The following is the first page of Head Start California's 32-page official comment submitted to the Federal Register on October 5, 2026. To view the full 32-page submission, download the PDF here.
October 5, 2026
Robert F. Kennedy, Jr.
Secretary, Department of Health and Human Services
Re: ACF-2026-0595-0002, Reducing Federal Burden for Head Start Programs
Dear Secretary Kennedy,
Head Start California (HSC) appreciates the opportunity to comment on the Administration for Children and Families’ (ACF) notice of proposed rulemaking to rescind and replace the Head Start Program Performance Standards, 45 CFR Part 1301, 1302, 1303, 1304, and 1305 (ACF-2026-0595-0002; RIN 0970-AD30). Head Start California is a nonprofit membership association that represents Head Start grant recipients throughout the State of California. Our organization supports 136 Head Start providers who collectively serve more than 70,000 children and their families across the state. These providers employ over 28,000 individuals and receive nearly $1.6 billion in Federal Head Start grant funding annually. We offer our comments based on discussions with Head Start programs throughout California.
Although the Notice of Proposed Rulemaking (NPRM) suggests that the proposal will increase flexibility, align with state childcare licensing, and lower per-child costs, our membership of local, community-based Head Start agencies believe that the proposed changes would instead fundamentally alter the Head Start model, undermining quality, weakening outcomes, increasing administrative burden, and reducing the number of children and families served. While Head Start staff are often the first to raise that the current standards are overly prescriptive, the approach taken by the NPRM is akin to using a sledgehammer where a scalpel would be more appropriate.
We respectfully urge you to withdraw the current proposal and develop a replacement that:
- Builds upon feedback from the Head Start community to right-size the Head Start performance standards.
- Offers clear, consistent guidance and performance expectations for all Head Start programs nationwide, including compliance with the Head Start statute.
- Retains high-quality standards related to: group sizes; teacher-to-student ratios; intensity and duration of services; staff qualifications; and other evidence-based program design elements that are driven by research on outcomes and effectiveness for at-risk young children and families.
We would welcome the opportunity to engage with the Office of Head Start in developing a revised proposal that responds to these recommendations.
Head Start California Comments on the NPRM
The following is the first page of Head Start California's 32-page official comment submitted to the Federal Register on October 5, 2026. To view the full 32-page submission, download the PDF here.
October 5, 2026
Robert F. Kennedy, Jr.
Secretary, Department of Health and Human Services
Re: ACF-2026-0595-0002, Reducing Federal Burden for Head Start Programs
Dear Secretary Kennedy,
Head Start California (HSC) appreciates the opportunity to comment on the Administration for Children and Families’ (ACF) notice of proposed rulemaking to rescind and replace the Head Start Program Performance Standards, 45 CFR Part 1301, 1302, 1303, 1304, and 1305 (ACF-2026-0595-0002; RIN 0970-AD30). Head Start California is a nonprofit membership association that represents Head Start grant recipients throughout the State of California. Our organization supports 136 Head Start providers who collectively serve more than 70,000 children and their families across the state. These providers employ over 28,000 individuals and receive nearly $1.6 billion in Federal Head Start grant funding annually. We offer our comments based on discussions with Head Start programs throughout California.
Although the Notice of Proposed Rulemaking (NPRM) suggests that the proposal will increase flexibility, align with state childcare licensing, and lower per-child costs, our membership of local, community-based Head Start agencies believe that the proposed changes would instead fundamentally alter the Head Start model, undermining quality, weakening outcomes, increasing administrative burden, and reducing the number of children and families served. While Head Start staff are often the first to raise that the current standards are overly prescriptive, the approach taken by the NPRM is akin to using a sledgehammer where a scalpel would be more appropriate.
We respectfully urge you to withdraw the current proposal and develop a replacement that:
We would welcome the opportunity to engage with the Office of Head Start in developing a revised proposal that responds to these recommendations.
Categories
Most Recent Posts