HHS Notice Would Limit Head Start Access—Why Advocates Oppose It
Lee Johnson III, PhD, Early Childhood Education Senior Fellow
The Southern Education Foundation (SEF), alongside other early childhood advocacy organizations including the Center for American Progress, the Center for Law and Social Policy, the Child Care for Every Family Network, the National Women’s Law Center, and Start Early, recently submitted public comments opposing the new citizenship verification requirements proposed by the U.S. Department of Health and Human Services (HHS) for the Head Start program. Read our full comment here.
This notice is a departure from established precedent about what is considered a federal public benefit and who should qualify for it. The proposed rule would impact children, particularly those from mixed-status families, in accessing life-affirming Head Start programming across the nation. Since 1965, the federal Head Start program has provided comprehensive early childhood services to young children living in poverty. Its effectiveness is backed by research, including recent findings, showing positive outcomes across the developmental continuum and into adulthood.
Under the proposed changes, some Head Start programs would be required to verify the citizenship or immigration status of each child served. While intended to align eligibility with federal requirements, this proposal could add unnecessary layers of paperwork and create administrative burdens, discourage eligible families from applying, and reduce access for children in immigrant families. The additional challenges and red tape associated with producing citizenship verification documents will also deter families who have difficulty obtaining documentation, such as unhoused families, children in foster care, rural families, and those with low incomes who cannot afford documentation fees.
At its current funding level, Head Start only serves about a quarter of eligible children nationwide. Adding requirements without increased funding further reduces the number served, especially in small or rural programs with limited capacity.
Investments in young children’s health and well-being across the South create significant and long-lasting positive outcomes, and the economy benefits from the contributions of immigrant families nationwide. However, this notice’s harms would fall disproportionately on the South, where Head Start enrollment is among the highest in the nation.
The notice conflicts with statutory requirements set by the Head Start Act of 1965, which requires that programs serve all children from low-income families, those experiencing homelessness, or in foster care, without regard to immigration status. SEF strongly urges HHS to withdraw this notice and protect enrollment for all eligible children and ensure continued compliance with the law.