APA Services submitted public comments on the proposed changes to Head Start Program Performance Standards (Docket No. ACF–2026–0595) (PDF, 274KB)opens in new window urging the agency, in the absence of substantial revisions, to withdraw a proposed rule that would rescind and replace Head Start’s Program Performance Standardsopens in new window. The comments raised significant concerns with proposed revisions that would remove or revise numerous federal requirements governing program operations, health and safety, workforce practices, and services for children and families.
While APA Services supports targeted efforts to streamline requirements that divert time and resources from children and families, its comments cautioned that flexibility must not erode consistent, evidence-based protections. The comments emphasized Head Start’s whole-child model and urged the Administration for Children and Families (ACF) to maintain strong standards for mental health consultation, developmental and behavioral screening, referrals, individualized supports, family engagement, and coordination with qualified community providers. Furthermore, concerns were raised about proposed changes to requirements for dual language learners, stressing the importance of linguistically responsive services that support children’s home languages and English-language development.
APA Services also urged ACF to preserve clear national expectations for serving children with disabilities and safeguards against exclusionary discipline. Weakening limits on suspension and expulsion, the comments warned, could disproportionately harm children with disabilities and children whose behavior reflects trauma, stress, or unmet developmental or mental health needs. APA Services called for preventive, developmentally appropriate, and evidence-informed supports—including collaboration with families and qualified professionals before a child is removed from a program—and cautioned that excessive reliance on varying state or local requirements could produce uneven access to essential services.
APA Services will continue to monitor the rulemaking and advocate for policies in Head Start, and other early childhood education programs, that combine effective program flexibility with strong, research-based protections for children’s learning, development, health, and well-being.
For more information, email Kenneth Polishchuk.