Starting Nov. 1, all U.S. Department of Education grant recipients will be required to have written justification for drawing down pre-approved funding, according to a Monday agency memo.
This additional step is part of a federal governmentwide effort under the Trump administration 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” — or DOGE — Cost Efficiency Initiative, also known as “defend the spend.”
The Education Department memo from Murray Bessette, acting assistant secretary for the Office of Planning, Evaluation and Policy Development, said 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 directive applies to all Education Department grant recipients, including those with programs for early childhood education, K-12, higher education and adult education.
The written justifications can be no longer than 255 characters and clear without additional narrative, the memo said.
“This is very much a common sense measure that doesn’t really require much on the part of the grantees, but does provide for better oversight and monitoring, especially going forward,” Bessette, who is also principal deputy assistant in the Office of Planning, Evaluation and Policy Development, told K-12 Dive.
Concerns about payment delays
Some education administrative groups, however, are concerned the process could cause delays in moving federal resources to schools, districts and states.
“Because federal education funds are drawn down through state agencies, the new justification requirements would create additional administrative work for both states and school districts,” said Sasha Pudelski, director of advocacy for AASA, The School Superintendents Association, in an online post Tuesday.
Pudelski said the new process would require states to develop guidance, provide technical assistance and to review submissions, while districts may be required to give detailed explanations for pre-approved expenditures.
The written justifications seem duplicative of existing accountability measures, which include extensive oversight like “detailed application and budget approvals, monitoring requirements, audits and fiscal reviews,” Pudelski said.
“Adding another layer of pre-approval paperwork increases administrative burden without meaningfully improving accountability, redirecting limited administrative capacity away from teaching, learning, and student services,” Pudelski said.
The National Association of State Directors of Special Education, in a Wednesday statement to K-12 Dive, said this new requirement will “impact every student in every school,” especially students with disabilities.
The federal Individuals with Disabilities Education Act, NASDSE said, includes both formula and discretionary grant funds that students with disabilities depend on to receive timely services.
"Any delay in Federal disbursement will directly impact services and potentially deprive our most vulnerable students of FAPE [free and appropriate public education], including children who attend private schools but receive public funding,”NASDSE said.
But a senior Education Department official said the current system requires email exchanges between some grantees and the agency to clarify spending justifications, which slows the payment process.
Many other federal agencies have a written justification process in place for drawdowns, said the official. For example, the U.S. Department of Labor, which has an interagency agreement to manage grants for the Education Department's Office of Career, Technical and Adult Education, has processed 7,600 payments worth $2 billion for those programs since September 2025. Of those, only six payments were flagged for needing further explanation, said the official.
While some other federal agencies may have longer character counts for the written justification, the Education Department has directed its grantees to provide the shorter 255-character explanation, the official said.
If the Education Department or a partnering agency flags a written justification, the grantee will receive an email asking for more explanation. After the grantee updates the request, the payment will be processed, the memo said.
The Education Department will provide support services to grantees and has step-by-step instructions for submitting written justifications.
