In May 1990, I participated in my first federal Head Start monitoring review at the Inter-Tribal Council of California, under Lee Fields, then the Region XI/XII branch chief.
I could not have known then that I was entering Head Start monitoring at a moment of transition. During fiscal year 1990, federal staff began using a revised instrument called the On-Site Program Review Instrument—OSPRI, or “Osprey,” as we called it. It was replacing the earlier SAVI-based approach used to help programs assess compliance.
I also could not have imagined that, more than 36 years later, I would still be working with Head Start programs as the community confronted another period of consequential change.
Since that first review, I have experienced SAVI, OSPRI, PRISM and multiple iterations of the Office of Head Start monitoring protocols. I watched the system move toward differentiated and aligned monitoring, and then to Focus Area 1 and Focus Area 2—each with its own evolving versions, emphases and expectations.
The names of the instruments changed. The questions changed. The evidence changed. The organization of reviews changed. The consequences of findings changed.
Head Start changed too.
That history has caused me to think differently about the Head Start community’s response to the August notice of proposed rulemaking. Are we reacting to change itself? Or are we reacting to the way this change has been presented—and to a political context that has caused many people to question its motive and ultimate destination?
The Monitoring Tool Becomes the Regulation
Throughout my travels, I have repeatedly observed that the monitoring instrument becomes something more than a tool. For many agencies, it becomes the most familiar and most frequently used expression of the federal requirements.
Programs turn the monitoring tool into checklists, policies, file-review forms, supervisory expectations and annual self-assessment procedures. Staff become more familiar with the wording of the tool than with the language of the Head Start Act or the Head Start Program Performance Standards.
If the agency can tick every box, it believes it is in compliance.
I became so convinced of the monitoring tool’s influence that, during my years as Senior Director of Head Start Monitoring at Danya International, I worked to include the gender composition of classroom staff as a monitoring data point. It was part of my continuing effort to bring more men into early childhood classrooms as teachers.
The idea made it into one draft iteration of the monitoring tool and all the way into the software developed by Mobile Audit under the guidance of John Gallagher and his brilliant team. It was ultimately removed as the tool became too unwieldy—not because gender diversity in the early childhood workforce was unimportant.
I did not view the measure as a basis for a compliance finding. There was no federal requirement that classroom teams be gender-balanced. I saw it as a way to make an overlooked workforce issue visible. If monitoring asked the question, programs would begin asking it of themselves. They might examine recruitment practices, discuss the issue during self-assessment and consider what children could gain from seeing both men and women in teaching and caregiving roles.
That experience reinforced something I had already observed across the country: what the monitoring system asks about becomes visible. What it measures becomes a management priority—even when the underlying regulation has not changed.
That is understandable. Programs want to know what federal reviewers will examine and what evidence they will expect to see. But over time, the monitoring instrument can become an operational regulatory framework of its own.
Compliance may gradually come to mean satisfying each item in the protocol rather than understanding and achieving the broader purpose of the underlying requirement. What appears in the tool receives attention. What disappears from it may appear less important—even when the underlying responsibility has not disappeared.
This matters to any discussion of regulatory stability. The formal regulations may remain unchanged while the operational meaning of compliance continues to move. A revised question, evidence guide, interview strategy or reviewer interpretation can change program practice without changing a word in the Code of Federal Regulations.
Head Start programs are therefore shaped by more than formal regulation. They operate at the intersection of the Act, the Performance Standards, fiscal requirements, monitoring instruments and anticipated reviewer interpretation.
That influence is neither entirely positive nor entirely negative. A monitoring tool can reduce a complex standard to a checkbox, but it can also make an overlooked quality issue visible throughout the national Head Start community. Its practical influence can extend well beyond its formal authority.
Why does that monitoring history belong in a discussion of the current NPRM? Because it helps explain both the community’s capacity for change and the intensity of its concern.
Programs know from experience that regulatory language does not remain on the page. It travels. It becomes a monitoring question, an evidence expectation, a management priority, a self-assessment measure and, eventually, an operational definition of compliance. When a requirement is added, removed or reframed, experienced Head Start leaders are not reading only the words of the proposal. They are already imagining what the next monitoring tool will ask, what it may stop asking and what programs may consequently come to value—or overlook.
That is the bridge between monitoring history and the present moment. The community has repeatedly demonstrated that it can adapt to new requirements and new systems of accountability. But the same history has taught it that changes described as technical, flexible or burden-reducing can travel far beyond the regulatory text. The reaction to the August NPRM is therefore not adequately explained as fear of change. It also reflects hard-earned knowledge about how federal policy becomes daily program practice—and anxiety about the purpose toward which that practice may now be redirected.
We Have Navigated Change Before
The historical record confirms what many of us have experienced firsthand.
The HHS Office of Inspector General documented the transition from SAVI to OSPRI in fiscal year 1990. PRISM later redirected greater attention toward management systems. By 2005, the Head Start Bureau was conducting approximately 700 reviews a year with a pool of roughly 2,600 contracted reviewers, according to a Government Accountability Office review.
The Performance Standards were substantially revised in 1998 and then comprehensively rewritten and reorganized in 2016. Monitoring changed with them. In fiscal year 2018, OHS implemented the revised Aligned Monitoring System, introducing FA1 and FA2 while retaining CLASS, follow-up and special reviews. The OHS Report to Congress described that redesign as a response to the new standards and an effort to streamline monitoring.
Along the way, the community navigated Early Head Start, school-readiness requirements, child-outcome systems, CLASS, five-year grants, the Designation Renewal System, revised eligibility rules, changing service-duration expectations, evolving health and safety requirements, workforce provisions, COVID directives and many other shifts.
Some changes were barely felt. Some required revised procedures or additional documentation. Others affected staffing, budgets, governance, enrollment, facilities and the basic relationship between a grant recipient and the federal government.
Some were tectonic.
The Head Start community did not navigate every change perfectly, and it did not agree with every change. But it adapted—again and again.
That makes it difficult for me to conclude that the present response can be explained simply as resistance to change.
Are We Afraid of Change—or of Motive?
The distinction may be uncomfortable, but I believe we need to examine it honestly:
Are we afraid of change, or are we legitimately afraid of the motive we believe may be behind it?
The current NPRM did not arrive in a political vacuum. Members of the Head Start community have read proposals associated with the Heritage Foundation and Project 2025 calling for the elimination or sunsetting of Head Start. Heritage has continued to advocate replacing or fundamentally restructuring the federal program. That history understandably affects how people interpret a proposal described in terms of deregulation, burden reduction, local flexibility and removal of federal requirements.
It would be unreasonable to tell the community to ignore that context.
That interpretation is not being shaped solely by outside political documents. It is also influenced by the way the federal government is presenting its own actions. A recent OHS Information Memorandum explicitly attributed significant Head Start problems to decisions made during the previous administration. ACF announcements describe proposed changes as restoring local flexibility, community responsiveness and parental decision-making.
For those who have spent years in Head Start, these are not newly discovered principles. Local program design, parent participation and responsiveness to community needs have been part of Head Start’s identity for decades—even when federal requirements have limited how programs could exercise that authority.
When familiar Head Start values are presented as something that must now be returned to the program, experienced members of the community may hear more than an explanation of policy. They may hear a political judgment that the program they have operated, defended and continuously improved was fundamentally misdirected.
That does not establish an improper motive behind any particular proposal. But method matters. When regulatory change is repeatedly framed as the correction of what a previous administration did wrong, technical rulemaking begins to feel like a political contest. The resulting distrust should not be surprising.
The way change is communicated can create distrust even when the substance of the change has not yet been fully examined.
But context and evidence are not the same thing.
The existence of proposals to eliminate Head Start does not, by itself, establish that every provision in the current NPRM is intended to advance that outcome. Neither should the language of flexibility cause us to assume that every proposed change will strengthen local decision-making or preserve quality.
We have to do the harder work of examining the proposed rule provision by provision—its text, its likely implementation and its foreseeable consequences.
Distrust Cannot Become Our Operating Strategy
Distrust may be understandable. It may even be protective. It causes us to ask questions, identify risks and resist assurances that are not supported by evidence.
But distrust cannot be where we get stuck.
If every willingness to consider change is interpreted as a willingness to surrender Head Start as we know it, we lose the ability to distinguish between changes that may strengthen the program and changes that genuinely threaten what must be protected.
Speculation can consume the energy we need for analysis and action. It can cause us to argue about what we believe may happen while giving insufficient attention to what the proposed language would actually do. It can also make thoughtful discussion more difficult: people may fear that acknowledging a useful change will be interpreted as endorsing the entire proposal—or that questioning a familiar requirement will be interpreted as abandoning Head Start’s values.
We cannot allow that dynamic to keep us from doing the work.
I have lived through enough versions of Head Start regulations and monitoring to know that not every change is a threat, not every familiar requirement is indispensable and not every promise of flexibility produces greater freedom.
Experience requires us to examine all three possibilities.
A Conversation Worth Having Locally
This is not only a national policy conversation. It is a question worth working through with staff, governing bodies, Policy Councils and community partners.
What exactly are we reacting to?
Is it the proposed change itself? Its likely operational effect? The way it was presented? The political environment surrounding it? Or what we fear it may signal about the future of Head Start?
Those conversations can help an agency distinguish among:
- provisions that present demonstrable risks to children, families or quality;
- provisions that require clarification before their impact can be understood;
- changes that may provide useful flexibility;
- protections that must be preserved even if their current regulatory language changes;
- and concerns that rest primarily on assumptions about future intent.
The purpose is not to talk anyone out of concern. It is to reduce the emotional toll enough to convert concern into disciplined action.
That means identifying what must be protected, what might be improved, what implementation consequences have been overlooked and what evidence should be placed in the public record. It also means preparing programs for the possibility of change without treating preparation as endorsement.
The Work Ahead
Head Start has never been static. Its endurance has depended partly on its ability to evolve while holding onto a central promise: children and families with the fewest resources deserve comprehensive, high-quality opportunities shaped with parents and communities—not merely for them.
The question before us is not whether Head Start should remain frozen in its current form. Nor is it whether every proposed change should be accepted in the name of flexibility.
The question is whether we can move beyond distrust without surrendering vigilance.
We can acknowledge the political context without allowing speculation to replace evidence. We can question motive without pretending that we can prove it from every line of regulatory text. We can remain open to change without abandoning the qualities that make Head Start Head Start.
And then we can get to work—protecting what matters, identifying what can be strengthened and ensuring that every change is measured against its effect on children, families, communities and quality.