Day 16 of the 20-Day Public Comment Challenge: Waiver Authority
Today’s Prompt:
Today’s provision is the waiver authority, proposed § 1301.18. The rule would let a program ask HHS to waive almost anything in it. Only nutrition, physical activity, and eligibility are off limits. The section never says how HHS decides, what a program has to show, or whether an approved waiver is ever made public. If you’ve been through a waiver request, write about that. What did you have to document? How long did it take? Did anyone explain the decision? If you haven’t, say what you’d need to know before asking for one.
Day 16 Prompts for the Action Alert
Staff: “I am a [role] at [program] in [county] County. I’ve worked in Head Start/Early Head Start for [number] years. My program requested a waiver for [requirement], and here is what that took: [what you had to show, how long it took, what you heard back]. If ACF can approve waivers without a standard, two programs in the same county could run different rules on ratios, discipline, or hours. Families comparing their options have no way to see that.”
Parent: “I’m a Head Start/Early Head Start parent in [county] County. If my child’s program gets an exception to a rule and the program in the next town doesn’t, I have no way to find out. That matters to me because [your reason].”
Community Partner: “As [title] at [organization], we refer families to more than one Head Start program in [county] County. A waiver process with no published standard makes it harder to tell families what to expect, because [specific reason tied to your referrals or intake].”
Where it says that: Reducing Federal Burden for Head Start Programs, 91 Fed. Reg. 51248, at the waiver-authority discussion (proposed Aug. 7, 2026) (to be codified at 45 C.F.R. pt. 1301) (Docket No. ACF-2026-0595). The waiver text is proposed § 1301.18(a) and (b). The rule removes specific existing flexibilities because § 1301.18 is broader, naming current § 1304.17 (disaster relief determinations in emergencies) and § 1302.14(b) as examples. The waiver authorities already in the Head Start Act are Sec. 640(b), Sec. 640(d)(4), Sec. 640(f)(1), Sec. 644(b)(2), and Sec. 648A(a)(4).
This is one of 20 daily prompts. You don’t have to wait, browse them all and submit on any prompt that fits your situation, anytime between now and October 6. See the rest on the 20-Day Comment Challenge page.
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- Focus on one area of the proposal you feel most passionate about.
- Add a short, real story about how that change would affect you, your child, or your classroom.
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