June 17, 2015

New Proposed Head Start Performance Standards Released Today

By Bellwether

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Today the Department of Health and Human Standards released a notice of proposed rulemaking for revised Head Start Performance Standards. This may seem bureaucratic and wonky, but it’s a big deal. The performance standards are the regulations that govern the operation of Head Start programs–from governance, educational programming, to comprehensive and family services, to finances–and they haven’t been revised since 1998.
Because the standards are exceptionally comprehensive (the existing standards, which the proposed new ones seek to replace, include 1400 distinct provisions, and the NPRM document runs to more than 400 pages, including both the proposed new standards and a narrative explanation of the changes), I haven’t had a chance to fully review them yet, but here are a few quick highlights and takeaways:
Dosage matters: The big news item in the new proposed performance standards is an increase in the minimum required hours for Head Start programs. Currently, Head Start preschool programs are required to operate at least 128 days a year and offer at least a 3.5 hour day. Under the new proposed standards, that minimum would rise to 6 hours  of programming 180 days a year (a full school-day and school-year)–more than double the minimum number of hours of Head Start programming that most preschool-aged kids would receive. Currently, only 43% of Head Start preschool programs offer at least this much service to children. Under the proposed standards, grantees would still have the ability to propose a “locally-designed program option variation,” which could include partial day programs if that would best meet the needs of their community, but these options would require approval by an HHS official at least once every two years. This is important because one clear takeaway from the research on both Head Start and other early childhood programs is that dosage matters. Shockingly, kids who spend more time in preschool programs learn more. And dosage is particularly important for the most at risk kids who start out further behind (and are less likely to get great support for learning in the time they’re not in Head Start or preschool). Shifting resources from lower-dosage to higher-dosage Head Start program options is a research-based choice that also reflects the realities of today’s working families. Other provisions in the new standards–such as an increased focus on tracking attendance and intervening when children are chronically absent–would also work to increase dosage. But while these policies are a good idea, they raise a lot of questions: Since most Head Start preschool programs don’t currently meet the new requirements, transitioning to them would be complicated and take time. Offering longer days and years also costs more–which means Head Start will either need more funding or to serve fewer kids. (The Obama administration’s FY2016 budget proposal included increased resources to expand the Head Start day, but those proposals have not been enacted by Congress.
Curriculum matters: As I and others have written, curriculum is a major weakness in many early childhood programs today, and the current Head Start performance standards may encourage programs to use broad, developmental curricula without the depth of content or structured supports for teachers to promote learning goals for young children. The proposed performance standards include significant changes to requirements for Head Start curricula, including a requirement that curricula be based on scientifically valid research, include an organized scope and sequence that is sufficiently content-rich to promote measurable progress towards development goals in the Head Start early learning framework, and that programs provide professional development, support for staff to effectively implement the program, and ongoing monitoring of how staff implement the curriculum.  The proposed revisions also explicitly mention additional curricular enhancements to existing commonly used developmental curricula. I’ll have more to say about these requirements–what they accomplish and what they don’t–in the coming days and weeks, but for now let’s just say they’re very different from the language about curriculum in the current performance standards.
De-kludgifying, to the extent feasible: The existing performance standards are a case study of kludge. Since the standards were created decades ago, provisions have been added to them but few have been taken away, and the resulting structure is confusing and hard to follow. Related topics are addressed in different parts of the standards, and some provisions are redundant or confusing. The NPRM would fundamentally overhaul the structure of the standards into a much more logical structure and in the process streamline and clarify many provisions. This should also make it easier for both current and prospective grantees to understand what they are required to do–and where they have flexibility.
Reducing regulatory burden and increasing program flexibility–but by how much?: The text of the NPRM is clear that one of HHS’s goals in the new proposed performance standards is to reduce regulatory and red tape burden on Head Start grantees (which nearly everyone agreed was too high) and to increase flexibility for innovation and customization to local needs. The provisions that I’ve reviewed so far include a number of steps to reduce bureaucratic and process requirements and micromanagement of programs. While many of these are small, in the context of 1400 distinct provisions and requirements, many small changes can add up to a big difference for grantees. At the same time, when you have that many requirements to start with, you can take a lot of steps to streamline and still have a lot of requirements–and more than you need. Ultimately, this is an issue of looking at the changes in the context of the totality of the program and how they relate to grantees’ overall flexibility to do what they believe is best for the kids they serve, and it’s going to take awhile to figure out whether these changes go far enough or not.
Designation renewal: The designation renewal system, created under provisions in the 2007 Head Start reauthorization that require HHS to identify low-performing grantees and require them to compete to retain their grants, has been controversial within Head Start. Last year, I wrote a paper that praised the goals of the policy but also noted a variety of opportunities for improvement. Many Head Start grantees have been critical of the program, but they’re unlikely to find satisfaction in the new proposed regs on that account: The NPRM includes only minor technical changes to the provisions related to designation renewal and explicitly does not invite comment on this policy.
Research: Whatever you think of the specific proposals in the NPRM, it’s an impressive document that is deeply informed by the research literature on how young children learn and develop and seeks to bring Head Start into greater alignment with what research indicates matters to improve outcomes for the most at-risk kids–given the constraints in existing law. The difficulty of research, of course, is that it’s not a perfect roadmap for policy–it can tell us what matters, but not always how best to accomplish it, and reasonable people can–and should–disagree on some of the policy decisions this document reflects. And existing law places limitations on what HHS can change: some important policy issues can only be addressed in the context of reauthorization. But HHS staff and others involved in developing these proposals deserve credit for the thoughtfulness, work, and emphasis on research that has gone into this document.
I sincerely hope these proposals lead to a robust public and policy debate about the future of Head Start and the best way to accomplish its goals for children and families, and that this debate ultimately results in even stronger policies to improve outcomes for Head Start children and families. We will be doing our best to advance that goal: Stay tuned here for more analysis and commentary.

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