In this letter, senior fellow Diane Schilder and senior research associates Justin Doromal and Catherine Kuhns offer comments on the US Department of Health and Human Services Administration for Children and Families’ proposed rulemaking on Restoring Flexibility to Support Head Start Program Access ACF-2026-0364.

The research team cites research underscoring the importance of retaining workforce provisions in the 2024 Final Rule that are being proposed for recission. Specifically, the authors report the following:

• The lack of qualified educators able to provide the required services, with inadequate compensation, is a primary reason Head Start programs cite as why they are not fully enrolling children.
• Investments in the Head Start workforce and strategies to attract and retain a qualified Head Start workforce are needed. Strategies include providing comparable salaries to local preschool teachers, establishing salary scales to reflect qualifications and ensuring salaries cover the basic cost of living do not come at the expense of serving children.
• The requirement for livable wages for Head Start educators could be especially beneficial to children and families living in states with the largest compensation gaps between Head Start teachers and K-12 teaches.

As such, we recommend not repealing the 2024 Head Start rule. Authors provide evidence that these regulations clearly support the intent of the Head Start statute.