Comment on FR Doc # 2026-09383

While the proposed rule change takes pressure off of Head Start programs to find additional funding to stay comparable to competitors, it also detracts from the ability to bring in top talent to our programs. Our programs largest competitor are schools districts. In each of the districts we are in, the school district teachers and staff are already compensated at a better rate and have better benefits than we are providing. This rule is helping to close the gap and hold us accountable to do better. It is helping to keep a trained workforce with our programs and not jump ship to the school districts we are serving in. Head Start is the gold standard for early child education across this country. Don't they deserve to be compensated for it? The ongoing concern is that with the continued flat or near flat funding for Head Start programs that we will continue to lose staff to our competitors. This also gives reason to continue flat funding programs. This NPRM also asked for comments on our standards. One I would like to address the lead requirements that were added in the NPRM. The requirements are cumbersome. Our programs are being asked to test every 2 year for lead. We are currently in school district operated buildings, which are required to test every 5 years. The lead requirement means we need to test 2 1/2 times as often for the same water and walls as regulated by the state for school children? This does not make any sense to me. Many of our schools are newer than the date that lead paint was banned from use. It would be nice if the rules stayed in place to address what to do in those situations so we do not continue to spend funds for areas that could not possibly have lead paint.