Feldesman Leifer LLP has filed comments, authored by partners Nicole M. Bacon and Ted Waters, on the proposed changes to Head Start regulations (found here). The potential modifications add some positive changes to resolve longstanding ambiguities in eligibility determinations as well as add an additional factor, housing cost, to the income determination to try to account for differences in cost of living across the country.

However, as detailed in our comments, many of the proposals are impractical without a significant increase in funding – a responsibility falling under the purview of Congress rather than the Executive Branch. Furthermore, they continue to hold Head Start programs to impossibly high standards with burdensome self-reporting requirements. We encourage the Office of Head Start to truly consider these proposed changes and, instead, offer positive changes that simplify and enhance the program, leveraging the expertise and professionalism of local programs.

Should you have feedback on the Head Start Program Performance Standards or questions on any other Head Start related matter, please reach out to Ms. Bacon (nbacon@feldesman.com) or Mr. Waters (ewaters@feldesman.com).