Four times a week, Millicah Wanjiru brings her three-month-old twins to the Denise Louie Education Center in Seattle, Washington. Wanjiru hasn’t had a home of her own for three years; when she was six months pregnant, she started staying at an emergency shelter for women and children called Mary’s Place. The one-hour Denise Louie parenting classes for her and other Mary’s Place residents, funded through an Early Head Start grant, always begin with parents introducing themselves with a song. Then the babies do tummy time and Wanjiru gets feedback from the home visitors leading the class on how their development is progressing. Her babies are growing fast: both of them can already roll over. When they do, the group of parents and teachers clap and cheer.

The babies get hearing tests and vaccinations, and the nurses help parents talk through questions to ask when they visit the pediatrician. Once, one of the twins had a lot of mucus in her eyes and Wanjiru feared that she was going blind; a nurse at the class advised putting breast milk on it and it cleared up “like magic,” she said. She also gets diapers, formula, and snacks when she attends.

For Wanjiru, who suffered trauma while living on the streets, the class “helps us with routine, it’s like normalcy,” she said. She’s also getting parenting guidance, help with how to talk to her babies, how to soothe them when they cry, and, equally important, other people to talk to as she navigates parenting. The program gives her toys and books to read to her babies. She last had a baby 15 years ago, when she was a teenager, so she feels like she’s starting all over. Wanjiru is now trying to secure a room in a transitional housing complex, and the class has promised to follow her there with home visits; it will serve her until her children turn 3 and can enroll in a Head Start classroom.

“It’s wonderful,” Wanjiru said. “I hope this program never ends.”

But this program is indeed at risk of ending. The Trump administration recently proposed a rule that, if finalized, would erase a huge number of standards and rules that guide the quality and services offered in Early Head Start and Head Start, the free, federal preschool program for low-income children. Among what’s lost are important guidelines that ease eligibility and paperwork for homeless families like Wanjiru’s, which make sure they can enroll and benefit. If the rule is finalized, Denise Louise may no longer be able to partner with Mary’s Place to offer services for homeless parents like Wanjiru through Early Head Start, said Linda Mitchell, chief government affairs officer at Mary’s Place. All told, the administration’s changes make it much less likely that Head Start will continue serving the more than 60,000 homeless children who are currently enrolled.

When Congress reauthorized the Head Start Act in 2007, it included a mandate that programs around the country prioritize enrolling children in families who are experiencing homelessness. But it said that the details of how programs should do that would be spelled out in standards developed by the Department of Health and Human Services. Those guidelines, which in addition to easing paperwork burdens for families unlikely to have much documentation allow programs to prioritize homeless families, have been in place for 10 years, and Trump’s proposed rule would replace all 133 pages of them.

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“These are families who are moving around frequently, from couch to car to motel maybe to shelter,” said Barbara Duffield, executive director of SchoolHouse Connection, a nonprofit focused on homelessness among children. That means they may need to enroll their children midway through the school year. It also means that holding onto the documentation ordinarily required of parents who enroll is difficult—things like birth certificates, immunization records, and proof of income to show a family is eligible. “If you’re fleeing domestic violence in the middle of the night and going from place to place, records may not be the thing you think to take with you,” Duffield explained. “If you’re on the move constantly you don’t have anywhere to store anything.”

The current Head Start standards, issued at the end of 2016, spell out how programs can work around these challenges to make sure homeless children participate. For example, the current standards say that, despite a requirement to maximize enrollment, programs can reserve up to 3 percent of their spots for homeless children for 30 days in case they show up unexpectedly. It also says that programs must include such families when they do assessments of the needs of their communities and can prioritize them on waiting lists. Meanwhile, under the current standards, homeless families can self-attest—essentially swear—that they’re homeless if they can’t immediately gather proof of eligibility, allowing their children to enroll while they secure the necessary documents, and their homelessness makes them automatically eligible. That is all “operationalized due to those performance standards,” Duffield said. Without guidelines specifically permitting these accommodations for homeless families, programs will be unlikely to offer them, she said. “Head Start is a very compliance-focused program. People are afraid to do anything if they can’t point to a specific place where it says, ‘Yes you can do this.’”

The proposed rule acknowledges that, with more stringent paperwork requirements, “some families, such as those experiencing homelessness, may have a more challenging time providing such documentation.” Without self-attestation, in particular, the administration estimates that 8 percent of children who are currently enrolled would no longer be eligible if the rule is finalized. “They admit this would impact families who are homeless, but they don’t offer a solution,” noted 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.

“The administration is saying these rules are duplicative and they’re redundant and they’re burdensome and we just need to rely on the statute,” Duffield said. But “the law doesn’t execute itself.”

If programs aren’t explicitly told that they can set spots aside for homeless children, they won’t do so, Duffield said, especially as the Trump administration amps up the pressure to enroll more children; the proposed rule claims that it would preserve or expand the program by as many as 236,000 slots. Programs must also dedicate time and resources to finding and enrolling homeless families because “they don’t typically walk in the door,” Duffield said; without that being mandated and supported, programs may stop doing so. “We’re just going to go backwards in time.”

The end result, as the proposed rule itself acknowledges, will be fewer homeless children enrolled in Head Start. Head Start served 60,221 homeless children in the 2024–25 school year, which represents 7.7 percent of enrollment, up significantly from the 26,235 served in the 2006–07 school year, the last year before Congress mandated their inclusion. “There are very few things I feel certain about, but I feel certain that you’ll start to see the number of children who are homeless go back down and the children who need it most won’t have it,” Duffield said.

Even proposed eliminations that do not specifically target homeless families could have an outsize impact on them. Other changes put forward in the proposed rule would weaken standards on class sizes and ratios, curriculum, punishment, and family engagement and add in requirements like only teaching in English. Homeless families in particular will feel the impact of dropping required health and developmental screenings. “The totality of the changes will disproportionately impact families who are unhoused,” Hamm said.

The treatment of homeless families in the proposed rule stands in contrast with children in foster families. The rule retains all of the guidelines for these families, including their ability to be categorically eligible and self-attest.

The proposed rule is open for public comment through October 6. Duffield plans to submit a comment not only criticizing the changes but asking for adjustments that would help homeless children, such as requiring Head Start programs to designate specific liaisons for homeless families and create individualized plans to support homeless students. But it’s not just advocates and program directors weighing in. Within a week, members of the public had submitted over 500 comments, which is “a lot for this stage,” Hamm said; there were 3,257 two weeks later. Many are negative. “The Head Start program is so important for our country. I am against these changes. Investment in Head Start is an investment in the country’s future,” saysone . “Preschool should not only be for rich white people, but for all children. Everyone deserves to have the opportunity for a great education,” says another.

“I think a lot of people will submit comments about this,” Hamm said. “It’s been getting a lot of attention.”

Once the public comment period ends, HHS must review and respond to the comments. In the past, it has taken administrations as long as a year to complete that process, Hamm said, but this one “has been working with a much faster turnaround,” so she estimated it might take a matter of months. After that, the administration can publish a final rule, and the rule would take effect 60 days after that unless blocked by a judge.

Lawsuits aren’t likely to be filed until after a final rule is published. When The Nation asked the American Civil Liberties Union, which has brought a lawsuit against other administration changes to Head Start, if it would file a lawsuit against the rule, the organization said, “We’re closely reviewing the proposed rule and evaluating all available legal options.” Hamm argued that the changes impacting homeless children are, on their own, “contrary to Congress’s directive to focus specifically on enrolling children who are homeless and removing barriers,” and that other changes are also contrary to the Head Start Act.

Advocates are hopeful that Congress will put a stop to the rule. “The [Head Start] community will expect Congress to do something about this and hold the administration accountable,” Hamm said. But its levers to do so are limited. Members of Congress could insert a prohibition on implementing the rule in must-pass funding legislation, but the Senate has already passed a continuing resolution that would fund the government through December 11 (the House still has to pass its version). Assuming the rule becomes final, Congress could overturn it through the Congressional Review Act, but to do so, President Trump would have to sign the measure, or Congress would have to override a veto.

Senator Patty Murray, long a champion for early childhood education and Head Start, said at a recent press conference, “I will press administration officials when they come before Congress. I’ll sound the alarm as loudly as I possibly can, and I will carry this fight into every negotiation I walk into.”

“I’m hoping the groundswell of support translates into action on both sides of the aisle, because there’s nothing that should be partisan about this program,” Duffield said. By enabling parents to stabilize their lives, she added, “Head Start ends homelessness.”

Wanjiru’s babies are still very young, but she already has her eyes on their education and wants to enroll them in the Head Start program for 3- to 5-year-olds at Denise Louie as soon as she can. “The earlier start for kids, the better,” she said. “The more they get school, the more they learn and they more they know.”

When presented with the possibility of not being able to access Head Start as a homeless parent, she was taken aback. “We definitely need Head Start,” she said. “That would punish us.”