Despite being seen by some as additional red tape, starting November 1, 2026, all U.S. Department of Education (USDE) grant recipients will be required to have written justification for drawing down pre-approved funding. ,
According to a September 28, 2026 agency memo. an additional step has been added to add accountability and transparency for spending taxpayer funds. The directive comes from President Donald Trump’s February 2025 executive order for the Department of Government Efficiency (DOGE) Cost Efficiency Initiative, also known as “defend the spend.”
As per the memo, grant recipients will be required to provide “clear, detailed justifications for each payment request.” Each request must include the program name, expense categories and amounts, and the start and end dates for expenses. The written justifications can be no longer than 255 characters and clear without additional narrative. The directive applies to all Education Department grant recipients, including those with programs for early childhood education, K-12, higher education and adult education.
Some education organizations, including the National Association of State Directors of Special Education (NASDE), are expressing concern that the process could cause delays in moving federal resources to schools, school districts, and states. Presently, federal education funds are drawn down through state agencies, but the new justification requirements would create additional administrative work for both states and school districts since another layer of pre-approval paperwork increases administrative burden and redirect limited administrative capacity away from teaching, learning, and student services.
On September 30, 2026, NASDE released a statement the new requirement will “impact every student in every school,” especially students with disabilities. In fact, the federal Individuals with Disabilities Education Act includes both formula and discretionary grant funds that students with disabilities depend on to receive timely services.
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