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Gov. Stein submits letter to DHHS as public comment period for changes to Head Start comes to a close on Oct. 6

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Courtesy of Lindsay Saunders on behalf of East Coast Migrant Head Start Project

Gov. Josh Stein sent a letter to the U.S. Department of Health and Human Services (HHS) on Monday, asking that the department to reconsider many of its proposed changes to Head Start, including the new English-language instruction mandate, the elimination of staff-to-child ratios and group-size caps, and more.

The department announced these proposed changes on Aug. 6, and the rules are open for public comment until Tuesday, Oct. 6, 2026. You can submit a comment here. For more information on the proposed rule changes, explore these resources from Head Start.

“We are removing unnecessary bureaucracy, strengthening nutrition and physical health, trusting parents and local communities, and opening Head Start to hundreds of thousands more children,” said HHS Secretary Robert F. Kennedy in an August press release regarding the proposed changes. “That’s how we renew the promise of Head Start for the next generation.”

On Monday, Stein said in his letter that he shares “the goal of ensuring that Head Start programs can serve more children and families while operating effectively” and that he appreciates “efforts to reduce unnecessary administrative burden and provide local programs with appropriate flexibility.” However, he raised concerns about how the changes to the program could impact its accessibility and quality.

“At the same time, I am concerned that the proposed rule… would remove or substantially weaken safeguards that are central to Head Start’s quality, accountability, and comprehensive-service model,” wrote Stein.

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What is Head Start?

Head Start is a federally funded program that supports “children’s growth from birth to age 5 through services centered around early learning and development, health, and family well-being.”

Head Start services are available to eligible families at no cost for children ages 3-5, with the Early Head Start program supporting children from birth to age 3 in eligible families. There are also supports for pregnant women or expectant families. The program was officially launched in 1965 under President Lyndon B. Johnson, and it has enjoyed bipartisan support from legislators and voters alike since its inception, according to the First Five Years Fund.

According to the North Carolina Head Start Association, our state is home to 59 federally funded Head Start grantees, including Tribal (Cherokee), migrant, community action, nonprofit, government, and educational programs. According to a press release from the governor, both Early Head Start and Head Start are “comprehensive programs that support more than 17,600 North Carolina children from birth to age five.”

The programs “provide high-quality early education and care, health screenings, nutritious food, prenatal care for pregnant women, and services that prepare children for school and beyond,” the release says.

Additionally, the program brings in more than $290 million in federal funds directly to the North Carolina economy, supporting over 5,600 jobs at local agencies, private nonprofit child care centers, and school systems, according to the release.

“Head Start is where many North Carolina children first learn to love school,” said North Carolina Superintendent Maurice “Mo” Green in the release. “By the time they reach a kindergarten classroom, they know how to listen, share and ask questions, and their families already know how to be partners in their child’s education. Teachers and principals see the difference. Many Head Start classrooms sit inside our public schools or work alongside our NC Pre-K programs, so when Head Start is strong, our schools start stronger.”

More on proposed changes

In his letter, Stein asked the department to “protect key standards for Head Start programs as the department considers proposed changes to the federal program.”

According to the press release, Stein asked the department to take the following actions with respect to the rule change:

  • Retain federal staff-to-child ratios and group-size limits to ensure enough teachers are present so every child receives the attention, support, and care they need
  • Preserve the full range of services that help children learn and thrive while supporting their health and strengthening their families
  • Support a stable and qualified early childhood education workforce by maintaining standards related to qualifications, compensation, benefits, and professional development
  • Maintain adequate program duration and accountability to support children’s learning and fit the realities of families’ work schedules
  • Preserve a workable administrative-cost standard and retain the current 15 percent ceiling established in federal law rather than imposing a uniform 5 percent limit
  • Maintain meaningful language access and family engagement, including the ability of programs to support children’s home languages while they learn English

Green said in the release that he agreed with Stein.

“Small class sizes, qualified teachers, full-day schedules and health and family supports are what make (Head Start) work,” said Green. “I join Governor Stein in asking that those standards be kept in place for every child, no matter where in North Carolina that child lives.” 

You can read Stein’s full letter here.

Expanded class sizes

In the current law, the federal government is empowered to establish class ratios based on the age of the children being served and “scientifically-based and developmentally-appropriate performance standards.” In states with more stringent rules, the programs are required to meet those standards.

Early childhood education research has found that there are significant benefits to children’s achievement, especially their literacy acquisition.

The governor’s letter said the proposed changes would remove the federal rules regarding class sizes and student-teacher ratios, shifting the rulemaking power to states. Stein raised concerns that this would eliminate national consistency and that, in states with less strict rules, “programs could be permitted to operate with larger group sizes or higher child-to-staff ratios than current Head Start standards allow.”

“Small classes and sufficient staffing allow teachers to see, hear, and respond to each child,” wrote Stein. “Individualized attention is especially important for the types of children Head Start serves: infants and toddlers, children from low-income families, children with disabilities or developmental delays, and dual-language learners.”

Graphic by Lanie Sorrow

Impact on dual-language learners

Since 2016, Head Start has “required supports for bilingualism,” meaning that if a child’s native language is not English, the program prioritizes education for that child in both their native language and English.

The proposed rule change, however, would mandate that Head Start instruction occurs in English, prioritizing teaching English to children whose language is not English. There is an exception for the Indian Head Start agency “so long as the language being spoken relates to the furtherance of tribal heritage.”

“Incorporating children’s home languages (is) an important asset for learning, family engagement, and healthy identity development. Programs need the flexibility to use research-informed approaches that support both English language acquisition and children’s home languages,” wrote Stein. “Suppressing a child’s home language is more likely to slow English acquisition than to speed it up.”

Many advocacy and research groups, as well as the National Head Start Association, have raised concerns about how the English-language instruction mandate would negatively effect the program model.

“Nationally, one-third of children under the age of 5 are dual language learners (DLLs), and DLLs account for an even higher percentage of Head Start (36%) and Early Head Start (40%) enrollment,” according to a report from the National Institute for Early Education Research. “If Head Start mandates English-only instruction and removes other supports for bilingual learners, Head Start will become less effective with a population for which it has produced especially strong results in the past.”

Input from states, the public

Before finalizing the rules, the governor requested that the department “conduct a transparent assessment” of the impact rules would have on “program capacity, staffing, family costs, service quality, and state systems.” He also asked for “meaningful opportunity for state and local partners to shape any revisions.”

“I stand ready to help HHS identify requirements that can be streamlined without sacrificing program quality, child safety, workforce stability, or access to comprehensive services,” wrote Stein.

Currently, the only opportunity for input from states or the public is through the 60-day public comment period, which ends on Oct. 6. You can submit comments here.