The 20-Day Comment Challenge: Protect Head Start Standards
One Head Start rule a day, September 17 through October 6, help shape the official record on Docket ACF-2026-0595. Submit Your CommentWhat’s Happening
On August 7, 2026, the Office of Head Start published a Notice of Proposed Rulemaking titled "Reducing Federal Burden for Head Start Programs" (91 Fed. Reg. 51248-51322; RIN 0970-AD30, docket ACF-2026-0595).
It proposes to rescind the current Head Start Program Performance Standards and replace them with a much shorter set of rules that defer most specifics to state law. Comments are due October 6, 2026. Everything filed becomes part of the official record, and the agency has to respond to its substance before issuing a final rule. If the rule is ever challenged in court, that record is what gets examined.
What we’re doing
One prompt a day for 20 days, September 17 through October 6. Each takes a different piece of the proposal, gives you an example way to start for staff, parents, or community partners, and tells you exactly what to ask for and where it comes from.
A few things before you begin
- Write as yourself, not for your program. You don’t need to speak for anyone but yourself. What you’ve seen firsthand is exactly what makes a comment worth reading.
- Keep it simple. One clear point tied to something specific you’ve seen is stronger than trying to cover everything, and it’s easier to write.
If you partner with Head Start
We especially want to hear from you, and your situation is different. School districts, clinics, food pantries, libraries, technical colleges, referral agencies: write what you see on your end. The children arriving in your kindergarten classrooms. The families you refer back and forth. The students in your early childhood courses headed into these jobs. The agency can’t hear that from Head Start, which is why it lands differently coming from you.
How to submit
Use our action alert to submit your comment directly to the ACF docket (ACF-2026-0595). There’s one space to personalize with your own thoughts, experience, or how one of these changes would affect you, the rest of the letter, including the opposition statement and closing ask, is already written for you.
Not sure what to say? Below are 20 daily prompts, one for each day of the challenge through October 6. Each one focuses on a different piece of the proposed rule and gives examples for staff, parents, and community partners. Pick today’s prompt, or any prompt that fits your situation, and use it to write your personal note before you submit.
20-Day Public Comment Challenge Prompts:
Day 1 | Introduce Yourself
Say who you are, how you’re connected to Head Start, and why this proposal affects you. No policy background needed, just your own words.
Day 2 | Group Size and Ratios
Federal ratio limits would disappear under the proposed rule, leaving classroom sizes up to each state. Describe what two more children per adult would mean in your classroom.
Day 3 | Recruitment, Waiting Lists and Reserved Slots
Federal guidance on recruitment priorities and reserved slots for children in foster care or without stable housing would get much less specific. Say how your program decides who gets the next open slot.
Day 4 | Non-teaching Staff Training and Breaks
Federal training requirements for bus drivers, cooks, and family advocates, and the required staff break policy, would both go away. Say what your role actually requires that a job posting would miss.
Day 5 | Administrative Cost Cap
The cap on administrative costs would drop from 15 percent of the grant to 5 percent. Say what a cut that size would mean for your program’s payroll, enrollment records, or compliance staff.
Day 6 | Program Year Hours
The minimum program year would drop from 1,380 hours to as few as 128 to 160 days. Say what a much shorter year would do to your schedule or your program’s calendar.
Day 7 | Home Based Services
The proposal gives fewer details on home-based services, including how often a home visitor must see a family. Say what a visit covers, and what fewer visits would cost.
Day 8: Suspension, Expulsion & Behavioral Support
The federal ban on removing children, and the required level of behavioral and mental health support, would both go away. Describe what your program did instead of removing a child.
Day 9 | Homelessness documentation and reporting duty
A parent’s own word would no longer establish homelessness, and staff would pick up a new duty to report suspected eligibility problems. Say what documents a family staying with relatives can actually get.
Day 10 | Coaching and child development specialist role
Required coaching and the Child Development Specialist role would both be cut. Say what a coach does in a normal week, or name one thing a coach changed about your teaching.
Day 11 | Parent Committees
The parent committee is the closest thing Head Start has to a local governing voice, and this proposal would make it optional. Describe one thing your committee changed.
Day 12 | English-Only Versus Dual Language Support
The rule pushes toward English-only instruction while the Head Start Act still requires support for children learning two languages. Describe one classroom moment where a child’s home language mattered.
Day 13 | Screening versus the disability enrollment requirement
Screening requirements would become much less specific while the law still requires that 10 percent of enrolled children have a disability. Give an example if you have one.
Day 14 | Where would families go instead
If your program shortened its year, raised class sizes, or closed, where would you go instead? Give the distance, the cost, and the waiting list if you know them.
Day 15 | Health, oral health, and mental health specificity
The proposal gives much less detail on required health, oral health, and mental health services. Describe a screening, referral, or consultation you doubt would happen without a federal requirement.
Day 16 | Waiver Authority
The rule would let a program ask HHS to waive almost anything in it. It never says how HHS decides, what a program has to show, or whether an approved waiver is made public.
Day 17 | Two Rules, the Same Staff
Two rules would hit the same staff, one ending pay and benefit rules, this one ending training, coaching, and required breaks. Say what both together would mean for your team.
Day 18 | The Parental Authority Framing
The rule is framed around parental authority and letting states decide. Does removing the ratio requirement give you more say over your child’s classroom, or less information about it?
Day 19 | Last Chance to Comment
If you have not filed yet, today is the day, because tomorrow is the deadline. Pick any topic from the past 18 days, or one of your own.
Day 20 | Today is the last day to comment
Today is the deadline. Fewer hours, fewer days in quality care, fewer services, from fewer staff who are paid less. Say what that adds up to for you.
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