Defend the Spend: What Districts Need to Know About New Federal Grant Oversight
Learn how federal funding changes impact special populations.
Federal funding plays a significant role in supporting special populations programs, so changes to federal grant requirements deserve attention, even when their effect on Texas school districts is not yet clear.
One development to watch is Defend the Spend, a federal initiative introduced in 2025 as part of the Department of Government Efficiency (DOGE) effort to increase oversight of federal spending. While the initiative itself is not new, the U.S. Department of Education recently announced plans to implement the initiative for grant recipients beginning November 1, 2026.
What will this mean for our programs and services supported by federal funds? We do not have all the answers, but we know enough to begin preparing.
So, what's changing?
Beginning November 1, 2026, U.S. Department of Education will require grant recipients to provide a brief explanation when requesting a federal grant payment.
The explanation is limited to 255 characters and must identify:
- The federal grant program
- The types of expenses, such as personnel, supplies, travel, or contracted services
- The amount associated with each expense category
- The beginning and ending dates of the expenditures
The amounts listed must equal the total payment requested. Districts currently collect much of this information. The real question is whether we will need to provide it in a different format in the reimbursement process.
District leaders who managed COVID-era federal relief funding may remember the SmartSheet submissions required with each drawdown. That memory may make a few of us shudder! This process may not look like the previous one, but the experience illustrates how quickly new reporting requirements can increase administrative work, although the current announcement does not establish that the process will operate the same way. It is important to remain aware of changes as the November 1 deadline looms.
Grant recipients have been advised that payment requests could take longer to process if the U.S. Department of Education needs clarification or identifies a concern. Requests may be approved, returned for additional explanation, or denied. Here is to hoping there are many more approvals than anything else!
What does this mean for Texas school districts?
Most Texas school districts receive federal education funds through the Texas Education Agency rather than directly from a federal agency. It is not yet clear whether Defend the Spend will change the reimbursement process for districts. Questions that still need to be answered include:
- Will TEA require additional information with reimbursement requests?
- Will districts need to change their current procedures?
- Can TEA use information districts already submit?
- Will additional state or federal review delay reimbursements?
The November 1 implementation date does not necessarily mean that districts receiving funds through TEA will need to change their procedures on that date.
Districts that receive grants directly from a federal agency should consult their business office or grant administrator to determine whether Defend the Spend applies. Requirements and implementation dates may vary by agency.
Why should special populations leaders pay attention?
Federal funding supports many programs administered by special populations leaders, including special education services funded through the Individuals with Disabilities Education Act (IDEA), Title I programs and language instruction programs funded through Title III.
Although business offices and federal programs staff typically submit the reimbursement requests, special populations administrators play an important role in ensuring that expenditures are:
- Allowable under the grant
- Consistent with approved activities
- Supported by appropriate documentation
- Communicated clearly to the staff responsible for reimbursement
AASA, The School Superintendents Association, has expressed concern that Defend the Spend could increase administrative work and delay grant payments. The Department of Education has stated that it does not expect normal processing times to change, although requests requiring clarification may take longer. Federal staffing and organizational changes may also be relevant as districts monitor how consistently and quickly payment requests are reviewed.
What can districts do now?
For now, districts should not change their reimbursement procedures based solely on this announcement. Instead:
- Continue following current TEA requirements
- Maintain clear and complete expenditure documentation
- Coordinate with business office and federal programs staff
- Monitor communications from TEA, TASBO, and federal grant agencies
- Confirm requirements for any grants received directly from a federal agency
Defend the Spend does not change which expenses are allowable under existing federal grants.
What’s next?
Additional guidance is expected regarding both Defend the Spend and proposed revisions to the federal Uniform Grant Guidance. Although these are separate developments, each could affect how districts document expenditures and manage federal funds.
TASB Student Solutions will continue monitoring information from the Texas Education Agency (TEA) and the Texas Association of School Business Officials (TASBO). TASB Student Solutions will share updates as they become available.