January 31, 2026 4:10 am

Impact of Project 2025 on Education and Nonbinary Student Protections

Project 2025 by the Heritage Foundation outlines conservative initiatives for the next administration, impacting education policy.
Project 2025: What Does It Mean for Education?

Project 2025: Mandate for Leadership: The Conservative Promise is a comprehensive document exceeding 900 pages, authored by the Heritage Foundation, a conservative think tank involved in U.S. public policy. Although technically nonpartisan, it is guided by two former Trump administration officials and is widely seen as a conservative policy blueprint for the next conservative administration. The document covers various aspects of government, including the judicial system, Department of Health and Human Services, Homeland Security, and the Department of Education.

We interviewed Paulette Granberry Russell, JD, president of the National Association of Diversity Officers in Higher Education, to gain her insights on how Project 2025 proposes the federal government handle the Department of Education and its potential impact on higher education.

Paulette Granberry Russell, J.D.

Project 2025’s Stand on Civil Rights and Gender Identity

On page 322, Project 2025 outlines its core principles for the future administration. One such principle reads: “Enforcement of civil rights should be based on a proper understanding of those laws, rejecting gender ideology and critical race theory.” Additionally, page 331 suggests that the Office for Civil Rights rescind the Biden administration’s proposal to include a “nonbinary” category alongside “male” and “female” in student data collection. We asked Russell how these positions could affect education and student wellbeing.

According to Russell, the Biden administration’s guidance extends protection from discrimination and harassment beyond the male-female binary by including a “nonbinary” category. This allows the Office for Civil Rights (OCR) to monitor complaints targeting nonbinary students or those perceived as such.

Russell emphasized the importance of understanding nonbinary student experiences, pointing out that data shows these students are more likely to face verbal threats, stalking, and sexual assault. Including a “nonbinary” category helps OCR monitor and address discriminatory behaviors, thus creating more supportive learning environments.

Impact of Shifting Civil Rights Enforcement

Project 2025 also proposes on page 330 that the Office for Civil Rights should move to the Department of Justice (DOJ), which would then enforce civil rights protections solely through litigation. We asked Russell about the potential impacts of this change on post-secondary institutions.

Russell noted that federal agencies like the OCR have specialized knowledge and resources dedicated to understanding educational discrimination. The OCR provides accessible regulatory guidance and can resolve complaints through investigations and mediation, offering quicker relief than litigation. Russell argued that both systems—regulatory guidance and litigation—are necessary for a comprehensive approach to addressing discrimination and fostering systemic change.

Title IX and Gender Identity

Project 2025 recommends rescinding the current administration’s Title IX regulations and defining “sex” solely as biological sex recognized at birth (pages 333-334). Russell discussed how this would impact institutions of higher education.

Russell explained that the expanded definition of sex under Title IX currently protects LGBTQIA+ students. Removing these protections could increase discrimination and harassment, affecting efforts to create a safe and inclusive learning environment. She cautioned that this could lead to feelings of isolation, safety concerns, poor mental health, and reduced extracurricular involvement among affected students.

Accreditation and Diversity Policies

Another proposal in Project 2025 (page 352) aims to prohibit accreditation agencies from using their Title IV gatekeeper role to mandate diversity, equity, and inclusion policies. Russell discussed the potential ramifications of this policy.

Russell emphasized that accreditation ensures institutions meet quality standards. Removing the role of accreditation agencies in promoting diversity and inclusion could reduce accountability and exacerbate systemic barriers, affecting research opportunities, STEM participation, and overall educational quality. She stressed that maintaining these standards is crucial for fostering an inclusive campus culture and supporting student success.

Impact of Eliminating Area Studies Programs

Finally, Project 2025 suggests winding down “area studies” programs at universities (page 356), claiming they sometimes fund programs counter to American interests. We asked Russell about the potential effects on students and interdisciplinary degree programs.

Russell warned that eliminating area studies would limit students’ cultural and global understanding. She pointed out that Project 2025 advocates reallocating at least 40% of funding to international business programs focused on free markets and American interests, which she likened to a forced ideology litmus test. Russell argued that such a move is inconsistent with the mission and values of 21st-century higher education, which should aim to provide a broad and inclusive educational experience.

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