Day 17 of the 20-Day Public Comment Challenge: Two Rules, the Same Staff
Today’s Prompt:
Two rules would hit the same staff. One would end the 2024 pay and benefit rules. This one would end training rules, coaching, the Child Development Specialist, and required breaks. ACF added up what the two rules would save. It never asked what they would do to hiring and to keeping good people. Say what both rules together would mean for the staff at your program.
Day 17 Prompts for the Action Alert
Staff: “I am a [role] at [program]. Both rules would change my job. One would end the pay and benefit rules. The other would end [coaching, training for my role, my break]. Together that would mean [what you would think about when you decide whether to stay].”
Parent: “My child’s teacher at [program] has been there [number] years. That matters to my child. One rule would cut pay. The other would cut training and support. That is not a plan to keep teachers like her.”
Community Partner: “I am the [title] at [organization] in [county] County. It is already hard to hire early childhood staff here. [What you see: open jobs, how long they stay open, where people go instead.]”
Where it says that: The other rule is RIN 0970-AD21, docket ACF-2026-0364, published May 12, 2026 at 91 Fed. Reg. 25842. It would end the 2024 pay and benefit proposal; it is itself still a proposal, and comments closed June 11, 2026 with no final rule issued. This rule, RIN 0970-AD30, would end training rules for non-teaching staff, required coaching, the Child Development Specialist role, and required staff breaks. ACF’s cost analysis for this rule assumes the pay proposal never takes effect; a second estimate assuming it does shows savings about 19 percent higher, close to $2.64 billion instead of $2.2 billion, but ACF states that second estimate leaves out how the pay proposal would phase in and the resulting cost of retaining remaining staff.
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.
Wondering how public comments help? Watch a 3-minute explainer
This short video walks through what the proposal would change, why it matters, and exactly how to submit a comment, even if you’ve never done this before.
How to leave an impactful comment
You don’t need to be a policy expert to submit a strong comment, and you don’t need to cover every issue in the proposal. In fact, a comment that focuses on one thing is often more powerful than one that tries to address everything.
- 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.
- Submit it before October 6, 2026.
Advocacy Is How Head Start Wins
Advocacy is central to WHSA’s mission. Whether it’s protecting funding, shaping policy, or making sure lawmakers hear directly from the people doing this work, your voice matters. Here’s how to get involved:
Join Our Advocacy Email List
Stay informed on policy updates and action opportunities
View NPRM Resources from our friends at Together for Head Start
Together for Head Start has put together many resources on their linktr.ee/headstartnprm
Explore Our Advocacy Link Tree
One place for all our advocacy tools and resources
Complete WHSA's 2-part Action Alert
This Action Alert sends a message directly to your elected officials, and submits a comment! Two very impactful ways to speak up for Head Start, in one.
