On May 12, the federal Office of Head Start published a Notice of Proposed Rulemaking (NPRM) proposing to rescind 2024 Head Start teacher wage regulations. The regulations required creation of wage scales and progress toward pay parity by 2031, with Head Start salaries reaching public pre-K levels or 90% of kindergarten teacher pay. It also rolled back requirements related to employment benefits, including access to health insurance. Early Futures Partnership and community partners submitted this comment opposing the proposed rule changes.
As representatives of Nebraska’s early childhood ecosystem, we submit these comments in opposition to the proposed changes outlined in the Head Start Notice of Proposed Rulemaking (NPRM) “Restoring Flexibility to Support Head Start Program Access.”
While we appreciate the intention to create more administrative flexibility, we are deeply concerned that repealing the workforce compensation provisions of the 2024 final rule would undermine much-needed efforts to strengthen the Head Start workforce and reduce staffing shortages.
Recruitment and retention are pervasive challenges for Head Start and other early learning programs. Competitive compensation is critical to addressing these workforce challenges. Weakening these supports will reduce access to Head Start for the families who rely on it. That is why during this comment period, we raise the following concerns with the proposed rules.
First, the NPRM removes critical wage requirements in the Head Start program, including developing and updating formal pay scales for all staff, paying educators staff wages comparable to public preschool teachers, providing salaries sufficient to cover basic living costs and promoting wage compatibility between Head Start Preschool and Early Head Start staff. These proposed changes are especially concerning given that early childhood educators remain among the lowest-paid professionals in the country, contributing directly to persistent recruitment and retention challenges.
Second, the NPRM rolls back important benefit-related requirements, including access to health insurance and paid leave, behavioral health supports, access to child care subsidies and student loan forgiveness and periodic reassessment of benefits packages. As with wages, prospective workers also weigh benefits as they assess whether they can remain in the workforce.
Taken together, these proposed changes arrive at a particularly destabilizing moment for the child care sector in Nebraska and across the country. Early childhood programs continue to face severe workforce shortages, rising operating costs and ongoing difficulty recruiting and retaining qualified staff. Rolling back workforce compensation and benefit protections now will only deepen these challenges, further strain an already fragile system and reduce access to Head Start services for the children and families who depend on them. For these reasons, we strongly urge the U.S. Department of Health and Human Services to reconsider the proposed changes.
Community Action Partnership of Lancaster and Saunders Counties
Connected Roots Care Center
Early Futures Partnership
Kids Can Community Center
Lincoln Littles
Nebraska Early Childhood Collaborative
