By Emilie Martin, Research and Advocacy Coordinator, National Parents Union
America prides itself on being a place where anyone can build a life of opportunity regardless of where they are born or how much money they have. Today, for our youngest Americans, that launchpad into opportunity just became much harder to access. The Department of Health and Human Services has just released a new rule on our nation’s Head Start program that – if approved – will lower our national standard for how we care for our youngest, most vulnerable children.
Head Start is a critical lifeline for families across the country and has been since President Lyndon B. Johnson established the program as a part of his War on Poverty, calling it, “one of the most constructive, and one of the most sensible, and also one of the most exciting programs that this nation has ever undertaken.” President Johnson underscored the need to build ladders of social mobility, saying the goal of the program is to “to make certain that poverty’s children would not be forevermore poverty’s captives.”
Ask a Head Start parent what they love about their program and not one will say “the Program Performance Standards.” They’ll tell you about the teacher who noticed their child holding books an inch from their face because they needed glasses, or the home visit two weeks after the baby came home to help everyone get settled.
Every one of those things happens because a federal rule says it has to. But, on August 7th, the Administration for Children and Families (ACF) issued a Notice of Proposed Rulemaking that would erase that rulebook.These changes to the Head Start program will make kids less safe, create barriers to hard-working parents, parents working and contributing to the economy and leave our most vulnerable children without critical support.
Head Start serves 800,000 kids from birth through age 5 in our country. There are more than 18,000 head start locations across the country. Over the past 60 years, the program has served over 40 million children, creating stronger families, mobilizing women in the workforce, and disrupting cycles of poverty.
Head Start programs across the country have a leadership structure that empowers communities to build programming that is right for them. Parents across the country serve on Policy Councils that decide how money is spent and what programs are available to their kids.
The Head Start Act created the framework, but it is a national set of standards, called the Head Start Program Performance Standards, that set the regulations each program must follow. These standards, which were updated in 2024, do everything from establishing training for teachers, to establishing health and mental health programming services, services for students with disabilities and creating reporting requirements to improve the program.
The new proposed rule replaces 1,400 requirements with twenty short rules, transforming a system of high-quality centers of access into a deregulated wild west. Anything not specifically named in the Head Start Act is turned over to state child care licensing, or to whatever each local program decides on its own.
This will mean limited and unreliable access to screenings for kids who may be in need of additional support, a lack of commitment to high quality care and learning, and a dramatic cut to how many adults are supporting kids across the country.
State licensing sets bare minimum safety requirements. They are designed to keep children from getting hurt, not to guarantee that a child is screened for hearing troubles or speech delays, or that a parent gets a seat at the table.
Head Start has always been unusual among federal programs because it hands parents actual power. Not with a survey or a suggestion box, but with a seat at the table, a vote on what matters, and a committee at every center.
The proposed changes directly impact the regulations designed to keep parents involved and in charge.
Today, every center is required to have a parent committee and federal rules cover how it is structured and what it does. The proposal would allow a committee without requiring one, and it drops the rules entirely.
These committees are where a parent who has never spoken at a public meeting learns that they can.
This assessment is how a program notices that a shelter opened, or that a plant closed and put parents out of work, or that twelve families moved in speaking a language nobody on staff speaks. Under the proposal, an assessment would still be mandatory but the requirements for how often it must be done, what data it has to include, and when it has to be updated are removed.
An assessment with no deadline and no information guidelines can draw any conclusion that is convenient and fits the budget.
This is the family and community engagement piece that helps families determine their goals, then helps them find the resources they need to make them happen.
In a proposal built on removals, ACF snuck in an added requirement: programs would have to provide educational material and instruction demonstrating healthy marriage as a positive good. Head Start classrooms are filled with grandparents raising grandchildren, single parents, foster families, widowed parents and every other version of family you can imagine, and no parent or child should be made to feel ashamed or excluded because of this. Head Start has run for sixty years without a marriage instruction mandate that would establish a federal position on what family should look like.
Today a class of four-year-olds holds no more than 20 children with two adults in the room. That regulation is stricter than any state regulation in the country. This proposed rule change replaces the federal ratio and group size limits with state licensing minimums. For example, Texas allows 18 children per adult at that age. HHS projects this change will shrink the teaching workforce by up to 24 percent. That means each teacher will see a roughly 32 percent increase in students. As a direct result, more teachers will be overwhelmed with large class sizes they can’t serve as effectively, which will both increase turnover and staffing shortages while decreasing quality of care.
Preschool classrooms will no longer be required to run 1,020 hours per year. The new minimum would be three hours per day – not even a full work shift. The agency’s solution is that families may need to find other child care, which would cost parents money and work time, while the very parents that Head Start aims to serve are often working multiple full-time jobs and still struggling to make ends meet without the added costs of supplementary child care.
Congress wrote three duties into the Head Start Act that protect children experiencing homelessness: find and prioritize these children, let them enroll and attend with a 90-day grace period for records to catch up, and coordinate with the school district’s McKinney-Vento liaisons. Head Start served more than 60,000 children experiencing homelessness in 2024-25, the highest count on record.
The proposed rule change repeals these regulations. So, a mother with no shelter loses the signed declaration and the proposal would bar self-attestation. Currently, there is a 90-day window that allows a child to start while waiting for records to catch up to them. Under the proposed rule change, that exemption would disappear. Right now, programs can hold a spot for a family living in a shelter for 30 days. Under the new rule, a director who reserves a spot would violate the regulation.
The new proposal would require all lessons to be taught in English and prioritize teaching English to a child who doesn’t speak it, effectively eliminating bilingual education at the time that a child’s brain is most malleable for language acquisition. ACF also cuts the requirement to have one adult in the room who speaks the language spoken by most of the class. They also budget almost $47 million to remove non-English books, curriculum and word toys out of 18,767 classrooms.
The proposal still requires a standardized, research-based curriculum, but the regulation on how it should be implemented would be removed.
The proposal would still require research-based developmental screening, but the 45-day and 90-day timing is removed. A screening in April instead of October costs a child almost an entire year without help, and early identification is how a child with a disability gets services before kindergarten instead of years later.
ACF is proposing to cut the rule that bars expulsion and limits suspension, leaving each program to write its own policy. This affects boys more than girls, and disproportionately affects Black boys more. Head Start has some of the lowest expulsion rates in early childhood, and the federal ban explains much of that. ACF would also cut the monthly mental health consultant in the same rule. Combined with delays in screenings, the loss of language services, and increases in class sizes, it’s likely that more children will act out and face exclusionary discipline simply because their needs aren’t being identified or met.
Another new provision would bar programs from requiring or incentivizing postsecondary credits, hours or credentials until they can prove the credential is necessary for that position. The provision also requires alternate ways to show the skill. Qualification requirements for Head Start directors, family child care providers, coaches, family service staff and health professionals are removed completely.
Skills based hiring is a fair idea; requiring a program to justify preferring the more qualified candidate is a wild one. Head Start prides itself on not just providing places for kids to go while their parents are working, but places for kids to learn and grow; this starts by hiring qualified educators.
Programs will still be required to interview, verify references, and obtain state, tribal or federal criminal record checks before hiring. However, the new rule would remove the requirement that programs re-run background checks every five years. HHS added that in 2016 to protect child safety; now it’s described as an unnecessary administrative burden.
For now, these are just proposed changes, and ACF wants to know how you feel about it. The public comment period is open until October 6th and anyone can file one. The agency has to read what comes in and respond to it before anything becomes final. This is your opportunity to share how these changes will impact you and your community, and we want to empower you to play an active role in the process.
Go HERE and follow the instructions to submit your comments by October 6th. You can file as an individual or an organization.
Three things make a comment carry weight:
The National Parents Union represents 1.8 million families across more than 1,800 organizations in every state. Head Start built a lot of those parent leaders in exactly the committees this proposal makes optional.
Let them hear your voice. Tell the Department of Health and Human Services to continue to invest and support a critical federal program that has helped pull millions of kids out of poverty.