Comment on FR Doc # 2026-09383

Re: Comment on “Restoring Flexibility to Support Head Start Program Access” Docket ID: ACF-2026-0364 RIN: 0970-AD21 I am submitting this comment on the proposed rule, Restoring Flexibility to Support Head Start Program Access. I support ACF’s concern that the 2024 wage and benefit requirements could reduce access to Head Start services if Congress does not provide more funding. The main issue is whether the wage and benefit rules would improve staffing enough to make the possible loss of child slots worth it. Head Start is not just preschool. It also connects families to things like health, nutrition, mental health, disability support, and family services. The proposed rule recognizes that Head Start provides these services to low-income pregnant women and children from prenatal age to age five, and that early childhood is important for learning, behavior, and health (ACF, 2026). So when a Head Start slot is lost, it is not just one classroom seat being lost. It can mean losing access to a larger package of services that low-income families may rely on. For that reason, ACF is right to care about access. The proposed rule estimates that the 2024 wage and benefit requirements would cost about $1.2 billion for wage standards and $877 million for benefit standards by full implementation in 2031, for a total of about $2.1 billion. Without additional funding from Congress, ACF estimates that programs would need to cut about 106,000 Head Start slots, including about 84,000 Head Start Preschool slots and 22,000 Early Head Start slots (ACF, 2026). If those are actual filled slots, then the harm to children and families could outweigh the benefit of mandatory wage increases. At the same time, compensation still matters. Low pay can affect recruitment, retention, vacancies, and classroom stability. A funded slot does not help much if a program cannot hire enough staff to actually open the classroom. The proposed rule itself acknowledges that competitive wages and benefits are important for attracting and keeping a qualified Head Start workforce, even while arguing that applying the same national rule everywhere may reduce access under current funding conditions (ACF, 2026). Because of this tradeoff, I support pausing the mandatory wage and benefit requirements under current funding conditions. But I do not think fully removing them should be treated as the final answer. ACF should use a narrower approach. First, ACF should use a funding trigger. Wage and benefit requirements should only be required if Congress provides dedicated funding to implement them without reducing the number of children actually being served. This still keeps better pay as a goal, but it avoids making low-income children and families pay for it through fewer slots. Second, ACF should keep local flexibility and focus compensation support on programs where low pay seems to be limiting access. Head Start programs operate in different local labor markets and have different needs. Some programs may have severe vacancies, high turnover, closed classrooms, or large pay gaps with nearby employers. In those places, compensation support may increase access because it helps programs staff classrooms. Other programs may be closer to full enrollment and may need flexibility to spend money on transportation, facilities, health services, family support, or other local needs. The same national wage rule may not fit both situations. ACF should also clarify whether the projected 106,000 slot loss refers to actual filled child slots or includes funded-but-vacant capacity. That distinction matters. Cutting already-vacant funded slots is not the same as cutting children who are actually being served. Since this changes how we should weigh costs and benefits, ACF should provide clearer evidence on how the projected slot loss was calculated and how it connects to actual enrollment (ACF, 2026). Overall, I support ACF’s concern that the 2024 wage and benefit requirements could reduce Head Start access if they are implemented without more funding. But compensation is still relevant where low pay contributes to turnover, vacancies, or closed classrooms. A better policy would use a funding trigger, keep local flexibility, and focus extra compensation money on programs where staffing shortages are keeping classrooms from opening. That would better protect children and families while still addressing staffing problems where pay seems to be part of the problem. Citations ACF. 2026. “Restoring Flexibility to Support Head Start Program Access.” Federal Register. https://www.federalregister.gov/documents/2026/05/12/2026-09383/restoring-flexibility-to-support-head-start-program-access.