Early Futures Partnership Submits Comment on Proposed Federal Changes to Head Start

Early Futures Partnership submitted this comment today on the Administration’s proposed changes to Head Start. We urge Nebraskans to learn more about the proposal and submit their own comment in opposition before the October 6 deadline. Learn more about the proposed changes to Head Start 

Thank you for the opportunity to submit public comment to Notice of Proposed Rule Making (NPRM): “Reducing Federal Burden for Head Start Programs,” Docket ACF-2026-0595 (RIN: 0970-AD30).

Early Futures Partnership, a joint initiative in Nebraska supporting early childhood community practice and public policy, is writing to share concerns about the proposed changes to the Head Start Program Performance Standards (HSPPS). We advocate for quality early care and learning opportunities for Nebraska’s youngest children, including the 5,400 children served by Head Start across 64 of Nebraska’s 93 counties. Streamlining requirements to better serve children is welcome, but those efforts should not come at the cost of Head Start’s proven ability to ensure that all children, regardless of their families’ income, have the support they need for school readiness and successful life outcomes.

Summary
The NPRM in its initial form lacks a clear regulatory framework that preserves Head Start’s consistent ability to deliver high-quality early childhood education and wraparound services to all children, regardless of where they were born, while supporting a more flexible standard that empowers local control.

Our topline concerns:

• Lower standards undermine Head Start’s proven model: Head Start consistently delivers positive school readiness and life outcomes through quality early learning experiences and support services to children and families with limited access to resources. Removing many existing standards could create a system in which the quality of a child’s experience depends on where they live.
• A lower administrative cap constrains program resources: Overhead such as facilities costs and support personnel are essential for programs to operate as highly functioning Reduction in the cap would restrict high functionality, especially those with less organizational or community support.
• Less guidance leads to confusion: A regulatory framework that enables flexibility for local control and clear expectations leads to better The NPRM removes many standards without clear guidance, which could lead to confusion and inconsistency across the Performance Standards.
• Weakened best practice for support services: Evidence-based guidance for health, disability and parental supports lead to better developmental Many of the standards outlining how to deliver these services would be eliminated—requiring programs to develop their own instead of following a clear guidance playbook.

Analysis and Recommendations

1. Replacement of current HSPPS § 1303.5 with newly inserted § 1303.14
   • Topic: Limitations on development and administrative cost
   • Impact: Decreasing the administrative cap from 15% to 5% will hinder grantees’ ability to meet their fiduciary responsibilities for oversight and other requirements in statute, especially for those who have fewer community partners or organizational support. Noted in the NPRM is that only 3.7% of grants nationwide meet the proposed threshold—meaning that the anticipated impact will be widespread.
   • Recommendation: Restore current HSPPS § 1303.5 and remove newly inserted § 1303.14

2. Addition of newly inserted § 1301.12
   • Topic: Personnel policies
   • Impact: Restricting local control over administrative and support staff minimum qualifications and incentivizing credentials would deter grantees’ ability to serve their communities’ needs through higher quality program delivery. Placing the burden of proof on grantees to demonstrate their desired staff qualifications and educational supports adds additional regulatory burden.
   • Recommendation: Remove subsection (c) from the newly inserted 1301.12

3. Replacement of current HSPPS § 1302.21 with newly inserted § 1301.05
   • Topic: Center-based option
   • Impact: Removal of the current federal standards for ratio and group size requirements would create an inconsistent standard across the country for the quality of one-on-one teacher interactions with children. It would also place many grantees outside the scope of safety standards established by states regarding ratio and group size requirements, since not all states require Head Start programs to be licensed, including Nebraska.
   • Recommendation: Restore current HSPPS 1302.21 and remove newly inserted § 1301.05

4. Removal of current HSPPS § 1302.17
   • Topic: Suspension and expulsion
   • Impact: Removal of HSPPS 1302.17 would allow expulsions and lift suspension limitations of young children. This raises concerns that children with disabilities, developmental delays, behavioral needs or histories of trauma could be disproportionately removed from programs.
     Recommendation: Restore current HSPPS § 1302.17

5. Replacement of current HSPPS § 1302.31 with newly inserted § 1301.04
   • Topic: Teaching and the learning environment
   • Impact: Requiring programs (excluding Tribal) to provide English-only instruction does not recognize the cognitive benefits of supporting home-language development. This may lead to delayed school readiness and efforts to identify children with developmental delays or disabilities, which rely heavily on language-based tools. It is also important to note that programs already instruct multilingual learners in English.
   • Recommendation: Remove subsection (a) from the newly inserted § 1301.04

6. Replacement of current HSPPS § 1302.12 with newly inserted § 1301.02
   • Topic: Determining, verifying and documenting eligibility
   • Impact: Removal of self-attestation to verify eligibility based on homelessness, income or age would present an enrollment barrier for vulnerable populations. Noted in the NPRM is that roughly 8% of currently enrolled children would lose access without further documentation, which is unobtainable for many of those experiencing homelessness, in foster care or experiencing domestic violence. Head Start is often the only place of stability for many of these children.
   • Recommendation: Amend subsection (i)(3) from current HSPPS § 1302.12 into the newly inserted § 1301.02

7. Replacement of current HSPPS § 1302.16 with newly inserted § 1301.03
   • Topic: Attendance
   • Impact: Removal of attendance monitoring and follow-up requirements would eliminate many of the current safeguards in place to ensure that children have successful life outcomes and receive the supports they need for school readiness. Attendance promotion strategies are a unique aspect of Head Start’s proven model.
   • Recommendation: Replace subsection (a) in newly inserted § 1301.03 with current HSPPS § 1302.16

8. Replacement of current HSPPS § 1302.60-63 with newly inserted § 1301.10
   • Topic: Additional services for children with disabilities
   • Impact: Removal of HSPPS standards for early intervention support services, referral, coordination of services and other disability-related requirements under the federal Individuals with Disabilities Education Act (IDEA) would remove the ease with which programs may follow best practice guidance. Programs may not have the capacity to familiarize themselves with IDEA regulations, especially given the proposal to cut the administrative cap. Additionally, children awaiting IDEA eligibility determination could lose services.
   • Recommendation: Restore current HSPPS § 1302.60-63 and remove newly inserted § 1301.10

9. Replacement of current HSPPS § 1302.40-47 with newly inserted § 1301.04(b), 07, 08, & 09
   • Topic: Health, nutrition and mental health services
   • Impact: Removal of best practice guidance on research-based screening timelines, additional health care coordination and other comprehensive support services would leave children and families served by Head Start with less access to these critical support services that they may otherwise lack.
   • Recommendation: Restore current HSPPS § 1302.40-47

10. Removal of current HSPPS § 1302.22
    • Topic: Home-based option
    • Impact: Removal of specific implementation details for the home-based option under the Head Start Act would eliminate the ease with which programs may follow best-practice guidance. Programs may not have the capacity to develop their own best practices, especially given the proposal to cut the administrative cap. This includes frequency, duration, program design, curriculum and caseloads for home visitors.
    • Recommendation: Restore current HSPPS § 1302.22

Conclusion
While well-intentioned in its goal of streamlining operations, the proposed rule creates unintended vulnerabilities that could erode the foundation of Head Start as a proven model to serve all children, regardless of where they live. Early Futures Partnership respectfully urges a robust baseline of federal guidance recommended in our analysis and preservation of the 15% administrative cap. This will ensure local programs retain both the clear playbook and essential operational infrastructure required to deliver lasting outcomes for children and families served by Head Start.

Thank you again for the opportunity to submit public comment.

Sincerely,

Marti Beard                                                                       Jason Prokop
Co-President                                                                    Co-President
Early Futures Partnership                                                 Early Futures Partnership