The Trump administration hollows out federal special education oversight via administrative relocation. They are preserving the law on paper. They are moving the work that makes the law real to a building where the phones will not be answered. The Department of Education is dismantling the Individuals with Disabilities Education Act by relocating every person, every function, every line of accountability that has given that statute any meaning, while pretending the law still exists in the same room.

Let me show you what the text actually says.

Matthew 25:35–40: “For I was hungry and you gave me food, I was thirsty and you gave me something to drink, I was a stranger and you welcomed me, I was naked and you gave me clothing, I was sick and you took care of me, I was in prison and you visited me.” The righteous ask when they did this. The king answers, “Truly I tell you, just as you did it to one of the least of these who are members of my family, you did it to me.”

The passage does not say “I was hungry and you left the food on the counter.” It does not say “I was sick and you wrote me a letter saying the clinic has moved.” The command is proximate. The command is functional. The command is the work of the hands that reach out, not the posture of the mouth that pronounces the blessing.

The administration’s strategy is the posture of the mouth pronouncing the blessing while the hands reach for the door. The Department of Education says the statute is intact. The staff who implement the statute are now at HHS. The funding flows, they say—the same officials who, as this column has previously documented when the administration first shifted these offices three weeks ago, have been moving programs to other agencies via interagency agreements that do not require congressional approval. This is an end run around the statutory requirement that only Congress can dismantle a cabinet department.

Jacqueline Rodriguez of the National Center for Learning Disabilities put the legalist maneuver plainly: “The concern is not that IDEA disappears overnight. The concern is that the administration is preserving IDEA at the Department of Education on paper, while moving much of the work that makes IDEA real for families somewhere else.” This is the gap between letter and life. The letter of the law remains; the life of the law is relocated; the gap is where the vulnerable fall through.

Jesus had a word for this maneuver. He called it the whited sepulcher.

Matthew 23:27: “Woe to you, scribes and Pharisees, hypocrites! For you are like whitewashed tombs, which on the outside look beautiful, but inside are full of the bones of the dead and of all kinds of uncleanness.” The passage is part of the seven woes against the religious authorities of Jesus’ day—men who were meticulous about tithing cumin while neglecting “the weightier matters of the law: justice and mercy and faith” (23:23). The legalist does not destroy the law. The legalist preserves the law’s appearance while evacuating its substance. The legalist is the most dangerous figure in the text, because the legalist cannot be accused of lawbreaking while doing the work of the law’s undoing.

What is happening now to special education is a legalist operation. The Department of Education is not repealing IDEA. The Department of Education is hollowing IDEA. The plain-language reading of the statute is this: students with disabilities have a legal right to a free appropriate public education. The federal government has a legal obligation to keep states accountable for that right. The federal government provides funding. The federal government monitors compliance. The federal government investigates violations. The federal government offers technical assistance. Every one of those verbs requires staff. Staff who know the law. Staff who are reachable by phone. Staff who can be fired by a secretary of education who answers to an elected president.

Move the staff to HHS, and the federal government still has a legal obligation on paper—but the line of accountability runs through a secretary whose attention is consumed by Medicaid, Medicare, FDA drug approvals, and pandemic preparedness, an agency with missions that dwarf special education monitoring, and a physical location that no parent can find. Move the staff to HHS, and “no one left behind” becomes “everyone left on hold.” This is the same administrative neglect we saw when federal civil rights data for schools was already six months overdue—the infrastructure of accountability does not just fail when it is repealed; it fails when it is relocated.

I want to name something here, because the complicity of the tradition is the load-bearing thing.

The tradition that formed my conscience read Matthew 25 as individual charity. For decades, the captured-brand Evangelical apparatus trained believers to hold the Bible in one hand and vote for policies that dismantled the structures of care in the other—Medicaid work requirements, the perennial push to block-grant IDEA funding, the gutting of the social safety net—feeling no contradiction. The text was filtered into personal good works—a one-to-one act, a private act, a heart-act. The structural command was quietly dropped. The command that the institutions through which believers live—the federal agencies, the school systems, the funding streams—must be organized so that the sick get visited systematically, reliably, with accountability and resources, was never taught.

That was the tradition’s failure. The God of the Bible cares how power is organized. The God of the Bible asks about the design of the system, not just the character of the individual. The God of the Bible says to the king, not just to the neighbor: did you keep the vulnerable safe?

The legalist’s own text is Romans 13—the command to be subject to governing authorities. The legalist will say this is a legitimate exercise of governmental authority to reorganize for efficiency. But Romans 13:4 specifies that governing authorities are God’s servants for the good. The good in this context is not abstract efficiency; it is the concrete justice the prophets demand. Isaiah 1:17: “Learn to do right; seek justice. Defend the oppressed.” Micah 6:8: “To act justly and to love mercy and to walk humbly with your God.” There is nothing humble about a reorganization that disability advocates, parents, and educators uniformly describe as creating “more confusion, slower guidance, weaker monitoring and less accountability.”

When Amos 5:24 thundered “Let justice roll on like a river, righteousness like a never-failing stream,” he was indicting a system that performed worship while crushing the poor. The administration is performing a kind of policy worship—the ritual of preserving a law’s name—while allowing the machinery of justice for disabled students to be washed away into a different department, a different budget, a different set of congressional oversight committees. The stream is being diverted. The river is being dammed. An abomination dressed as administration.

A different building, a different desk—these do not change job responsibilities, the press secretary claims. But a different agency with a different mission, a different culture, a different set of priorities? That changes everything. It changes who they answer to. It changes what they prioritize. It changes how quickly they respond. It changes whether the parent who calls this fall to ask why her son’s IEP evaluation is overdue ever gets a person on the line, or only a recording.

Denise Marshall of the Council of Parent Attorneys and Advocates called the strategy “a sham.” A sham is a legalist thing—it preserves the form while the substance is elsewhere. The sham is the Department of Education that still exists, technically, legally, on the map, while the actual work of education for the most vulnerable students in the country has been relocated to an agency whose relationship to those students is incidental rather than central.

There is a verse that has been on my mind. It is not one the captured-brand Evangelicals quote. It is Jeremiah 22:13–16, the prophet’s word to the king who was building his palace by injustice: “Woe to him who builds his house by unrighteousness, and his upper rooms by injustice, who makes his neighbors work for nothing, and does not give them their wages.” The prophet is naming what the king is doing—not the king’s inner thoughts, not the king’s religious profession, not the king’s claim to divine favor—but the king’s administrative choices. The bricks. The labor. The pay that is or is not delivered.

Jeremiah says the king knew God to the extent that the king did justice for the poor and needy. “Is that not what it means to know me?” says the Lord. The measure of the king’s knowledge of God was the king’s administrative competence in keeping the vulnerable safe.

The measure of this administration’s knowledge of God is its administrative competence in keeping vulnerable students safe. The measure is failing. The measure is being failed on purpose.

The advocates on Thursday’s call asked for a timeline. They were not given one. They asked for a plan. They were reassured instead. They asked how the funding would flow once the staff were relocated to a different building, a different floor, a different desk. They were told not to worry.

“Do not worry” is what the shepherds said in the nativity scene—not what the wolves said. The shepherds said do not worry because they had good news. The wolves say do not worry because they have a plan, and the plan is that no one notices.

Congress retains the power to stop this. Only Congress can dissolve a cabinet department. The administration knows this. That is why the administration is dismantling the department piece by piece, office by office, staff-member by staff-member, through interagency agreements that do not require a vote and will not generate a headline until the harm is already done.

This is the legalist maneuver. This is the whited sepulcher. This is the administration that says we are not taking over the statute, period, while moving the people who make the statute real to a building where the phones will not be answered.

There will be children. There will be specific children, with specific names, in specific school districts, with specific individualized education programs, who will not get the services they are legally owed this fall. There will be delays. There will be guidance that does not arrive. There will be monitoring that does not happen. There will be accountability that does not follow, because the line of accountability has been cut.

The children will not understand what has happened to them. They will think something is wrong with them. They will think they were not enough. That is what happens when the shepherd does not come.

The shepherd was never coming. The shepherd was reassigned. The shepherd’s office is now at HHS. Please hold.