A group of scholars at the Brookings Institution analyzed Project 2025’s proposals for education and their implications.

What struck me as most bizarre about Project 2025 was not its efforts to block-grant all federal funding of schools, nor its emphasis on privatization of K-12 schools. (Block-granting means assigning federal funding to states as a lump sum, no strings attached, no federal oversight).

No, what amazed me most was the split screen between the report’s desire to hand all power over education to states and communities, and the report’s insistence on preserving enough power to punish LGBT students, especially trans students and to impose other far-right mandates, like stamping out critical race theory. You know, either you let the states decide or you don’t. The report wants it both ways.

It’s also astonishing to realize that the insidious goal of the report is eventually abandon federal funding of education. That’s a huge step backward, taking us to 1965, before Congress passed the Elementary and Secondary Education Act, whose purpose was to raise spending in impoverished communities. I essence, P2025 says that decades of pursuing equitable funding “didn’t work,” so let’s abandon the goal and the spending.

Here is the Brookings analysis:

Project 2025 outlines a radical policy agenda that would dramatically reshape the federal government. The report was spearheaded by the right-wing Heritage Foundation and represents the policy aims of a large coalition of conservative activists. While former President Trump has attempted to distance himself from Project 2025, many of the report’s authors worked in the previous Trump administration and could return for a second round. Trump, himself, said in 2022, “This is a great group, and they’re going to lay the groundwork and detail plans for exactly what our movement will do.”

In other words, Project 2025 warrants a close look, even if the Trump campaign would like Americans to avert their gaze.

Project 2025’s education agenda proposes a drastic overhaul of federal education policy, from early childhood through higher education. Here’s just a sample of the Project 2025 education-related recommendations:

• Dismantle the U.S. Department of Education (ED)
• Eliminate the Head Start program for young children in poverty
• Discontinue the Title I program that provides federal funding to schools serving low-income children
• Rescind federal civil rights protections for LGBTQ+ students
• Undercut federal capacity to enforce civil rights law
• Reduce federal funding for students with disabilities and remove guardrails designed to ensure these children are adequately served by schools
• Promote universal private school choice
• Privatize the federal student loan portfolio

It’s an outrageous list, and that’s just the start of it.

We’ve reviewed the Project 2025 chapter on education (Chapter 11), along with other chapters with implications for students. We’ve come away with four main observations:

1. Most of the major policy proposals in Project 2025 would require an unlikely amount of congressional cooperation

Project 2025 is presented as a to-do list for an incoming Trump administration. However, most of its big-ticket education items would require a great deal of cooperation from Congress.

Proposals to create controversial, new laws or programs would require majority support in the House and, very likely, a filibuster-proof, 60-vote majority in the Senate. Ideas like a Parents’ Bill of Rights, the Department of Education Reorganization Act, and a federal tax-credit scholarship program fall into this category. Even if Republicans outperform expectations in this fall’s Senate races, they’d have to attract several Democratic votes to get to 60. That’s not happening for these types of proposals.  

The same goes for major changes to existing legislation. This includes, for example, a proposal to convert funding associated with the Individuals with Disabilities Education Act (IDEA) to no-strings-attached block grants and education savings accounts (with, presumably, much less accountability for spending those funds appropriately). It also includes a proposal to end the “negotiated rulemaking” (“neg-reg”) process that ED follows when developing regulations related to programs authorized under Title IV of the Higher Education Act (HEA). The neg-reg requirement is written into HEA itself, which means that unwinding neg-reg would require Congress to amend the HEA. That’s unlikely given that HEA reauthorization is already more than a decade overdue—and that’s without the political baggage of Project 2025 weighing down the process.

The prospect of changing funding levels for existing programs is a little more complicated. Programs like Title I are permanently authorized. Eliminating Title I or changing the formulas it usesto allocate funds to local educational agencies would require new and unlikely legislation. Year-to-year funding levels can and do change, but the vast majority of ED’s budget consists of discretionary funding that’s provided through the regular, annual appropriations process and subject to a filibuster. This limits the ability of one party to make major, unilateral changes. (ED’s mandatoryfunding is more vulnerable.)

In sum, one limiting factor on what an incoming Trump administration could realistically enact from Project 2025 is that many of these proposals are too unpopular with Democrats to overcome their legislative hurdles.

2. Some Project 2025 proposals would disproportionately harm conservative, rural areas and likely encounter Republican opposition

Another limiting factor is that some of Project 2025’s most substantive proposals probably wouldn’t be all that popular with Republicans either.

Let’s take, for example, the proposed sunsetting of the Title I program. Project 2025 proposes to phase out federal spending on Title I over a 10-year period, with states left to decide whether and how to continue that funding. It justifies this with misleading suggestions that persistent test score gaps between wealthy and poor students indicate that investments like Title I funding aren’t paying off. (In fact, evidence from school finance reforms suggests real benefits from education spending, especially for students from low-income families.)

The phrase “Title I schools” might conjure up images of under-resourced schools in urban areas that predominantly serve students of color, and it’s true that these schools are major beneficiaries of Title I. However, many types of schools, across many types of communities, receive critical support through Title I. In fact, schools in Republican-leaning areas could be hit the hardest by major cuts or changes to Title I. In the map below, we show the share of total per-pupil funding coming from Title I by state. Note that many of the states that rely the most on Title I funds (darkest blue) are politically conservative.

[Open the link to see the map.]

Of course, the impact of shifting from federal to state control of Title I would depend on how states choose to handle their newfound decision-making power. Given that several red states are among the lowest spenders on education—and have skimped on programs like Summer EBT and Medicaid expansion—it’s hard to believe that low-income students in red states would benefit from a shift to state control.

What does that mean for the type of support that Project 2025 proposals might get from red-state Republicans in Congress? It’s hard to know. It’s worth keeping in mind, though, that the GOP’s push for universal private school voucher programs has encountered some of its fiercest resistance from rural Republicans across several states.

3. Project 2025 also has significant proposals that a second Trump administration could enact unilaterally

While a second Trump administration couldn’t enact everything outlined in Project 2025 even if it wanted to, several consequential proposals wouldn’t require cooperation from Congress. This includes some actions that ED took during the first Trump administration and certainly could take again.

Here are a few of the Project 2025 proposals that the Trump administration could enact with the authority of the executive branch alone:

• Roll back civil rights protections for LGBTQ+ students
• Roll back Title IX protections against sex-based discrimination
• Dismantle the federal civil rights enforcement apparatus
• Eliminate current income-driven repayment plans and require higher monthly payments for low-income borrowers
• Remove protections from predatory colleges that leave students with excessive debt

Federal education policy has suffered from regulatory whiplash over the last decade, with presidential administrations launching counter-regulations to undo the executive actions of the prior administration. Take, for example, “gainful employment” regulations that Democratic administrations have used to limit eligibility for federal financial aid for colleges that leave students with excessive loan debt. A second Trump administration would likely seek to reverse the Biden administration’s “gainful employment” regulations like the first Trump administration did to the Obama administration’s rules. (Then again, with the Supreme Court striking down Chevron, which provided deference to agency expertise in setting regulations, the Trump administration might not even need to formally undo regulations.)

Other Project 2025 proposals, not explicitly about education, also could wreak havoc. This includes a major overhaul of the federal civil service. Specifically, Project 2025 seeks to reinstate Schedule F, an executive order that Trump signed during his final weeks in office. Schedule F would reclassify thousands of civil service positions in the federal government to policy roles—a shift that would empower the president to fire civil servants and fill their positions with political appointees. Much has been written about the consequences of decimating the civil service, and the U.S. Department of Education, along with other federal agencies that serve students, would feel its effects.

4. Project 2025 reflects a white Christian nationalist agenda as much as it reflects a traditional conservative education policy agenda

If one were to read Project 2025’s appeals to principles such as local control and parental choice, they might think this is a standard conservative agenda for education policy. Republicans, after all, have been calling for the dismantling of ED since the Reagan administration, and every administration since has supported some types of school choice reforms.

But in many ways, Project 2025’s proposals really don’t look conservative at all. For example, a large-scale, tax-credit scholarship program would substantially increase the federal government’s role in K-12 education. A Parents’ Bill of Rights would require the construction of a massive federal oversight and enforcement function that does not currently exist. And a proposal that “states should require schools to post classroom materials online to provide maximum transparency to parents” would impose an enormous compliance burden on schools, districts, and teachers.

Much of Project 2025 is more easily interpretable through the lens of white Christian nationalism than traditional political conservatism. Scholars Philip Gorski and Samuel Perry describe white Christian nationalism as being “about ethno-traditionalism and protecting the freedoms of a very narrowly defined ‘us’.” The Project 2025 chapter on education is loaded with proposals fitting this description. That includes a stunning number of proposals focused on gender identity, with transgender students as a frequent target. Project 2025 seeks to secure rights for certain people (e.g., parents who support a particular vision of parental rights) while removing protections for many others (e.g., LGBTQ+ and racially minoritized children). Case in point, its proposal for “Safeguarding civil rights” says only, “Enforcement of civil rights should be based on a proper understanding of those laws, rejecting gender ideology and critical race theory.”

These types of proposals don’t come from the traditional conservative playbook for education policy reform. They come from a white Christian nationalist playbook that has gained prominence in far-right politics in recent years.

At this point, it’s clear that the Trump campaign sees Project 2025 as a political liability that requires distance through the election season. Let’s not confuse that with what might happen during a second Trump administration.