WCAC Submits Public Comment on Proposed Federal Head Start Rule Changes

Office of Head Start, Administration for Children and Families 

U.S. Department of Health and Human Services (via regulations.gov) 

Re: Reducing Federal Burden for Head Start Programs (Docket No. ACF-2026-0595; RIN 0970-AD30) 

Worcester Community Action Council (WCAC), the Community Action Agency for Worcester and 46 surrounding communities, operates Head Start for 144 center-based preschoolers and 48 home-based Early Head Start for pregnant women and children under three in 13 South County towns. We submit these comments for our program and for the families it serves. We support cutting paperwork, however, by ACF’s own analysis, most of the rule’s projected $2.2 billion in annual savings1 comes from fewer teachers ($668 million), shorter preschool days ($214 million), fewer health and mental health services ($223 million), and fewer home visitors ($172 million). Those are cuts to the adults who work with children and families. Below is a breakdown of each segment of the rulemaking proposal: 

Keep federal ratio and group-size limits (§ 1301.05): Massachusetts has some of the strongest licensing standards in the country, and its floor is still looser than Head Start’s. Under the proposed rule, a class of three-year-olds could grow from 17 children to 20 in a full-day class, or 24 in a half-day session.2 The Act bars revisions that reduce the quality of services below the 2007 standards, and about 26 percent of Head Start sites have no state license to fall back on.3 We ask ACF to keep § 1302.21(b), with a waiver only where a program presents evidence and its Policy Council approves. 

Withdraw the 5 percent administrative cost cap (§ 1301.14): Congress set the cap at 15 percent and allowed a lower one only where a specific program’s costs are found excessive. Resetting the cap to 5% across the board rewrites the number that is set in Head Start’s primary governing statute. This change would result in many programs being forced to relinquish their grants and close their doors. 

Keep eligibility pathways for families in crisis (§ 1301.02): ACF estimates about 8 percent of enrolled children would lose eligibility without self-attestation, even though the Act directs that homeless children be enrolled while documents are gathered.4 At Massachusetts’s $15 minimum wage, a single parent of two working full time earns $31,200. That is above the $27,320 poverty line, so without the housing cost adjustment that family has only limited access to Head Start.5 For families considered homeless under the McKinney-Vento Act, of the Head Start Act directs the Secretary to establish regulations that “allow families to apply, enroll, and attend,” while required documents are obtained within a reasonable time frame. Head Start and Early Head Start served more than 60,000 children experiencing homelessness in 2024 – 2025 (the highest number on record), and that population has been a growing share of enrollment for a decade: from 4.24% to 6.98% of Head Start enrollment since 2015 – 2016 and from 7.72% to 9.5% in Early Head Start over the same period. We ask ACF to keep self-attestation as a last resort with 90 days to document, and to keep the housing cost adjustment and the flexibility on age documentation. 

 

Replace English-only instruction with an English-acquisition goal (§ 1301.04(a)): Every child should enter kindergarten ready to learn in English, and we accept accountability for that. In Southbridge, 36 percent of residents are Latino, mostly Puerto Rican, so many of the affected children are U.S. citizens.6 The Act requires English-learning children to make progress in English and in other areas, and it requires assessments that are valid for them. Research shows that using a child’s home language supports learning English rather than slowing it.7 We ask ACF to hold programs accountable for English outcomes and keep support for children’s home languages. 

Keep health, mental health, and behavior protections: In small towns far from specialists, the 45-day screening deadline is what gets a child’s evaluation started. Monthly mental health consultation helps teachers address a child’s behavior before it becomes a crisis. Allowing expulsion at the same time as removing that support puts the children with the greatest needs at the greatest risk of losing their place. We ask ACF to keep the 45-day screenings, monthly mental health consultation, and the limits on suspension and expulsion (§ 1302.17). 

Keep home-based standards and service duration: Home visiting has no state licensing system, so removing the federal caseload and visit standards leaves no standard at all. On program hours, our 2024 Family Survey found child care access was a key barrier for our families, and we raised United Way funds to extend classroom hours.8 The rule’s projected savings from shorter days would push in the opposite direction. We ask ACF to keep the current home-based and duration requirements. 

Other provisions: 

  • Credential incentives (§ 1301.12(c)). Strike this. The Act still requires half of Head Start teachers to hold bachelor’s degrees, and we compete with school districts to hire them.9 
  • Parent committees (§ 1301.01). Keep them required. Community Action is built on the principle that the people it serves help govern it.10 
  • We support streamlining the facilities approval process (Part 1303), aligning background checks with state law, moving away from CLASS as an automatic trigger for recompetition, and simplifying slot conversions between preschool and Early Head Start. 
  • Implementation. Make the rule effective no sooner than the program year starting at least 12 months after publication. State in the rule that practices no longer required remain allowable costs. 

Head Start and Community Action both began under the Economic Opportunity Act of 1964. We ask ACF to adopt the changes that free staff to serve children and to withdraw those whose savings come from serving children less.