Scores of Iowa public school districts now have affirmative action plans that encourage race-based hiring and other diversity initiatives, according to a new report by Parents Defending Education, potentially imperiling their federal funding under new guidance issued by the Trump administration.
The plans, which are required by state law, include hiring goals for minority teachers, courses on "equity in mathematics," and bonuses for teachers who specialize in "culturally responsive leadership." Some set percentage targets for "BIPOC representation" or explicitly say that race is "considered when making employment decisions."
While the law requiring the plans does not instruct districts to use racial preferences, it does expect them to set "goals and timetables for reduction of underrepresentation." The result, in practice, has been a glut of race-conscious hiring initiatives across Iowa’s public school system, putting a state that Donald Trump won comfortably in 2024 on a collision course with his administration’s priorities.
"The fact that this is taking place in a state that President Trump carried by such a wide margin in 2024 serves as a reminder of just how pervasive identity-based policies are in America and that identifying and terminating these programs is going to be an ongoing process for the foreseeable future," said Nicole Neily, the director of Parents Defending Education. "Hiring on the basis of race was reprehensible during Jim Crow, and it's just as odious—and illegal—as it was then."
The Department of Education said in a "Dear Colleague" letter this month that it would treat any form of race-based decision-making as a violation of federal law. The guidance, which takes effect on Feb. 28, even applies to programs that do not use race directly but are "motivated by racial considerations," such as trainings that traffic in "crude racial stereotypes" or decisions that rely on "non-racial information as a proxy for race."
That language could implicate a host of programs enshrined in the affirmative action plans. Des Moines Public Schools, for example, has a goal of increasing "the number of teachers of color in Kindergarten by 8%" and the "number of teachers of color in Third Grade by 5%." While those goals "are not to be treated or understood as rigid and inflexible quotas that must be met," according to the plan, race will "serve as a selection criteria" for any roles "where underrepresentation exists."
The Des Moines plan also gives teachers a salary bump if they complete Drake University’s "Culturally Responsive Leadership" degree program, which includes courses on "Urban Education" and "Equity in Mathematics."
In the Waterloo Community School District, a program provides "financial resources and resilience support for Waterloo staff of color seeking a teaching certification." In the Pella Community School District, "race, sex, or disability" can serve as a "‘plus’ factor for individuals from an underrepresented background," while in the Sioux City Community School District, there are "multiple committees and teams devoted to diversity, equity, and inclusivity."
All of those districts could lose federal funding if they do not suspend their affirmative action plans by the Feb. 28 deadline.
A spokeswoman for the Waterloo school district, Emily Frederick, said that the plan referenced in Parents Defending Education’s report was "outdated" and had not been in use since 2022. But the district’s most recent plan, which was active through the end of 2024, includes a long list of race-based programs as well as outright quotas, such as a policy of ensuring that "a person of color is represented on every hiring committee."
"We are currently in the process of updating [our policies] per further guidance from the U.S. Department of Education and our attorneys," Frederick told the Washington Free Beacon.
A spokeswoman for Sioux City Community School District, Leslie Heying, noted that its plan "is dated 2022-2024" and said that the district was "working to align our protocols and processes" with the "Dear Colleague" letter.
Representatives from other districts did not respond to requests for comment.
The law requiring the plans was passed in 1989, at a time when affirmative action was less politically salient. Its language of "goals and timetables" came directly from the executive order that Lyndon B. Johnson signed in 1965—and which President Trump repealed on his second day in office—mandating affirmative action in federal contracting.
While that order forbade the use of racial quotas, it also forced contractors to create plans to remedy the underrepresentation of minorities.
The result was an unstable compromise between principles of non-discrimination and principles of equal results. Iowa’s education law, which uses the phrase "equal employment opportunity," shows how that compromise can collapse into quotas and lead to the very sort of preferences that civil rights law officially prohibits, creating major liabilities for employers now that the political winds have shifted.
The plans themselves exemplify this dynamic. On page six of its "equal employment" plan, the West Des Moines Community School District states that an "affirmative action ‘goal’ is not a rigid 'quota' or a 'set-aside' of a specific position for a person of a particular race." But on page 13, it outlines a set of "numerical goals" that are extremely specific, such as hiring "two non-unit and/or supervisor/specialists who identify as a race/ethnicity that is underrepresented."
A plan for the College Community School District likewise includes detailed "goals" for each job category. By 2026, the plan states, there should be a "a minimum of 11% BIPOC" representation among the district’s 12 school principals, only one of whom—or 8 percent—is currently a minority. The same goal applies to elementary, secondary, and special education classroom teachers.
For roles where "BIPOC" are overrepresented relative to their share of the population—such as assistant principals, 20 percent of whom are minorities—the plan does not call for reductions in hiring. Instead, it says that the district should "continue to meet the staffing goal of a minimum of 11% BIPOC," ensuring a permanent underrepresentation of white staffers.
As of Monday morning, the plan had been removed from the College Community School District's website.