FFYF Submits Comments on 2023 Head Start NPRM

Last week, the First Five Years Fund (FFYF) submitted comments in response to the Notice of Proposed Rulemaking (NPRM), Supporting the Head Start Workforce and Consistent Quality Programming, published by the Office of Head Start (OHS) on November 20, 2023. 

Head Start plays a critical role in the lives of families living in poverty, setting young children on a path to thrive in school and outside of the classroom. A large body of research has found Head Start to be a highly effective program that benefits children and their families in both the short and long term. Like many early care and education (ECE) programs, Head Start has faced challenges in recent years, especially following the unprecedented Covid-19 pandemic. We commend the Administration for proposing changes to address these recent challenges facing the program. 

While the NPRM includes many of the right goals, we believe sweeping changes to the program are best done through Congressional reauthorization. The ECE landscape and the needs of families and communities have changed significantly since the Head Start for School Readiness Act of 2007 expired in 2011. Congress should take the steps necessary to address issues within the program, update problematic systems, and ensure Head Start evolves in a way that best supports the needs of children, families, and early childhood educators. 

FFYF’s comments discuss two of the leading challenges facing programs: chronic undercompensation for the Head Start workforce and outdated eligibility requirements. Supporting the workforce through competitive compensation is of the utmost importance, and we wish to ensure that program administrators continue to have autonomy over decision-making that best supports the needs of their staff and families regarding employee pay and benefits. We support OHS’s proposal to make an adjustment for housing costs for eligibility determination that would allow more families in need to access Head Start. We encourage Congress and OHS to take a more in-depth look at Head Start’s current eligibility measures to ensure programs reach full enrollment and more families can access the program. 

Our comments also include our leading concerns with the proposed rule. We urge OHS to consider the additional federal investment needed to implement new regulations, the unforeseen impact on the Early Head Start – Child Care Partnerships, and the need for closer examination of program monitoring and reporting systems. Our comments discuss potential priorities for reauthorization. We encourage the Administration to work with Congress to update the program so it will continue to best serve children, families, and early childhood educators for decades to come. 

The full text of the letter appears below.

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