ED has entered into new interagency agreements transferring Section 117 foreign gift reporting enforcement to the State Department and six school safety and family engagement programs to HHS. Both agreements raise significant legal concerns and create new administrative complexity for states, districts, and institutions.

The February 2025 Dear Colleague Letter, related FAQs, and April 2025 Title VI certification requirement are no longer operative enforcement tools, but the Department's underlying interpretations remain in place and enforcement continues through other mechanisms. Institutions should not read recent court decisions as ending federal scrutiny of DEI-related activities.

Sligo Law Group, Lawyers for Good Government, and DC Law Collective filed suit in the U.S. District Court for the District of Maryland on behalf of more than 140 career federal employees, challenging the Trump administration's use of reductions in force to carry out politically motivated mass terminations without due process.

OPM has proposed replacing the independent Merit Systems Protection Board with OPM itself as the reviewer of both suitability determinations and RIF appeals — meaning OPM would adjudicate the very actions it helped implement, with no meaningful judicial review and a burden-of-proof structure that is nearly impossible for employees to satisfy.