PEER Center Comments: Head Start Program Performance Standards

The U.S. Department of Health and Human Services proposed regulations in May 2026 that would remove standards requiring sufficient wages and benefits be provided to Head Start staff and educators. In this comment, we explore the implications of those new regulations for the U.S. Department of Education’s proposed rules establishing standards for higher education program performance.

Specifically, a key concern among some commenters on that U.S. Department of Education proposed rule has been potential access issues for early childhood educators. Head Start educators are expected to hold postsecondary credentials; yet if wages in the early childhood education field are too low, some early childhood education programs will lose access to Direct Loans, potentially impacting students’ ability to finance their education.

To ensure the efficacy of both the Head Start program and the new accountability framework adopted by Congress, we instead urge the Health and Human Services Department to maintain standards for the wages of early childhood educators.