On Tuesday, September 15, Feldesman Tucker Leifer Fidell LLP, responded to the Notice of Proposed Rulemaking (NPRM) published on June 19, 2015 (80 Fed. Reg. 35430).  FTLF’s comments are not indented to be a comprehensive review of the NPRM, but instead provide suggestions on how to further improve the clarity, effectiveness and fairness of certain aspects of the Performance Standards.  The suggested changes will reinforce OHS and Head Start programs efforts of fulling the mission of serving the children and families in communities throughout the nation.