What would happen to Head Start programs if they began to follow state childcare licensing standards instead of the decades-old federal performance quality standards that the Trump administration proposed partially rolling back this month?
A majority of toddlers would see worse adult-to-child ratios, and only two states would meet Head Start lead teacher qualification requirements, according to a 50-state policy analysis of state childcare licensing standards published by the Children’s Equity Project at Arizona State University this month.
Only five states would require Head Start centers to be accessible to children with disabilities, and only about a third of states would require programs to accommodate children with disabilities in classroom activities, the report says. Additionally, there would be uneven implementation of disciplinary approaches, with some states still allowing or not explicitly banning abusive language, rest-related punishment, physical restraint, and locked or dark-room timeouts.
The researchers compared states' licensing standards to existing federal Head Start quality standards and found "the quality of early care and learning programs is too often not aligned with best practices and research."
"Further, high-quality early childhood experiences are unevenly distributed, varying based on state, program type, funding stream, and zip code," the report found.
While state licensing standards provide a baseline "quality 'floor'" to make sure children are safe, federal quality standards — which the Trump administration proposed sweeping changes to in early August — are meant to provide a "quality 'ceiling'" to ensure overall child development.
"State licensing answers one question: What is the minimum set of standards required so children are not in danger?" the report said. "By contrast, Head Start asks: What conditions produce lifelong improvements for children’s development, health, learning, and family well-being?"
On Aug. 7, however, the U.S. Department of Health and Human Services proposed undoing some federal requirements for Head Start programs, shifting their reliance instead to state standards. Such changes would affect classroom sizes, teacher-child and staff-child ratios, curriculum implementation, and transportation practices.
The report released by ASU said state licensing standards and federal quality standards "are not interchangeable in function or in content."
Although HHS will still be required to keep a set of standards — called the Head Start Program Performance Standards under the Improving Head Start for School Readiness Act — the administration proposed changing some of their contents in a way that is alarming researchers such as Meek and early childhood education advocates and workers.
"Their content is being changed quite radically, stripping basic health, safety, and quality requirements," Meek said. "The most extreme example is adult to child ratios.”
HHS officials, however, said earlier this month that its proposal was meant to give states, local communities and families more autonomy to design their programs based on their needs.
“We have 1,600 Head Start providers across the country, and one-size-fits-all mandates from Washington cannot fully account for the realities facing these 1,600 grantees,” said Alex Adams, the assistant secretary of HHS’ Administration for Children and Families, in an Aug. 6 press call.
The changes, Adams said, are expected to add 236,000 Head Start slots for children and save $2.2 billion. In fiscal year 2026, Congress funded Head Start at $12.4 billion.
Ratios may worsen. What does that mean?
Under the HHS proposal, there could be more children in classrooms with fewer requirements for highly qualified teachers, according to ASU's research.
No state has adult-to-child ratios as low as Head Start’s federal requirements across any age group, Meek said. Some of Meek's findings include:
- In 24 states, adult-to-child ratios for 2-year-olds would at least double, and in Mississippi they would triple.
- In 20 states, adult-to-child ratios for 3-year-olds would increase by at least half — and more in some cases.
- Overall, 80% of the children between ages 5 and under in Head Start would see adult-to-child ratios worsen due to the administration's proposal.
Worsening ratios may compromise centers' ability to provide equitable education for children with disabilities and multilingual learners, Meek added.
"District leaders will also see an impact, especially those who use Title I dollars to fund preschool slots, as those slots are required to align to the Head Start education standards," said Meek.
The influx of more children into classrooms, the removal of workforce supports and other changes would impact school readiness and the transition to kindergarten, Meek warned.
"This comes at a time when schools are already strained, underfunded and facing significant challenges in getting students to grade level in reading and math," said Meek. "This will only exacerbate those dynamics."
The proposed rule to walk back some Head Start Program Performance Standards provisions was published in the federal register Aug. 7, and its comment period closes Oct. 6. As of Aug. 17, it had already received over 800 public comments.