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BALTIMORE, MD – Attorney General Anthony G. Brown joined a coalition of 23 attorneys general and the governor of Kentucky in submitting a comment letter opposing the U.S. Department of Health and Human Services’ (HHS) proposal to dramatically cut regulations governing the Head Start program.
Head Start is an early childhood education program designed to help break the cycle of poverty in adulthood by providing young children from low-income backgrounds with comprehensive services to meet their emotional, social, health, nutritional, and educational needs. The proposed rule would gut long-standing and evidence-backed Head Start Program Performance Standards, impose an English-only mandate, and reduce the cap on allowable administrative and development costs from 15 percent to 5 percent, while adding other burdensome requirements that would undermine children’s ability to learn and be prepared to succeed in school.
Head Start has operated with bipartisan support for over 60 years and helps address the national childcare gap, estimated at 28.2 percent of children with potential need who cannot access care within a reasonable distance. In both 2024 and 2025, Maryland Head Start and Early Head Start programs served more than 7,000 children and nearly 100 pregnant individuals. Head Start is critical for children who are frequently turned away from or otherwise cannot access quality early education, such as children with disabilities, children experiencing homelessness, migrant children, children learning English, and children from low-income households.
The proposed rule would eliminate over 1,400 regulations designed to protect enrolled children, pregnant individuals, and families, which could upend a nationwide system of care. Specifically, the proposed rule would eliminate requirements for early support and coordination of services for children with disabilities, maximum child-to-staff ratios, safety standards and safe transportation practices, parent committees, staff credentialing and training requirements, and research-based timelines for health, developmental, and vision screenings. It would also remove minimum hours of service, the prohibition on expulsions, limits on suspensions, and end the ability of families to self-attest in eligibility determinations.
The Department of Health and Human Services describes the proposed rule as returning discretion to the states and allowing programs to respond to local conditions. In reality, the proposed rule would create state-by-state disparities in early childhood education and care and significantly increase workload and costs for state agencies. HHS acknowledges that the rule would mean larger class sizes; fewer teachers, coaches, and home visitors; shorter program days; and reduced health, dental, and mental health services, leading to poorer educational outcomes for children and added strain on the states’ public health and welfare systems. The proposed cap on administrative costs could make it harder for programs to apply to become, and remain, Head Start providers, further limiting services for children in Maryland. Several provisions also vest undefined discretion in HHS, leaving Maryland Head Start programs exposed to political targeting by this federal administration.
Joining Attorney General Brown in the letter are the attorneys general of Arizona, California, Colorado, Connecticut, Delaware, the District of Columbia, Hawaiʻi, Illinois, Maine, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, Washington, and Wisconsin, as well as the governor of Kentucky.
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