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How Head Start’s Requirements Can Be a Disservice to Families and Communities

The Brief

Head Start provides invaluable services to low-income children and families, but since it was established in 1965, changes in society mean that the program’s requirements might be out of date. Changes to Head Start should be considered to ensure that those most at-risk and vulnerable are able to access the program’s critical services.

Since 1965, over 36 million children and families have benefited from Head Start’s educational, health, and social services. While some changes and improvements have been made to the program over time, most recently through the 2007 reauthorization, the structure has largely been unchanged since its inception. The changes in society and across states mean the program’s requirements may be out of date in some areas, leaving communities beholden to a program that is not able to address their needs, reach those who could benefit most, or pair well with other programs to support the holistic needs of children and families around the country.

Today, mothers are the primary or sole earners for 40% of households with children under 18, compared with 11% in 1960. Additionally, as wages around the country increase to respond to changing costs of living, many low-wage workers have seen their incomes rise above the federal poverty level. While this is great news for many workers, unfortunately, this can also mean low-income families are no longer eligible for the Head Start program.

Children from birth to age five from families with incomes below the federal poverty line are eligible for Head Start and Early Head Start, which in 2019 is $21,330 for a family of three and $25,750 for a family of four.1 For a full-time worker, this translates to $10.22 an hour to support a family of three and $12.34 an hour to support a family of four.2 Any family whose income is at or below these levels can qualify for Head Start; income above these levels means their children do not qualify.

The $12 an hour minimum wage in Washington, Massachusetts, and California, and the $14 an hour minimum wage in the District of Columbia automatically make a family of three with one full-time worker ineligible for Head Start. The $15 an hour minimum wage implemented in places such as Seattle and New York City translates to an annual income of $31,200, which is almost twice the federal poverty level for a household of two and still well above that for a three-person household. As more cities and states are set to reach $15 an hour in the coming years, more and more families will become ineligible for Head Start, simply based on their income relative to the federal poverty level.

After California passed their wage increase in 2016, the California State Advisory Council on Early Learning and Care published a report recommending how to bring early childhood policies in line with the state wage increases. The report concluded that the goal to support working families’ finances could have reverse effects, and many children could lose access to programs without changes to the “radically outdated income thresholds” of the programs.3

Dr. Barbara Nemko, who has served as the Napa County Superintendent of Schools for six terms, echoed this sentiment. She told BPC, “We must adjust the federal formula to ensure that disadvantaged children in high-cost states are eligible for these essential preschool services. It is a moral as well as an economic imperative.”

These insights from California identify a critical point of consideration: Head Start has no flexibility to allow for regional and state variations in costs of living, and therefore, many families who would otherwise benefit from the program are left out. Many of these low-wage families living in high-cost areas are still struggling to get by and could benefit from Head Start’s services. While these families might not be considered impoverished based on federal guidelines, the cost of living in their community is so high that even with increased minimum wages, they may not be making ends meet.

In some communities, Head Start programs face under-enrollment which means that programs are not serving as many children and families as they have the funding for. In 2010, undercover tests by the Government Accountability Office revealed instances in which Head Start grantees did not follow regulations regarding eligibility verification and enrollment. A 2019 follow-up report found “systematic vulnerabilities” persist, in that Head Start staff do not always properly verify eligibility as required, and in some cases may have engaged in fraud to bypass eligibility requirements all together.4 These findings are concerning for a myriad of reasons, including the fact that many vulnerable children and families are in need of services such as those Head Start offers, and are going without. If Head Start programs are struggling to fill slots and engaging in potentially fraudulent activity to do so, something needs to change.

One process Congress developed to institute change is through a grant competition process, the Designation Renewal System. DRS was developed to improve oversight, accountability, and quality, and develop market competition, by determining whether existing Head Start grantees meet program requirements and requiring them to compete for renewed funding if they do not. A study by the Department of Health and Human Services found that grantees in the re-competition process proposed lower enrollment numbers than they had in the past, indicating widespread issues with fully filling classrooms.5
An interview with one Head Start grantee conducted by HHS and included in the study illuminated these struggles. The provider explained, “we converted some slots to full-day, converted some to Early Head Start, just looked at locations and one area we were having more problems with enrollment, so we elected to close some and moved those slots somewhere else.” 6

While DRS allows individual programs to shift resources to where they are needed most within their service area, such as across ages of children, a program’s declining enrollment numbers does not mean resources are shifted to other communities where the need may be growing. Further, only a small number of service areas go into DRS in the first place. As of 2015, 31% of programs went through DRS, most of which received their grants back.7

Changes to Head Start should be considered to ensure that those most at-risk and vulnerable are able to access the program’s critical services. In some cases, based on a community’s gentrification or changing demographics, this might mean moving a program from one community to another to better reach those who still live below federal poverty guidelines. In other areas, flexibility to eligibility guidelines might be needed if not enough families are eligible to fill the program. In any event, each state and community differ, and families would ultimately benefit from flexibility within Head Start, which could also help state agencies align their own programs with the implementation and delivery of Head Start services.

At a time when demand for early childhood services far exceeds availability, the case for continued and even expanded investments must be accompanied by a commitment to efficiency, good governance, and a consistent focus on quality assurance and results. As we’ve written before, program alignment and coordination at the state level is important, not only because it promotes the efficient use of public funds but also because it bears directly on families’ ability to access the resources they need. Most importantly, children and families stand to benefit tremendously from Head Start—but only if they can access it in their community.

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End Notes

1 U.S. Federal Poverty Guidelines Used to Determine Financial Eligibility for Certain Federal Programs. For the 48 contiguous states and D.C. Accessed at:
2 The national standard for full-time workers is 2,087 hours per year, according to the U.S. Office of Personnel Management.
3 California State Advisory Council for Early Learning and Care, Bringing Child Care Policy in line with the New Minimum Wage, January 2017. Accessed at:
4 US Government Accountability Office. Head Start:
Action Needed to Enhance Program Oversight and Mitigate Significant Fraud and Improper Payment Risks. September 13, 2019. Accessed at:

5 Applicants proposed lower child-teacher ratios and lower enrollment numbers, but those differences were observed in the Head Start programs and not the Early Head Start programs.
6 Administration for Children and Families, Early Implementation of the Head Start Designation Renewal System. September 2016. Accessed at:
7 The first four cohorts of competed programs were notified in December 2011, January 2013, February 2014, and December 2014. The first cohort included 129 programs, the second cohort 126, the third cohort 103, and the fourth cohort 90. Across the first three cycles, about 74% of awards went to an incumbent grantee or delegate agency, 19% of awards went to other established Head Start grantees or delegates, and 7% of awards went to providers with no previous experience operating Head Start. Data included in:

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