NPRM Proposes Changes to Head Start Wage and Benefits Regulations
On May 12, a Notice of Proposed Rulemaking (NPRM), Restoring Flexibility to Support Head Start Program Access, was published in the Federal Register. As stated in the NPRM, the purpose of the proposed regulation changes is to “remove requirements related to wages and benefits that the Administration believes are not in line with the plain language of the Head Start Act.” Here, we break down the proposed changes, provide information on submitting comments, and offer our insight into how programs might move forward.
NPRM proposes rolling back key aspects of the 2024 Final Rule related to staff wages and benefits.
The 2024 Final Rule, Supporting the Head Start Workforce and Consistent Quality Programming, created new wage and benefits standards for Head Start grantees. The NPRM proposes to rescind those requirements.
The Administration for Children and Families (ACF) proposes to remove the standards in § 1302.90(e) which require that, by August 1, 2031, programs provide comparable wages to public school teachers, offer wages that cover the cost of living, and develop or update a pay scale, in addition to other requirements. ACF also proposes to remove standards in § 1302.90(f) which require that, by August 1, 2028, programs provide or facilitate coverage for health care, offer paid leave, and offer access to behavioral health services, among others.
The primary reasons cited by ACF for rescinding these requirements is that they are costly and exceed the requirements of the Head Start Act. ACF also acknowledges a desire to ensure flexibility for programs to determine how to best meet local needs and address staff recruitment and retention challenges.
Public comments are due by June 11, 2026.
Per the NPRM, comments are due in approximately three weeks. Comments may be submitted electronically or by mail. See the details in the NPRM. Note that all comments must include the agency name and docket number (ACF-2026-0364). You will be able to review all comments submitted, as they are posted publicly on the site.
Competitive wages are still vital to staff recruitment and retention.
Many programs have already begun working toward meeting the wage and benefits requirements. Assuming the changes in the NPRM move forward, there will no longer be wage and benefits requirements as part of the HSPPS. And yet, the importance of a well-compensated Head Start workforce cannot be understated. Data shows that the median wages for child care educators are only $15.41 per hour (US Bureau of Labor Statistics, 2025). These staff are the backbone of Head Start programs; low wages feed into high staff turnover. Shortages of qualified educators also make it challenging for Head Start grantees to implement a high-quality program, not to mention the cost of lost productivity and recruiting new employees.
We encourage programs to continue to focus thoughtfully on wages and benefits, and to use wage and benefits comparability studies to ensure staff are well compensated. A thorough wage study will consider not only local Head Start and child care programs, but also schools, non-profit organizations, and business in your service area. Offering compensation near or at local market rates is essential to maintaining a stable workforce. When staff feel valued, they are more like to stay and grow with your program.
We encourage you to explore Foundations for Families’ Consulting Services. If your program needs assistance conducting a wage and benefits comparability study, please be in touch. Our team of consultants will work with your program to determine a process, timeline, and approach that is the best fit for your needs.
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