Comment from New York City Comptroller Mark Levine on “Reducing Federal Burden for Head Start Programs” A Proposed Rule by the Administration for Children and Families

Hon. Secretary Robert F. Kennedy, Jr.
Department of Health and Human Services
Washington, D.C. 20528

Dear Secretary Kennedy,

As the elected Comptroller of the City of New York, I write in strong opposition to the Department of Health and Human Services’ (the Department) proposed rule changes to the Head Start Program and Performance Standards (the Standards), published in the Federal Register on August 7, 2026.

Done properly, with care and precision, regulatory reform can be a useful tool for modernizing public systems and improving outcomes. Well-considered changes to regulations can also increase government efficiency, safeguard public funds, and ensure that public programs produce strong results. The proposed changes to the Standards would do the opposite.

Since it first launched in 1965, Head Start has afforded our youngest New Yorkers living in poverty and their families the opportunity to receive high-quality early childhood education and services that put them on a path to academic, social, and financial success. Head Start does this by serving the rich mix of New York City’s families. According to data retrieved from the Head Start Program Information Report (PIR), in 2025, there were more than 20,000 children and more than 800 pregnant women enrolled in Head Start in New York City from all racial and ethnic backgrounds. The largest groups identified as Hispanic or Latino (29%), Black or African American (27%), White (non-Hispanic or Latino) (25%), Biracial or Multi-Racial (11%), Asian (6%), and American Indian/Alaska Native (2%).

I am deeply concerned that the proposed changes eliminate a significant portion of the Standards that form the backbone of Head Start’s program effectiveness. These changes threaten to erode Head Start’s instructional quality including, eliminating the delivery of proven health and mental health services, and creating unnecessary financial and administrative burdens for Head Start program administrators. Ultimately, if enacted, these proposals would undermine the foundations that have made Head Start one of New York’s and America’s most successful anti-poverty programs. I strongly urge the Department to withdraw the proposed changes.

While my concerns with the proposal are extensive, I am highlighting some of the most troubling changes that would impact New Yorkers below:

Requiring English-Only Instruction

New York City residents speak a variety of languages at home and in their businesses. In an increasingly global economy, the ability to speak multiple languages is an asset in multiple career pathways, from business, to medicine, to international relations. Roughly three quarters, more than 15,000, of the children enrolled in Head Start in New York City are Dual Language Learners.[1] In addition to English, they speak Spanish, Chinese, Yiddish, Arabic, and much more, allowing them to build connections with their peers and communities as their families pursue the American dream.

While learning English is an important component of Head Start programming, research shows that the most effective way for children to learn English is to do so in tandem with their home language. This allows them to build the neural connections they need to speak and process in English and other languages with fluency. Requiring English-only instruction would make it more difficult for almost three quarters of children enrolled in Head Start to receive a high-quality education and undermine the cultural connections that make Head Start programs pillars of their communities.

Capping Administrative Costs at 5% (down from 15%)

Reducing the Head Start administrative cap from 15% to 5% would make it unnecessarily difficult for many Head Start providers to continue operating. While controlling administrative costs can be a valid objective, for many programs in New York City, a 5% cap would not be enough to cover basic fixed costs like rent, HR operations, insurance, and other crucial operating needs.

This rule change would also pose a particular challenge to the many small-scale Head Start programs who operate with a higher proportion of fixed costs. The Department acknowledges as much in the notice of proposed rulemaking (NPRM), but offers no plan for mitigation outside of the potential for waivers and the possibility that “other provisions of the proposed rule may partially offset the impact of the administrative cap.”[2] According to the NPRM, “About half of Head Start grants (about 50 percent) serve 200 or fewer children, representing smaller-scale operations that may have more limited ability to distribute fixed administrative costs.”[3] It is surprising and reckless that the Department would propose rule changes that would place half of the nation’s Head Start programs on unstable financial footing. Many Head Start grantees in New York City fall into this category.

Head Start programs across New York City and the country do their best to operate at maximum efficiency, ensuring that the vast majority of their funding goes directly to the services that benefit children most. According to ACF’s own Regulatory Impact Analysis, only about 3.7% of Head Start grants are currently operating at or below 5% administrative costs.[4] ACF states that “relatively few grants currently operate at or below the proposed 5 percent cap,” and that many programs operate “closer to a 10 percent [threshold].”[5],[6] Forcing programs under that amount would take flexibility and control away from providers who should have the latitude to utilize their grants in the way that most effectively serves their community.

Removing Health Support for Pregnant Women

Maternal mortality is a crisis among women living in poverty in New York City, in particular among Black or African American women. In 2022, New York City recorded 66 pregnancy-associated deaths, the highest total since 2016, with the leading cause related to mental health conditions.[7] According to the NYC Maternal Mortality Review Committee, more than 86% of pregnancy-associated deaths had some chance or a good chance of being prevented.[8]

Early Head Start programs in New York City help fill a crucial gap in providing pregnant women with access to important health services. In 2025, Early Head Start served over 800 pregnant women in New York City.[9] Across New York State, Early Head Start provided services to more than 1,200 pregnant women, including 200 women with high-risk pregnancies.[10] 98% of the enrolled Early Head Start pregnant women in New York State received prenatal healthcare and 95% received education related to fetal development.[11] These interventions are crucial for keeping women healthy during pregnancy and preventing pregnancy-related illness and death.

It should go without saying that children benefit when they are born to healthy mothers. The Department’s statement that, “ACF no longer believes that Federally prescribed requirements regarding services to enrolled pregnant women are necessary to achieve the goals of the Early Head Start program and impose administrative burdens on grant recipients” is wrong and threatens to exacerbate an already deadly challenge in New York City and across the country.[12]

There are myriad other significant concerns with the proposed revisions to the Standards, including:

• Reducing or eliminating required services for children with disabilities
• Eliminating federal child-staff ratio requirements
• Weakening the role of parents in program governance, a hallmark of Head Start
• Requiring documentation for homeless families who have no way of obtaining it
• Removing teacher training, coaching, and curriculum requirements
• Eliminating requirements for staff training on abuse and neglect

These changes would seriously damage Head Start providers’ ability to offer high-quality instruction, compromise children’s health and safety, and strip children and families of the services they need.

New York City is America’s economic engine. Our children grow up to become leading doctors, lawyers, scientists, investors, policymakers, and innovators. The federal government’s role is to enable states, families, and children to live up to their full potential. Head Start has always been a demonstration of that commitment. It should remain so.

I urge you to rescind these proposed regulatory changes and instead work with Head Start providers, parents, administrators, and policymakers around the country to ensure that we continue to build on the 60-year-old promise of Head Start.

Sincerely,

Mark Levine
Comptroller of the City of New York

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Endnotes

[1] According to data retrieved from the Head Start Program Information Report

[2] Reducing Federal Burden for Head Start Programs, 91 Fed. Reg. 51248 (August 7, 2026)  https://www.federalregister.gov/documents/2026/08/07/2026-16134/reducing-federal-burden-for-head-start-programs. 51285.

[3] ibid

[4] 91 Federal Register, 51285

[5] 91 Federal Register, 51298

[6] 91 Federal Register 51285

[7] New York City Department of Health and Mental Hygiene. (2025). Pregnancy-associated mortality in New York City, 2022. New York City Department of Health and Mental Hygiene, Bureau of Maternal, Infant, and Reproductive Health.

[8] ibid

[9] According to data retrieved from the Head Start Program Information Report (PIR)

[10] ibid

[11] ibid

[12] 91 Federal Register, 51272