HHS Proposes Rescinding Head Start Workforce Standards—What It Could Mean for Children, Families, and Programs Across the South
HHS Proposes Rescinding Head Start Workforce Standards—What It Could Mean for Children, Families, and Programs Across the South
By Lee Johnson III, PhD, Senior Fellow, Early Childhood Education
The Southern Education Foundation (SEF) recently submitted public comments to the U.S. Department of Health and Human Services (HHS) in response to a proposed rule titled “Restoring Flexibility To Support Head Start Program Access.” The proposed rule would rescind several compensation and benefit requirements finalized in the 2024 Head Start rule.
For over 60 years, Head Start has been a vital support for children from families with low incomes, helping nearly 40 million children succeed through high-quality early learning and comprehensive services. As one of the nation’s most comprehensive early childhood programs, Head Start supports children’s learning, development, health, and family well-being. Research shows that a stable, qualified, and well-compensated early childhood workforce is critical in advancing positive outcomes for young children land supporting their families’ economic participation.
While SEF recognizes the U.S. Department of Health and Human Service’s (HHS) intent to provide local flexibility, removing the workforce and benefit provisions adopted in 2024 may compromise the infrastructure necessary to sustain high-quality services for children and families served by Head Start.
Under the proposed rule, Head Start programs would no longer be federally required to:
- Maintain salary comparability with similarly qualified K–12 public school educators;
- Implement wage scales tied to educator qualifications, experience, and responsibilities;
- Consider geographic cost-of-living factors in compensation decisions;
- Support compensation parity for infant and toddler caregivers with comparable qualifications; or
- Meet certain employee benefit requirements, including health insurance and paid leave.
The proposed rule arrives at a time when many Head Start and Early Head Start programs across the South are already managing persistent staffing shortages, compensation challenges, and difficulty recruiting and retaining qualified educators. These challenges are often most pronounced in rural communities and historically under-resourced areas, where Head Start is a critical source of early learning and family support. SEF’s primary concerns are outlined below:
- Rescinding salary comparability and compensation standards would make it more difficult to recruit and retain Head Start educators. Head Start programs already compete with K–12 public schools and other employers that frequently offer higher wages and more comprehensive benefits. Across much of the South, compensation disparities continue to contribute to educator turnover and staffing shortages. In fact, early childhood educators across the region earn approximately $20,000 less annually than K–12 public school teachers, pointing to the magnitude of existing compensation gaps.
- Weakening workforce compensation standards would disrupt classroom consistency, continuity of care and would negatively affect children’s learning and development. Stable relationships between children and educators support healthy development, learning, and long-term outcomes. When turnover increases, those relationships can be disrupted, creating instability for children, families, and programs.
- Removing federal requirements for employee benefits, including health insurance and paid leave, would place additional strain on the workforce. These benefits support educators’ well-being, reduce burnout, and strengthen retention. Removing them could place additional strain on programs already struggling to maintain adequate staffing levels.
- Eliminating key workforce standards would disproportionately affect Early Head Start and infant-toddler educators. Educators serving infants and toddlers perform highly specialized work during one of the most important periods of child development, yet they have historically been among the lowest-paid members of the early childhood workforce. Compensation and benefit standards help support stability in programs serving the youngest children.
- Workforce quality and program access should not be viewed as competing priorities. While HHS has stated that the proposed rule is intended to help preserve enrollment capacity, staffing shortages themselves can limit access when programs are unable to staff classrooms or fully utilize funded enrollment slots.
While the proposed rule would not prohibit local programs from continuing to offer competitive compensation, wage scales, or employee benefits, SEF remains concerned that removing federal baseline expectations may increase variation across communities and place additional pressure on programs already operating under considerable workforce constraints.
For this reason, SEF opposes the proposed rescission of the workforce compensation and benefit requirements finalized in the 2024 Head Start rule and urges the Department to withdraw it.