Head Start Changes Would Harm Dual Language Learners and Their Families

Head Start, the largest federal investment in early childhood education and care in the United States, faces a serious threat. In August, the U.S. Department of Health and Human Services published a notice of proposed rulemaking that would eliminate more than 1,400 provisions from federal requirements that help ensure the quality and consistency of Head Start programs across the country.1 Although framed as deregulation and reduction of burden on local providers, these changes threaten to undermine the very standards and features that for decades have enabled Head Start to support the development and school readiness of children and the broader wellbeing of their families.

Head Start has served more than 40 million young children and their families2 since its founding, garnering widespread popularity3 and strong bipartisan support.4 Though the changes the Trump administration has proposed will affect all children and families that benefit from Head Start, they especially risk undermining the success the program has had for Dual Language Learners (DLLs)—children with at least one parent who speaks a language other than English at home—and their families. Nationally, DLLs make up one-third of all children ages 0 to 5,5 and in 2024, they were roughly 35 percent of Head Start enrollees.6 Due to these demographic realities, Head Start has long recognized the value of creating structures that provide access to instruction and services for DLLs and their families. The program’s current regulations require providers to implement curricula that account for secondary language development, hire staff who share children’s home languages, and collect DLL-specific data.7 As a result, Head Start has become a powerful tool for preparing DLLs for kindergarten and beyond as well as for supporting the integration and advancement of immigrant families.

"Though the changes the Trump administration has proposed will affect all children and families that benefit from Head Start, they especially risk undermining the success the program has had for Dual Language Learners."

If implemented, the proposed changes would undermine or eliminate most of Head Start’s standards, core infrastructure, and guiding principles that support DLLs, while adding unnecessary requirements, such as mandating that all program instruction be English only. On a larger level, the changes would set the stage for considerable variation in instructional quality across states and jeopardize the long-term success of hundreds of thousands of children and their families.

Head Start and Its Meaningful Supports for DLLs

Originally created in 1965 as a part of President Lyndon Johnson’s War on Poverty, Head Start operates with a budget of approximately $12.4 billion annually.8 It delivers comprehensive early learning, health, nutrition, and family support services to children ages 3–5 living in poverty and has since expanded to serve infants and toddlers via Early Head Start. In fiscal year 2024 alone, Head Start was funded to serve more than 715,000 children and pregnant women across the United States and six U.S. territories.9 The program model centers a two-generation approach focused on promoting children’s school readiness,10 providing comprehensive health services,11 and empowering and supporting parents. Head Start has demonstrated strong results for all children, and a 2010 national impact study found particularly strong benefits for DLLs in vocabulary, math, and emergent literacy skills compared to their monolingual peers.12 

This success stems in part from robust Head Start Program Performance Standards (HSPPS), which feature numerous DLL-specific provisions.13 Dating back to the program’s original 1975 standards, there has been an understanding that intentional and specific requirements and approaches are crucial to ensuring that linguistically diverse children and families can access high-quality programming.14 This aligns with K-12 civil-rights protections15 in Lau v. Nichols (1974), which established that delivering the same instruction to students who do not speak English and those who do does not constitute equality of educational opportunity, as long as language barriers prevent the former from meaningfully accessing content.16 Related, current program standards for language access, staff who speak the languages of children served, and disaggregated data also align with research-backed best practices for DLLs and with Head Start’s core goals. 

The Proposed Regulations: Misalignment of Purpose and Practice

The HSPPS have historically translated the Head Start Act’s policy framework and statutory mandates into specific, detailed requirements for grantees. The law was designed with flexibility in mind, intending for the HSPPS to evolve over time to reflect new research and best practices.17 The current HSPPS are the most evidence-based, comprehensive education standards for DLLs18 and require providers to implement research-based practices that support both English language acquisition and the continued development of children’s home languages. The set of standards being proposed would eliminate many of these requirements and shift oversight responsibilities to states, which would use their own child-care licensing requirements to regulate Head Start programs.19 

The proposed rule would remove quality standards defined in the HSPPS, meaning that the degree and quality of instruction and language access would likely vary considerably across states. The proposal argues that programs would be able to refer to state child-care licensing requirements, yet this ignores the important role of HSPPS in setting the minimum standards needed to operate a child-care program and keep children safe. For example, in comparison to the HSPPS, only six states have licensing requirements that meet Head Start’s staff-to-child ratio for 3-year-olds20 and only 21 have any family engagement policies.21

The Administration for Children and Families (ACF), the U.S. Department of Health and Human Services division that oversees Head Start, has stated that the proposed rule’s purpose is to restore flexibility to local programs, reduce unnecessary federal burden, and eliminate duplication with standards in the Head Start Act and other federal laws and regulations. However, the suggested changes would do the opposite: Programs would have less ability to make decisions tailored to the needs of children in their care, and they would be subject to additional administrative and implementation burdens. “Streamlining” the HSPPS does not reduce bureaucracy or increase efficiency. Instead, by removing standards that guide implementation of important program provisions, the proposed rule seems destined to create confusion and unnecessarily disrupt critical services for children and their families. 

"The proposed rule would remove quality standards defined in the HSPPS, meaning that the degree and quality of instruction and language access would likely vary considerably across states."

Three components of the proposed rule illustrate this likely impact: the English-only mandate, the removal of cultural and linguistic responsiveness standards, and the elimination of key data provisions.

English-Only Instruction Mandate

Despite framing the proposed changes as deregulation, the mandate for English-only instruction would be a significant addition to program standards. This requirement would replace the current provision that programs “recognize bilingualism and biliteracy as strengths,” an approach backed by substantial research,22 with the only exemption being for American Indian and Alaska Native Programs that use their languages as a furtherance of tribal heritage. ACF estimates the addition would affect nearly 18,800 Head Start classrooms where at least half of enrolled children are DLLs,23 though the change would also be felt by many other DLLs. The forced shift away from comprehensible instruction for DLLs would be felt particularly strongly in states where more than half of Head Start enrollees are DLLs, such as California (66 percent), New Jersey (65 percent), New York (56 percent), and Arizona (53 percent), as of 2025.24

The notice of proposed rulemaking states this mandate supports efforts to “minimize nonessential multilingual services and redirect resources toward English-language education and assimilation,” justifying the change using President Donald Trump’s Executive Order 14224, which designated English as the country’s official language.25 However, framing multilingual services as “nonessential” is in direct opposition to evidence on how DLLs develop their language skills.26 DLLs’ linguistic development differs from that of their monolingual peers,27 and rather than acting as a barrier to English acquisition, multilingual instruction helps them access content while building foundational language skills. A National Academies of Sciences, Engineering, and Medicine consensus committee found that there is no evidence DLLs are confused by early bilingualism and that they benefit from the continued development of both their home language and English.28 The proposed rule cites no research suggesting English-only instruction outweighs these well-documented benefits, perhaps reflecting an ideological preference rather than an evidence-based one. In reality, the mandate will not make DLLs learn English or integrate faster; it will make instructional content and supports inaccessible. 

This policy will also carry a high financial burden for providers, especially those serving large DLL populations. ACF estimates that transitioning to English-only instruction could cost programs $124.4 million in total, including $46.9 million to replace curricula and classroom materials (such as educational toys and books) and $51.7 million for teacher retraining, recruitment, or replacement.29 However, these figures underestimate the true costs because they only include classrooms where at least half of enrollees are DLLs. The proposed rule acknowledges, without elaborating, that English-only instruction “may result in additional costs or burden not described here for programs serving [DLLs] or operating in predominantly non-English-speaking communities.” The estimates also fail to consider the long-term costs of adopting an instructional approach associated with worse outcomes for DLLs.

Furthermore, it is unclear what English-only instruction is meant to look like in practice, especially in Migrant and Seasonal Head Start30 and places such as Puerto Rico where Spanish is the predominant language. With no indication of whether the mandate applies to spoken interactions or only formal instructional content, providers and families are left to guess what compliance means. These programs would face a disproportionately high share of the costs to implement a policy that defies research, limits program flexibility, imposes extra burdens, and restricts effective instruction and service delivery. 

Removal of Cultural Responsiveness and New Confusion Around Language Access Requirements

To ensure DLLs can meaningfully access instruction as well as build trust with families, the HSPPS prompt programs to provide language access measures (such as translation and interpreting) and to utilize culturally responsive practices. The proposed regulations seek to undo most of these standards by, for example, eliminating certain staffing requirements, including that staff, contractors, and consultants be familiar with the ethnic backgrounds and heritages of families served, and that if a majority of children speak the same non-English language, programs have at least one staff member who speaks that language. ACF frames the change as consistent with the anti-DEI Executive Order 1415131 and justifies it as giving programs additional flexibility and mitigating workforce shortages. 

Hiring staff with an understanding of families’ languages and cultures builds trust and encourages communication. The proposed rule admits as much, noting that “reduced language capacity may negatively affect communication […] and weaken family engagement.” Positive, ongoing, reciprocal relationships between staff and families are crucial because early childhood programs are often a family’s first interaction with the U.S. education system.32 And even when educators are welcoming, families with limited English proficiency need concrete language supports such as interpreters and translated written materials to participate in genuine, two-way collaboration with program staff.33 Far from a simple efficiency tradeoff, the proposed changes would weaken core elements of the Head Start model, given that strong family engagement is needed for parent-focused activities and health and other service referrals. 

In terms of language access, the proposed rule notes that the Head Start Act’s protections for families with limited proficiency in English remain in effect, regardless of the revised standards, but certain HSPPS requirements and standards dictating how programs should provide language access would be eliminated. The changes seem destined to create confusion for providers, who remain bound by requirements to provide language access in the Head Start Act and other federal laws and regulations, but with proposed standards that would require English-only instruction and offer less detailed information on how to provide language access.

ACF’s proposed solution is for providers to use technology-based translation tools in place of trained linguistically and culturally diverse staff or interpreters. However, technology often leveraged for interpreting and translation, such as Google Translate, is at best a tool to support low-stakes communication. Such tools are not a suitable replacement for qualified educators and family liaisons who share a family’s language and cultural frame of reference, especially with the nuanced conversations Head Start staff are routinely expected to have with families about a child’s development or home circumstances. 

Removal of DLL-Specific Data Collection Requirements

The proposed rule would also eliminate the requirement that programs aggregate and analyze child-level assessment data by subgroup (such as DLLs)—data that help programs make strategic decisions about how to best serve children and families. ACF argues this will reduce administrative burden, give programs more flexibility in how they use their data, and cut compliance costs. However, this change is at odds with statutory requirements. 

The Head Start Act requires expert review teams to determine “whether programs have adequately addressed population and community needs (including those of limited English proficient children and children of migrant or seasonal farmworker families)” to help identify areas of strength and improvement. Without disaggregated performance data, this will become extremely difficult. The proposed rule makes no mention of how this legal requirement will be met once the disaggregated data provision disappears. 

If providers stop breaking data down by subgroup, DLLs risk becoming statistically invisible within Head Start data systems. When programs identify children as DLLs,34 this helps providers determine which children need the most support, which curricula and assessments are appropriate, and which teaching staff have the linguistic skills to best serve DLLs. Without disaggregated data, programs lose access to a valuable resource for decisions affecting children’s most sensitive years for cognitive development, communication skills, and language acquisition.35 The costs compound over time and extend beyond the classroom. Programs would no longer be able to determine whether they are meeting DLL and family needs, nor whether changes in family engagement strategies have positive outcomes. At the policy level, inadequate data would weaken funding and resource allocation, staffing decisions, and policy development. And gaps between DLLs and their monolingual peers will likely widen—precisely the outcome identification and disaggregated data requirements were designed to prevent. 

Degrading Program Quality and Access

Ultimately, the proposed standards cannot deliver on the promises they have made. Rather than eliminating duplication in federal regulations, restoring flexibility, or lessening administrative burden, the proposed changes will add new compliance costs, introduce legal and operational ambiguity, and disregard a set of regulatory protections backed by research—all without clear evidence for how their removal could improve outcomes for the children and families Head Start exists to serve. For DLLs, the rule threatens to dismantle many of the specific structures and requirements that have made Head Start uniquely accessible and beneficial. 

These issues are further compounded by the proposed rule’s provision allowing programs to apply for a waiver from any requirement other than those related to eligibility, nutrition, and physical activity. Providers might be able to seek a waiver from the English-only instruction mandate, for example, but it is unclear what the practical or legal implications of that would be. A rule that embeds case-by-case exceptions invites inconsistent and inequitable instruction and service delivery across Head Start grantees, with DLL children and their families bearing the consequences. 

"Ultimately, the proposed standards cannot deliver on the promises they have made." 

There remains some uncertainty as to the final form that the proposed rule will take. The notice of proposed rulemaking is open for a 60-day public comment period ending October 6, during which interested parties can submit formal comments. ACF is then required to review all comments before finalizing the rule; major changes based on public comments are not expected. Experts estimate a final rule will be released in 2027,36 although there is no deadline, with full implementation in 2031.37 

For 50 years, the HSPPS have ensured that DLLs and their families are not only able to take part in Head Start programs but also to thrive, through strong relationships between families and staff who understand their language and culture and with programmatic decisions grounded in detailed data. By dismantling the program standards underpinning these and other critical features, the proposed changes jeopardize the very goals Head Start aims to achieve.