HHS recently proposed shifting Head Start regulation from the feds back to the states. Media coverage describes the effort using words like "gut", "upend", and "weaken." I'm here to defend the step.
The goal should be to get most impact from limited Head Start funding. Reducing regs lowers cost per child, allowing more access. Critics don't consider this tradeoff.
Federal regulations are typically = or > than that of states. Critics are saying the shift to state regs lowers standards. The better question is whether those standards were effective at maximizing the impact of the Head Start dollars.
There are about 18,000 Head Start centers that are subject to current federal regs. There are 90,000+ licensed child care centers that are only subject to state regs. The HS centers aren't being deregulated. They will simply be under the same regs as the other 90k centers. Implicit in the language of gutting regulations is that >80% of centers today have sub-standard regulation.
But are the federal regs creating better outcomes? There has long been criticisms from both think tanks and providers that the regs have become overly prescriptive and compliance-oriented. The higher the regulatory burden, the fewer children a center can serve.
Most of these regs are well-intended. There are reasons for two annual home visits, supervised daily toothbrushing, one-hour absence calls, federally dictated calendars, etc. The question is benefit/cost.
Head Start requires a smaller child:staff ratio than most states. Smaller class sizes aren't a bad thing. The question is whether they improve the classroom and what is the cost.
The evidence for lower teacher-child ratios creating better child outcomes is weak. Very large class sizes are bad. But research has generally not shown change in outcomes in the class size differences between federal and state mandates.
Most of the cost of child care and pre-K is the staff and the facility. If classrooms can go from 1:8 to 1:10, 25% more children can attend at a minimal cost. There is significant unmet need in childcare due to cost. Lowering the cost of service creates more spots.
Child care and pre-K doesn't become the Wild West. There will still be regulations on class sizes. They just won't be unique federal Head Start rules. Instead, Head Start programs would generally follow the same standards that already apply to the more than 90,000 early childhood centers outside the program.
States have already decided about the tradeoff between quality, cost, and access for more than 80% of the market. There's little reason to assume federal regulators are better positioned to strike that balance for the remaining 20%. Those decisions are best made at the state level, where policymakers can account for local resources, labor markets and community needs.
People will jump to conclusions about moving regs back to the states. The reality is much more nuanced than the headlines.