Thanks to your incredible engagement and feedback, we are pleased to share the final draft of our comments in response to the Office of Head Start Notice of Proposed Rulemaking (NPRM).
NHSA submitted comments on behalf of nearly 1,000 Head Start and Early Head Start programs, all State, Regional, and National Head Start associations, and other Head Start-affiliated organizations and supporters; in addition, nearly 2,000 Head Start parents also weighed in with their own response.
- The proposed Head Start rule was open for a 60 day comment period that ended on January 19. Here's NHSA's summary of what it covered. It’s expected to be finalized later this year after consideration of public comments.
- It’s the biggest set of changes to Head Start in the last decade, focusing on a wide range of areas including workforce compensation, mental health, and a variety of reporting requirements.
- It sets a vision for the future of Head Start, with aspirational policy goals like reaching pay parity with public school teachers with similar qualifications, and prioritizing mental health for both children and staff.
- 💰 These worthy goals cost money. Without significant additional funding from Congress, cost savings will have to come from reducing the number of children in Head Start and Early Head Start.
- 🚸 It is overly prescriptive with many one-size-fits-all solutions that remove local autonomy and focus more on inputs than on outcomes.
- 🏠 Small, rural, and tribal programs will be the most heavily impacted since they are least likely to have financial flexibility or additional community resources to meet all the new requirements.
Takeaways for Congress:
- While we appreciate the intention, this is not a sustainable way of making changes of such magnitude to Head Start.
- This is going to require more dedicated funding or children and families will lose access to the program.
- Let’s take another look at ways in which this proposed rule can dial back on the level of prescriptiveness and allow programs to focus on the decisions that are best for their communities and the children and families they serve.
- The comment period has closed and a final rule is expected to be issued later this year.