Washington Update

What this means for our field:  An IAA changes who administers a program. It is not, by itself, a change to the law that creates the program or the appropriation that funds it. Holding that distinction is the most useful thing we can do in the conversations ahead. Two of these reach our members beyond special education: the civil-rights agreement wherever your graduates meet Section 504 and ADA duties, and the privacy agreement wherever FERPA touches IEP records. The agreement closest to us is the ED-HHS agreement covering OSERS, and that is where I will spend most of our time.

2.  What an Interagency Agreement Actually Is

An IAA lets one federal agency provide services to another on a reimbursable basis. It rests on the Economy Act (31 U.S.C. 1535) and ED's own statutes; it is paid for only out of appropriations ED already holds, so no new money is created or moved; and it is a routine, bipartisan tool with government-wide standardized forms. ED has a recent precedent in its own house: an IAA with the Department of Labor now runs the WIOA Title II and Perkins V programs, processing more than 4,900 payment requests totaling $1.3 billion as of May 2026.

What this means for our field:  An IAA is an administrative services arrangement, not a handoff of the law. That is reassuring on legal authority, and it is exactly why the real questions live in the operational details: who does the work, on what system, under whose direction, and with what oversight.

3.  The Agreement Closest to Us: ED-HHS / OSERS

Effective June 15, this agreement has HHS support the administration of the full OSERS portfolio at ED's direction: IDEA Parts B, C, and D; the Rehabilitation Act programs; Randolph-Sheppard; the Disability Innovation Fund; Special Olympics Education; the Education of the Deaf Act programs including NTID; the Helen Keller National Center; the American Printing House for the Blind; and Gallaudet University. OSERS oversees roughly $15.5 billion in FY 2026 for early intervention and K-12 special education.

For us, the detail that matters most is that IDEA Part D, and within it the Personnel Preparation program that funds the people who prepare special educators, is named in the agreement. It is administered under this agreement; it is not eliminated by it. The agreement governs administration, not funding levels. ED still designs the competition, sets the priorities and eligibility, and holds final authority.

A few mechanics: FY 2026 awards still run through ED's G5 system, while later awards would move to HHS's GrantSolutions and Payment Management System. The day-to-day work is to be done primarily by ED staff detailed to HHS, and the terms of that detail are a separate staffing agreement that has not yet been negotiated.

What this means for our field:  On the question that matters most to us, the federal lever for building the special-educator workforce, the structure is intact on paper. HHS is the administrator, not the policymaker. That is the accurate read to carry into conversations, and it is why the open questions below deserve our attention: a structure sound on paper still has to be sound in practice.

4.  Two Tracks: Don't Conflate Them

If you take one habit from this update, take this one. Two separate things are happening to our programs, and blurring them is the surest way to lose an argument with a member or a reporter.

Bottom line:  The IAA changes who helps administer the programs. It does not set their funding, and it does not move the law. Our June edition covered Track 1 in depth; this edition is about Track 2. When the two get conflated, we lose precision, and precision is our advantage.

5.  What the Agreements Keep the Same

It is as important to be precise about what does not change. Drawn directly from the signed agreements and their fact sheets:

• ED keeps final, conclusive authority over enforcement, policy, and personnel decisions across all four agreements.
• IDEA's protections predate the Department of Education and continue; the federal duty to enforce IDEA is unchanged.
• The fact sheets state there is no anticipated adverse impact on program eligibility for agencies, entities, or institutions.
• States and grantees, per the Department, should not expect programmatic disruptions, and should keep working with their existing OSERS and HHS staff through the same channels.
•  FY 2026 awards continue to run through ED's G5 system.

What this means for our field:  These assurances are real and on paper, but “should not expect disruptions” is the Department's expectation, not yet a track record. Our job is to hold the agencies to it, document any gap between promise and practice, and bring the specifics forward. That is advocacy with evidence, the only kind that moves anyone.

6.  What's Still Open: The Watch List

Several questions are genuinely unresolved. I would rather name them honestly than paper over them.

• The staffing agreement. Who details from ED to HHS, how many, and how their work is funded. This is the detail most likely to determine whether expertise travels with the function.
• The grant-system transition. The timing of the move from ED's G5 to HHS's systems is not yet set.
• The FY 2027 Part D competition. How the next Personnel Preparation competition runs, and where to apply when the NOFO publishes. ED still sets priorities and criteria.
• The Senate's FY 2027 bill. The House has acted; the Senate writes its own bill, after which the chambers reconcile. The funding lines are not final.
• Reorganization authority. Appropriators in both parties flagged concern about fragmenting programs in the FY 2026 explanatory statement; the House FY 2027 bill is silent on the IAAs. Whether Congress and the courts weigh in is unsettled.
• Oversight visibility. The report's 30-day grant-briefing directive, running through November 2027, should add public visibility into NOFO timing. Process updates come through known OSERS and HHS channels, so watch those first.

7.  Where TED Stands

Let me be plain, as I was in the room on the 18th. This is a hard moment, and not a change we would have chosen. But worry is not where this story has to end.
Here is what I most want you to hold onto, because it is true and it is earned. TED has been at the table with HHS, and HHS has been at the table with us. Every conversation we have had there has been rooted in a shared commitment to people with disabilities and the educators who serve them. That relationship did not begin with these agreements, and it does not end with them. It is the foundation we build from.

“Our commitment to students with disabilities, and to the educators who serve them, has never belonged to any single agency or office.”

So we will do what we have been doing, and do it well. We will work with HHS to protect the federal commitment to special-education personnel preparation and research, and to strengthen support for the profession. We will stay at the table in good faith, ready to give credit where it is earned, wherever these programs are housed, and clear-eyed wherever the practice diverges from the promise.

What anchors that posture is discipline. We read the documents before we react. We separate the funding fight from the administration question, because conflating them costs us credibility. And we hold our advocacy to the standard of evidence, focused on what actually happens to the people in our pipelines and the scholars doing the research. That is the work, and it is ours to do: program by program, scholar by scholar, shortage by documented shortage.