1. United States
2. R.I.
3. Letter

I have submitted a comment on the federal register. I also want your office to be aware of how vociferously I oppose key provisions of the proposed rule because they would remove or weaken Head Start Program Performance Standards in a manner inconsistent with the Secretary’s statutory obligation under 42 U.S.C. § 9836a(a)(2)(C)(ii) to ensure that revisions to the Head Start Program Performance Standards do not reduce the quality, scope, or types of services provided under the Head Start Act. While administrative burden reduction is appropriate, the proposed rule goes beyond administrative simplification and would eliminate or dilute core federal standards governing staffing, safety, instructional time, health services, disability supports, and family services. I request withdrawal or substantial revision of the rule. At minimum, ACF must retain enforceable federal baseline standards and provide a provision-by-provision statutory compliance analysis under 42 U.S.C. § 9836a(a)(2)(C)(ii) demonstrating that no reduction in service quality, scope, or type will result. I. Statutory Compliance Requirement (42 U.S.C. § 9836a(a)(2)(C)(ii)) Under 42 U.S.C. § 9836a(a)(2)(C)(ii), the Secretary must ensure that revisions to the Head Start Program Performance Standards do not reduce the quality, scope, or types of services provided. The NPRM does not provide a sufficient provision-by-provision analysis demonstrating compliance with this statutory requirement. Requested Actions (Required Under 42 U.S.C. § 9836a(a)(2)(C)(ii)) ACF should: Publish a crosswalk comparing current Head Start Program Performance Standards with proposed revisions, identifying all provisions modified, rescinded, or weakened. For each change, explicitly determine whether it affects the quality, scope, or type of services under 42 U.S.C. § 9836a(a)(2)(C)(ii). Provide a cumulative impact analysis assessing whether the aggregate effect of all changes results in any reduction in service quality, scope, or type. Identify evidentiary support for any conclusion that no reduction occurs. II. Required Federal Baseline Standards The proposed rule removes or weakens multiple core Head Start Program Performance Standards. Under 42 U.S.C. § 9836a(a)(2)(C)(ii), ACF must ensure that any final rule does not reduce service quality, scope, or type. The following federal baseline standards should be retained or replaced with functionally equivalent enforceable requirements. A. Staffing, Group Size, and Workforce Standards Retain federal minimum staff-to-child ratios and group size requirements to ensure service quality under 42 U.S.C. § 9836a(a)(2)(C)(ii). If credential requirements are modified, replace them with enforceable competency-based standards that preserve service quality. Maintain workforce qualification standards sufficient to ensure continuity and consistency of services. B. Child Safety and Discipline Protections Retain suspension only as a last resort consistent with service quality requirements under 42 U.S.C. § 9836a(a)(2)(C)(ii). Retain prohibition on expulsion for behavioral reasons as a baseline service protection. Require documented behavioral intervention supports prior to exclusionary discipline. Maintain transportation safety requirements, including bus monitor or equivalent protections. C. Instructional Time and Service Duration Retain or replace the 1,020-hour instructional requirement with a federal standard ensuring no reduction in the scope or type of educational services under 42 U.S.C. § 9836a(a)(2)(C)(ii). Maintain minimum service duration requirements sufficient to preserve program intensity and developmental outcomes. D. Health, Mental Health, and Developmental Services Retain screening timelines, validated assessment tools, and follow-up requirements necessary to preserve service quality. Maintain referral tracking and completion requirements for health and dental services. Retain required mental health consultation services as a core program component. E. Disability Services Retain disability coordination requirements to ensure no reduction in service scope under 42 U.S.C. § 9836a(a)(2)(C)(ii). Maintain transition planning and service coordination standards that exceed baseline IDEA requirements where necessary to preserve service type and quality. F. Home-Based and Family Services Retain minimum home-visit frequency, duration, and caseload standards unless ACF demonstrates no reduction in service quality, scope, or type under 42 U.S.C. § 9836a(a)(2)(C)(ii). Maintain family engagement caseload expectations or equivalent service capacity standards. G. Language and Instructional Access Remove any English-only instructional mandate unless ACF demonstrates no reduction in service type, scope, or quality under 42 U.S.C. § 9836a(a)(2)(C)(ii). Preserve bilingual and dual-language instructional models as permissible service types. H. Administrative Structure and Waivers Retain administrative cost limitations unless ACF demonstrates compliance with 42 U.S.C. § 9836a(a)(2)(C)(ii). Require waiver safeguards including: public justification, time limitations, outcome reporting, and transparency requirements. III. English-Only Instruction (§ 1301.04(a)) The proposed English-only instruction requirement may reduce the type and quality of services provided to dual-language learners, implicating 42 U.S.C. § 9836a(a)(2)(C)(ii). Requested Action Remove the English-only mandate unless ACF demonstrates it does not reduce service type, scope, or quality under 42 U.S.C. § 9836a(a)(2)(C)(ii). Preserve bilingual and dual-language instruction as permissible service models. IV. Cost Savings vs. Service Reductions The Regulatory Impact Analysis does not clearly distinguish administrative cost savings from reductions in service quality, scope, or type as required under 42 U.S.C. § 9836a(a)(2)(C)(ii). Requested Action Disaggregate administrative efficiency savings from any service-level reductions. Provide a statutory compliance determination for each category of change under 42 U.S.C. § 9836a(a)(2)(C)(ii). ⸻ V. Program Integrity and Statutory Risk Several proposed changes may reduce staffing levels, instructional time, and service delivery consistency. Absent enforceable federal baseline standards, these changes risk reducing the quality, scope, and types of services in violation of 42 U.S.C. § 9836a(a)(2)(C)(ii) and may create significant interstate variability in program implementation. Conclusion Head Start is a national program designed to ensure consistent minimum service quality for low-income children and families. While administrative simplification is appropriate, the proposed rule must comply with 42 U.S.C. § 9836a(a)(2)(C)(ii) and may not reduce the quality, scope, or types of services provided. I respectfully request that your office help with the withdrawal or substantial revision of the rule. At minimum, ACF must retain the federal baseline standards outlined above and provide a complete statutory compliance analysis demonstrating that no reduction in service quality, scope, or type will result. Head Start should be strengthened through efficiency, not weakened through deregulation that risks statutory noncompliance.