On Thursday, the Trump administration released a proposed rule that would eliminate hundreds of regulations that set safety, quality, and other standards for Head Start, the nation’s free preschool program for low-income children, deleting the entire 133-page set of standards and replacing them with a far more slimmed down version that eliminates numerous health and safety requirements.

What would be left is “a really watered-down Head Start program that removes a lot of the health and safety requirements, quality standards, and comprehensive services,” Katie Hamm, who served as deputy assistant secretary for early childhood development at the Office for the Administration for Children & Families under President Joe Biden, told The Nation.

Department of Health and Human Services Secretary Robert F. Kennedy, Jr., whose uncle Sargent Shriver helped create Head Start in 1965, said in a press release that the rule is “removing unnecessary bureaucracy, strengthening nutrition and physical health, trusting parents and local communities, and opening Head Start to hundreds of thousands more children. That’s how we renew the promise of Head Start for the next generation.”

The proposed rule eliminates the requirements that limit Head Start class sizes and mandate a minimum number of adults to care for young children. Instead, programs are instructed to follow state rules, but no state has staff-to-child ratio regulations for all age groups that are at least as good as Head Start’s; following state ratios will worsen the minimum requirement for 97 percent of 2-year-olds in Head Start, 93 percent of 3-year-olds, and 71 percent of 4-year-olds, a report from Arizona State University’s Children’s Equity Project found. In its proposed rule, the administration estimates that Head Start teachers would be able to serve between 16 and 32 percent more children in their classrooms if the rule is finalized and that it will “preserve or expand” as many as 236,000 Head Start slots.

But Head Start program directors have told Jennie Mauer, executive director of the Wisconsin Head Start Association, that they have a “deep fear about a requirement to serve more children,” she told The Nation. Some are already operating at lower ratios than required in order to meet the significant needs of the children they serve. More children are coming into Head Start with emotional and developmental issues; for young children, she pointed out, that often means behaviors like biting or throwing that require intensive, hands-on supervision. It’s not that programs don’t want to serve more kids; “they want to serve children in their care in ways that really meet their needs,” she said. If the administration puts pressure on them to serve more children, staff may quit and programs may just have to close, Hamm noted.

The proposed rule also gets rid of a requirement to have at least one bus monitor on all buses, with more as necessary. Programs are concerned about what that will mean when 3- and 4-year-old are put on buses by themselves. “I am really worried about safety,” Pittman said.

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It also eliminates curriculum requirements that guide the commercial educational materials that programs can buy and implement. Currently, the rules say that curricula must be scientifically valid, aligned with the program’s outcomes framework, and have standardized materials and training procedures. Head Start is such a big purchaser of these materials that these rules have driven up quality across these companies’ products. But “the accountability and the monitoring comes from what’s in the standards,” Hamm said.

It also gets rid of the requirement that Head Start programs be open for a certain number of hours each year, instead saying they have to be open a minimum of just three hours a day, seven days a week.

Gone, too, are guidelines on when and how children can be suspended or expelled and a ban on corporal punishment. For many other standards—those outlining when and how to give all children developmental screenings, provide medical and dental care supports, serve children with disabilities, and include vulnerable families like those who are homeless or in the foster care system—the proposed rule deletes the current guidelines and instead tells programs to follow what’s in the Head Start Act. But the act designated the 133-page guidelines as the place where its requirements would actually be spelled out. “What the act says is that the standards are supposed to tell programs how to implement these things, so it becomes quite circular,” Hamm said. “It leaves programs without clear instructions about when and how to implement things.” For developmental screenings, for example, programs are currently required to do them within 45 days of enrollment and then follow up to make sure children are getting the necessary services; those requirements would all be erased.

Layoffs are the likely result of these changes, Lauri Morrison-Frichtl, executive director of the Illinois Head Start Association, said on Thursday’s press call, particularly of the staff who currently offer the mental health and disability services that will no longer be required. Pittman said her program will likely have to do the same. “It will have a drastic impact on children and families,” Morrison-Frichtl said.

“This rule would make Head Start classrooms less safe, weaken standards for critical screenings and health services, strip away support that helps families access care, and deny children the strong start they deserve,” Representative Summer Lee (D-PA), said in a statement to The Nation. “The administration could strengthen Head Start, expand it, and invest in the educators who make it work, but instead they are deliberately hollowing out one of our nation’s most successful anti-poverty programs.”

The administration claimed in its press release that the proposed rule “recognizes parents as children’s primary teachers” and retains rules that programs must engage with them. But “it actually takes away power from parents,” Pittman argued, who currently vote on everything from programs’ budgets to curriculum. Parent committees that weigh in on programs’ policies and services become voluntary under the proposed rule, while current procedures that guide what happens when a program’s board and parent council disagree would be eliminated, tipping the scales away from parents. “This was one government program that really did include parents as equal partners, giving them a space at the table to make decisions about their child, their program,” she said. “That is now being removed.”

The proposed rule also reduces a cap on how much grant funding Head Start programs can spend on administrative overhead from the current 15 percent to 5 percent. “At five percent, I don’t know how you could produce quality services,” Pittman said. “That’s like building a house without the framing.” Programs use that money for everything from buses to staff background checks to replacing broken refrigerators. The spending is closely audited, not just by the federal government but by parent councils and governing boards. “Every penny is allocated,” Pittman said. “Everyone I know, including myself, has never become rich from being a Head Start employee.”

The proposed rule says it will free up $2.2 billion by 2031, which it claims is “the largest known reinvestment in the program since its creation.” But the Trump administration is not offering any new funding; it bases those savings on looser child to staff ratios, the reduction in mandatory hours of operation, the lower cap on administrative costs, and reduced spending on services like teacher coaching, mental and health services, and home visiting. “They’re assuming that a lot disappears,” Hamm noted.

HHS’s press release claimed, “Nothing in the rule requires Head Start providers to change their current program parameters if they are working for their community.” But given its cost-savings projections, it is clearly anticipating that programs will decide not to offer many services that are currently mandatory. “It feels really disingenuous,” Mauer said. “Programs are going to have to reallocate resources to care for more kids. Things aren’t adding up here.”

“This proposed rule is a mandate to do more with less,” Representative Rosa DeLauro (D-CT) said in a statement to The Nation.

The administration claims in its press release that the rule “restores flexibility to programs to meet local needs.” But Morrison-Frichtl says the existing standards allowed flexibility already. She oversees 54 Head Start grantees across Illinois, and “each one looks different, they reflect their community.” The standards are “not simply red tape,” she said. They “ensure that children are safe, healthy, supported, and prepared to learn.”

“Children should not pay the price of deregulation,” she added.

Last week, The Nation reported on an earlier version of the proposed rule that included a new and troubling change to eligibility that would have shut out a number of immigrants, and potentially children who are American citizens, by only allowing those who have at least one parent who is a citizen, U.S. national, or “qualified alien” to enroll. That restriction doesn’t appear in the proposed rule. Last year, the administration attempted to block immigrants from enrolling in Head Start, a move that a judge put on hold as a lawsuit plays out. On Wednesday, the administration sent an additional new proposed rule to review called “Ensuring Program Integrity for Head Start Programs,” the contents of which aren’t yet public.

What did stay in the proposed rule released on Thursday, however, is a mandate to teach children only in English and not their family languages. That would severely disrupt many Head Start teachers’ work. Morrison-Frichtl recently spoke to a teacher in Illinois, most of whose students are dual language learners. “She said she would be devastated,” she said. Even on a practical level, Mauer pointed out, how will teachers help children, say, put on all of their snowpants in the winter if the kids speak Spanish but teachers can’t? “It appears that the people writing these rules have not met children,” she said. “This is just not based on the evidence that we know about learning [nor] on the practical realities of how you support kids in the classroom.”

Advocates have warned that some of the rule’s changes may contradict the Head Start Act or other laws, which could leave the proposed rule vulnerable to litigation. There’s a requirement in the statute to provide services to dual language learners, which Hamm sees as contradicting the English-only instruction requirement, as does the lower cap on administrative spending, she said. In addition, the law’s reauthorization in 2007 stated that the performance standards can’t reduce the quality and scope of services provided. When asked whether it would bring a lawsuit against the proposed or final rule, the American Civil Liberties Union, which brought the lawsuit against the administration’s attempt to block immigrants from enrolling in Head Start, said in a statement to The Nation, “We’re closely reviewing the proposed rule and evaluating all available legal options.”

For its part, the administration disagrees. “Nothing in this proposed rule alters or waives statutory obligations; rather, it aligns regulatory text more closely with governing law,” it said in its press release.

The proposed rule does not represent the administration’s first attack on Head Start. After Project 2025, an agenda crafted by conservative Trump allies to guide the next Republican president, called for eliminating Head Start, a leaked draft of Trump’s first budget called for doing just that. The administration has fired huge numbers of federal Head Start employees and closed regional Head Start offices. It refused to dole out money to programs that Congress had already appropriated, leading some to briefly close. In May, the administration proposed rolling back higher wage and benefit levels for teachers set by the Biden administration.

“The Trump administration wanted to eliminate Head Start entirely but backed down after outcry from parents, providers, and Congress,” DeLauro said. “Now they seek to hollow out the program through rule making.”

Democratic Senator Patty Murray agreed. “After Congress and the nation forcefully rejected Trump’s efforts to destroy Head Start, this administration now wants to quietly gut Head Start by eliminating the basic health and safety standards our kids rely on,” she said in a statement, calling it a “travesty.” The rule will be open to public comment for 60 days, and Murray urged parents and teachers to weigh in. “I have seen what happens when enough ordinary people refuse to let something get ripped away from them,” she said.

Morrison-Frichtl and Mauer pointed out that the administration did not talk to program directors or Head Start grantees directly about how it could make running Head Start programs easier. Now, they’ll be weighing in after the rule has already been drafted.

“I’m alarmed,” Mauer said. “It’s really demonstrating a profound misunderstanding of the role that the standards have played and are playing in our programs.”