The proposed deregulation of Head Start has understandably created stress, anger, fear, and confusion. But it may also create an opening the Head Start community should not waste: an opportunity to help design a stronger, more workable framework rather than simply react to one designed for us.
The Head Start community should keep telling its story: Head Start works. It changes children’s and families’ lives. It does not need a new regulation to tell it to empower parents, respond to local communities, or be flexible. Those principles are already baked into its DNA.
None of that requires us to defend every layer of compliance that has accumulated around Head Start over decades. Nor does it require acquiescence to an approach that treats regulation as inherently bad or assumes that Head Start needs to be remade from the outside.
There is a third, more productive path: protect what matters, use this moment to improve what does not, and do not allow an invitation to simplify to become a confession that Head Start was not already doing the work well.
Every person who has worked in Head Start has had the experience of looking at a form, a process, a reporting requirement, or a locally added layer of approval and asking: Why do I have to do this? What is this actually accomplishing? Does it protect children and families, or is it taking time away from them?
Rather than treating those questions as an admission that Head Start has failed, we should treat them as evidence that the people closest to the work have the expertise to help shape better systems.
Strike While the Iron Is Hot
This is an unusual opening. We can continue to advocate fiercely for Head Start and make the case for its value. At the same time, why not go back to the administration with our own answer?
Something like this: You are right about one thing. Some requirements have become cumbersome. The Head Start community knows where they are, what they cost, and how to redesign them without sacrificing children, families, staff, or public accountability. Here is our version of what a stronger, more workable regulatory framework should look like.
That is not surrender. It is leadership.
It flips the narrative. Instead of waiting for someone else to decide which protections are expendable, the Head Start community can distinguish between the requirements that create meaningful protection and the bureaucratic processes that consume capacity without creating commensurate value.
A Method We Have Used Before
As Senior Director of Head Start Monitoring, working directly with the Office of Head Start, I helped design compliance models used to determine whether a program was in compliance, had a deficiency, or needed attention before an issue became a compliance problem. Our task was not to treat every mistake as proof that a system had failed. It was to distinguish a one-time error from a system that was not functioning.
Two concepts were central: scope and materiality.
Scope asks: How widespread is this? Is it one event among hundreds of opportunities for a process to work, or is it a pattern affecting multiple classrooms, children, or systems?
Materiality asks: If this failed, how serious was the consequence? Did it create a meaningful risk to a child, family, employee, public funds, or the program’s ability to deliver services?
At a systems level, that discipline mattered. In earlier versions of monitoring, a single incident could sometimes be treated as if it automatically proved system-wide noncompliance. That was not always a fair or useful conclusion. A single incident must always be addressed. But it does not necessarily mean the entire system has failed.
This work also led us to reconsider the regulations themselves. Sometimes the intent was exactly right, but the language was not consistently understood or interpreted across programs. The right response was not to discard the protection. It was to clarify it. Sometimes words such as “sometimes,” “as needed,” or “when necessary” were intentionally included to allow local decision-making. In practice, they could leave programs uncertain about what was expected and invite inconsistent monitoring.
I had seen the same principle from the program side years earlier, when my leadership team at the Mississippi Band of Choctaw Indians Early Childhood Education program designed systems for Tribal child care alongside Early Head Start and Head Start. We carried forward the Head Start requirements that strengthened children, families, and staff, and did not replicate processes whose primary function appeared to be proving compliance. The lesson was simple: regulations do not create quality by themselves. Good regulations can support quality; badly designed or duplicative systems can get in its way.
The Question Is Not Simply “Keep or Discard?”
The better question is: What is the protection or outcome we are trying to preserve, and what is the least burdensome reliable way to achieve it?
For each requirement, programs, staff, families, and those responsible for oversight can ask five practical questions:
- What problem was this requirement intended to prevent or solve?
- What does it require people to do in real life—not just on paper?
- What evidence tells us that it improves safety, access, learning, fiscal integrity, family voice, or another meaningful outcome?
- What is its actual cost in staff time, money, morale, turnover, delayed services, and lost time with children and families?
- Could the same protection be achieved through clearer language, a simpler process, a different control, or less frequent documentation?
This is not an invitation to make child safety, civil rights, family access, or fiscal responsibility negotiable. Some protections address risks that are rare but potentially devastating. The absence of a reported incident is not proof that a safeguard has no value.
It is, however, an invitation to be precise. If a practice is essential, preserve it. If the protection is sound but the paperwork is excessive, simplify it. If the outcome matters but the prescribed process is not the best way to produce it, allow a better local solution. If a requirement is duplicative and does not meaningfully protect children, families, staff, or public resources, it may be time to retire it.
A Local Review Can Be Serious Without Becoming a Giant Spreadsheet
Programs do not need to conduct a burdensome national crosswalk of every citation to begin this work. Start where the burden is most visible: the practices staff describe as consuming time without improving their work; the recurring forms that duplicate other records; the requirements that regularly confuse staff and reviewers; and the layers added locally over years that may not actually be required by federal regulation.
Then examine the requirement and the local process separately. Often the federal expectation is reasonable, while the burden comes from a local interpretation, an inherited policy, a consultant recommendation, or a monitoring tool that has grown more complicated than the rule itself.
Look for Policy Collisions
One of the most common—and least discussed—sources of burden is what I call a policy collision: two reasonable expectations that collide in the real life of a classroom.
For example, a program may require teachers to send the meal and snack head count to the kitchen by 9:00 a.m. That makes sense. The kitchen needs accurate information to prepare food, manage ordering, and avoid waste. At the same time, the program may tell teachers that they should not be completing paperwork while children are arriving and morning routines are settling. That also makes sense. It reflects what we know about responsive teaching, relationships, and the needs of young children during transition.
The teacher is then left to decide which reasonable policy to violate.
The same thing happens when multiple quality and compliance systems reward conflicting practices. A classroom may receive praise in a CLASS observation for a particular approach and be scored down on an ITERS or ECERS observation for that same approach. I have seen teachers change their environment or their behavior depending on which system was observing them. That is not quality improvement. It is performance for the observer.
Or, to put it in the language of a classroom team trying to get through a real morning: “So which one of these rules am I supposed to break today?”
That line is tongue-in-cheek, but the problem is real. When policies collide, the burden of reconciling them is handed to the teacher—usually in the middle of greeting children, responding to families, managing a transition, and trying to create a calm start to the day.
These collisions are not evidence that teachers are resistant or that one framework is necessarily wrong. They are evidence that policies, monitoring tools, quality initiatives, and administrative procedures have been developed in separate lanes without enough coordination across the whole system.
This moment gives programs an opportunity to map those collisions deliberately. Put the expectations side by side. Ask where they compete for the same time, require contradictory behavior, duplicate documentation, or leave staff to resolve an impossible choice. Then decide which expectation protects the more material outcome, whether one can be redesigned, and how the system can provide one clear, workable direction to staff.
The goal is not deregulation for its own sake. The goal is intelligent design: a system that is strong enough to protect what matters and simple enough to let people do the work that matters.
Programs Have More Expertise Than They May Realize
There is sometimes an understandable impression that regulations are created by a small group of people with special insight unavailable to those doing the daily work. The truth is more human and more hopeful than that.
Regulations are built through discussion, interpretation, competing priorities, available evidence, political and legal constraints, and efforts—sometimes successful and sometimes not—to translate a good idea into language that can be implemented and monitored consistently. They are not created by magic. They can be clarified, improved, and, when appropriate, removed.
The people closest to children and families have essential expertise in that process. Teachers know when documentation is taking them away from children. Family-service staff know when a process delays help. Fiscal staff know when a control protects public funds and when it merely creates duplicate work. Directors and governing bodies know which systems reinforce quality and which quietly weaken it.
That expertise should not be used to defend every existing requirement. Nor should it be surrendered to an effort that treats all regulation as waste. It should be used to make careful, evidence-informed decisions about what to protect, what to clarify, what to simplify, and what to leave behind.
If this moment is going to bring change, the Head Start community should help define the change. We have the experience. We have the evidence. And, most importantly, we know the difference between a requirement that protects children and families and a bureaucratic burden that pulls us away from them.