4,000+ Comments on Proposed Head Start Standards Changes

In the first two and a half weeks after the Notice of Proposed Rulemaking (NPRM) to substantially change the Head Start Program Performance Standards (Performance Standards) was published, more than 4,000 comments were submitted in on Regulations.gov. The NPRM, Reducing Federal Burden for Head Start Programs, was published on August 7, and comments are due by October 6, 2026.

As we noted in our blog post earlier this month, the proposed changes to the Performance Standards, if approved, would have significant impacts on Head Start programs, families, and staff. Submitted comments largely reflect this sentiment. The Head Start community is deeply engaged in responding to the NPRM, with comments submitted from a variety of organizations as well Head Start administrators, staff, and parents, and even former Head Start children.

Comments on the NPRM cover a wide range of topics such as concern about deregulation and the potential lowering of quality standards for Head Start, worsening workforce challenges, and the safety of enrolled children. There are comments related to screening, assessment, home visiting, caseloads, ratios, and much, much more. There are also reflections about how state quality standards vary, and the impact this would have on the quality of experiences for children and families enrolled in Head Start depending on where they live. The number of comments is likely to grow in coming weeks.

Many national organizations have shared their positions on the NPRM. Recently, BUILD Initiative published a blog post, Where we Stand on Head Start, expressing concerns about quality and safety, workforce equity, reduced access to services, and systems fragmentation. The National Head Start Association (NHSA), one of the primary advocacy organizations for Head Start, has not yet released guidance for programs beyond its initial press release, Fewer Rules Cannot Mean Fewer Results.

While national news organizations have cited informal statements from members of the United States Senate and House of Representatives, elected officials at the federal level have not yet issued formal press releases in response to the NPRM. There was state and national news coverage on the Head Start NPRM when it was released, with some outlets taking positions in support of or expressing concerns about the proposed changes.

Additionally, new resources are available to help programs and stakeholders better understand and comment on the proposed changes in the NPRM. A resource we’ve found comprehensive is First Five Years Fund’s Frequently Asked Questions: 2026 Head Start NPRM. It provides information organized by topic area (e.g., Health and Safety, Staffing and Qualifications, Governance) and specifies whether proposed changes in the NPRM would still be required by law, mixed/partially required, removed, or a new requirement. For example, under Governance, the FAQ addresses whether the NPRM would change any aspects of governing body composition and Policy Council. The response explains that the governance structures are required directly by the Head Start Act and thus, are still required by law.

As a reminder, public comments on the NPRM are due by October 6, 2026. To submit a comment, visit the NPRM and click the Submit a Public Comment button. Note that you can insert comments and/or upload supporting documents. Comments may be submitted by individuals, organizations, or anonymously.

We will share additional information and resources regarding the NPRM and its potential impact on Head Start programs, staff, children, and families, and we encourage you to submit public comments. Please contact us if your program is in need of assistance.

Thank you.

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