Industry Update: Head Start Program Performance Standards Proposed Changes

August 24, 2026

This webinar is discounted for subscribers to the Head Start Training Package.

Please note: This webinar is limited to Head Start agencies, subrecipients, and regional Head Start associations.

On August 7, 2026, the Office of Head Start (OHS) published a Notice of Proposed Rule Making (NPRM) proposing to eliminate most of the current Head Start Program Performance Standards and instead, largely defer to the provisions of the Head Start Act for program requirements.  

This proposed rule is certainly one of, if not the most, significant change in the Head Start program since it was codified as a stand-alone program in 1980.  The proposed changes will eliminate many of the hallmarks of the Head Start programs such as teacher/student ratios and supportive services like screenings and assessments that have made the Head Start program the preeminent early childhood program in the country.  Indeed, it is not an overstatement to claim that many of the innovations found in Early Childhood Education programs today, across geographic and income levels, were developed in Head Start programs over the past 50+ years.  

Our initial analysis is that these proposed changes will create continuing chaos, as the Head Start Act was never intended to be program terms and conditions but was to be implemented and clarified through federal regulations such as the Performance Standards.  Some provisions, such as capping administrative costs at 5%, may be devasting to agencies that do not have significant sources of funding to cover necessary overhead costs. 

The firm's attorneys are conducting a thorough examination of the proposed changes.  Join us for this industry update to share our observations on the key revisions, highlight particularly impactful changes, and discuss the potential implications for Head Start recipients.

We encourage all Head Start grant recipients to review the proposed changes and submit comments by October 6, 2026, through the Federal Rulemaking Portal.

The on-demand version of this webinar will be available for purchase after the conclusion of the live webinar. 

Target Audience

  • CEOs / Directors
  • CFOs
  • Fiscal Staff
  • Compliance Directors
  • Grants Management Staff
  • Anyone who needs to stay apprised of potential changes in the Head Start Program Performance Standards

Learning Objectives

After this webinar, you will be able to:

  1. Understand the proposed changes in the Head Start Program Performance Standards
  2. Determine how the potential revisions may impact your organization
  3. Decide if you or your organization will submit comments to the Administration for Children and Families

Course summary

Available credit: 
  • 1.00 Certificate of Attendance
Course opens: 
08/07/2026
Course expires: 
09/25/2026
Event starts: 
08/24/2026 - 1:00pm EDT
Event ends: 
08/24/2026 - 2:00pm EDT
Cost:
$185.00
Add to calendar: 

Phillip A. Escoriaza

Phillip Escoriaza, a Partner in the firm’s Federal Grants practice group, counsels Head Start programs, non-profit organizations, municipalities, local government agencies, and for-profit grantees. A TV and radio news commentator and university professor, Phillip served in Puerto Rico’s Office of the Governor, the Government Development Bank, the Senate of Puerto Rico and as General Counsel, University of Puerto Rico’s main campus. His bilingual, nationwide practice assists clients with grant funding administrative requirements and strategies, procurement and funded-property standards, allowable costs and cost allocation, audit resolution, and disputes with federal and local agency funders. [Full Bio]

Ted Waters

Ted Waters serves as Managing Partner of the firm and a member of the Federal Grants and Health Care practice groups, Ted is a national authority in the area of federal grants, particularly in the community service spheres. He advises Head Start clients on all aspects of program requirements, including governance, cost share and the never-ending list of grant administration matters. Ted's experience in administrative issues is widely recognized, and he routinely handles government audits, internal investigations and litigation. [Full Bio]

Available Credit

  • 1.00 Certificate of Attendance

Price

Cost:
$185.00
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