A year after an electoral mandate promised a seismic restructuring of American institutions, the nation’s education system finds itself caught in the quiet eye of a storm, bracing for a second wave of change far more permanent and profound than the first. The initial blitzkrieg of executive orders, federal investigations, and financial strong-arming that defined the first year of Donald Trump’s second term successfully forced schools and universities onto the defensive. Now, however, the administration confronts a far more formidable challenge: transforming its temporary victories, won through coercion, into a durable legacy etched into federal law. The central question looming over Washington is whether the very strategy that brought the administration its early wins has simultaneously crippled its ability to achieve its ultimate goal, creating an overhaul that risks consuming itself from within.
A System Under Siege How a Blitz of Executive Action Put American Education on the Defensive
The opening year of the administration’s term was characterized by an unapologetic deployment of what insiders termed “sheer executive muscle.” This campaign was not a subtle adjustment of policy but a full-frontal assault designed to shock the educational establishment into compliance. A dizzying number of executive orders flowed from the White House, touching everything from university diversity initiatives to college oversight, creating a landscape of constant uncertainty for administrators. This was a multi-front war, marshaled not just by the Department of Education but by a broad coalition of federal agencies, including the Departments of Justice, Health and Human Services, and even the General Services Administration, all coordinated to apply maximum pressure on targeted institutions.
At the heart of this strategy was an unprecedented barrage of civil rights investigations. The Department of Education’s Office for Civil Rights, supplemented by other federal bodies, launched over 120 separate probes into universities and dozens more into K-12 school districts across the country. These investigations, often targeting policies on diversity, student protests, and transgender rights, were wielded as a potent weapon. Kenneth Marcus, a former civil rights chief in the first Trump administration, noted that the approach utilized civil rights enforcement tools with a “confidence and vigor that is unprecedented in Republican administrations,” signaling a strategic decision to use the legal architecture of civil rights to advance a conservative agenda. The sheer volume of these probes served to bog down institutions in legal and administrative battles, diverting resources and creating a chilling effect on policy decisions.
The most powerful weapon in the administration’s arsenal, however, was the financial hammer. In a move that sent shockwaves through the academic world, the administration froze over $5 billion in federal research grants and contracts to some of the nation’s most prestigious universities. Institutions like Harvard, which saw over $2 billion in funding halted, and Cornell, which faced a $1 billion freeze, were put in an untenable position. The list of affected universities grew to include Columbia ($400 million), the University of Pennsylvania ($175 million), Brown ($510 million), Northwestern ($760 million), and UCLA ($584 million). At the K-12 level, similar tactics were employed, with threats to withhold funding for school lunches in Maine and to revoke the federal status of five Virginia school districts over their transgender-inclusive policies. This financial leverage proved effective in the short term, compelling several universities to alter their policies to unfreeze desperately needed funds.
The Stakes of the Second Term Why a War on the Educational Status Quo Matters
The administration’s aggressive actions were not random but were meticulously designed to achieve a clear set of ideological objectives. The overarching goal was to fundamentally realign American education with the administration’s political and cultural vision, effectively ending what it views as decades of progressive dominance in academia and public schooling. This war on the educational “status quo” is about more than just policy; it represents a determined effort to reshape the institutions that mold the nation’s youth, rooting out philosophies and programs deemed antithetical to its agenda. The stakes, therefore, extend beyond the classroom to the very cultural fabric of the country.
Central to this agenda is the systematic dismantling of Diversity, Equity, and Inclusion (DEI) programs, which the administration views as a primary driver of divisive and discriminatory practices on campus. Alongside this effort is a push to redefine and enforce protections against antisemitism, often linking the issue to antiwar protests that swept campuses in previous years. Furthermore, the administration has championed a significant devolution of power, seeking to bolster parental rights and enhance state-level control over educational matters. This dual focus on cultural issues and federal overreach aims to energize its political base and deliver on long-standing conservative promises to reduce Washington’s footprint in local schools.
A key battleground in this ideological war has been the redefinition of student rights, particularly concerning transgender policies. The administration has moved decisively to enforce a strict biological definition of sex, barring transgender students from participating in sports and using facilities that align with their gender identity. This policy, enforced through the threat of civil rights investigations and funding cuts, places the federal government in direct opposition to the more inclusive policies adopted by many school districts and universities. This fight over the interpretation of “sex” under federal law is emblematic of the administration’s broader effort to roll back the legal and social gains of LGBTQ+ individuals and codify a more traditionalist worldview into federal policy.
The Anatomy of the Overhaul A Two Phase Strategy of Coercion and Codification
Despite the initial successes of its pressure campaign, the administration has long recognized the inherent vulnerability of its achievements. Victories won through executive orders and enforcement actions are, by their nature, impermanent. A future president could, with the stroke of a pen, reverse these directives, unraveling the administration’s work overnight. This understanding has prompted a critical strategic pivot, moving from a campaign of temporary pressure to a concerted effort to build a lasting policy infrastructure that can withstand political shifts.
This transition marks the beginning of what conservative legal expert Bob Eitel has dubbed the “year of rulemaking.” After a period defined by aggressive enforcement, the focus is now shifting toward the far more complex and arduous task of codifying the administration’s agenda into formal federal regulations. “This has been a year of enforcement through investigation,” Eitel explained. “Next year will be the year of rulemaking.” This second phase is arguably the most critical part of the entire overhaul. It represents the bid to transform a political vision into enduring legal reality, creating “lots and lots of rules” that would be difficult and time-consuming for any subsequent administration to dismantle.
The primary legal vehicles for this permanent overhaul are Title IX of the Education Amendments of 1972, which prohibits sex-based discrimination, and Title VI of the Civil Rights Act of 1964, which bars discrimination based on race and national origin. The administration’s plan involves engaging in the formal rulemaking process to rewrite the regulations that implement these landmark laws. By formally enshrining its definition of sex as strictly biological and its interpretation of antisemitism as a form of discrimination under Title VI, the administration aims to create a permanent legal basis for its policies on transgender student rights and campus speech. This move from enforcement guidance to binding regulation is the cornerstone of its strategy to create a legacy that outlasts its time in office.
Voices from the Trenches Experts Weigh in on the Promise and Peril of the Rulemaking Gambit
Proponents of the administration’s strategy express unwavering confidence in this two-phase approach, viewing it as a bold and necessary correction to years of bureaucratic inertia and progressive overreach. They argue that the initial campaign of “sheer executive muscle” was essential to break the resolve of an entrenched educational establishment. Kenneth Marcus championed the “confidence and vigor” of the enforcement actions as a sign that the administration was serious about its commitments. From their perspective, the pivot to rulemaking is a natural and logical next step, building on the momentum gained during the first year.
Conservative legal scholar Bob Eitel articulated this view, framing the shift as a move from a temporary enforcement posture to the creation of lasting, durable rules. He and other supporters believe that the depleted state of the Department of Education is not a bug but a feature, resulting in a more nimble and ideologically aligned agency capable of executing the president’s agenda without the resistance of career staff. They argue that a smaller, more focused department can effectively push through the new regulations, solidifying the administration’s policy goals and providing clear, unambiguous guidance to schools and universities for years to come.
However, critics and former officials paint a starkly different picture, predicting a collision with the unglamorous realities of federal bureaucracy. Ted Mitchell, a former top official in the Obama administration’s Department of Education, foresees an inevitable “regulatory logjam.” He argues that the very act of gutting the agency has robbed it of the essential expertise and manpower required for the “long, detailed and painstaking work” of drafting complex regulations that can withstand legal challenges. The process involves extensive research, public comment periods, and meticulous legal justification, all of which demand a level of institutional capacity that the department may no longer possess.
This skepticism has been amplified by significant legal defeats that have blunted the administration’s most potent weapon. Federal judges in both Boston and California ruled that the freezing of research funds for Harvard and UCLA was an illegal abuse of executive power, with one judge condemning it as a “pressure campaign.” These court rulings did more than just return funds to two universities; they created a legal precedent that has emboldened other institutions to resist. As Mitchell noted, a strategy of “bludgeoning them one by one” is not scalable to the thousands of educational institutions across the country, especially now that the legal pathway to fight back has been illuminated.
The Administration’s Achilles’ Heel Analyzing the Self Inflicted Obstacles to Success
The greatest threat to the administration’s education overhaul may not come from its political opponents or legal challengers, but from a deep, internal paradox of its own creation. In its zealous pursuit of dismantling the federal education bureaucracy, the administration has hollowed out the very agency it now needs to enact its ambitious vision. Education Secretary Linda McMahon has successfully carried out the long-promised goal of shrinking the department, halving its workforce and pushing out many experienced career employees. This has left a skeletal agency tasked with undertaking one of the most complex and demanding regulatory agendas in its history.
This dramatic reduction in manpower has severe practical consequences. The agency is simultaneously facing a crowded agenda dictated by Congress. It is already under tight deadlines to implement the sweeping provisions of the newly passed “One Big Beautiful Bill Act,” which includes major reforms to student loan programs, an expansion of Pell Grants, and the creation of a new school choice tax credit. These legislatively mandated tasks are resource-intensive and must compete with the administration’s own ideological rulemaking priorities for the attention of a vastly diminished staff. This creates a bottleneck where ambition far outstrips capacity, making it difficult to advance on any front effectively.
Compounding these internal weaknesses are the unforgiving procedural hurdles of federal rulemaking. The Higher Education Act imposes a “master calendar rule,” which requires that most new regulations be finalized by November 1 of a given year to take effect the following July. Missing this deadline can result in a full-year delay in implementation, a critical setback for an administration operating on a fixed political clock. This strict timeline leaves little room for error, yet the combination of a depleted workforce, a packed agenda, and the inevitable legal challenges makes delays almost certain.
The administration’s grand design for a permanent educational realignment ultimately ran aground on the shoals of its own making. The same aggressive tactics that secured early victories—the staff purges, the executive blitz, and the disregard for bureaucratic norms—became the very shackles that prevented its ambitions from being forged into lasting law. It was a strategy whose success in the short term guaranteed its struggle in the long term, leaving the future of the American classroom hanging precariously in the balance.
