Re: Reducing Federal Burden for Head Start Programs, 91 Fed. Reg. 51,248 (Aug. 7, 2026), RIN 0970-AD30, Docket No. ACF-2026-0595
Dear Secretary Kennedy, Assistant Secretary Adams, and Director Casco White:
Thank you for the opportunity to comment on the proposed rule, Reducing Federal Burden for Head Start Programs. Policy Matters Ohio is a nonprofit, nonpartisan research institute dedicated to creating a more vibrant, equitable, sustainable, and inclusive Ohio. Through research, policy analysis, strategic communications, and coalition building, we examine how public systems affect Ohio children, families, workers, and communities. Our work includes extensive research on early childhood education and family economic security.
The proposal is framed as a reduction in administrative burden. In reality, it would reduce access to quality early childhood education for children who need it most. It would dismantle the quality standards that have made Head Start one of the nation’s most effective anti-poverty programs for nearly sixty years. The rule would eliminate or weaken the majority of Head Start’s Program Performance Standards that successfully ensure children receive comprehensive developmental, educational, health, nutrition, and family support services. It is an abdication of duty to America’s children to lower standards to this degree and allow children’s access to quality care and education to depend upon their state or zip code. At a time when families in Ohio are facing high childcare costs, educator shortages driven by low wages, and economic instability, federal policy should be strengthening programs like Head Start, not weakening them.
We oppose this proposed rule and urge the Department to make substantial changes or withdraw it in its entirety.
Ohio families need more early childhood support, not less.
Ohio families already face significant barriers to accessing high-quality early childhood care and education. The average annual cost of infant care in Ohio is $10,417; a family would need nearly $149,000 in annual income for that care to meet the federal affordability benchmark. Further, a family would have to make $352,428 (1100% of the FPL!) a year to afford care for an infant and a toddler at the average childcare center. In other words: It would take the typical Ohio family about five years and three months to have enough income to afford just one year of childcare for their two kids. At the FPL, a family of four in 2025 would have to work nearly eleven years to afford the same.[1]
Ohio also has one of the least accessible publicly funded child care systems in the country.[2]
Ohio’s childcare workforce has experience severe instability. From 2019 to 2025, the number of childcare workers in Ohio dropped by 39.6%, with the biggest decrease of nearly 5,000 workers happening between 2019 and 2020. Many areas around the state simply have not recovered from this loss of workforce and many remaining childcare facilities are at a high risk of closure because lack of state investment has resulted in razor thin margins keeping wages low while costs continue to increase.[3] These circumstances have left many communities with persistent staffing shortages and fewer options for families.
In this context, it is easy to see how Head Start is a critical component of Ohio’s early childhood infrastructure and weakening the program through the proposed rule will have substantial negative outcomes for Ohio families.
Head Start serves many of Ohio’s most vulnerable children. In 2024, Head Start and Early Head Start served more than 33,000 Ohio children across 651 program sites. Among them were approximately 1,700 children in foster care, more than 1,600 children experiencing homelessness, and nearly 4,000 children receiving IDEA developmental or special education services.[4] Those children deserve high-quality care and education to prepare them for kindergarten and life, and Head Start is often their only chance to get it.
Specifically, changes that weaken standards for developmental screening, disability services, family engagement, health supports, and comprehensive services would disproportionately affect children already facing substantial barriers. Those measures should not be implemented.
Head Start’s standards are not a burden; they are the foundation of program quality and success.
The central flaw in this proposed rule is its failure to distinguish between paperwork and program quality. The Head Start Program Performance Standards establish the conditions that allow programs to deliver meaningful outcomes for children, families, and communities. Specifically, we urge the Department to maintain standards governing staff-child ratios, class sizes, educator qualifications, early intervention, mental health supports, home visiting, nutrition, and inclusion of children with disabilities.
The proposed rule would defer in many cases to state licensing standards. Doing so could reduce the efficacy of Head Start in certain states, as licensing standards are designed primarily as minimum qualifications for health and safety. Head Start is so successful because it has always gone beyond minimum standards, and with good reason: reducing poverty requires more than just passive supervision of children. It requires intentional investment in learning, development, health, nutrition, and family well-being. Reducing standards will mean children who are already constrained by economic hardship will lose another path out of poverty and the educational and health outcomes that come with it.
The rule threatens Ohio’s workforce and economy.
Head Start is not only an early childhood education program, but also essential economic infrastructure. Reliable early childhood programs make employment possible. According to a 2026 poll by Groundwork Ohio, 53% of Ohio parents say they or someone they know would enter the workforce if quality childcare were available and 11% of Ohio parents reported trouble finding or keeping a job due to childcare issues.[5] The proposed rule would weaken one of the state’s most important tools for providing affordable childcare and supporting workforce participation.
The Department’s own analysis anticipates substantial reductions in staffing and compensation. Together for Head Start’s analysis shows that the proposed changes will result in nearly 1500 jobs lost, and an increase in childcare costs for all Ohio children of more than $500 a year.[6] Ohio has recent, ongoing experience with childcare staff shortages. We know that fewer qualified professionals means fewer supports for families, lower program quality, diminished educational and developmental outcomes, and costs that continue to increase while childcare deserts grow.
Ohio families, employers, and local economies depend on strong childcare systems. Weaking one of the nation’s most successful programs will move our state and country in the wrong direction. Children experiencing poverty deserve more opportunities for high-quality education through programs like Head Start.
Thank you for the opportunity to comment,
Ali Smith
Senior Project Coordinator
Policy Matters Ohio
[1] Ohio’s Childcare Crisis, by Ali Smith, Kathryn Poe, and Heather Smith. Policy Matters Ohio. April 15, 2025.
[2] Warning Signs: State Child Care Assistance Policies 2025, by Karen Schulman. National Women’s Law Center. May 2026.
[3] Bureau of Labor Statistics Occupational Employment and Wage Statistics. Accessed January 31, 2025.
[4] 2025 Head Start: Ohio. First Five Years Fund.
[5] Ohio Voters Agree: Child Care Is an Affordability Issue State Leaders Can Address. Groundwork Ohio and First Five Years Fund. August 24, 2026.
[6] Fact Sheet: The Administration’s Proposed Changes to Head Start Will Cut Jobs and Increase Costs for Families. Together for Head Start, in partnership with Head Start Associations.