Center for American Progress

CAP Comments on HHS’ Notice Rolling Back Program Performance Standards Key to Fulfilling the Head Start Promise
Article

CAP Comments on HHS’ Notice Rolling Back Program Performance Standards Key to Fulfilling the Head Start Promise

The Center for American Progress recently submitted comments to the U.S. Department of Health and Human Services opposing a recent rule that would dramatically reduce the standards supporting Head Start governance, quality, and access.

On October 6, 2026, the Center for American Progress submitted comments to the U.S. Department of Health and Human Services (HHS) opposing the agency’s notice of proposed rulemaking titled “Reducing Federal Burden for Head Start Programs,” which would overturn the vast majority of Head Start’s program performance standards. These standards govern Head Start grantees’ operations and help them remain statutorily compliant, deliver high-quality services, and provide access to the vulnerable families who depend on its services.

In the letter, CAP argues that overturning the program performance standards could have damaging consequences for program quality because of proposed reductions in teaching and learning standards, alignment of health and safety standards with highly variable state licensing systems, removal of protections for children experiencing homelessness or with disabilities, and the addition of an English-only language mandate, which poses particular harms for dual language learners. The comment also details the disproportionate reliance that rural communities have on Head Start programs, as children in these places lack access to other licensed options, including home-based care, center-based care, and state preschool programs. Undermining Head Start’s existing program performance standards not only risks program quality but could also result in widespread job losses, cuts to health services funding, and potential new child care costs for the families least able to afford them.

Click here to read CAP’s comment letter.
 
Author’s note: CAP submitted an original public comment on October 2 that contained a minor methodological error, which was subsequently corrected in a supplemental comment submitted on October 6. The letter above contains the corrected methodological estimates

The positions of American Progress, and our policy experts, are independent, and the findings and conclusions presented are those of American Progress alone. American Progress would like to acknowledge the many generous supporters who make our work possible.

Author

Hailey Gibbs

Associate Director, Early Childhood Policy

Team

Early Childhood Policy

We are committed to advancing progressive policies with bold, family-friendly solutions that equitably support all children, families, and early educators.

Default Opt Ins

Variable Opt Ins

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.