Comment on FR Doc # 2026-09383

Scot AndersonOpposeIndividual
Summary: The commenter, a former Head Start Executive Director, opposes the proposed rule because they believe removing the regulatory floor on wages and benefits will not increase program access. They argue that the underlying fiscal pressures and labor market competition remain, and that without additional funding, programs will still be forced to make difficult trade-offs between staff pay and service quality.
Thank you for the opportunity to comment on the Administration for Children and Families recent proposed rule “Restoring Flexibility To Support Head Start Program Access”. I am writing as an individual with 42 years of experience administering Head Start programs, including 30 years as an Executive Director/Head Start Director and 12 years working for a federal contractor providing interim management services for the Office of Head Start. I appreciate the Administration’s commitment to expanding access to the gold standard of early childhood education and care provided by Head Start. However, I am concerned that the proposed changes in this rule will not lead to increased access to Head Start. Only addressing the funding or local labor market forces for local Head Start programs will have that impact. Head Start has served as a cornerstone of the nation's commitment to young children and families from high needs backgrounds for more than six decades. Local programs provide comprehensive early learning, health, nutrition, and family support services to children from prenatal through age five. Head Start addresses the full spectrum of conditions that shape a child's development during the most critical window of brain development. Local programs support working parents by providing a safe and enriching environment for their children, enabling greater economic participation and self-sufficiency. In communities where poverty is concentrated and resources are scarce, Head Start programs anchor neighborhoods and support the social infrastructure that families depend on. A strong Head Start program is built on stability, and that stability comes from a consistent and qualified workforce. Teachers, family service staff, bus drivers, cooks, and program leaders, who show up every day for hundreds of thousands of eligible children and families, are the heart of Head Start. We must do everything we can to recruit, retain, and support these dedicated staff, including paying them a competitive salary that reflects their training and expertise. In today’s federal funding environment, the compensation needed to recruit and retain qualified staff competes directly with other increasing program expenses. This means that local programs are forced to make hard choices every day. These difficult decisions due to a lack of funding include reducing or converting slots, eliminating positions, replacing fewer supplies and furnishings, and limiting or delaying facility improvements. Local programs are also facing rising costs beyond salaries. Expenses for food, transportation, facilities, insurance, and other essentials have steadily increased in recent years, while federal funding has remained largely flat and is again proposed at similar levels for FY27. Eliminating this regulatory floor, as proposed in this NPRM, does not eliminate the underlying cost pressure. It simply removes the federal requirement to address it, leaving local programs to navigate an impossible tension between serving more children and paying the staff who serve them fairly. Wages in competing job sectors will not decline because the federal government has stepped back from a Head Start compensation standard. Local programs will still face the same local labor market pressures, competing with other organizations to hire and retain quality staff, after this rule is finalized. If the workforce compensation provisions of the 2024 final rule are repealed, that will not change these underlying fiscal pressures. The funding challenge is real and requires action from both Congress and the administration. Without meaningful additional investment, local programs are forced into difficult trade-offs that affect both Head Start program access and quality. Thank you for your consideration.

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