Comment on FR Doc # 2026-09383
Indiana Head Start AssociationSupportAdvocacy
Summary: The Indiana Head Start Association supports the proposed rescission of certain wage and benefit requirements because they create significant operational challenges and financial pressures for local programs without sufficient federal funding. However, the association emphasizes that the workforce crisis remains a priority and suggests alternative approaches like phased implementation, regional flexibility, and targeted grants to ensure high-quality services and competitive pay.
The Indiana Head Start Association (IHSA) appreciates the opportunity to provide comments regarding the proposed rescission of the wage and benefit requirements contained within §1302.90(e) and (f) of the Head Start Program Performance Standards.
IHSA recognizes and appreciates the Administration’s acknowledgment that Head Start programs continue to face significant workforce shortages, recruitment barriers, and financial pressures. We also agree that implementing large-scale compensation requirements without sustained Congressional appropriations creates substantial operational challenges for local programs. As noted in the NPRM, the projected implementation costs associated with the 2024 wage and benefit requirements are significant and could potentially result in substantial reductions in funded enrollment nationally if additional funding is not provided.
At the same time, IHSA strongly believes the underlying workforce crisis facing Head Start has not been resolved. Across Indiana, programs continue to experience:
•persistent staffing shortages,
•difficulty recruiting qualified staff,
•increasing turnover,
•rising behavioral and mental health needs within classrooms,
•and workforce burnout associated with increasing expectations placed on early childhood professionals.
Competitive compensation and benefits remain critical components of maintaining a stable, qualified workforce capable of delivering high-quality, comprehensive services to children and families.
IHSA encourages ACF to consider approaches that preserve local flexibility while continuing to prioritize federal investment in workforce stabilization. Programs should not be placed in the position of choosing between maintaining access to enrollment for children and offering competitive wages necessary to recruit and retain staff.
IHSA encourages consideration of:
•phased implementation tied to Congressional appropriations,
•regional flexibility models,
•targeted workforce stabilization grants,
•rural workforce considerations,
•and incentive-based approaches rather than unfunded mandates.
Head Start programs operate within vastly different community and labor market conditions. Rural communities in particular face unique challenges related to workforce availability, compensation parity, transportation, and access to qualified substitutes and support staff. Greater flexibility may help programs respond to local conditions; however, long-term workforce stabilization must remain a federal priority.
IHSA appreciates the opportunity to provide feedback and looks forward to continued partnership with ACF and Congress to ensure both workforce stability and continued access to high-quality Head Start services for vulnerable children and families.