to those challenges and a greater opportunity to engage industry experts, Vann-Jackson said. Industry experts Vann-Jackson cites include School


Transportation News’ Transporting Students with Disabilities & Special Needs conference, the National As- sociation for Pupil Transportation, the National School Transportation Association, and the National Associa- tion of State Directors of Pupil Transportation Services. “Many of these organizations have political or organi-


zational advocacy committees tied into legislative efforts at the federal level,” she said, noting the best approach for districts is to stay engaged and diplomatically voice concerns. Special education attorney Julie Weatherly observed


it is difficult to assess the impact moving the Office for Civil Rights (OCR) to the DOJ will have on students with disabilities, given significant staffing reductions as well as the closure of seven OCR regional offices with no specific plans as to how the changes will work. “While OCR has allowed for significant backlogs in


complaint resolution to accumulate over time, my expe- rience working with OCR in the Section 504 complaint process has traditionally involved a more administrative and collaborative approach focused on resolution and remedies for a specific student, rather than the more liti- gious and broader approach often utilized by DOJ,” said Weatherly, who keynotes next month’s TSD Conference. She emphasized transportation departments serving


students with disabilities may face DOJ investiga- tive procedures examining systemic violations of the Americans with Disabilities Act (ADA) and Section 504 complaints referred by OCR and filed more like a class-action lawsuit. “DOJ traditionally will ask for all kinds of district-wide


information through deposition-style interviews, exten- sive records, data review requests and on-site visits and observations during its investigations with a much more heavy-handed approach,” she explained. “Transporta- tion departments should conduct internal audits of their practices, policies and procedures regarding transpor- tation of students with disabilities to ensure they are aligned with the nondiscrimination requirements of the ADA and Section 504.” Departments should be prepared to respond to student and staff safety issues, discipline, appropriate supervi- sion, student and staff-based bullying and harassment, service animal transportation, and the provision of equitable, timely, and appropriate and required accom- modations and transportation services to students with disabilities in accordance with their IEPs and 504 plans, she added. “They also need to ensure documentation of


compliant practices, policies and procedures and imple- mentation thereof exists and is ready if ever requested,” Weatherly said, sharing that legal counsel should be


sought to assist in an internal review as well as if an OCR complaint is filed in order to prepare for addressing and responding appropriately to DOJ’s enforcement process. Glenna Wright-Gallo, a former assistant secretary


of the Office of Special Education and Rehabilitation Services at ED and current vice president of strategic research and policy for adaptive technologies provider Everway, noted while the entitlement doesn’t change, the June 2026 IAA moving IDEA Parts B, C, and D operations from ED’s Office of Special Education and Rehabilitation Services (OSERS) to HHS introduces “real friction risk on the administrative side.” Under the IAA, HHS is supporting specified IDEA administrative functions including grant administration, monitoring-related work, data functions and fund draw- downs, she noted. “ED retains statutory authority and ultimate respon-


sibility for IDEA oversight, policy and enforcement functions,” Wright-Gallo added. “For districts, that means a new point of contact and a new system learning curve at exactly the point where transportation directors need fast answers on allowable uses, reimbursement timing and compliance questions.” There is recent precedent for this kind of disruption. The Career and Technical Education and adult educa- tion programs Perkins V and Workforce Innovation and Opportunity Act (WIOA) Youth Program Title II moved to the Department of Labor (DOL) in the first pilot IAA in May 2025 and again when Every Student Succeeds Act Title I, Title II-A, and Title IV-A followed in November 2025, Wright-Gallo noted. “Rural school leaders reported receiving funds roughly


two months late because DOL’s grant system did not rec- ognize state education agencies’ existing bank accounts, which was a basic onboarding failure,” she added. “That same category of risk applies to the fiscal year 2027 transi- tion of IDEA grants into HHS’ GrantSolutions and Payment Management System. Fiscal year 2026 awards remain in ED’s G5 system for now, so delays are not imminent.” She noted three compounding factors raise the odds


of delay or confusion, including reduced technical as- sistance capacity, mixed federal messaging and staffing shortages, including among school bus drivers. While the legal right to transportation as a related ser-


vice hasn’t changed, Wright-Gallo said the risk is delay through a slower drawdown of IDEA funds, a teacher’s aide request backlog, or a rocky fiscal year 2027 systems transition. That could push back the purchase of adapt- ed vehicles, hiring and training of aides, or approval of specialized routes tied to a student’s IEP. Wright-Gallo noted while federal restructuring has changed the operational home of programs, federal staffing, and the movement of grant systems and guidance for some non-students with disabilities, those changes do not alter IDEA, Section 504 or McKinney-


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