The Quiet Dismantling of Head Start: How the Trump Administration Is Using Regulation to Reshape a Program It Can’t Eliminate

With a budget of about $12.3 billion per year, Head Start makes up the federal government’s largest single investment in early care and education. Each year, the program promotes school readiness by serving over 700,000 pregnant women and children from birth to age five in families with low incomes. Since Head Start began in 1965, it has served more than 40 million children and their families.

Despite Head Start’s long track record, the Trump administration has consistently targeted the program for either elimination or drastic reform. Project 2025, which was authored by several individuals who worked in either Trump’s first administration or his 2024 campaign, called for the complete elimination of the program due to false claims of scandal, abuse, and a lack of academic value for children. In early 2025, the administration seriously considered releasing a budget proposal that called for the program’s elimination (eventually the administration relented and released a budget proposal that kept Head Start funding at the current level).

More recently, the administration has targeted Head Start via regulatory changes. In May, the administration announced a proposed rule, “Restoring Flexibility to Support Head Start Program Access”, which would remove requirements established during the Biden administration related to staff wages and benefits. And, just a few weeks ago, the Trump-aligned Heritage Foundation released a report stating that, “Ideally, lawmakers should end Head Start. For now, officials must cut the program’s webs of red tape.”

A yet-to-be released rule, titled “Modernize the Head Start Program by Reducing Requirements and Enhancing Alignment with State and Local Systems,” provides a preview of what’s to come in the administration’s targeting of the program. While the exact contents of the proposed rule are not yet known, the administration hinted at the possibility of large-scale changes to Head Start in their FY27 HHS budget justification. In that document, the administration proposes “to allow individual state standards to apply to programs, including licensing and monitoring standards, health and safety requirements, child-to-staff ratios, and definitions of quality” because they claim these changes will allow the program to serve more children with existing levels of funding. The rule is expected to be released at some point this summer and, given that the administration has a long history of pushing legal boundaries, there’s every reason to believe they will use the rulemaking as an opportunity to essentially remake the Head Start program.

Last reauthorized in 2007, the Head Start Act gives the Secretary of Health and Human Services the authority to modify the Head Start Program Performance Standards (see Section 641A). These standards, which were modernized in 2016 to improve program quality, reduce burdens on programs, and improve regulatory clarity, set uniform requirements in terms of curriculum, staff qualifications, health and safety, child-to-staff ratios, family engagement, and comprehensive services. It appears that the administration’s proposed rule will seek to alter the performance standards so that individual state standards take precedence over the uniform federal standards. 

Potentially allowing individual state standards to substitute for the federal standards could compromise the program in multiple ways. Research suggests that child care quality, as measured by the Early Childhood Environmental Rating Scale (ECERS), is generally higher in Head Start centers compared to non-Head Start settings. State licensing and monitoring standards for child care vary enormously across states and, in many cases, are far weaker than Head Start’s requirements. Several states have child-to-staff ratios that are significantly higher than what Head Start allows. Higher ratios could mean less individualized attention, fewer meaningful interactions per child per day, and weaker outcomes, particularly for children with disabilities and dual language learners who need more intensive support. 

Health and safety requirements under Head Start are substantially more rigorous than most state licensing standards. Head Start requires health screenings, vision and hearing assessments, dental exams, immunization verification, and mental health consultations within specified timeframes after enrollment. Most state child care licensing regimes require none of these  or require them on a much looser timeline. Eliminating these requirements would mean that some of the nation’s most vulnerable children, many of whom have no other access to health care, lose a critical touchpoint for identifying developmental delays, vision problems, and other conditions that are far more treatable when caught early. Additionally, comprehensive services, including home visiting, family support, nutrition, and mental health, are largely absent from state licensing frameworks, which focus on health and safety minimums rather than holistic child and family development. These services are central to Head Start’s two-generation model and much of its documented long-term impact. State standards would not require them.

As the administration inches towards releasing a proposed rule that could drastically change Head Start, it’s important that advocates push back on the rhetoric claiming that Head Start has no academic value. Researchers have found that Head Start participants have a higher likelihood of graduating high school, attending college, and receiving a post-secondary degree than children who did not attend the program. Compared with children in parental care, Head Start participants performed better on cognitive and social-emotional measures in kindergarten and had fewer attention problems.

Critics often cite the 2010 and 2012 Head Start Impact Study reports as evidence that Head Start is ineffective because early academic gains appear to fade by elementary school. But that interpretation overstates what the studies actually conclude.  The 2010 HSIS Final Report found that children assigned to Head Start showed statistically significant improvements in language, literacy, pre-academic skills, health access, and some parenting practices during the pre-K year. The Executive Summary similarly emphasizes positive impacts on school readiness while noting that many cognitive gains diminished by the end of first grade. However, the study’s design complicates strong negative interpretations: many children in the control group attended other center-based pre-K programs, meaning the evaluation estimated Head Start relative to alternative early childhood education, not relative to no pre-K at all.

The 2012 Third Grade Follow-Up Report also does not support the claim that Head Start has no impact. The report finds that while average differences between treatment and control groups were small by third grade, there were still meaningful impacts for important subgroups, including children in higher-risk households, Black children, and dual language learners. And a long-run analysis of Head Start cohorts finds that even though early test-score gains fade, participants experience significant improvements in educational attainment and other adult outcomes. 

In many ways, the administration’s strategy for Head Start mirrors the way it’s approached the Department of Education: unable to completely eliminate something they dislike, they instead seek to dismantle it piece-by-piece. This forthcoming proposed rule seems designed to hollow out the program from within, leaving the Head Start name intact while gutting the federal standards that have long defined its quality and scope.