The Trump administration's efforts to reform Head Start standards would remove substantive federal safeguards for the early childhood education program and place more burdens on its low-income students and families, according to public comments from critics of the proposed rule.
On the other hand, many commenters agreed with the proposed rule's aim to cut back on what the administration said are duplicative and unnecessary rules and to strengthen family and local program decision-making. Others said the reforms, if enacted, would help determine whether federal taxpayer resources are being used effectively for the 61-year-old program.
Collectively, nearly 40,100 comments were submitted following the U.S. Department of Health and Human Services' Aug. 6 announcement of the Head Start proposed rule for program and performance standards. The comment period ended Tuesday, and HHS will now review the comments before issuing a final rule.
The proposed changes are substantial and include removing federal rules for class ratios and sizes, curricula expectations and certain staffing requirements. Instruction would be in English only, and there would no longer be a prohibition on corporal punishment, according to the draft rule.
The National Head Start Association — a membership organization that includes the program's families, students and staff — said in its feedback that it supports HHS' intent to reduce unnecessary burdens on Head Start programs and educators, but that the proposed rule goes too far in its deregulatory approach.
NHSA said the proposed rule would disproportionately affect children experiencing homelessness, children with disabilities, dual language learners, families in rural communities with limited access to specialized services, and children served in settings that are exempt from state licensing requirements, such as some school district-affiliated programs.
"While the proposal is intended to increase flexibility and reduce administrative burden, in many cases it may simply shift that burden from compliance with clear federal requirements to navigating and understanding a hodgepodge of state, local, and federal regulations and laws," NHSA wrote.
The proposal's call for larger class sizes, fewer resources to support educators working with children who have experienced trauma, no staff break requirements, or teacher wellness supports would "make an already difficult job harder for Head Start educators," said the Massachusetts Head Start Association, which serves over 10,000 children and pregnant women.
In its comments, the National Association for the Education of Young Children called on HHS to withdraw the proposed rule, saying it is "reducing quality and risking harm by removing critical, evidence-based standards designed to support high-quality early learning environments for children, families, and educators."
HHS also proposes reducing the cap on administrative costs from 15% to 5% of total approved program expenses — a change that would hamstring local programs' abilities to respond to their communities' needs, critics of the proposed rule said.
"A uniform 5 percent cap would force programs, for example, to choose between adequate staffing and improvements such as renovating space, expanding hours, and investing in technology, because both draw from the same limited funding," said North Carolina Gov. Josh Stein in a letter responding to the HHS proposal.
Nearly 200 Democratic and Independent members of Congress also sent HHS' Secretary Robert F. Kennedy, Jr., a letter urging the agency to withdraw the proposal. Among their concerns is that it would "illegally" modify and weaken the services required by the Head Start Act enacted by Congress.
"What you are proposing seriously weakens the high-quality, comprehensive research-backed services required by law, undermines access to critical services, restricts access for children and families, and creates uncertainty for Head Start programs across the nation," wrote the federal lawmakers. They added that the proposal removes more than 90% of the standards that ensure children receive high-quality early education and comprehensive services.
Support for Head Start reforms
The Head Start program provides educational services along with health, nutrition and other supports to about 771,000 infants, toddlers and preschool children and their families who are from low-income households. October is Head Start Awareness Month.
While HHS' Administration for Children and Families office administers the program at the federal level, services are delivered through local programs at centers, family childcare organizations, or through home-visiting, depending on community and family needs.
Alex Adams, the assistant secretary of HHS’ Administration for Children and Families, said in a press call announcing the proposed rule in August that the reforms are meant to expand parental choice, enhance efficiency, strengthen parental engagement, and improve young children’s health and physical activity, education and employment outcomes.
The new rule would require Head Start programs to serve nutrient-dense, whole foods and to provide 30 minutes of physical activity — outdoors if weather permits — for every 3.5 hours of classroom instruction. Additionally, programs would be required to be licensed under state requirements.
Adams predicted the reforms, if enacted as proposed, would add 236,000 Head Start slots for children and save $2.2 billion. Congress funded Head Start at $12.4 billion in fiscal year 2026.
Several people wrote anonymous messages that supported the proposed rule for its potential to find areas of wasteful spending and cost savings. "The proposed Performance Standards changes can actually help programs focus their resources on what matters most: children," one anonymous commenter said.
Some said the Head Start program should be terminated.
Jonathan Butcher and Madison Marino Doan, acting director and policy analyst respectively for The Heritage Foundation's Center for Education Policy, wrote that the Head Start program should be sunsetted. "As federal officials prepare to end the program, policymakers should give parents the option to use their child’s portion of Head Start spending at a public or private preschool provider of their choice," Butcher and Doan wrote.
