Rights Without Enforcement: Individuals with Disabilities Education Act (IDEA), Section 504, and School Psychology Practice in an Era of Federal Retrenchment

The 2025 restructuring of federal education governance has direct consequences for school psychologists serving students protected under the Individuals with Disabilities Education Act (IDEA) and Section 504 of the Rehabilitation Act. Staff reductions at the Office for Civil Rights (OCR) have produced a complaint backlog exceeding 24,000 cases; the Office of Special Education Programs has experienced parallel reductions that have effectively eliminated a federal technical assistance infrastructure built across decades. In June 2026 the Department transferred IDEA administration to the Department of Health and Human Services and civil rights enforcement to the Department of Justice, a change whose consequences differ sharply by framework because IDEA carries statutory procedural safeguards that Section 504 lacks. Current disparities in service quality across states are substantial, and they exist despite federal oversight, which clarifies rather than softens the prediction. Historical evidence from periods of federal retrenchment suggests these disparities will widen as monitoring and enforcement diminish. Students on Section 504 plans are particularly exposed: their enforcement mechanism was never the statute itself but OCR complaint investigation, and that mechanism has largely collapsed. The analysis applies established, empirically supported practices to a context those studies did not anticipate: diminished federal enforcement. Specific approaches include building local accountability systems, strategic documentation informed by research on individualized education program (IEP) quality, consultation frameworks with demonstrated effectiveness, and advocacy consistent with professional ethics. Federal statutes remain in force; students retain their legal rights. The question is how school psychologists maintain professional standards when the infrastructure supporting those standards has been substantially eroded.Impact StatementFederal agencies that enforced the education rights of students with disabilities were substantially reduced in 2025, and in 2026 their remaining functions were transferred to other departments. The laws did not change, so students still hold the same rights, but the systems that made those rights real have weakened. This article explains what changed, why students served under Section 504 are more exposed than students receiving special education under IDEA, and what school psychologists can do locally to keep services adequate and to create records that will matter when enforcement returns.