By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. As the Trump administration continues advancing its plan to dismantle the Department of Education through a series of interagency agreements, uncertainty remains the defining feature of the federal education landscape. Each week brings new indications of how deeply these moves are straining the systems students, counselors, and institutions depend on — from grant management and program oversight to civil rights enforcement and borrower support. What was once framed as administrative “streamlining” has instead revealed widespread disruption, shrinking capacity, and growing confusion across agencies. Against this backdrop, educators, state leaders, tribal nations, and higher education institutions are raising alarms about the operational, legal, and equity implications. It is within this environment of rapid change and diminished transparency that NACAC continues to monitor developments, engage partners, and advocate for the stability and protections that students and institutions urgently need.

Policy & Legislative Updates 

Internal documents continue to underscore how fragile — and risky — the administration’s dismantling of the Education Department truly is. Even the small-scale transfer of OCTAE to the Labor Department strained ED’s capacity and nearly disrupted funding, raising serious concerns as far larger programs are slated for relocation to Labor, HHS, Interior, and State. Staff describe a lack of answers, rising anxiety, and real fears that these moves will weaken oversight, destabilize grant management, and disrupt services that students and institutions rely on. While the administration frames these shifts as efficiency, the internal assessments paint the opposite picture.

The ripple effects are being felt across communities. Tribal leaders have sounded the alarm that the administration’s decision to shift dozens of Native American education programs to other federal agencies was made without the legally required tribal consultation. Leaders from Standing Rock to the American Indian Higher Education Consortium warn the transfers will create instability, add bureaucratic hurdles, and undermine supports for Native students — a direct breach of trust and a failure to center those most impacted. Tribal advocates are calling for the transfers to pause until meaningful consultation occurs and capacity concerns are addressed.

On campuses, heightened immigration enforcement is adding another layer of uncertainty. North Carolina institutions are responding to intensified ICE and CBP activity across Raleigh, Durham, and Charlotte by issuing urgent reminders about FERPA protections and protocols for verifying warrants, but anxiety among students is rising. International students, faculty, and staff report unconfirmed sightings of federal agents and growing concern that existing protections are insufficient in this moment. National survey data reinforce these trends: a new EdWeek analysis shows increased immigration enforcement is leading to missed school days, disengagement, and higher demand for mental health supports — especially in high-poverty districts. Many schools still lack clear written protocols, leaving students and educators without reliable guidance. Our partners at the Presidents’ Alliance on Higher Education and Immigration have developed resources designed to support school counselors, K-12 educators, and college counselors working with mixed-status and undocumented families. These tools provide timely information, policy clarity, and community support to help educators and counselors advocate for students and expand access to higher education.

Legal challenges are also accelerating. The Department of Justice has sued California and its three public higher education systems to strike down the state’s decades-old policy allowing undocumented students to pay in-state tuition — a move that threatens affordability for thousands and adds another layer of uncertainty for institutions already navigating a volatile policy environment. Meanwhile, the administration’s broader effort to dismantle ED has resurfaced a two-century-old debate over the federal role in education. Scholars note that shifting congressionally mandated programs across multiple agencies is more symbolic than substantive, and almost certain to create confusion at a moment when institutions need clarity and stability.

Congressional scrutiny is intensifying. Senator Elizabeth Warren has called on the department’s inspector general to investigate the dismantling effort, citing incomplete responses from ED, concerns about weakened civil rights enforcement, and questions around staff selected for reductions in force. Her letter highlights the growing unease in Congress as transparency declines, and the administration accelerates timelines for moving programs out of the department.

Transparency within the administration’s reorganization efforts is shrinking, with reports that senior officials have been required to sign non-disclosure agreements limiting what they can share about the department’s restructuring. Staff relocations to Labor and HHS are already underway, even as timelines, logistics, and implications for students and institutions remain unclear. The challenges are already evident: the transfer of career and technical education programs to Labor earlier this year resulted in grant-system glitches, delayed reimbursements, and confusion among state leaders. These individuals warn that shifting $28 billion in K–12 funding — particularly Title I — into a workforce-focused agency is likely to deepen inequities and operational dysfunction. Despite assurances of a “smooth transition,” educator feedback reflects a growing sense that capacity shortfalls and misaligned missions are putting vulnerable students at risk.

The administration’s shrinking of ED’s internal capacity is also showing up in borrower relief efforts. The department is seeking an 18-month extension to resolve borrower defense claims under the Sweet v. McMahon settlement, citing diminished staffing and resource constraints. Advocates warn that delays would undermine the agreement’s core promise of timely relief for students defrauded by predatory institutions.

Elsewhere, the administration continues to pressure institutions through federal investigations. Northwestern has reached a $75 million settlement — similar to earlier agreements with Columbia and Brown — to close federal probes and restore access to research funding. The agreement requires updated discrimination and harassment policies and new protections for Jewish community members and international students. While ED leaders call these deals a model for accountability, critics warn that the settlements reinforce ongoing federal intrusion into institutional governance.

Legal challenges to the dismantling effort are expanding as well. A broad coalition of states, districts, unions, and disability-rights advocates has amended its lawsuit arguing that outsourcing core ED responsibilities violates federal law and destabilizes systems that students and educators rely on. The complaint points to mounting delays, reduced capacity, and increased confusion as clear evidence of harm.

In contrast to these destabilizing trends, new research highlights the important role international students have played in strengthening U.S. higher education. A new National Bureau of Economic Research (NBER) analysis shows that the surge of Chinese students entering U.S. master’s programs in the early 2000s not only fueled academic growth but also helped keep tuition down for American students and boosted local economies. These findings come as policymakers consider tighter visa restrictions and increased scrutiny of Chinese nationals.

On campuses, financial and policy pressures continue to drive difficult decisions. November saw a wave of program cuts, layoffs, and other cost-saving measures tied to declining research funding, steep drops in international enrollment, and new state laws mandating program closures. Institutions cite a challenging landscape shaped by shifting federal policy and eroding public trust.

Concerns about institutional autonomy deepened further when the Trump administration asked a state court to compel the University of Pennsylvania to release names and contact information of Jewish students and employees — a demand widely condemned by higher education leaders, civil rights groups, and Jewish organizations. Penn has refused to release identifying information without consent, citing its responsibility to protect privacy and safety.

In more positive news, NCAN’s FAFSA Tracker offers critical insight into early FAFSA completion trends for the class of 2026. While overall completions are rising under the simplified form, significant disparities persist across race, income, and community type — a reminder that simplification alone cannot close longstanding equity gaps in financial aid access.

Research on direct admissions also reinforces that policy changes work best when paired with sustained support. New analyses show that direct admissions boosts application and enrollment rates, but affordability, advising, and clear communication remain central barriers. NCAN’s new Direct Admissions Best Practices hub brings together state models and practical guidance for partners seeking to strengthen or implement these programs, emphasizing that direct admissions are most effective when integrated into a broader strategy that centers student support.

Finally, new data from the National Student Clearinghouse Research Center show that college completion rates have remained remarkably stable despite the pandemic-era disruptions faced by the fall 2019 cohort. Full-time enrollment and early exposure to college coursework continue to be strong predictors of completion, with dual-enrollment students posting especially high success rates. Yet persistent gaps by income, gender, age, and enrollment intensity underscore the ongoing equity challenges facing institutions and policymakers.

NACAC Advocacy 

This week, NACAC continued to deepen our advocacy on several fronts as the landscape around federal education policy grows more complex. We met with coalition partners to coordinate our shared response to the administration’s accelerating effort to dismantle the Education Department. These conversations focused on the operational disruptions already emerging across federal programs, the cascading impact on students and institutions, and the need for a unified strategy to defend core functions ranging from civil rights enforcement to financial aid administration.

Our team also engaged in ongoing discussions around Negotiated Rulemaking — particularly the RISE and AHEAD committees — as we prepare for another round of regulatory debates that will shape the future of accreditation, student protections, and institutional accountability. Workforce Pell continues to be a central topic in these conversations. NACAC is working closely with partners to ensure that any expansion aligns with quality standards, safeguards students from predatory practices, and strengthens — rather than fragments — pathways to meaningful postsecondary credentials.

We also spent time this week in conversations with congressional offices. These meetings provided insight into evolving legislative priorities and helped us better understand how we can support and strengthen our partnerships with lawmakers. With shifting appropriations dynamics, growing concern about agency reorganization, and heightened attention to affordability heading into 2026, maintaining close communication with congressional staff remains essential. Our goal is to ensure that NACAC members’ perspectives on access, equity, and student well-being are shaping the policies under development in real time.

Across all of this work, NACAC continues to emphasize the same core message: students, counselors, and institutions need stability, transparency, and a functioning federal education infrastructure. We will remain at the table with partners and policymakers to protect these commitments and advocate for solutions that keep students at the center of every decision.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

As we navigate another week of shifting policies and mounting uncertainty, one constant remains: the collective strength of this community. Counselors, educators, and advocates continue to show up for students with clarity and conviction, even as the systems around them grow more unstable. Your work — the daily guidance, the advocacy, the steady presence — is shaping outcomes in ways that matter deeply.

In this moment, I am reminded of a reflection from Michelle Obama:

“You may not always have a comfortable life and you will not always be able to solve all of the world’s problems at once. But don’t ever underestimate the impact you can have, because history has shown us that courage can be contagious and hope can take on a life of its own.”

While uncertainty feels overwhelming, these words ground us in what endures: our shared commitment to students, our belief in opportunity, and the power of collective action. NACAC will remain beside you in this work — steadfast, vigilant, and hopeful about what we can accomplish together.