On January 19, 2014, APA submitted comments (PDF, 541KB)opens in new window on an Office of Head Start (OHS) Notice of Proposed Rulemakingopens in new window that would, if enacted, implement requirements to support the Head Start program workforce and integrate mental health services into Head Start programming, among other proposed changes. The comments are broadly supportive of the proposed rule but encourage OHS to consider flexibility that may help underserved areas implement the changes and consider the funding sources that would support the proposed changes. They were drafted in collaboration with APA’s Committee on Children, Youth, and Families, Coalition for Psychology in Schools and Education, Committee on Ethnic Minority Affairs, and the Interdivisional Task Force for Child and Adolescent Mental Health.
Head Start programs, which are locally operated educational programs that provide free early learning and childhood development programming for children under the age of 5 and pregnant individuals from low-income families, have been historically federally underfunded compared to the needs of the program and the communities they serve, and have been experiencing widespread staffing shortages.
To address these shortages and recruit and retain staff, OHS proposes staff wage increases. While APA’s response supports these well-intentioned goals, it notes that mandatory wage increases, without increases in program funding from Congress, are likely to lead underresourced programs to limit staff positions or even lose the ability to maintain programming.
APA also supports the proposed rule’s efforts to promote the inclusion of mental health services along with psychical health services in programs and schools. The comments provide recommendations to further support the mental health of program participants, including recommendations to include staff training and childhood screening for trauma and adverse childhood experiences. The association encourages flexibility in requirements for mental health services due to the current widespread shortage of mental health providers, especially in underserved areas.
Lastly, APA expresses support for sections in the proposed rule that would improve efforts at Head Start programs to eradicate exclusionary disciplinary practices, such as suspension and expulsion, and provides recommendations in the areas of health and safety, family engagement, enrolled pregnant individuals and prenatal and postpartum services, and staff health and wellness.
For more information, contact Kenneth Polishchuk.