Potential Title IV Disruption Catastrophic (Glen McGhee)

Impact of Department of Education Dismantlement on Higher Education Act Programs

On March 20, 2025, President Trump signed an executive order to begin dismantling the Department of Education, a move that threatens to create significant upheaval across higher education's federal support system. While the order cannot immediately eliminate the department without congressional approval, it has already resulted in substantial workforce reductions and signals major changes ahead for the administration of federal education programs 1.

Title IV: The Most Vulnerable and Consequential Program

Among all eight titles of the Higher Education Act (HEA), Title IV federal student aid programs would create the most severe upheaval for the higher education sector if destabilized through the Department of Education's dismantling. Title IV represents the foundation of federal financial support for higher education, administering approximately $111.6 billion in financial assistance to 9.8 million students in FY202211. This massive program encompasses Pell Grants, federal student loans, and work-study opportunities that directly enable student access and persistence.

Financial Impact Scale

The sheer financial magnitude of Title IV makes its disruption particularly consequential. In 2021 alone, 10.5 million students received $125 billion in federal student aid through the Department of Education15. Title IV's Office of Federal Student Aid received the largest departmental budget allocation - over $68 billion, with $20 billion promised for distribution during 20254. This represents the largest financial relationship between the federal government and higher education institutions.

Enrollment Consequences Already Evident

Even small disruptions to Title IV administration have already demonstrated severe enrollment impacts. Recent problems with the Free Application for Federal Student Aid (FAFSA) system implementation led to measurable enrollment declines:

• 43% of private institutions reported smaller freshman classes
• 27% noted fewer financial aid recipients
• 18% reported decreased racial or ethnic diversity in incoming students2

These enrollment impacts disproportionately affect disadvantaged student populations. The FAFSA completion rates dropped nearly 10%, showing how administrative dysfunction can directly reduce educational access2.

Complex Regulatory Framework

Title IV administration involves an extraordinarily complex regulatory structure that would be challenging to transfer or maintain during a departmental transition. The program includes more than 300 pages of regulations, with significant compliance requirements for institutions6. Recent rule changes have created new financial responsibility, administrative capability and certification requirements applicable to institutions participating in Title IV programs7.

Presidential Assurances vs. Implementation Reality

While President Trump has indicated that essential functions like Pell Grants, Title I funding, and programs for students with disabilities would be "fully maintained and redistributed to various other agencies and departments," the implementation details remain unclear18. The executive order instructs Education Secretary Linda McMahon to "undertake all necessary actions to facilitate the dissolution" while ensuring continuous provision of services8.

However, the Department's workforce has already been reduced from over 4,000 to approximately 2,000 employees through layoffs and voluntary resignations14. This reduction in administrative capacity raises serious questions about the continuity of Title IV program implementation.

Other HEA Titles: Significant but Less Catastrophic Impact

While all HEA titles would face disruption through departmental dismantling, Title IV's combination of massive funding scale, direct impact on enrollments, and regulatory complexity makes its destabilization particularly consequential.

Other HEA titles, while important, would not create the same level of immediate financial and enrollment chaos:

• Title I: Provides general provisions and administrative requirements, but lacks direct funding mechanisms
• Title II: Supports teacher preparation programs, but with significantly smaller funding scales
• Title III: Provides institutional aid for minority-serving institutions, representing important but more targeted support
• Titles V-VIII: Offer specialized program support for specific institutional types or educational priorities

Conclusion

The dismantling of the Department of Education threatens all federal higher education programs, but Title IV student aid programs represent the most consequential area for potential upheaval. The scale of financial support, direct impact on enrollment and access, complexity of administration, and early evidence from FAFSA disruptions all indicate that Title IV destabilization would produce the most severe consequences for higher education institutions and students.

While the administration has promised to maintain essential functions, the mechanisms for doing so remain unclear, and the significant reduction in departmental workforce suggests potential administrative challenges ahead. The higher education community must closely monitor this transition to ensure that critical student financial support systems remain functional during this unprecedented departmental restructuring.

Citations:

1. https://thehill.com/homenews/education/5179987-trump-executive-order-department-of-education-linda-mcmahon/
2. https://www.insightintodiversity.com/fafsa-issues-led-to-decreased-enrollment/
3. https://www.everycrsreport.com/reports/IF12780.html
4. https://onwardstate.com/2025/03/20/how-the-dismantling-of-the-department-of-education-will-affect-college-students-across-the-nation/
5. https://www.levyinstitute.org/pubs/rpr_2_6.pdf
6. https://imprimis.hillsdale.edu/the-crisis-and-politics-of-higher-education/
7. https://www.faegredrinker.com/en/insights/publications/2024/2/significant-new-financial-responsibility-administrative-capability-and-certification-requirements-loom-ahead-for-title-iv-institutions
8. https://www.nbcnews.com/politics/trump-administration/education-department-trump-what-is-next-student-loans-fafsa-rcna197302
9. https://www.startribune.com/trump-orders-a-plan-to-dismantle-the-education-department-while-keeping-some-core-functions/601240066
10. https://www.nbcnews.com/news/education/dozens-colleges-see-fafsa-turmoils-impact-freshman-classes-rcna167342
11. https://sgp.fas.org/crs/misc/R43351.pdf
12. https://www.asugsvsummit.com/video/preview-of-the-great-upheaval-higher-educations-past-present-and-uncertain-future
13. https://www.cnn.com/2025/03/20/politics/dismantling-department-of-education-trump/index.html
14. https://www.insidehighered.com/news/government/student-aid-policy/2024/11/04/what-abolishing-education-department-could-mean
15. https://campuscafesoftware.com/title-iv-student-financial-aid-guide/
16. https://www.insidehighered.com/news/government/student-aid-policy/2025/03/13/how-education-department-layoffs-could-affect-higher
17. https://www.insidehighered.com/news/government/student-aid-policy/2024/11/14/future-financial-aid-under-trump
18. https://www.latimes.com/world-nation/story/2025-03-19/trump-to-order-a-plan-to-shut-down-the-us-education-department
19. https://www.insidehighered.com/news/admissions/traditional-age/2024/10/23/after-fafsa-issues-steep-drop-first-year-enrollment
20. https://fsapartners.ed.gov/knowledge-center/fsa-handbook/2020-2021/appendices/appx-g-higher-education-act-1965-table-contents-august-26-2020
21. https://www.nasfaa.org/news-item/35894/Trump_Signs_Executive_Order_Seeking_to_Dismantle_ED
22. https://www.nasfaa.org/news-item/35508/ED_Title_IV_Student_Aid_Exempt_From_White_House_Pause_on_Federal_Grants_and_Loans
23. https://www.nea.org/nea-today/all-news-articles/how-dismantling-department-education-would-harm-students
24. https://www.carnegiehighered.com/blog/fafsa-delays-impact-2024-enrollment/
25. https://fsapartners.ed.gov/knowledge-center/library/functional-area/Overview%20of%20Title%20IV
26. https://www.insidehighered.com/news/government/student-aid-policy/2025/02/07/five-ways-education-department-impacts-higher-ed
27. https://www.usatoday.com/story/news/politics/2025/03/12/education-department-cuts-student-loan-fafsa-iep-impact/82310137007/
28. https://www.cbsnews.com/news/trump-fafsa-student-loans-what-does-the-department-of-education-do/
29. https://www.foxsports.com/stories/nfl/dallas-cowboys-free-agency-draft-2025
30. https://www.washingtonpost.com/business/2024/06/22/gen-z-millennials-debt-inflation/
31. https://help.studentclearinghouse.org/compliancecentral/knowledge-base/gainful-employment-financial-value-transparency-faqs/
32. https://19thnews.org/2025/03/trump-executive-order-department-of-education/
33. https://www.ctpost.com/news/education/article/bridgeport-school-superintendent-search-20230032.php
34. https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2024-06-20/implementation-gainful-employment-funding-metric-requirements-institutions-under-administrative-capability-and-financial-responsibility
35. https://crsreports.congress.gov/product/pdf/R/R43159
36. https://www.bestcolleges.com/news/trump-wants-to-end-education-department-what-does-that-mean-for-financial-aid/