For Immediate Release

OAKLAND, Calif. — The National Center for Youth Law (NCYL) is calling on the Department of Health and Human Services (HHS) to withdraw a proposed rule that would substantially weaken federal standards governing Head Start programs, putting at risk comprehensive services and protections that children and families have relied on for more than 60 years.

A comment letter submitted today by NCYL to HHS categorically opposes the proposed rule, Reducing Federal Burden for Head Start Programs, and warns that the changes would do far more than reduce administrative requirements. They would fundamentally weaken the national standards that define what high-quality Head Start services look like, with the harshest consequences falling on children and families already facing the greatest barriers to opportunity.

“Head Start works because it recognizes that children don’t experience education, health, housing instability, family stress, disability, language access, and economic insecurity as separate issues,” said Johnathan Smith, Managing Director of Education and Federal Strategic Advocacy at NCYL. “The federal government should strengthen that comprehensive approach, not dismantle the standards that make it possible.”

The proposed rule would replace detailed, enforceable federal standards with broad and ambiguous requirements; eliminate school-readiness and learning expectations; remove health and safety practices; weaken reporting and accountability; and shift responsibility for core protections to states, local programs, and other systems. NCYL cautions that this approach would create a patchwork of protections in which the quality and scope of services children receive could depend increasingly on where they live and the capacity of individual programs.

Among the proposed changes highlighted in NCYL’s letter:

• Weaker educational standards: The rule would permit larger class sizes, fewer adult-child interactions, shorter program days, reduced support and coaching for educators, weaker staff qualifications, diminished screening and assessment, and less robust teaching and learning environments. It would also eliminate important supports for children who speak languages other than English.
• Reduced health and mental health services: HHS estimates the proposal would result in $111.3 million less being spent annually on health and mental health services. But eliminating these detailed federal standards could delay critical developmental screenings, health care, dental care, and mental health referrals, particularly for families who rely on Head Start as a critical entry point to services.
• Weakened safety protections: The proposal would eliminate core requirements that address child supervision, staff conduct, background checks, safety training, disaster preparedness, and other safeguards, while weakening protections such as bus monitors and child-to-adult ratios.
• Less protection for children’s information: The proposed rule would eliminate Head Start-specific privacy protections that go beyond the federal Family Educational Rights and Privacy Act (FERPA) and would require programs to make eligibility records available to HHS upon request. Expanding federal access to sensitive information could discourage families from enrolling their children.
• Greater barriers for children and families facing inequities: The proposal would weaken targeted protections and outreach for children with disabilities, children experiencing homelessness, children in the foster system, dual language learners, immigrant families, infants and toddlers, and other children facing barriers to opportunity.
• Reduced language access for immigrant and dual-language families: The proposed English-only mandate and elimination of requirements related to bilingual capacity and culturally responsive services would undermine family engagement and access to care. Research led by NCYL with newcomer immigrant youth found that bilingual educators and culturally responsive staff can be critical to young people’s academic progress, well-being, and sense of belonging.

Weakening Head Start would also have consequences beyond individual programs. Head Start is a critical part of the country’s early childhood infrastructure, supporting parents and caregivers who rely on stable care to work, attend school, or pursue training. Reductions in services, hours, staffing, or program availability could ripple through families, local economies, schools, and communities.

NCYL is calling on HHS to withdraw the proposed rule in its entirety.

“Any future revisions to federal Head Start standards must prioritize establishing a strong baseline for education, health, safety, privacy, family partnership, and access, while maintaining targeted protections for children and families facing the greatest barriers to opportunity,” Smith said.

###

The National Center for Youth Law centers youth through research, community collaboration, impact litigation, and policy advocacy that fundamentally transforms our nation’s approach to education, health, immigration, foster care, and youth justice. Our vision is a world in which every child thrives and has a full and fair opportunity to achieve the future they envision for themselves.