A substantial revamp of the Head Start program is underway. On Friday, August 7, 2026, the Administration for Children and Families (ACF), Office of Head Start published a Notice of Proposed Rulemaking (NPRM), 91 Federal Register 51248, proposing significant changes to the Head Start Program Performance Standards (HSPPS). 

If finalized, these changes could have far-reaching operational, programmatic, and financial consequences for Head Start Agencies. Some of the proposed changes could make it considerably more difficult for programs to sustain operations and continue providing comprehensive services over the long term.

Head Start agencies should carefully evaluate how the proposed changes would affect their programs and consider submitting comments before the October 6, 2026 deadline. 

Why Head Start Programs Should Review Proposed Rules Carefully

Head Start regulations have long warranted careful review and modernization. Agencies have had to navigate complex regulatory requirements and changing interpretations that, in some instances, have created unnecessary administrative burdens. 

The current NPRM, however, goes considerably further than just streamlining administrative requirements. Rather than carefully revising specific standards that may be outdated or unnecessarily burdensome, the proposal would eliminate numerous requirements that have helped define the Head Start model and support our nation’s most vulnerable young children. Many of these requirements address core elements of program quality and service delivery, making it important for Head Start agencies to consider carefully the practical consequences of their elimination.

Core Program Requirements That Would Be Impacted  

Key program components that would be eliminated or substantially revised under the proposed rule include:

• Developmental assessments and screenings with individualized lesson plans; 
• Requirements designed to help ensure children are up to date on well-child checks and dental services;
• Requirements addressing the complexities of determining eligibility and enrollment;
• Uniform standards for teacher-to-child ratios; and 
• Staff qualifications and professional development requirements.

The Administration proposes to eliminate these and many other program elements from the HSPPS and defer instead to provisions of the Head Start Act for program requirements and grant terms and conditions. 

Proposed 5% Limitation on Administrative Costs Raises Significant Concern

The 2024 Uniform Guidance changes increased the de minimis rate to recover indirect costs from 10% to up to 15%. In the proposed update to the HSPPS, ACF recommends a substantially lower administrative cap of 5% of the total approved budget. This restriction could present programs not only with an administrative burden when managing multiple streams of funding, but also leave agencies unable to recover all indirect costs and potentially operating at a financial loss. 

Why Head Start Programs Should Submit Comments 

No one understands better than Head Start programs themselves what it takes to fulfill the promise of the Head Start Act and effectively serve children and families. The public comment process provides an important opportunity for programs to explain where the proposed changes may conflict with Head Start Act requirements, operational realities, and the extensive body of child development research that informs successful program strategies.

It is critically important for the Head Start community to review the NPRM closely and provide ACF with specific, substantive comments about how these proposed changes could affect programs, children, and families. Making your voice heard matters. 

Comments are due no later than October 6, 2026. Comments should reference Docket No. ACF-2026-0595 and/or RIN number 0970-AD30 in the subject line, and may be submitted through www.regulations.gov or by email at Deregulation@acf.hhs.gov.

Upcoming Feldesman Webinar 

Feldesman will host a webinar on August 24, 2026 at 1:00 p.m. ET, examining the proposed changes to the Head Start Program Performance Standards and what they could mean for Head Start agencies. 

Organizations seeking assistance evaluating the NPRM or preparing comments may contact Ted Waters and Phillip Escoriaza.