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Comments on Changes to Head Start Preschool Requirements

Recently, the Department of Health and Human Services (HHS) proposed to remove from the 2016 Head Start Program Performance Standards a requirement that programs offer full-time, full-year service for every enrolled preschooler. We submitted comments recommending that HHS provide a more transparent justification for the change.

The aim of Head Start is to support school readiness for children from low-income families. The 2016 Performance Standards required programs to, by 2021, offer at least 1,020 annual hours of service for all students. In support of the requirement, HHS noted that empirical research linked longer preschool duration with improved educational outcomes.

Now, HHS is proposing to remove that requirement, but the Departments’ justification for the proposal is unclear and inconsistent. Our comments ask HHS to clarify whether its change in course is motivated primarily by funding concerns or by a reevaluation of the benefits of full-time instruction relative to part-time instruction. For each possible justification, we discuss some of the information HHS needs to provide to better justify its change of course.