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Last week ������Ƶ submitted comments on the Administration for Children and Families’ (ACF) to the Head Start Performance Standards. The Notice of Proposed Rulemaking, which was released back in June, includes many to Head Start, the nation’s largest early education program. The new, streamlined standards are grounded in the growing body of research on��how children learn and how to best prepare them for kindergarten and the later grades. While the proposed standards are still prescriptive, they now focus less on process and more on outcomes.

We commend many of the reforms, including the increased focus on research-based curricula, the language limiting suspension and prohibiting expulsion, and the emphasis on coaching as a form of professional development for teachers. We primarily focused our comments and recommendations on specific areas that ACF asked for public comment. Below are a few of our recommendations for improving the proposed standards so that Head Start is able to most effectively serve our nation’s vulnerable children.

• Full-day, full-year programs should be the ultimate goal. , and , is associated with better cognitive outcomes than half-day programs. Increasing the minimum hours per day to six hours would allow more time for positive and meaningful interactions between adults and children and would give Head Start teachers more time to implement developmentally appropriate curricula that include early math and literacy, and social emotional learning. ACF suggests a new six-hour minimum that better aligns with most elementary schools and with the schedules of many working families. We think all Head Start families should have access to full-day programs. If ACF is able to secure funding from Congress to increase dosage, this transition to full-day programs should be phased in over three years to limit disruption for families and program staff, and to ensure that they continue to best serve children.

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• If ACF faces the difficult trade-off between increasing dosage and maintaining enrollment, ACF should choose to maintain enrollment for now. It’s looking unlikely that Head Start will receive an increase in funding this year large enough to support all programs for a full-day and full-year. If minimum dosage increased without the appropriate level of funding over 120,000 Head Start slots could be cut, according to ACF. In many states, Head Start-eligible children don’t have access to another affordable, high-quality early education program. This is a difficult trade off, but we feel that unless these children can be guaranteed access to other comparable programs, Head Start programs should maintain their current dosage levels. If Head Start is not funded to support full-day programs this year, full-day Head Start should be a goal for reauthorization. Without the necessary funding, we propose two alternative options. One would be to have a staggered ramp up to full-day over the next several years. The other would be requiring part-day Head Start programs to partner with other programs, such as public pre-K and child care centers, so that children are in learning environments until the end of the school day, even if the whole day is not in Head Start. We expand on these options in our recommendations.

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• Head Start programs should not be obligated to join state QRIS systems at this time. Head Start programs should only join state QRIS when there is an unburdensome pathway for them to join and the QRIS has been validated to show that the tiers accurately reflect program quality. Numerous state QRIS validation studies are expected to be released this fall, which will shed more light on the use of this tool. Head Start programs already face administrative burden and requiring them to join QRIS might be duplicative of their existing reporting requirements. Since most states are still creating and improving their QRIS systems, it would not be appropriate to require Head Start programs to participate at this time.

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• All Head Start classroom teachers should eventually have bachelor’s degrees, but this should be a multi-year reform. The Institute of Medicine’s “Transforming the Workforce” report the goal of all lead teachers of children beginning at birth attain a bachelor’s degree be implemented over the next 10 years. Any rule changes in Head Start, and especially Early Head Start, should align with this recommendation. This policy change would be most challenging for Early Head Start programs. Early Head Start teachers are with children through the most developmentally influential part of their lives and it is important that these providers have sufficient knowledge around child development and language development. While we think it is important for all lead teachers to attain a bachelor’s degree with ECE specialization, Early Head Start teachers should only be required to do so��if programs, at an absolute minimum, are able to pay them comparably to Head Start pre-K teachers. Earning a bachelor’s degree is time intensive and expensive. It’s unreasonable to mandate this requirement without providing teachers with adequate compensation.

Head Start plays a unique and important role in the ever-growing early education space. While the proposed rule takes many important steps in the right direction, there are large aspects of Head Start that can only be changed through an act of Congress. Meaningful changes in program structure to better align Head Start with state programs are outside the scope of this proposed rule, but should be considered by Congress in Head Start reauthorization. In 2014, ������Ƶ released , where we offer some suggestions for larger structural changes to Head Start.

������Ƶ will be watching closely as ACF moves forward to incorporate public comments on the proposed standards. For more details on our recommendations, see our��.”