Head Start NPRM: Public Comment How-To Guide

On August 7, 2026, the Administration for Children and Families (ACF) released a Notice of Proposed Rulemaking (NPRM) for Head Start, a formal announcement published in the Federal Register when an agency intends to add to, remove from, or otherwise change policy through a rule or regulation. The proposal, Reducing Federal Burden for Head Start Programs, would replace the current Head Start Program Performance Standards (HSPPS) with a significantly shorter set of federal regulations, touching nearly every part of the program – from health and safety to staffing, eligibility, and governance. The proposed rule is open for a 60-day public comment period, which closes October 6, 2026 at 11:59pm ET. During this time, anyone – including parents, providers, and advocacy organizations – can submit formal comments.

Below, you’ll find tips on how to draft comments, including links to resources summarizing and analyzing the NPRM, and step-by-step instructions on how to submit them. 

---

DRAFTING COMMENTS

ACF is required to review and consider all public comments before finalizing the rule. It’s vital that ACF hears from a wide range of perspectives and that the comments include specific feedback on the following:

1. Impact: Explain how the proposal would impact you or your program, if you have a personal connection to Head Start, as well as how it may affect educators, children, and families. 
2. Concerns: Identify any areas of concern, including policies you think would be harmful, either directly or indirectly, or areas where a lack of details makes it difficult to gauge how changes would be implemented or how programs would be held accountable. 
3. Recommendations: Offer an alternative, whether to the language itself, the timeline, or the resources that would be needed to successfully make these changes. 

Comments don’t have to address every part of the NPRM. You can focus comments on one or more sections of the NPRM. You can also submit multiple comments. Your personal experience and perspective are particularly valuable, so the outline below includes several prompts to guide you in making comments your own.

If you’re looking for a resource to use as a starting point, the First Five Years Fund (FFYF) produced an analysis of the proposed changes we believe require additional scrutiny or discussion, raise potential concerns, or warrant official comment. These concerns, which are shared broadly across the early learning community, include group size and staff ratios; English-only instruction; the administrative cost cap; protections for children with the greatest need; and requirements around comprehensive services. 

You can also reference FFYF’s Searchable Guide, which summarizes the contents of the NPRM, including what would change, what would stay the same, and what would still be required under the Head Start Act. The guide links to specific regulations, making it easy to find and cite them in your comments. 

---

COMMENT OUTLINE

Be sure to include the docket or RIN number at the top of your comments. Re: Comments on Reducing Federal Burden for Head Start Programs (ACF-2026-0595, RIN 0970-AD30)

 To Whom It May Concern:

• INTRODUCE YOURSELF 
  • What’s your experience with early learning/Head Start? 
  • If you’re a parent or alum, how has Head Start impacted you and your family? What do you value about Head Start that might change through this proposed rule? 

• OVERVIEW/BACKGROUND
  • Identify the areas of the proposed regulation that you’re commenting on 
  • Highlight what you want ACF to take away from your comments 

• ANALYSIS: To the extent you’re comfortable, detail your arguments and provide specific examples or stories.
  • What is the practical impact of these changes? 
  • Does the NPRM correctly estimate impacts/savings?  
  • What are the potential harms or unintended consequences? 
  • What is unclear? What additional information or resources are needed? 
  • Note: if you’re relying on particular studies or evidence, provide clear citations 

• RECOMMENDATIONS
  • Are there alternative ways to meet the intended purpose of the proposed change? 
  • Is there specific language you’d like to see changed/restored/removed? 
  • Is the timeline for the proposed changes realistic given current resources? 

• CONCLUSION
  • Recap your main arguments and recommendations 
  • “Thank you for your consideration.” 

Please note that comments and any information included in the comment form, including your name, address, and phone number become part of the public record, and you should draft them accordingly.

---

SUBMITTING COMMENTS

1. Go to the official comment portal. 
2. Add your comments: The comment box is required, however, you can also upload a copy of your comments using the “Attach Files” option. If you plan to attach a document, you can simply write “See attached document” in the comment box. 
3. Complete the required information: Scroll down the page to fill in the remaining required information. You can comment as an individual, an organization, or anonymously. 
4. Double check what you’ve entered before submitting. 
5. Save your confirmation: Once you submit your comments, you’ll receive a Comment Tracking Number you can use to follow your submission. Please note that sometimes there is a lag between when you submit and when they appear on Regulations.gov.