Can Head Start Be Deregulated Out of Existence?
For much of last year, Head Start, the federal program that provides child-care and preschool services for low-income families, appeared to have a doubtful future. Project 2025, the policy blueprint for Donald Trump’s second term, had called for the total elimination of Head Start, alleging—with scant evidence—that it was mired in an “unaddressed crisis of rampant abuse and lack of positive outcomes.” The federal spending freeze of January, 2025, forced dozens of Head Start centers to close down temporarily; a few never reopened. That spring, a leaked White House budget proposal criticized Head Start’s “radical” curriculum and its congressionally mandated embrace of diversity, equity, and inclusion—a policy framework that Trump had already tried, via executive order, to ban in federal agencies. Elon Musk’s Department of Government Efficiency slow-walked billions of dollars in funding from Head Start’s parent agency, the Department of Health and Human Services, in violation of federal law; DOGE’s cuts led to the shutdown of Head Start’s regional offices in five major cities (which remain closed).
A flagship project of Lyndon B. Johnson’s War on Poverty, Head Start was D.E.I. avant la lettre—the equity mission is right there in the name—and yet, throughout its history, the program has enjoyed bipartisan support. Today, it serves roughly eight hundred thousand children, infants, and pregnant women who live under the poverty level (defined as thirty-three thousand dollars a year for a family of four). The program has proved harder to kill than its foes may have expected: after the A.C.L.U. filed a complaint on behalf of Head Start in federal court, a judge in Seattle issued a preliminary injunction in January of this year that blocked the D.E.I. ban and protected the remainder of Head Start’s operating capacity. Another preliminary injunction last year stalled H.H.S.’s efforts to exclude some immigrant children from the program.
Stymied in its pursuit of Head Start’s elimination, H.H.S. is now pivoting to a new mode of attack: deregulation. On August 7th, the Administration for Children and Families, the division of H.H.S. that oversees Head Start, issued a notice of proposed rule-making under the magnanimous title “Reducing Federal Burden for Head Start Programs.” A.C.F.’s proposal would eliminate Head Start’s mandated child-to-caregiver ratios; instead, providers would default to the limits set by individual states and localities, which vary widely and tend to be less strict than Head Start’s.
A.C.F.’s proposal also dilutes or eliminates a swathe of other obligations, related to disability services (such as adaptive curricula and mental-health screenings), home visits, vision and auditory screenings, parent committees, teacher accreditation, the provision of full-day child care, and more. Though Trump’s A.C.F. seems mostly to be doing away with mandates, it does add a few new ones—among them, notably, a requirement that most Head Start programs be conducted wholly in English. Strikingly, in at least two places in the notice, A.C.F. cites Trump’s executive order prohibiting federal agencies from using D.E.I. policies—a violation, or so it would seem, of the preliminary injunction that blocked the D.E.I. ban. (The proposal is open for public comment until October 6th, after which A.C.F. will issue its finalized rule.)
A.C.F. estimates that the revamp of Head Start’s performance standards could save the program more than two billion dollars annually and add seats for as many as two hundred and thirty-six thousand more children. The rhetoric behind the proposals has been less centered on efficiency than flexibility and empowerment. In slackening Head Start’s rules, A.C.F. stated, the agency would be “empowering states and local authorities to meet the unique needs of children and families.” Shedding “onerous regulations,” A.C.F. went on, would “empower small and local businesses, freeing them to focus on excellence in service delivery rather than bureaucratic compliance.” In an op-ed for the Washington Examiner, Alex Adams, the H.H.S. Assistant Secretary who leads A.C.F., wrote, “We want to empower local communities instead of micromanaging them.”
Not so long ago, the policy architects of Project 2025 were maintaining that Head Start was “fraught with scandal and abuse.” The new messaging suggests that this government program is merely fraught with government. “Washington is failing Head Start,” the headline of Adams’s op-ed read. “We’re empowering parents instead.”
In the days following the A.C.F. announcement, as I spoke with Head Start staffers, parents, and advocates in a half-dozen states, I could not find anyone who felt “empowered” by the proposed rule. They believed that relaxing Head Start’s performance standards is intended to create a pretext by which H.H.S. can reject funding requests for any service or staffing plan that is no longer legally mandated—in other words, a disempowering scenario.
“Their thesis is to water down the quality of the program, and, as a result, we can add more children,” Joel Ryan, the executive director of the Washington State Association of Head Start, told me. Head Start generally requires that a full-day program serving four- and five-year-olds can include no more than seventeen children per class of two instructors; the same program with a majority of three-year-olds maxes out at fifteen kids to two instructors. But A.C.F., Ryan went on, is “signalling very strongly that they will fund you for the things that you are required to do. If you are no longer required to have these small child-to-teacher ratios, you won’t be funded for them.”
It might be argued that, in ending Head Start’s ratios, A.C.F. is effectively codifying that the quality of the program depends on where a kid happens to live. For children ages four to five, for example, New York has one of the most stringent standards for state-approved child-care providers, at eight kids per caregiver; Florida and North Carolina, the laxest states, have an honestly shocking proportion of twenty kids to a caregiver. For ages one to three in Connecticut, the ratio maxes out at five toddlers to one adult; in Arkansas, it’s twelve to one. But axing the standards for ratios, group sizes, and teacher qualifications is likely the only plausible means by which Head Start could, according to H.H.S.’s calculations, save billions of dollars while also adding roughly thirty per cent more children to its rolls.
“They project enormous savings from the reduction in the number of teaching staff, and the reason for that is the ratios,” Jennesa Calvo-Friedman, who was the lead counsel on the A.C.L.U. lawsuits, told me. “But the only way programs are going to have higher ratios is if they’re forced to. There’s just not a Head Start director or teacher who would ever ask for that.”
Small class sizes are crucial in Head Start schools, where many kids have disabilities or unstable home lives; they often need high levels of individual attention in order to thrive. “There are these bold claims about flexibility,” Jennie Mauer, who leads the Wisconsin Head Start Association, said of A.C.F.’s proposals. “But I don’t think any teacher is saying, ‘I have lots of children with speech and language delays, autism behaviors, and complex family situations, and the answer is that we need to serve more kids for less pay.’ ” She added, “Have these people ever met any small children? Do they know how to get a classroom full of three-year-olds to put their snow pants on?”
If Head Start can be said to be in “crisis,” to borrow a word from Project 2025, it is most plausibly so with respect to enrollment, which has fallen by more than two hundred thousand seats since before the coronavirus pandemic. The precipitous decline can be attributed to multiple factors—including, happily, the expansion of universal pre-K in some states. But a significant contributor has been staffing shortages and their knock-on effects. According to a government estimate, one in five Head Start teachers left their jobs in 2022. Low pay—about forty thousand dollars a year, on average—played a major role in the turnover. As a result, H.H.S. under President Joe Biden permitted many Head Start programs, in the absence of additional funding for teacher pay, to reduce enrollment, which helped them set aside money to improve wages and slow the staffing churn.
Thanh Bui-Duquette is a Head Start director for four counties in western Wisconsin, which include some Spanish- and Hmong-speaking communities. In several of her classrooms, close to half of the students have a diagnosed disability, and, she said, “challenging behaviors related to trauma” are common. Her programs reached a turnover crisis starting in 2021, when her lowest-paid staffers were making around eleven dollars per hour and teachers with licensure and bachelor’s degrees were making twenty-two. By comparison, Bui-Duquette told me, some high-school students at the local fast-casual chain Culver’s were slinging corn dogs and ButterBurgers for eighteen dollars an hour. Bui-Duquette felt that she had no choice but to lift her staff’s wages to keep the program open, at the painful cost of lowering enrollment. “This effort has helped us with staff retention, and, for the first time in many years, we have zero per cent turnover in teachers,” she said.
About a quarter of Bui-Duquette’s staff members are former Head Start parents or alumni. “They believe in the Head Start model,” she said. “What is disheartening is that they continuously feel the need to prove that their work matters, and that is really draining and demoralizing.” She believes that, if the A.C.F. proposal is implemented, the staff turnover of a few years ago will resume, owing to lower standards and, presumably, lower pay. “They will find somewhere else to go,” Bui-Duquette said. “If these changes go through, we will not be Head Start anymore.”
In 2024, H.H.S. approved incremental, across-the-board wage increases that were intended to bring all Head Start teachers’ earnings in line with those of their counterparts at local public schools. In the hope of paying these educators a princely average of about fifty thousand a year while maintaining enrollment numbers, Biden asked Congress, in 2023, to give Head Start an additional $1.1 billion—about what aviation experts have estimated it would cost to refurbish Trump’s Qatari private jet. But Congress agreed to just two hundred and seventy-five million dollars—less than the estimated taxpayer bill for Trump’s ballroom. (In May, A.C.F. proposed rescinding the Biden-era wage increases.)
In its sixty-one years of existence, in fact, Head Start has never been funded at a level commensurate with the number of low-income children in the United States. A Government Accountability Office report found that, in 2020, Head Start served only about half of the preschoolers and ten per cent of the infants and toddlers who would have been eligible for a spot. Head Start’s budget for the most recent complete fiscal year remained more or less flat, at about $12.3 billion. That is several billion short of what the U.S. spent on the first twelve days of the war in Iran, a conflict that roughly sixty per cent of Americans oppose, and it is less than half of what is allocated in the One Big Beautiful Bill Act toward hiring, training, transportation, I.T., and bonus pay for Immigration and Customs Enforcement, an agency that about half of Americans want to abolish. By contrast, recent polling shows that eighty-seven per cent of Americans support Head Start, including eighty-four per cent of Republicans and ninety-four per cent of Democrats.
Head Start’s mutually reinforcing afflictions of low wages and low enrollment could be neatly solved, of course, by the data-driven policy innovation known as sufficient funding. Until that bleeding-edge value-add catches on among policy wonks, however, the remedy at hand is that of “Reducing Federal Burden.” Within the economic and ideological framework of A.C.F.’s proposal, it has been Head Start’s fate to shoulder this unwanted and unneeded regulatory burden, and now it can fling off this millstone and, in the Nietzschean sense, become what it is.
Through a different lens, however, this so-called burden is Head Start: the performance standards—which originated with a panel of experts in pediatrics and developmental psychology at Head Start’s founding and have been revised multiple times since—are what define and delimit the program’s mission and operations. “The idea that we have to get rid of the standards in order to offer more flexibility is totally at odds with how Congress designed Head Start,” Calvo-Friedman, the A.C.L.U. lawyer, told me. “The standards are understood by Congress to be the core of the program.”
When I spoke on the phone with Adams, of A.C.F., he seemed to reject this understanding of Head Start. “The heavy hand of regulation that previous Administrations have layered on has increased cost and reduced access,” he told me. “If you believe in this program, as I do, you would want more kids to access it, not fewer kids.” He pointed out that there is little in the proposed rule that’s explicitly required. “Flexibility is not a mandate,” he said. “If a facility likes its ratio, it can keep its ratio.” But the sharp drop in Head Start’s enrollment in recent years, he suggested, was a moral failing. “Previous Administrations have made purposeful decisions to rob children and families” of their chance to participate in Head Start, he said.
Part of the intent of A.C.F.’s proposal, Adams told me, is “to correct the errors of some of these self-appointed élites.” He disavowed the “belief that Washington, D.C., knows best, that people in these limestone buildings off of Independence Avenue should dictate one-size-fits-all decisions for every facility in the country.” Relaxing Head Start’s standards would restore agency to local directors, who are, Adams said, “some of the most high-calibre individuals I’ve ever worked with.” I asked if any of them had requested higher child-to-staff ratios. “We have had program directors who have said in their unique communities it would have been beneficial to them,” Adams replied. When I asked him who these directors are or if he could put me in touch with them, I did not receive an answer.
“I trust them to make good decisions,” Adams told me. “I trust that they’re in this for the right reasons. It’s unfortunate that others think they’re bad actors who are going to do bad things.” He repeated this line about “bad actors”—almost verbatim and with emphasis—a few moments later. I told him that I didn’t know anyone who was thinking or saying this about local Head Start directors. Surely both of us “would vehemently disagree that there are any bad actors among teaching staff or program staff at Head Start,” I said.
“That’s the message that was being sent, Jessica,” he replied. “That’s the message that’s being sent.”
I told Adams that I’d spoken with a program director in Wisconsin who had made the excruciating decision to “reduce access” to Head Start programs in her community, simply because it was the only way to retain staff and pay them a livable wage.
This director had chosen “to prioritize teacher pay more than access to children,” Adams remarked, unmoved.
But her dilemma was a matter of underfunding, I replied, not one of “bureaucracy or onerous regulations or someone from D.C. forcing them to serve fewer children.”
“They also might be discounting what was baked into regulations that leads to their daily cost of business,” Adams said.
I didn’t know which regulations he was talking about. But I did understand, just then, what he’d been telling me about the Washington bureaucrats who know better than a Head Start director, in these limestone buildings off of Independence Avenue. ♦