Is a Massive New Set of Federal Regulations the Best Way to Reform Head Start?

By 07/13/2015

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As I’ve previously written too many times to recall, for all its iconic status, the Head Start program has grave shortcomings. Although generously financed and decently targeted at needy, low-income preschoolers, it’s failed dismally at early childhood education. Additionally, because it’s run directly from Washington, it’s all but impossible for states to integrate into their own preschool and K–12 programs.

I could go on at length (and often do.) But you should also check out these earlier critiques, both by me and by the likes of Brookings’s Russ Whitehurst and AEI’s Katherine Stevens.

The reason this topic is again timely is because the Department of Health and Human Services recently released a massive set of proposed regulations designed to overhaul Head Start. These are summarized by Sara Mead, with her own distinctive spin.

What to make of them? Yin and yang.

On the upside: A mere seven years after Congress mandated this kind of rethinking, HHS is finally taking seriously the need to put educational content into the country’s largest early childhood program. These regulations would clap actual academic standards and curricular obligations onto the hundreds of Head Start contractors that answer directly to Uncle Sam. Head Start could begin to move—with much grunting and prevaricating to be expected from the contractors, as there has been from the executive branch—from its primordial function as a “child development” program (with no lasting effect on participants’ subsequent educational achievement) toward the kindergarten readiness program that it has long resisted becoming.

This is, to my eye, much the most important element of the regulatory shift. It’s worth actually quoting from the proposed regulations (if you want to see for yourself, track down Subpart C, particularly sections 1302.30, .31, and .32.):

Center-based and family child care programs must implement developmentally appropriate research-based early childhood curriculum…that is based on scientifically valid research and has standardized training procedures and curriculum materials to support implementation [and] is aligned with the Head Start Early Learning Outcomes Framework and, as appropriate, state early learning and development standards; and includes an organized developmental scope and sequence and is sufficiently content-rich within the…Framework to promote measurable progress toward development outlined in such Framework.

Wow: “research-based curriculum”; “scientifically valid”; “possibly aligned with state standards”; “content-rich”; “measurable progress.” All great, and arguably revolutionary. (It’s also important to note that they’re not prescribing any specific curriculum. Operators can choose. If it were my Head Start center, though, I’d need about three seconds to reach for the Core Knowledge preschool sequence.)

This is what Head Start needs. But the proposed overhaul contains trouble, too. It’s a spectacular example of heavy-handed federal regulation, replete with both dubious concepts (“dosage levels” for preschool instruction, which appears to mean program intensity and duration) and bad ideas (making it harder for Head Start centers to shed disruptive kids). All of which follows inexorably from the fact that Head Start would remain a direct-from-Washington contract program, far beyond the purview of states wanting to integrate it into their own preschool efforts and harmonize its curriculum with their kindergarten expectations. Observe that Head Start contractors may align their curricula with state standards “if appropriate”—but they won’t be under any obligation to do so, nor are states given any jurisdiction.

To be clear, Head Start has been direct from Washington for half a century and is already heavily regulated. Indeed, Mead suggests that the new regulations are more coherent and a bit less burdensome than the tangle of red tape that has accumulated over the decades.

Still, it’s hard to think about this without considering Charles Murray’s recent report that the Code of Federal Regulations now runs to some 175,000 pages, and that all this federal overreach has been bad for America in various ways. Head Start is a sizable example of sound impulses gone missing into the jungles of governmental extravagance and bureaucracy.

The HHS-led overhaul may also collide with a slow-moving initiative by the House Education Committee to rewrite the Head Start legislation. Given the composition of that group, it’s fair to speculate that any such legislative revision will give states much greater say in how the program operates in the future.

Certainly Head Start needs a change in direction, and the (ridiculously belated) reforms proposed by HHS are a good first step. Kids might actually learn things that would prepare them to succeed in kindergarten and beyond. The enduring question is whether a massive new set of federal regulations is the best way to effect the needed overhaul, particularly when de-federalizing it is half the change that’s most needed.

— Chester E. Finn, Jr.

This first appeared on Flypaper.

Comment on this article
  • Michael Wyland says:

    Some of my own thoughts on Head Start:

    Head Start for All? – Thoughts on a Wall Street Journal Editorial

    From the article:

    “There’s a reason Head Start is administered by the US Department of Health and Human Services (HHS) and not by the US Department of Education. Preschool is only one component of a properly designed Head Start program. Head Start is designed to help children become ready to learn by strengthening family function. Done right, Head Start serves families, not just children. In addition to preschool experiences, Head Start provides health, parent involvement, and social services to families. The theory behind Head Start is that successful family function is tied to each child’s education and life success. Poverty is a threat to successful family function and, therefore, a danger to a child’s escaping poverty as an adult. Head Start is designed to help the child by helping the family cope with, and even reduce the stresses associated with poverty.”

  • Jaime L. Manzano says:


    Just to let you know, I was the Deputy Assistant Secretary for Human Development Services in the “80’s. Oversaw Head Start. Sadly, it hasn’t changed. It was bad then, and we knew it. Not just in output, but cost and management as well.

    An anecdote: A comparison of cost per child between states and centers as enormous then, and probably now, leave aside the quality of services. But excessive costs were a negligible consideration against continuing a grant to any center in a congressional district. Same goes to financial management and staffing. Hopeless then, and probably hopeless now. Goes along with the phrase, “You can’t beat City Hall.”

    Had one success, but only partial. Had a grant cut because unused funds from previous years were being held unused in the center’s bank account. The sky fell on our office from congressional staff. As luck would have it, however, the directer of the center so happened to be up for charges of child molestation. Congressional staff backed off, but only on the point of dismissing questionable staff. The grant was continued, slightly reduced.

    This experience suggests that studies on performance are irrelevant. One needs a “Newtown” event to change Head Start. Corruption comes to mind. It probably is endemic. The program is likely to resemble a publicly tolerated “mafia” grant system, Routine political support
    throughout the year – and particularly during elections – are the order of the day, rather then the effective service to children.

    The thought of over 20 years of lost human potential reflected in the Head Start performance record is crushing when contemplated.

    If I had my druthers, I would probably give need-based cash vouchers to pre-school parents, and let them choose to whom they surrender their child for care. Maybe a tax deduction as well?

    Jaime L. Manzano,
    Federal Senior Executive and Foreign Service Officer,

  • Michael Wyland says:


    The decentralized nature of Head Start argues against a systems-changing scandal. There are Head Start centers that have been beset by scandals, but they have remained local stories.

    A few years ago, the gross Federal appropriation for Head Start was $8 billion to serve approximately 1 million kids (and families, though families usually get lost in the Head Start mix). This works out to $8,000 per year per enrolled child/family.

    In Sioux Falls many years ago, the Federal Head Start grant paid $175,000 per year for child transportation. Parents were actively discouraged from using their own vehicles to transport their kids. It would have been cheaper to give each family a voucher for ongoing taxi service than pay the bus costs. However, the School District (which ran the program) had an exclusive contract with a private school bus operator. The routes determined the number of buses, and the buses needed to be as full as possible, I guess.

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