This issue brief is part of a series from the Center for American Progress exposing how the sweeping Project 2025 policy agenda would harm all Americans. This new authoritarian playbook, published by the Heritage Foundation, would destroy the 250-year-old system of checks and balances upon which U.S. democracy has relied and give far-right politicians, judges, and corporations more control over Americans’ lives.
Authors’ note: The disability community is rapidly evolving to using identity-first language in place of person-first language. This is because it views disability as being a core component of identity, much like race and gender. Some members of the community, such as people with intellectual and developmental disabilities, prefer person-first language. In this column, the terms are used interchangeably.
The Heritage Foundation’s Project 2025—a 900-page authoritarian playbook for a far-right presidential administration—will radically harm disabled people across the United States.1 As the disability community continues to grow in the United States due to an aging population, long COVID, and other factors,2 it is important to evaluate how Project 2025’s agenda would specifically affect disabled people, who make up at least 28.7 percent of the U.S. population.3
Project 2025’s far-right, undemocratic plans4 will dismantle protections and services for disabled people across the country. Executive action could bring many of these plans to fruition swiftly. Below are five ways in which Project 2025 would harm the disability community.
1. Project 2025 plans to eliminate the rights of and protections for disabled students
Disabled students rely on the enforcement of specific federal laws and regulations in order to obtain an equitable education in the least restrictive setting. Project 2025 proposes multiple structural changes that would directly affect students with disabilities.
Moving the Office of Special Education and Rehabilitative Services to HHS
The U.S. Department of Education was created to strengthen the federal commitment to ensuring access to equal educational opportunity for every individual and to help “improve the coordination of Federal education programs.”5 By eliminating the department and segregating Office of Special Education and Rehabilitative Services programs6 to various agencies, including the U.S. Department of Health and Human Services (HHS),7 Project 2025 would make it much more difficult to coordinate a knowledge base and resources. It would also be harder to ensure that disabled students receive a free, appropriate public education in the most integrated setting, as promised by the Education for All Handicapped Children Act of 19758 and the Individuals with Disabilities Education Improvement Act (IDEA) of 2004.9
Eliminating earmarked funding for special institutions
Project 2025 intends to eliminate earmarked funding and thus strip disabled people of access to valued educational institutions,10 possibly including the National Technical Institute for the Deaf, the American Printing House for the Blind, and Gallaudet University.11 These institutions provide disabled students with education and support when they can’t receive an equitable education in mainstream public schools.
Redistributing public school funding into K-12 education savings accounts and converting most IDEA funding into a no-strings formula block grant
States or families would likely pay more due to unregulated allocation and use of IDEA funding under Project 2025.12 IDEA authorized the federal government to pay 40 percent of the average per-student spending for special education services.13 However, current funding is at less than 13 percent.14 Under Project 2025, schools would receive funding from individual student savings accounts managed by nonprofits.15 It is unclear whether these schools would be required to abide by IDEA16 and Section 504 of the Rehabilitation Act.17
Rescinding equity in IDEA regulation
Project 2025 would eliminate the equity requirements in IDEA.18 This would negatively affect data tracking and funding to address racial segregation and stigmatization issues that students of color often face within special education programs.19 In 2018, Trump administration Secretary of Education Betsy DeVos decided not to implement an Obama-era rule to standardize the Department of Education’s Civil Rights Data Collection survey data on students of color in IDEA programs. Her decision ensured that the government and the public could not track and address the inequities that students of color faced in schools.20 Project 2025 intends to continue those efforts to hamstring the Department of Education’s data collection. It also intends to remove the 15 percent reallocation of IDEA Part B funding to institutions, which addresses discrepancies around the overrepresentation of students of color in special education and around the rate of discipline—including suspensions—of students with disabilities. 21
2. Project 2025 would enact major cuts to key health coverage programs and services
If enacted fully, Project 2025 would worsen the already fragile state of care for disabled people,22 making it significantly harder for disabled people to receive the care and support they need.
Threatening Medicaid
Project 2025 would slash funding and services by converting Medicaid funding to block grants or per capita caps, thus restricting the amount of money states would have to spend on Medicaid.23 Project 2025 would also make it harder for states to provide essential home- and community-based services for people with disabilities.24 Most egregiously, Project 2025 would set time limits on Medicaid coverage or arbitrary lifetime caps on benefits, which could put millions of Americans at risk of losing coverage.25 Project 2025 would also attempt to introduce failed policies such as work requirements for Medicaid eligibility.26
Repealing Medicare’s ability to negotiate drug prices
Project 2025 would fully repeal the Inflation Reduction Act (IRA).27 If this occurs, up to 18.5 million Medicare Part D enrollees could face increased out-of-pocket costs for prescription drugs.28 People on Medicare would lose the financial security provided by the IRA’s annual and monthly out-of-pocket caps, and Medicare would once again be banned from negotiating lower prices directly with drug companies.29
Separating the subsidized ACA exchange market from the nonsubsidized insurance market
Project 2025 intends to separate nonsubsidized Affordable Care Act (ACA) plans from subsidized plans and to provide “market regulatory relief” from ACA regulatory mandates.30 In other words, it would strip consumer protections from people who buy insurance on their own. This would allow plans to revert to discriminating against people with preexisting conditions; setting lifetime caps on coverage; charging people more or denying them coverage altogether based on their medical history; or excluding benefits for basic services such as mental health care or maternity care.31
Losing access to choice and privacy
Project 2025 would reduce health care choice—including with regard to reproductive health care—by effectively banning abortion medication, which is used for a range of medical conditions that affect the disability community. It would also reduce health privacy by requiring HHS to force each state to surveil “how many abortions take place within its borders, at what gestational age of the child, for what reason, the mother’s state of residence, and by what method.”32 Project 2025 also advocates for tracking comparisons between live births and abortions across demographics, potentially targeting marginalized communities.33
Restructuring the Centers for Disease Control and Prevention
Project 2025 would reduce the size of the U.S. Centers for Disease Control and Prevention (CDC) and split the agency in two, jeopardizing its ability to mitigate pandemics by limiting its scientifically based public health recommendations and guidelines. The changes would decrease the CDC’s role in tracking disease outbreaks and recommending masking or clean air initiatives to reduce the spread of respiratory illness, in addition to limiting access to public health data. This would put disabled people, who tend to have weaker immune systems and complex medical needs, at higher risk.
3. Project 2025 would create even more barriers to employment for disabled workers
According to U.S. Bureau of Labor Statistics estimates, 7.6 million workers identified as disabled in September 2024.34 Project 2025 could eliminate basic worker protections for people with disabilities.
Eliminating Employment Information Report data collection
Project 2025 intends to remove the Equal Employment Opportunity Commission’s (EEOC) enforcement capacity of antidiscrimination laws by making it impossible to demonstrate how an employer’s workplace policies and practices can harm workers. Eliminating Employment Information Report data collection35 would weaken the EEOC’s authority to file, mediate, and settle discrimination lawsuits against employers on behalf of workers.36
Limiting EEOC consent decrees
By prohibiting the EEOC from entering into consent decrees,37 Project 2025 would make workplaces less safe for disabled employees. Currently, the EEOC can file a suit against a company that it has found to have likely violated Title I of the Americans with Disabilities Act (ADA). If found guilty, an employer may be forced into a consent decree,38 which would require them to change policy and practice to prevent future harm and to report on their efforts.39 Consent decrees may also provide financial settlements to affected employees.40 Limiting the ability of the EEOC to use consent decrees would reduce the federal government’s power to address discrimination against disabled workers.
Eliminating the Office of Federal Contract Compliance Programs
The Office of Federal Contract Compliance Programs was created after executive orders directed the U.S. Department of Labor to administer nondiscrimination and affirmative action provisions41 and consolidated multiple agencies’ equal employment opportunity contract compliance enforcement powers.42 Project 2025 intends to eliminate the office,43 pushing much of the burden of compliance enforcement onto the EEOC, which, as stated above, would lose much of its enforcement ability.
Limiting ADA protections for women
While Project 2025 affirms that pregnancy-related disabilities are protected under the ADA, it specifically states that employers would not be required to provide health insurance benefits for “elective abortions.”44 However, “elective” remains subject to interpretation and creates ambiguity in situations where medical intervention may be necessary. Providers fear that postponing care could result in negative health outcomes or even death.45Project 2025 also explicitly states the intention to misuse an outdated statute called the Comstock Act to achieve a backdoor, nationwide abortion ban by inhibiting the transfer of medication abortion via mail.46 Banning medication abortion would worsen preexisting health care disparities, particularly for disabled pregnant people, and create insurmountable barriers to care.47
4. Project 2025 would restrict disability and other social benefits
Overhauling the VA claims process
Project 2025 would automate the U.S. Department of Veterans Affairs (VA) claims process48 and make it more difficult for veterans to obtain disability benefits.49 The VA assigns disability ratings based on the severity of a veteran’s medical condition and uses those ratings to calculate benefits.50 Project 2025 would reduce the number of medical conditions that service members can claim to qualify for their disability rating.51 With this change, veterans currently eligible for a rating but who have not yet made claims could be denied benefits entirely.52 Veterans who have made claims and been granted a disability rating could see their VA benefits decreased.53 Automating claims could also increase denial rates54 and place a heavier administrative burden on veterans.55
Restricting SNAP and increasing work requirements
Even with the restrictive definition of “disability,”56 the Supplemental Nutrition Assistance Program (SNAP) provides about 4.1 million disabled people57 with essential nutrition assistance. Disabled individuals are more likely than nondisabled workers to work part time58 and to engage in contract work59 and have significant barriers to obtaining eligibility for Supplemental Security Income (SSI) and Social Security Disability Insurance (SSDI).60 This leaves many disabled people unable to access disability special rules around work requirements.61 Project 2025 intends to eliminate “work requirement waivers” for states,62 putting disabled people who aren’t receiving SSI or SSDI or who aren’t classified as disabled by the VA at risk of losing their eligibility.
5. Project 2025 would reduce the ability to enforce the ADA
Project 2025 proposes that the federal government stop using “disparate impact” regulations in assessing discrimination and cease bringing lawsuits that challenge the standard’s constitutionality.63 The disparate impact regulations from the U.S. Department of Justice seek to ensure that “programs accepting federal money are not administered in a way that perpetuates the repercussions of past discrimination” in employment, education, housing, and other areas.64Discontinuing the use of disparate impact rules would make it harder for the federal government to enforce civil rights protections under the ADA, for example.
Conclusion
Project 2025 takes a wrecking ball to federal measures that address real issues disabled people face in accessing critical supports and services. If even only some of the policies outlined here are fully enacted or required by executive order, disabled people would face insurmountable hurdles to living and participating in their communities.65
The authors would like to thank Will Roberts, Andrea Ducas, Emily Gee, Weadé James, Jared Bass, Alan Cohen, Jill Rosenthal, and Kate Kelly for their guidance and reviews. Thanks also goes to the Legal, Editorial, and Art teams for their guidance. Thanks to Haley Norris for their assistance in fact checking.