How Would Project 2025 Impact Higher Ed?

As a reform blueprint, the controversial document is worthy of real consideration.

Candidate Trump has disavowed the document (seriously or not). The former president may well lose the election. Nevertheless, the Heritage Foundation’s Project 2025 is a serious outline for governance in a conservative administration and deserves to be considered as such.

Among the Project’s contents is a chapter on the United States Education Department (ED). The chapter, written by Lindsey Burke of the Heritage Foundation with substantial input from seven other education-policy notables associated with the 2025 Presidential Transition Project, provides an agenda for conservative education reform that is one part bold, one part thorough, and one part cautious. It is excellent at providing a guide for how to reverse perverse progressive initiatives, but it is a work in progress for providing a vision of conservative education policy.

Project 2025 provides an agenda for conservative education reform that is one part bold, one part thorough, and one part cautious.Project 2025’s boldest ambition is to dismantle the ED—an ambition it states in the education chapter’s first sentence. The chapter’s first substantive section (pp. 325-30) details how precisely the ED’s 36 constituent programs should be distributed to Cabinet departments, including the Interior Department, the Labor Department, the Justice Department, and the Health and Human Services Department, and in many cases administered as block grants to the states.

This bold vision partly aims to achieve Heritage’s traditional and principled belief that there is no compelling justification for a bureaucratic federal role in education that permits the existence of an ED. Partly that belief is a pragmatic judgment that the ED’s existence renders it a single agency subject to interest-group capture, thus facilitating unnecessary expenditure (p. 321). Partly it attempts to rein in ED abuses, such as the imposition of radical ideology via the ED’s Office of Civil Rights (OCR), by subordinating OCR to the Justice Department’s more robust procedural guidelines (p. 330). Partly it incorporates interesting reconceptions of American education, such as a proposal to redistribute workforce education (broadly defined) to the Labor Department.

Project 2025 complements this bold ambition with a thorough agenda for how to manage the ED as it currently exists (pp. 331-41). This agenda includes items of great importance and highly bureaucratic language:

The next Administration should also rescind Dear Colleague Letter (DCL) GEN 22-11 and DCL GEN 22-10 and its letters to accreditation agencies dated July 19, 2022, which are attempts to undercut Florida’s SB 7044, providing universities more flexibility on accreditation (p. 332).

A great deal of this detailed agenda consists of rescinding initiatives of the Biden and Obama EDs. My own professional focus interests me most in its detailed plans to remove “diversity, equity, and inclusion” and gender-ideology initiatives—to rescind, in other words, the ED’s requirements for race discrimination and sex madness.

A great deal of this detailed agenda consists of rescinding initiatives of the Biden and Obama education departments.But the Project’s administrative plans and proposals for new education statutes (pp. 341-61) would accomplish an extraordinary variety of additional education reform: enshrining parental rights in law, restoring due process, advancing school choice and education savings accounts, reforming higher-education accreditation, loosening federal regulation on charter schools, ending federal roadblocks to effective school discipline, simplifying student-loan programs, ending fiat loan forgiveness, reforming “area studies” funding, and, of course, reforming the ED’s own procedures to prevent bureaucratic sabotage of conservative policies. “Education reform” involves a multitude of disparate reforms, and Project 2025 cogently sketches practicable means to advance all of these priorities.

Project 2025 does evince some caution to match its boldness. Consider how it phrases its discussion of “social gender transition”:

Facilitating social gender transition without parental consent increases the likelihood that children will seek hormone treatments, such as puberty blockers, which are experimental medical interventions. Research has not demonstrated positive effects and long-term outcomes of these treatments, and the unintended side effects are still not fully understood (p. 333).

Perhaps it is the better part of political wisdom not to say plainly that transgenderism is mutilation and madness, and the political ideology promoting it is sinful. Nevertheless, one could wish that Project 2025 forthrightly named one of the great evils of our day.

More largely, Project 2025 articulates a small-government vision—a presumption that less government is better. But the belief of a growing number of conservatives is that we must use the government to rein in the radicalization and corruption of the “woke elites” distributed in civil society and all levels of government. Consider Senator Tom Cotton’s proposed WEST (Woke Endowment Security Tax) Act, which would institute a six-percent excise tax on the endowments of 10 American universities. Or consider AEI senior fellow Frederick Hess’s suggestion in National Review: “Institutions that apply ideological litmus tests—such as mandatory DEI statements for admission, hiring, or academic promotion—should be stripped of state subsidies and rendered ineligible for taxpayer-funded financial aid or student loans.” Or consider whether there should be a positive federal role in educating students to learn American civic virtues, our country’s ideals and institutions of liberty and republican self-government, and, fundamentally, affection for America. All of these possible initiatives depend upon thinking of the federal government as an essential instrument for conservative education reform. Project 2025’s small-government framework seems to preclude working out how to translate ideas such as these into policy initiatives.

The goal of eliminating the Department of Education does not align rhetorically, politically, or practically with the goal of managing it effectively.Project 2025’s small-government framework may also lead it to an ultimately unproductive commitment to eliminate the ED. The vision of eliminating the ED does stir my heart. But I do not think it likely that we will soon acquire the broad-based political support necessary to ensure its repeal: a president, a majority of the House, and 60 votes in the Senate. Then, too, I worry that distributing education-department programs to the rest of the government would simply spread their habits of mind and commitments to other departments, and that teacher unions and the like would be perfectly able to lobby multiple departments effectively. The existence of the ED also provides a salutary object of ambition to motivate state education reformers. Finally, the goal of eliminating the ED does not align rhetorically, politically, or practically with the goal of managing it effectively. Project 2029, when it is published, should focus on how to manage the ED properly and let drop the internally inconsistent commitment to eliminating the department.

Project 2025 does extraordinarily well at detailing how terrible initiatives by the Biden and Obama EDs should be rescinded, especially in the realm of DEI and gender ideology. It is bold in wonderful ways, including its commitments to parental rights, accreditation reform, and the reconception of workforce education. But I judge that we will not be able to save American education from the malign woke advocates who have spread throughout every level of government and civil society if we forego use of the ED to promote a positive vision of conservative education reform. I urge the drafters of Project 2029 to incorporate a far greater admixture of that vision and to work out how to translate that vision into concrete policy initiatives.

David Randall is the research director of the National Association of Scholars.