Jessica Hottman gave birth to her son at 25 weeks, four and a half weeks before her due date.
When it was time for her son to enter Early Head Start, he had lingering health problems. Hottman had concerns, specifically relating to his gastrostomy tube. She wondered how the teachers would handle that.
But her worrying was in vain.
“They were able to really work with him,” Hottman said. “And now he's in pre-K and he’s on a level playing field with all of his peers, and he's caught up developmentally. And I think a lot of that had to do with being in our Early Head Start program.”
Now, the federal standards that make Head Start a quality program are at risk. If the Reducing Federal Burden for Head Start Programs proposal is finalized, several Head Start standards will be rolled back, leaving regulations for staff-to-child ratios, suspensions, practices involving children with disabilities and more up to individual states.
“The proposed rule would rescind more than 1,400 highly detailed regulatory provisions and replace them with a consolidated and streamlined framework. It simplifies eligibility, recruitment, selection, enrollment, and attendance (ERSEA) requirements; removes duplicative documentation and procedural mandates; and reduces reporting obligations not required by statute,” the proposal reads.
Oklahoma has its own health and safety guidelines and early learning guidelines for Head Start providers. But no specific law or agency requirement exists that prohibits expulsion or limits suspension protocols in the state. Barbara Sorrels, a consultant in early childcare who helped create the Oklahoma Standards, is concerned about what could fall through the cracks if federal standards no longer exist.
Sorrels said the guidelines outline the appropriate learning environment based on the children's age and stage of development, rather than addressing discipline.
Under the federal standard, Oklahoma is required to consider suspensions the last resort and only permit a suspension when a serious safety threat occurs or other interventions were unsuccessful. Before a child can be suspended, Head Start providers must involve parents and offer mental health services or community resources to address the child’s behavior.
Without federal safeguards to mitigate the issue, Sorrels said suspensions will likely increase and expulsions will become an option.
Suspensions in early childhood are already common in Oklahoma. The state had the second highest number of suspended preschoolers in public schools in the U.S., according to the Civil Rights Data Collection for 2023-2024. Being suspended or expelled in early childhood can result in poor academic performance and a larger chance of suspension or expulsion once a child enters K-12 schools, according to the National Association for the Education of Young Children.
Certain populations are also more at risk if federal regulations on suspension and expulsion roll back.
Historically, Black children and children with disabilities are exceptionally vulnerable to exclusionary discipline practices. The Civil Rights Data Collection from 2020-2021 showed Black children made up 18% of the preschool population but 38% of suspensions, while students qualifying for assistance from the Individual with Disabilities Education Act made up 23% of the preschool population but 74% of expulsions.
The National Association for the Education of Young Children also identified unconscious bias and misinterpretation of children’s normative behaviors as contributing factors to the statistics. Sarah England, the senior director of grants and advocacy at Sunbeam Family Services, said young children often communicate their needs through behaviors that can be misunderstood, especially in classes with young or inexperienced teachers.
“It doesn't mean that teachers are bad people,” England said. “It means that teachers need access to reflective support, and they need specialists that can help them slow down and examine their own implicit biases and how they might respond to those and level set within their classroom environment.”
Federal standards previously addressed the need to specifically serve children with disabilities. A program was required to ensure at least 10% of its total funded enrollment was filled with children eligible for services under the Individuals with Disabilities Education Act, another standard that would no longer exist if the proposal is finalized.
Lisa Kelly, the CEO of The Arc of Oklahoma, said the standard helped parents of children with disabilities enter the workforce. Beyond ensuring child care, it also helped identify children’s needs earlier, she said.
“There's research that shows that the earlier an individual can be diagnosed, and early intervention services can start, the greater their prognosis is for success in the future,” Kelly said. “Head Start is just one way that children can be identified and start that process early on before they enter the school system.”
Hottman is not only a parent, but also the disabilities coordinator for Sunbeam Family Services. She can help children with disabilities transition to public school, whether by connecting families with school resources or helping them set up an individualized education plan. The nonprofit also has its own mental health services, foster care department and community partnerships.
With Sunbeam having those services in house, it can be easier to meet the requirements of Head Start standards, England said. Other programs do not have as easy access to required resources, especially in rural areas.
“Let's say in rural America where they actually don't have somebody with all those letters behind their name, they're contracting out and having somebody come by and maybe review caseloads twice a year,” England said. “There already is quite a spectrum in the delivery and how people are meeting those practice and performance standards.”
Loosening Head Start regulations would only increase discrepancy among programs, England said. While the proposal states it would provide flexibility and allow programs to tailor its services to its population, England said removing the standards would take away the quality floor that ensures programs are meeting the needs of the vulnerable populations Head Start is set up to serve.
“We don't see quality as a burden, and we see that a lot of the proposed cuts to the rule are really related to the quality floor for children,” England said. “When we're talking about babies, birth through three, we're really talking about humans who don't really have the skills yet to communicate, and so it really is more of a all of these rules and regulations are designed to help the adult and children’s life and do what needs to be done to make those children, those families successful.”
One standard that is especially important to families with children with disabilities is the staff-to-child ratio standards. Hottman said low student-teacher ratios allowed teachers to show her son care and attention while he had medical needs. The proposal would also remove student-teacher ratio standards if it is finalized.
The federal child care ratio for 3-year-old children is one teacher per 8.5 children, which would allow classrooms to have two teachers per 17 children. Sunbeam Family Services changed its own guideline to reduce ratios to two teachers per eight children. If there is no longer a federal ratio requirement, England said child care providers worry they’ll have to increase ratios to remain eligible for federal funding as a Head Start program.
“There’s a very big concern that the Office of Head Start will force Head Start programs to weaken their quality standards,” England said. “And that they won't allow a lot of the wraparound supports that are no longer going to be named in the Head Start performance standards as eligible expenses on the grants.”
Oklahoma has state licensing requirements to address staff-to-child ratios in state Head Start programs. Infant and young toddler ratios are one staff member per four children and one staff member per six children, respectively.
At Tulsa Educare, the program keeps a ratio of three staff members per eight children in the toddler and infant classes, according to a study created by the Early Childhood Education Institute at the University of Oklahoma-Tulsa. Melissa Miller, a mental health specialist at Tulsa Educare, said low ratios can allow children to get the attention they need before it progresses to a point where intervention is necessary.
“With the more staff we have and the fewer children in the classroom, we're able to really do those individual supports and interventions that are going to help children be successful and not have the need to expel or suspend children,” Miller said.
Despite good outcomes with low staff-to-child ratios, Head Start programs with fewer resources may not be able to hire more teachers and serve fewer children. Permitting one additional infant per staff member was associated with a nine to 20% increase in infant care prices, according to an article from the Office of Assistant Secretary for Planning and Evaluation.
The proposed changes are ultimately intended to reduce the program's cost and administrative burden, but they also create new standards to meet executive orders under the Trump administration. To comply with an executive order that made English the language of the United States, the proposal would also eliminate Spanish instruction and require Head Start classrooms to prioritize English instruction only.
Losing Spanish materials could isolate Hispanic families and interfere with vital communication, an Oklahoma Watch report revealed earlier this month. Two Spanish-speaking mothers said they worried about being excluded from having a voice in their children’s care. Head Start standards currently encourage family involvement, but child care providers are worried the changes could affect a child’s development within their family system.
“We don't want to support the preschool-to-prison pipeline,” Miller said. “We want to help our children and families be successful.”
Oklahoma Watch, at oklahomawatch.org, is a nonprofit, nonpartisan news organization that covers public-policy issues facing the state.
