ProtectHead Start.

RE: OHS Docket No. ACF-2026-0595, Reducing Federal Burden for Head Start Programs, Black

Child Development Institute of [location] Response to Notice of Public Rulemaking (NPRM)

Dear Secretary Kennedy,

The Black Child Development Institute of [location] represents the diverse strengths and needs of Black

children and families across [location] as a village of the National Black Child Development Institute

(NBCDI). We are proud to be a part of the 56-year legacy of NBCDI to improve the quality of life of Black

children and families.

[INSERT VILLAGE-SPECIFIC PARAGRAPH HERE: relevant BCDI [location] work, state/local Head Start data, and on-the-

ground experience. Remove this instruction before filing.]

Our work is grounded in authentic relationships with families, children, and communities across [city/state].

Through community-based, agency, and philanthropic partnerships we address immediate community

needs via direct services and programs and drive long-term shifts in policy and child and family outcomes

through advocacy and community mobilization. The reach and power of our work provides deep insight to

the lived realities of Black children and families, including the impacts of regulations on access to and

quality of public services and programs within the U.S. Office of Head Start (OHS).

Key Concerns

Head Start serves as a critical foundation for many children and families by providing comprehensive

access to early learning, health and developmental supports, nutritious meals, family engaged decision-

making and well-being services, and stable care environments during the most formative years of life.

Established in 1965, this program was created to ensure that children from families with low incomes have

access to comprehensive services during the earliest years of life, helping to build a strong foundation for

children’s early learning and overall well-being. For many Black families, Head Start serves as a critical

source of child care accessibility, support, and stability during the foundational years of child development.

More importantly, Black families disproportionately rely on Head Start programs, with 29% [1] of all

enrolled children being Black, often due to longstanding inequities in access to affordable, high-quality

early childhood education and care, economic equity, and income equality.

The Black Child Development Institute of [location] recognizes the importance of responding to the

Department of Health and Human Services (HHS) Notice of Public Rulemaking on Reducing Federal

Burden for Head Start Programs as it has deep implications on the effective and equitable implementation

of federal early childhood policies connected to our Eight Essential Outcomes for Black Child

Development.

We also deeply understand both the significance of ensuring that Head Start programs have the flexibility

and resources necessary to respond to the children, families, and communities they serve and support

efforts to eliminate duplicative or unnecessary administrative requirements. However, this proposed rule

goes far beyond reducing administrative burden as it would remove many of the quality standards that

define what children and families receive through Head Start and fundamentally alter the federal

government's role in ensuring that children have access to a consistent, high-quality early childhood

experience. The issue before us is therefore not whether Head Start programs should have flexibility, but

instead what protections must remain federal so that flexibility does not become inequity. With this, we

undeniably believe that the proposed changes will dismantle the very foundation on which Head Start

programs stand.

By eliminating the current standards, the embedded safeguards that ensure families are seen as valued

stakeholders and children are safe, supported and receive the comprehensive services necessary for

healthy development and school readiness are at risk. The Black Child Development Institute of [location]

is particularly concerned about the implications for Black children and families, who represent a significant

proportion of children served by Head Start. The proposed rule would remove protections in areas where

many Black children and families already experience significant inequities, including access to health and

developmental services, disability identification and support, exclusionary discipline, culturally responsive

education, family engagement, and equitable access to early childhood opportunities.

Recommendations

We deeply oppose the proposed rule and urge the Administration for Children and Families to:



Maintain holistic physical and mental health, nutrition, and developmental supports. Head Start should

remain a comprehensive system of support, with continued expectations for health and dental

screenings, developmental referrals, mental health consultation, nutrition, health navigation, and

disability services. Programs should have flexibility in how services are delivered, but not whether

these same services are available to children and families.



Strengthen protections against exclusionary discipline. Preserve prohibitions on expulsion, corporal

punishment, seclusion, and discriminatory discipline, as well as strict limits on suspension. Programs

should be supported with adequate staffing, mental health consultation, professional development,

and family partnerships to address challenging behavior without inequitably removing children from

Head Start learning settings.



Safeguard culturally and linguistically responsive learning practices. Maintain expectations that

programs affirm children's racial, cultural, linguistic, and family identities and recognize home

languages as assets. For Black children, this should explicitly include African American/Black culture,

history, family structures, communal customs and language.



Center community expertise. Implementation should meaningfully engage parents, Black and Brown

family-serving organizations, disability advocacy organizations, early childhood educators, Tribal

communities, and other community-based organizations. By centering the voices and lived

experiences of children, families, educators, and providers most impacted by these proposed

changes, community knowledge should be sourced as essential expertise in determining what

children and families need to thrive in Head Start programs.



Protecting children with disabilities from program exclusion. Maintain strong standards for disability

inclusion and ensure that disability, behavioral, and/or service needs are never grounds for exclusion.

With this, Head Start programs must have the valuable resources and partnerships needed to support

children in learning settings and collaborate effectively with special needs families.



Preserving a strong federal Head Start quality standard, which requires the retention of federal

standards for teacher to student ratios, program duration, comprehensive services, developmental

screenings, mental health, disability inclusion, family engagement, recruitment, and culturally

responsive learning supports. Programs may exceed these standards, but federal funding should

never support a lower standard.

As an organization rooted in the rich lived experiences and undeniable brilliance of Black children and

families, the National Black Child Development Institute values Head Start as a vital early child care and

education infrastructure that children benefit from, profoundly shaping their development, learning, health,

and long-term well-being. It is vital that the success of any Head Start changes be measured by whether

children are safer, healthier, supported, affirmed, included, and whether families have meaningful agency.

Furthermore, the proposed changes to Head Start will erode access to early learning for many Black

children and cause detrimental disruptions during the most formative years of their lives.