GEEARS’ Official Public Comment on Notice of Proposed Rulemaking (NPRM) titled Restoring Flexibility to Support Head Start Program Access
On May 12, 2026, the U.S. Department of Health and Human Services, Administration for Children and Families released a Notice of Proposed Rulemaking (NPRM) titled Restoring Flexibility to Support Head Start Program Access. An NPRM is the formal process federal agencies use to propose changes to regulations and gather public feedback before issuing a final rule.
The proposed rule would rescind several workforce-related provisions adopted in the 2024 Head Start Program Performance Standards, including requirements related to staff compensation and benefits. Specifically, the proposal would eliminate provisions encouraging progress toward pay parity with public preschool teachers, formal pay scales, wage comparability across Head Start programs, and certain employee benefits such as health insurance, paid leave, and behavioral health supports.
As part of the federal rulemaking process, interested stakeholders may submit public comments for the agency’s consideration. Below is GEEARS’ comment letter, which highlights the importance of a stable and qualified Head Start workforce and encourages continued attention to workforce challenges while supporting access to high-quality services for children and families.
The Honorable Robert F. Kennedy, Jr.
Secretary, U.S. Department of Health and Human Services
200 Independence Ave. SW. Washington, DC 20201
Re: GEEARS Comments on the Head Start Notice of Proposed Rulemaking
To whom it may concern:
On behalf of GEEARS: Georgia Early Education Alliance for Ready Students, we appreciate the opportunity to comment on the Administration for Children and Families’ proposed rule, Restoring Flexibility to Support Head Start Program Access (Docket ID ACF-2026-0364). As a nonprofit organization dedicated to supporting high-quality early learning and healthy development for Georgia’s youngest children, GEEARS is committed to strengthening early childhood systems that support children, families, educators, and communities across our state.
Head Start plays a critical role in Georgia’s early childhood landscape. More than 20,000 children were served by Head Start and Early Head Start programs in Georgia last year through 379 locations across the state. In fiscal year 2024 alone, Georgia received approximately $281 million in Head Start funding. Head Start is particularly important in rural communities, where one in four child care slots are located in a Head Start program. The program also supports Georgia’s workforce and economy, enabling nearly 15,000 parents to work, attend school, or participate in job training while employing more than 6,000 Georgians.
GEEARS appreciates the Administration’s stated goal of expanding access to Head Start services. However, we are concerned about the potential workforce implications of rescinding the wage and benefit provisions adopted in the 2024 rule. We encourage the Administration to carefully consider how these changes could affect recruitment, retention, program stability, and access for children and families. While the proposed rule emphasizes flexibility for local programs, flexibility alone does not address the underlying workforce challenges that many Head Start programs continue to face.
Our concern is informed not only by statewide workforce trends but also by direct conversations with Georgia Head Start educators. In a 2022 series of focus groups with Head Start teachers and assistant teachers, educators consistently identified compensation, benefits, and staffing shortages as significant challenges affecting retention. Teachers described leaving—or considering leaving—for jobs that offered higher wages and less stress. As one educator explained, “You get worn out when you can go to McDonald’s or Walmart or even the mill and make twice what we make.” Another teacher shared that colleagues were leaving because they could earn comparable or better pay in positions with fewer responsibilities and less stress.
Educators also described how staffing shortages compound these challenges. Teachers reported spending long periods without assistant teachers or substitutes and feeling increasingly burned out as vacancies remained unfilled. One educator noted, “A lot of it comes from us being burned out … because of the lack of staffing.” Another described the challenge of retaining qualified staff, stating that positions had become “nearly impossible” to fill.
Importantly, teachers emphasized that higher compensation was critical to workforce stability. Several expressed concern that, despite their commitment to children and families, they could not continue supporting their own families on current wages. One teacher explained, “It’s not all about the pay, but I have a family, and I’m tired of living from check to check.” Educators also highlighted the importance of benefits such as health insurance and paid leave, noting that these supports influence both recruitment and retention.
These experiences are reflected in broader compensation data. Georgia Head Start teachers with a bachelor’s degree earn an average salary of just $43,376, ranking 47th in the nation when adjusted for cost of living. By comparison, Georgia public K-12 teachers earn an average of $74,277, creating a wage gap of more than $30,000 per year.
We recognize that compensation challenges cannot be solved through regulation alone and that adequate federal appropriations are necessary to support workforce investments. We also recognize that Congress has not provided dedicated funding to support implementation of the 2024 wage and benefit standards. However, we are concerned that removing these standards without addressing the underlying funding and workforce challenges may shift responsibility to local programs that are already operating within significant fiscal constraints.
Head Start’s success is built on the educators, family service staff, and support personnel who make the program possible. Georgia families, communities, and employers benefit when Head Start programs can recruit and retain a stable workforce capable of delivering the comprehensive services that children need to thrive. We respectfully encourage the Administration to carefully consider the potential workforce implications of rescinding these provisions and to continue pursuing solutions that strengthen both program access and workforce stability.
Thank you for the opportunity to provide comments on this proposed rule.