CAP Comments on HHS’ Notice Affecting Head Start Eligibility Criteria

The Center for American Progress submitted a comment letter to the Health and Human Services Department opposing the agency’s unprecedented notice requiring Head Start programs to verify citizenship status in order for families to qualify for services.

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On August 13, 2025, the Center for American Progress submitted comments to the U.S. Department of Health and Human Services (HHS) opposing the agency’s notice, titled “Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA); Interpretation of ‘Federal Public Benefit,’” which requires Head Start programs to begin verifying applicants’ citizenship status in order to qualify for services—something these programs have never been required to do in their 60-year history.

In the letter, CAP argues that stripping children of crucial support programs is both senseless and harmful to the communities to which these families belong. HHS should instead focus on supporting Head Start’s mandated goal of promoting school readiness, which can generate significant, long-lasting positive outcomes for children, the economy, and society as a whole.

Click here to read CAP’s comment letter.

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Hailey Gibbs

Associate Director, Early Childhood Policy

Rosa Barrientos-Ferrer

Senior Policy Analyst

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CAP Comments on HHS’ Notice Affecting Head Start Eligibility Criteria