusion of undocumented students from public schools and the collection of documents that would indicate a student’s immigration status. Finally, there are student privacy laws (e.g., FERPA) that prohibit sharing student information except in set circumstances. While this Supreme Court has shown a willingness to overturn long-standing precedent and, even now, states cannot stop ICE from carrying out arrests in their jurisdiction, they can develop policies and procedures dictating how state employees will respond to federal immigration enforcement. This resource will be updated as these challenges emerge and move through the legal system.

  • Build and share community knowledge about the rights of immigrant students and families in this changing landscape.

    Work with schools, districts, and states to develop policies and procedures for arrests or detentions that occur on or near school campuses.

    Advocate for state and local laws and policy to protect against federal efforts to limit access to public education regardless of immigration status.

  • Immigration enforcement and US schools: What could happen and what education leaders can do from the Brookings Institute

    American Federation of Teachers Immigration Resources

    Schools Under Siege: The Impact of Immigration Enforcement on Educational Equity from the Civil Rights Project at the University of California, Los Angeles on Texas Public Radio

    A Real Crime (Video)

Note on Eliminating the Department of Education: Throughout his campaign, President Trump reaffirmed his commitment to shutting down the Department of Education. To do so, Congress would have to pass legislation that not only terminates the Department, but also transfers all of its responsibilities to other actors at the federal and/or state levels. Because such legislation would involve a major policy change that is not related to the budget, proponents in Congress could not use reconciliation to pass it, and they do not currently have the 60 votes in the Senate necessary to pass the legislation by standard process. In addition, because the Department of Education may prove helpful to advancing the Administration’s agenda, there may not be immediate interest in shutting it down. As significant efforts to shut down the department are likely years away, this resource focuses on actions the Administration can take in the near term to undermine the Department and its mission.

Note on Reconciliation: Reconciliation is a parliamentary procedure that allows the Senate to bypass the filibuster and the requirement of 60 votes to pass legislation. Reconciliation bills can pass the Senate on a simple majority of 51 votes or 50 votes plus the Vice President’s vote to break the tie. Reconciliation bills may only be used to address spending, revenue, or the federal debt limit, and the Senate can only pass one reconciliation bill on each topic per fiscal year. The Senate is prohibited from using the reconciliation process to make policy changes that are not related to the budget, increase the federal deficit after a ten year period, or make changes to Social Security. There are currently 53 Republicans and 47 Democrats in the Senate.

THE FIRST SIX MONTHS (JANUARY 20 - JULY 31, 2025)

Administration Priority

Deprioritizing Federal Education Funding Programs

The incoming Trump Administration has indicated its intention to eliminate the Department of Education. The first step is likely to be reducing federal education funding and farming out federal education responsibilities to other actors. Block-granting major funding programs, such as Title I and IDEA, allows the Administration to accomplish both goals at the same time.

  • A key pillar of the Project 2025 agenda has been to convert federal grant programs overseen by the Department of Education into “no strings attached” block grants, reduce funding for those programs, and ultimately eliminate them. The programs at risk for elimination provide funding for students from low income families and schools in low-income communities (Title I), improving instruction quality (Title II), supporting multilingual learning (Title III), and ensuring access for students with disabilities (IDEA). Districts use these funds for a variety of initiatives from reading and math instruction to school-based mental health counseling and paraprofessionals. Combined, these grants account for on average 10% of school funding. Funding for these programs is discretionary, meaning that spending levels for them have to be approved by congress every year. Throughout the campaign, President Trump and his advisors expressed their intention to couple the use of block grants with a reduction in funding for –and even the elimination of– programs such as Title I and IDEA, which combined provide over $30 billion in assistance to students and communities that are already chronically underserved. 

    • This proposal is likely to be attached to a reconciliation bill that is expected to move by March and could be signed by the end of May (see budget reconciliation note).

  • Currently, federal education funding is distributed from the Department of Education to state education agencies (SEAs), which in turn disperse the funds to districts and schools in accordance with federal regulations. These regulations are intended to ensure that schools and districts receive funding proportionate to the level of student need so that all students have an equitable opportunity to learn. Each funding program (e.g., Title I) requires districts to utilize the funding for specific purposes and meet specific accountability requirements. Transitioning these programs into block grants reduces the oversight on how states use the resources, running the risk of hundreds of millions of dollars for vulnerable students being redirected for other state or local priorities. Block grants also make it challenging to track how funding is being used and assess the impact of the funding on improving student outcomes.

  • White House: In the first months of the Trump Administration, the President and his advisors will produce a budget for the upcoming fiscal year that could include the shift to block grants. Because Congress has not approved a budget for the current fiscal year, the President’s budget can and likely will include this fiscal year as well. This budget is not law and thus Congress is not required to follow it to the letter. However, it does signal the President’s priorities, and Republicans in Congress are likely to heavily rely on it during their own budget process.

    House of Representatives: The budget process in Congress starts in the House of Representatives. With 220 members, Republicans will be in the driver’s seat for this process, and they will likely follow the President’s budget closely. If the President’s budget calls for a reduction in and/or a shift to block granting Department of Education funding programs, House Republicans are likely to include that change in their budget legislation. Because this spending is discretionary, the House does not need to maintain funding at previous levels. They need a simple majority of 218 votes to pass their budget.

    Senate: Typically, the Senate considers the budget once the House approves it. However, because this is a lengthy process, the Senate may develop its own legislation and then reconcile it with the budget the house passes. As the budget primarily concerns spending and revenue, it can and likely will be passed as a part of the larger reconciliation bill (see textbox). That means that only 51 votes or 50 plus the Vice President’s vote are required to pass budget legislation. Republicans hold 53 votes in the Senate.

    Potential logistical and political barriers: The current federal fiscal year, FY 2025, is already halfway over so a big reduction midyear would be highly disruptive for school districts. More than half of American students and more than 70% of American schools receive some Title I funding. Ten states depend on federal funding for more than 15% of their K-12 funding and these also are states Trump won in the 2024 election. 

    To advance these policies we expect the Administration to fold reductions or planned elimination of federal education funding into the budget reconciliation process (see text box). As a result, the legislation only needs 50 votes in favor to pass, as the Vice President is likely to cast the deciding vote in favor.

  • Develop messaging narratives on the importance of Title I, II, III and IDEA funding in your school community.

    See the Partnership for the Future of Learning’s ESSER Storytelling Toolkit for guidance on messaging.

    Meet with your lawmakers on both sides of the aisle

    Advocate for increased funding at the state level in anticipation of potential reductions.

    California schools chief pledges to resist cuts in funding if Trump axes U.S. Dept. of Education by Emma Gallegos at Ed Source

Administration Priority

Federal Voucher Tax Credit: A Tax Shelter for the Wealthy

Federal voucher legislation proposed in the last session is anticipated to receive broad support from lawmakers in both branches of Congress. It is likely to be attached to a budget reconciliation bill that lawmakers will take up in March.

  • President Trump’s campaign promises and statements on expanding school choice and his nomination of Education Secretary Linda McMahon suggest that federal voucher legislation will be a top priority during his Administration. Lawmakers have proposed federal voucher legislation in the past to varying degrees of success. Last session, federal voucher legislation, H.R. 9462, the Educational Choice for Children Act (ECCA), advanced out of committee for the first time. It did not pass, but it is likely to be attached to the budget reconciliation bill that is expected to begin moving through Congress this March (see budget reconciliation note).

  • The ECCA would amend the Internal Revenue Code of 1986 to create a four-year pilot to funnel dollars to private and religious schools through tax breaks to wealthy donors. This House proposal is projected to result in more than $20 billion in lost tax revenue, but the Senate version could cost over $100 billion, reducing the public funds available for public schools dramatically. Under the ECCA, an individual who donates money to a Scholarship Granting Organization (SGO) would receive a dollar-for-dollar tax credit to offset their federal taxes. Individuals may donate to SGOs in any state in the country. The SGO treats these resources as private funds rather than public dollars and uses them to grant and administer vouchers to students with no government oversight. The legislation does not include requirements for, or restrictions on, schools receiving voucher funds from the SGOs. Further, it prohibits the government from requiring that those schools adhere to federal civil rights laws. SGOs must limit eligibility based on household income, but may offer a voucher to any family who make 300% or less of the median income in their area (likely defined at county-level), meaning that even wealthy families may qualify. Families may use these funds for tuition, curriculum, books, online tutoring, or other educational support.

  • The House of Representatives

    • A federal voucher tax credit will likely be included in a broader budget reconciliation bill. This legislation will be added to the U.S. House of Representatives Union Calendar to be eligible for consideration by the “Committee of the Whole.” This Committee will debate the legislation, including the voucher tax credit provisions, and vote on amendments before moving the bill to the House floor for a vote. The Committee includes all members of the House, but only needs a quorum of 100. This is the primary point for making changes to the draft legislation before it goes for a final vote.

    • To pass in the House of Representatives, H.R. 9462 will need a simple majority, which translates to 218 votes as there are 435 members in the House. Republicans currently hold the majority with 220 Republicans, 213 Democrats, and 2 vacant positions. If the bill is approved, it will be sent to the Senate to be considered. To defeat this legislation at least 5 Republicans will have to vote against the legislation in addition to the vast majority of Democrats.

    The Senate

    To advance H.R. 9462 in the Senate, we expect the Administration to fold the legislation into the budget reconciliation process, expediting the budget legislation process (see text box). As a result the legislation will need only 50 votes in favor to pass, as the Vice President is likely to cast the deciding vote in favor.

  • Contact your Congressional representatives on both sides of the aisle to share how voucher programs, like the ECCA, impact schools in your community.

    Join organizing and advocacy efforts in your community, state and nationally. If you are already engaging in this type of advocacy, include information on the ECCA in your work. Here are some resources:

    • The Partnership’s Truth in Ed Funding website provides toolkits and examples of organizing strategies.

THE FIRST YEAR (JANUARY 20, 2025 - JANUARY 20, 2026)

Administration Priority

Tax Credit Regulation

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Administration Priority

Parents Bill of Rights

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