Pay For Success

ICS’s Response to Head Start Proposed Revisions


This post was submitted as formal comment in response to the Notice of Proposed Rulemaking regarding the Head Start Performance Standards. Comment period has been extended until September 17. More details are available here.

The Institute for Child Success (ICS) writes in support of the proposed revisions to the Head Start Performance Standards. ICS is a private, nonpartisan research and policy organization with offices in Greenville, South Carolina and New York City. ICS works to create a culture that facilitates and fosters the success of all children. ICS supports policymakers, service providers, government agencies, funders, and business leaders focused on early childhood development, healthcare, and education – all to coordinate, enhance, and improve those efforts for the maximum effect in the lives of young children (prenatal to age five).

ICS supports the goals of strengthening Head Start’s impacts on child development and family well-being. Among the most notable of the recommendations is extending the minimum hours and days of program operation, from 3.5 to 6 hours per day and from 128 to 180 days per year, in line with longer operating schedules seen in the most successful early learning programs. Over 70 percent of Head Start programs in the South currently provide full-day programming, 5 days per week, as compared to less than half of programs nationwide. Full-day Head Start has the potential to improve academic and social outcomes while also improving attendance as schedules may be better aligned with parents’ work schedules. We support the proposed requirement for programs to consider provide a full-year program, with an acknowledgement that not all sites will be able to achieve this. Diverse Children

Several other revisions will work within the existing Head Start structure to make the program work better for children and families. A focus on tracking and improving attendance; more effectively targeting family engagement activities; and firm limits on the use of suspension and expulsion all make clear the importance of ensuring the current program fits the needs of those it serves. Programs will have the opportunity to monitor these policies and their impact through the proposed continuous improvement cycle, requiring data collection and aggregation three times per year. Analyzing program data can provide an important insight into what is working, what isn’t working, and how programs can better serve families. Social programs are increasingly expected to be evidence-based; this focus on data in Head Start helps bring the program more fully into this movement.

Head Start has always been an important resource of low-income families, but these revisions support an effort to integrate children of diverse socioeconomic backgrounds. Research has continually shown that the peer effects of serving mixed-income children can benefit low-income children who start pre-K the most at risk while not delaying the progress of high-income children. Allowing blending and braiding from other sources as well as private parent fees is particularly important to helping families access early childhood education in areas where programs are scarce. By mixing funding streams of enrolled children, as well as pushing to align Head Start curriculum with state early learning standards, Head Start moves toward a comprehensive early childhood system and away from the current silos.

The proposed regulations achieve their goal of removing several regulatory restrictions as well as raising other program standards which are linked with better outcomes. Continuing to allow for local flexibility and exceptions through a waiver process for specific requirements will help ensure that programs are able to continue providing important services to children and families while continuing on the path to improve quality.