A proposed federal rule threatens Head Start — comments due October 6
On August 7, HHS published a proposed rule that would significantly weaken the Head Start Program Performance Standards, replacing federal requirements for high-quality, 2-generation services with minimal state licensing regulations. If enacted, this would affect the more than 700,000 low-income children and families Head Start serves each year, with particularly severe consequences for families experiencing homelessness.
We’re asking you to take two actions in the next two weeks:
- Contact your Congressional representatives and ask them to oppose these changes through this link.
- Submit a comment to HHS opposing the rule. Here is a link to a template and instructions on how to submit a comment. By law, every comment submitted must be read, so this is a meaningful way to make your position known.
What the rule would change
At Horizons, we know that high-quality care comes through small class sizes, qualified teachers, language access, full inclusion of children with disabilities, protections from harsh discipline, real family partnership, and comprehensive health care. The existing Head Start Program Performance Standards (HSPPS) mirror this understanding.
Receding to state licensing standards would mean larger class sizes, less qualified teaching staff, no limit on suspensions and a return of expulsions, the elimination of multilingual instruction, reduced access for homeless families, optional (rather than required) family support services, and substantial cuts to health services.
The impact on children experiencing homelessness
Because Head Start is where most children experiencing homelessness access early education (in MA, 16% of all Head Start children were homeless), these changes will hit children experiencing homelessness the hardest.
The rule would remove self-attestation of housing status, effectively eliminating eligibility for the many homeless families living in cars and couch-surfing. These families, who exist outside the formal shelter system but feel the full consequences of homelessness, rarely have access to the types of documents now mandated for eligibility. Breaking from decades of precedent where Head Start was a safe haven for homeless families, the proposed rule would exclude many of the families Head Start is meant to serve.
For children experiencing homelessness who remain eligible, the decline in service quality would be significant. Head Start classrooms are often a child’s only consistent access point for health, dental, developmental, hearing, and vision screenings — all screening guidelines would be removed under the proposed rule. Larger class sizes would also reduce the individualized attention these children often need. At Horizons, where more than 70% of children primarily speak a language other than English, a shift toward English-only instruction would limit teachers’ ability to communicate with and support many of the children we serve.
HHS’s justification
HHS says the rule will save $1.5–3 billion a year by 2031 and pay for 236,000 more slots. The savings come from looser ratios, fewer operating hours, a lower cap on administrative costs, cuts to teacher coaching, and fewer home visits – the core components that make Head Start so impactful.
Pulling back federal minimums means quality will vary wildly by state, and children experiencing homeless or with disabilities or health needs will get hit hardest. What we need is more funding, not lower standards – and the MA Head Start Association and many advocates agree.
Current status
No changes have taken effect yet. Existing standards remain in place until HHS issues a final rule, and no deadline has been set for that decision. The public comment period closes at midnight on October 6; more than 2,000 comments have been filed so far.
We encourage you to submit a comment and contact your representatives before the deadline. Thank you for your support of high-quality Head Start.
— The Horizons Advocacy Team
