Head Start program staff are the foundation of our mission to provide high-quality early childhood education and comprehensive services to children and families who need us each day. Head Start teachers previously responded to Congress passing new education requirements by improving their qualifications. Now, most Head Start Preschool teachers have a bachelor’s degree. This means many Head Start teachers have similar qualifications as teachers in elementary school settings. However, they are too often paid much less.

Over the last several years, Head Start programs nationwide have experienced a severe shortage of staff across a variety of positions, particularly those who provide direct services to children and families. This staffing shortage is a result of:

• Persistently low wages, particularly for staff working directly with children and families
• A lack of comprehensive benefits
• High job stress

The changes to the Performance Standards are designed to strengthen and stabilize the Head Start workforce to ensure the sustainability of programs nationwide.

This summary describes the changes that support the Head Start workforce. Please refer to the updated Head Start Program Performance Standards for the detailed changes.

Wages — 45 CFR §1302.90(e)

The new requirements for Head Start staff wages cover four main areas and must be met by Aug. 1, 2031:

• Progress to pay parity: Ensure salaries for education staff are at least comparable to those of public preschool teachers or 90% of kindergarten teacher salaries, adjusted for role, responsibilities, qualifications, experience, and schedule of hours worked. Programs are required to regularly track and report on progress toward this goal.
• Pay scale: Develop or update a pay scale that reflects competitive wages for all positions. This scale must consider each role's responsibilities, qualifications, and experience, and be reviewed at least once every five years to ensure it remains competitive.
• Salary floor: Establish a minimum pay floor to ensure all staff receive wages generally sufficient to cover basic costs of living in the geographic area, if the worker’s hourly rate was paid according to a full-time, full-year schedule.
• Wage comparability: Promote wage comparability across Head Start Preschool and Early Head Start positions for staff with similar qualifications and experience.

Exemption: Head Start agencies with 200 or fewer total funded slots are exempt from the requirements above, though they still must:

• Establish pay scales that promote competitive wages for all staff
• Make measurable improvements in staff wages over time
• Demonstrate progress toward meeting the other requirements above

Waiver: If appropriation increases for Head Start programs are very low — below 1.3% on average for a period of four years — the rule provides flexibility in 2028 for the Secretary to establish a limited waiver process for the pay parity, salary floor, and wage comparability requirements. Programs would be eligible for a waiver, if they:

• Demonstrate the need to reduce enrolled slots to implement the wage requirements
• Meet quality benchmarks
• Provided Head Start services in the service area before Aug. 21, 2024

Programs that receive the waiver must still demonstrate improved wages over time, to the greatest extent practicable.

Staff Benefits — 45 CFR §1302.90(f)

As part of a comprehensive approach to improve staff recruitment and retention through enhanced benefits, grant recipients must provide the following benefits to staff by Aug. 1, 2028. Grant recipients must:

• Provide or facilitate access to health insurance for all staff. For full-time staff working 30 hours or more per week, programs must either provide employer-sponsored health insurance or facilitate enrollment in another health insurance option, such as through the Healthcare.gov Marketplace, appropriate state-specific health insurance marketplace, or Medicaid. Programs must also facilitate access to health insurance for part-time employees.
• Provide paid leave for full-time staff. The regulations do not specify between sick, vacation, personal, or family leave. This allows programs flexibility in how they administer the requirement.
• Provide access to short-term, free, or low-cost behavioral health services for full-time staff.
• Facilitate access to other relevant benefits such as Public Service Loan Forgiveness and child care subsidies for all eligible staff.
• Assess benefits package. At least once every five years, programs must assess whether their benefits package for full-time staff is comparable to elementary school staff in the program’s local or neighboring school district, and, if feasible, offer additional identified benefits to staff.

Exemption: Head Start agencies with 200 or fewer total funded slots are exempt from the requirements related to staff benefits, though they are still expected to make measurable improvements in staff benefits over time.

Staff health and wellness, 45 CFR §1302.93

Grant recipients must support the health and well-being of staff by:

• Providing regular breaks for all staff, with breaks of adequate length and frequency based on hours worked. For classroom staff, one teaching staff member may be replaced by a staff member who does not meet the teaching qualifications required for the age during break times, provided they have the necessary training and experience to ensure the safety of children and minimal disruption to the quality of services.
  • Programs must adhere to any more stringent applicable federal, state, or local laws.
• Cultivating a culture of wellness across the program that empowers staff as professionals and supports staff to effectively accomplish their job responsibilities in a high-quality manner.

Head Start programs are designed to provide comprehensive services to children and families, including health and mental health services. The updated standards enhance mental health supports to ensure they are integrated and consistently delivered to both children and adults across the Head Start program. The changes throughout the Performance Standards promote a holistic approach to healthy development, elevating the importance of mental health. The changes use strengths-based language and clarify existing mental health policies.

This summary describes the changes that integrate and strengthen requirements for mental health services. Please refer to the updated Head Start Program Performance Standards for the detailed changes.

Mental Health Integration and Multidisciplinary Approach — 45 CFR §§1302.40, 1302.41, 1302. 42, 1302.45, and 1302.46

The Performance Standards were updated in the following ways to reflect the integration of mental health services throughout the program and to reflect the multidisciplinary approach required for mental health services:

• Health and Mental Health Services Advisory Committee: Health Services Advisory Committees must shift to Health and Mental Health Services Advisory Committees. These committees function to build community partnerships that facilitate access to additional mental health resources and services.
• Family engagement: Communication and collaboration with parents must include a focus on mental health.
• Health services: Ensuring children are up-to-date on health services includes determining if the child is up to date on appropriate, preventative mental health care. Identifying a child’s health needs must account for relevant developmental or mental health concerns.
• Screening and referrals: Ensure all children receive adequate screening and appropriate follow-up. Parents must receive referrals about how to access services for potential social, emotional, behavioral, or other mental health concerns.
• Multidisciplinary approach:
  • Coordinate multidisciplinary supports for adult mental health and well-being. This includes engaging in nurturing and responsive relationships with families, engaging families in home visiting services, and promoting staff health and wellness.
  • Facilitate multidisciplinary coordination and collaboration between mental health and other relevant program services, including education, disability, family engagement, and health services.

Mental Health Consultants — 45 CFR  §§1302.45 and 1302.91

The updated Performance Standards reflect the following new requirements related to mental health consultation:

• Annual assessment of need: Programs must examine their approach to mental health consultation every year to determine if the services meet the program's needs.
• Frequency and coordinated supplemental services: Mental health consultation services must be available at least once a month. If a mental health consultant is not available to provide services once a month, programs must use other certified and trained mental health professionals or behavioral health specialists to ensure mental health supports are available on at least a monthly basis and must ensure coordination with the mental health consultant.
• Licensure: Mental health consultants may be licensed or practicing under the supervision of a licensed mental health professional. They must have knowledge of and experience serving young children and their families.
• Types of consultation: Mental health consultants provide services that build the capacity of adults in an infant or young child’s life to strengthen and support the mental health and social and emotional development of children. The updated Performance Standards specify that mental health consultation can include:
  • Promoting a program-wide culture of mental health and preventing mental health challenges from developing.
  • Supporting child and family services staff to implement strategies that build nurturing and responsive relationships and create positive learning environments that promote the mental health and social and emotional development of all children.
  • Supporting adults in understanding how exposure to trauma and substance use can influence risk.
  • Facilitating mental health interventions or supports, including in the event of a natural disaster or crisis.
  • Consulting with the program to support the well-being of children and families involved in any significant child health, mental health, or safety incident.

Suspension and expulsion, 45 CFR §1302.17

The Administration for Children and Families aims to limit the use of suspension across early childhood programs and to reduce the disproportionate use of these practices across different racial and ethnic groups of children. The updated Performance Standards include the following key changes related to suspension:

• Process requirements: Programs must consult with a mental health consultant before deciding to suspend a child, ensuring all possible support and interventions are attempted. Temporary suspension may be used to provide the program time to implement necessary services and support after all other recommended interventions and supports are attempted and a serious safety threat persists.
• Documentation and reentry: Programs must document temporary suspension plans extensively, similar to the extensive documentation required for transitioning a child to a more appropriate placement. The updated standard also specify steps to facilitate a child's quick and safe return to the program.

This summary reflects changes made to enhance high-quality programming across various aspects of Head Start services. Taken together, these changes are about helping Head Start programs effectively meet the evolving needs of the communities they serve, and building on the existing high-quality services provided by Head Start programs. In many instances, these changes do not reflect new requirements, but rather seek to provide additional clarification on existing requirements. These changes cover a variety of topics including:

• Definition of “Head Start”
• Eligibility, selection, and enrollment, including updates for migrant and tribal programs
• Income calculations
• Community assessment
• Modernizing engagement with families
• Transportation and identifying barriers to enrollment and attendance
• Family service worker caseloads
• Services to enrolled pregnant women and pregnant people
• Ratios in family child care settings
• Safety practices, including preventing lead exposure
• Standards of Conduct
• Training and professional development
• Incident reporting
• Participation in Quality Rating and Improvement System (QRIS)
• Facilities

This summary describes the changes that support quality improvements in Head Start programs. Please refer to the updated Head Start Program Performance Standards for the detailed changes.

Definition of “Head Start” and Related Terms — 45 CFR §1305.2

The updated Performance Standards aim to clarify the use of Head Start, Head Start Preschool, and Early Head Start to support shared understanding and clarity.

The changes include the following definitions:

• Head Start program refers to any program authorized under the Head Start Act, serving as an umbrella term for all such federally supported programs.
• Head Start Preschool (HSP): Specifically serves children aged 3 to compulsory school age, distinct from other preschool programs.
• Early Head Start (EHS) focuses on serving pregnant women, pregnant people, and children from birth to age 3.

The updated Performance Standards also include revisions to existing definitions to align with these changes and ensure consistency in terminology across policy documents.

Eligibility , Selection, and Enrollment — 45 CFR §§1302.12 and 1302.14

The changes to requirements related to eligibility, selection, and enrollment include:

• Children of staff members: Programs are allowed flexibility to consider the enrollment of eligible children of staff members as part of their selection criteria.
• Serving 10% children with disabilities: A program must ensure at least 10% of its total actual enrollment (not funded enrollment) is filled by children eligible for services under the Individuals with Disabilities Education Act, in alignment with the language in the Head Start Act.
• Eligibility and selection for tribal programs: Tribal Head Start programs may determine any pregnant people or age-eligible child in the service area to be eligible for services, regardless of income. Through their selection criteria, tribal programs may give priority to members of an Indian tribe who would benefit from the Head Start program.
• Migrant and Seasonal Head Start (MSHS):
  • Alignment with Public Law 118-122: Children and pregnant people are eligible for MSHS services if at least one family member’s income comes primarily from agricultural employment. This removes additional family income requirements previously in place, making it easier for families to access needed services.
  • Clarification of eligibility period: Once a child under 3 and their family is deemed eligible for MSHS, they remain eligible until the age of 3, ensuring consistent access to the program without the need for re-verification.

Income Calculations — 45 CFR §§1305.2 and 1302.12

The changes to the Performance Standards related to income calculations include changes to the definition of income as well as the flexibility to adjust for excessive housing costs when making eligibility determinations.

Definition of Income

The updated definition of income seeks to provide clarity and make it less burdensome to implement. “Income” means gross income and includes only:

• Wages
• Business income
• Unemployment compensation
• Pension or annuity payments
• Gifts exceeding the threshold for taxable income
• Military income (excluding special pay for a member subject to hostile fire or imminent danger or any basic allowance for housing)

Public assistance and refundable tax credits are not considered income.

Adjustment for Excessive Housing Costs for Eligibility Determination

The high cost of living in some regions means that families earning slightly above poverty wages spend a significant portion of their income on housing. This situation has led to concerns that the previous eligibility criteria might not fairly reflect families’ financial needs. The updated Performance Standards allow programs to adjust for excessive housing costs when making eligibility determinations.

Housing costs are a family’s total annual applicable housing expenses, which may include:

• Rent or mortgage payments
• Homeowner's or renter's insurance
• Utilities (e.g., electricity, gas, water, sewer, trash)
• Interest and taxes related to housing

Programs may use bills, bank statements, and other relevant documentation to calculate a family’s housing costs to determine eligibility. If a family spends more than 30% of their total gross income on housing costs, their total gross income can be reduced by the amount spent on housing costs that exceed 30% of their income.

Community Assessment — 45 CFR §1302.11

All Head Start programs are required to complete a community assessment once during the five-year grant period. Updates to the related Performance Standards are intended to help reduce burden on programs. These changes include:

• Annual updates: Required only if there are significant shifts in community demographics or needs, to ensure services remain relevant and responsive.
• Purpose clarification: The updated standards clarify that community assessments are intended to strategically inform program planning and service delivery.
• Data use: Programs are encouraged to use existing data sources to alleviate the cost and complexity of data collection.
• Transportation needs and resources: Programs must include challenges and barriers to program participation, such as transportation needs and transportation resources available in the community.
• Gaps in services: Programs must include gaps in community resources in areas relevant to addressing the needs of eligible children and their families.

Modernizing Engagement with Families — 45 CFR §§1302.13, 1302.15, 1302.34, and 1302.50

The changes to the Performance Standards related to modernizing engagement with families include:

• Communication adaptation: Programs must identify and use communication methods that are accessible for prospective and enrolled families, considering their diverse needs and preferences.
• Use of technology: Programs are encouraged to use modern technologies to facilitate easier, more accessible interactions that reduce the administrative burden for families for recruitment, application, and enrollment processes.
• Regular improvements: Programs must regularly examine their enrollment process and implement improvements to make it more user-friendly for families.

Transportation and Other Barriers to Enrollment and Attendance — 45 CFR §§1302.14 and 1302.16

The changes to the Performance Standards related to transportation and barriers to program participation include:

• Identification of transportation needs and resources: Programs must include challenges and barriers to program participation, such as transportation needs and available resources in the community.
• Supportive actions: Programs are encouraged to provide or facilitate transportation solutions, if feasible, to ensure access for all eligible families, particularly those facing the greatest barriers.

Family Service Worker Family Assignments — 45 CFR §1302.52

The updated Performance Standards require programs to ensure individual family service staff have no more than 40 assigned families, unless the program can demonstrate high-quality family services with larger caseloads.

Exceptions:

• Programs may request a waiver if they can prove they are able to maintain quality services with higher caseloads.
• Temporary exceptions are allowed for operational needs during staff absence, attrition, or emergencies.

Services to Enrolled Pregnant Women and Pregnant People — 45 CFR §§1302.80, 1302.81, and 1302.82

The changes to the Performance Standards related to services to pregnant women and people include:

• Enhanced postpartum support: The required newborn visits within two weeks of a child’s birth must include a discussion of maternal mental and physical health, safe sleep, infant health, and support for basic needs.
• Services tracking: Programs must track and record the services an enrolled expectant person receives to help identify specific prenatal care services and resources needed to support a healthy pregnancy.
• Reduce disparities: Programs must provide services that help reduce barriers to healthy maternal and birthing outcomes for each family, including services that address disparities across racial and ethnic groups, and use data to inform program services.
• Mental health services: Services to expectant families must include mental health services, as appropriate, to address prenatal and postpartum mental health concerns, including anxiety, depression, grief or loss, birth trauma, and substance use, as well as the benefits of substance abuse treatment.
• Curricula: Any curriculum used to support services for pregnant women and pregnant people should be a maternal health curriculum to support prenatal and postpartum education needs.

Ratios in Family Child Care Settings — 45 CFR §1302.23

The changes to the Performance Standards clarify age and ratio requirements in family child care settings, including:

• Mixed age with preschoolers and one provider: When there is one family child care provider and the group includes preschoolers (children over 36 months), the maximum group size is six children, with no more than two children under 24 months of age.
• Mixed age with preschoolers and two providers: When there are two family child care providers and the group includes preschoolers (children over 36 months), the maximum group size is 12 children, with no more than four children under 24 months of age.
• Infants and toddlers only: When the group consists solely of children under 36 months and there is one provider, the maximum group size is four children and no more than two children may be under 18 months of age.

Safety practices, 45 CFR §1302.47

The changes to the Performance Standards related to safety practices and preventing lead exposure include:

• All personnel follow safety practices: The changes clarify that all personnel, including staff, consultants, contractors, and volunteers, must follow established safety practices.
• Alignment to the Federal Child Abuse Prevention and Treatment Act (42 U.S.C. 5101): Definitions of child abuse and neglect are aligned with federal standards to ensure consistency and clarity across programs.
• Preventing lead exposure: Programs must develop plans to prevent children from being exposed to lead in water and paint in Head Start facilities, including testing and inspection at least every two years in facilities where lead may exist.

Standards of Conduct — 45 CFR §1302.90(c)

The updated Performance Standards align requirements for Standards of Conduct related to the maltreatment and endangerment of children, with four major categories of child maltreatment. This includes behavior that is:

• Corporal punishment or physically abusive: Including hitting, kicking, shaking, and restraining
• Sexually abusive: Including inappropriate touching and inappropriate filming
• Emotionally harmful or abusive: Including using seclusion, name calling, and shaming
• Neglectful: Including leaving a child unattended on a bus and withholding food as punishment

Training and Professional Development — 45 CFR §§1302.92 and 1302.101

The changes to the Performance Standards related to training and professional development include:

• Annual mandated reporter training: A program’s system for training and professional development must include annual training for all personnel on recognizing and reporting child abuse and neglect. All staff must be trained to implement reporting procedures.
• Annual trainings: Specifies a requirement for annual training on:
  • Positive strategies to understand and support children’s social and emotional development, such as tools for managing children’s behavior
  • The knowledge, experience, and competencies to improve child and family outcomes
• Individual professional development plans: Clarifies that all full-time Head Start employees who provide direct services to children must have individualized professional development plans, in alignment with the Head Start Act.
• Employee engagement: Clarifies that programs must have management systems that promote clear roles and responsibilities for all staff, ongoing staff supervision, and effective employee engagement practices that are integrated into training and professional development systems.

Incident Reporting — 45 CFR §1302.102

The updated Performance Standards clarify incident reporting requirements in the following ways:

• Reporting timeline: Incidents must be reported to the U.S. Department of Health and Human Services (HHS) immediately, and no later than seven calendar days following the incident.
• Involved parties: Clarifies that incidents must be reported if they include a Head Start staff member, contractor, or volunteer, regardless of whether the child involved receives Head start services and/or if the child receives services fully or partially funded by Head Start or participates in a classroom at least partially funded by a Head Start grant. Incidents must be reported if they include a Head Start staff member, contractor, or volunteer.
• Types of incidents: The types of incidents that should be reported to HHS include significant incidents that affect the health or safety of a child, specifically:
  • Any suspected or known maltreatment or endangerment of a child by staff, consultants, contractors, and volunteers that violate the Standards of Conduct
  • Serious harm or injury of a child resulting from lack of preventative maintenance
  • Lack of supervision that results in serious harm, injury, or endangerment of a child
  • Any unauthorized release of a child

Participation in QRIS — 45 CFR §1302.53(b)(2)

The updated Performance Standards clarify that programs should participate in their Quality Rating and Improvement System (QRIS) to the extent practicable if the state or local area has strategies in place to support their participation.

Facilities — 45 CFR §§1303.42, 1303.43, and 1303.44

The changes to the Performance Standards related to facilities include:

• Suitable facilities: To apply for funds to purchase, construct, or renovate a facility, grant recipients are no longer required to have a written statement from an independent real estate professional confirming the lack of other suitable facilities in the area.
• Outcome of preliminary eligibility: If a recipient seeks to use federal funds for reasonable fees and costs necessary to submit an application for funds to purchase, construct, or renovate a facility, they must be granted approval from the responsible HHS official. Once approval is granted, the funds are allowable regardless of the outcome of the preliminary eligibility determination.
• Application requirements: When applying to purchase, construct, or renovate a facility, the application must include the facility’s value. The Performance Standards no longer specify that it must be the fair market value. The updated standards clarify that appraisals can be conducted in-person or virtually. In addition, an HHS official may only require documents needed to determine compliance with regulations.
• Definition of major renovations: The definition of major renovations is updated to include activities that cost $350,000 or more. This threshold is aligned to other federal regulations and will increase to align to the simplified acquisition threshold, should it change. Tribes may comply with the Child Care and Development Fund threshold if applicable and higher.