Head Start or Back Slide: The Perils of Institutions—and of Institutional Reform

The Perils of Institutions

It never ceases to amaze me how often some legislation or proposal coming out of the White House or from GOP lawmakers seems to be the real thing, a delivered wing and an answered prayer of promised change.

But then you remember to read the fine print. And lo and behold, there’s a little poison pill lurking in the weeds, just waiting for its chance not only to crash the good things gliding our way but to actually make the world worse than it was before.

This is going on right now in the Swamp, where the usually level-headed Sen. Mike Lee (R-Arizona) has led a bipartisan group of lawmakers on long-overdue reform of the nation’s permitting processes. The bill answers many prayers, as multiple provisions would undoubtedly prevent radical environmentalists from frivolous litigation against legitimate development projects. All in all, the bill treats environmentalists like what they are—legal terrorists using the environment as a shield to further their radical agendas.

The cuckoos literally use Cuckoos—the real needlessly protected ones—to get their way.

But lo and behold, I took a look—and then a second look, and then a third—and there it is: a deal-breaker, at least for me. After all these years that conservatives fought against judges giving agencies deference, and the Supreme Court finally throwing it out in Chevron, deference suddenly rears its ugly head again in this bill. Specifically, it would codify judicial deference to agencies on the scope and contents of environmental reviews under NEPA (National Environmental Protection Act). That’s the last place it ought to be.

And that brings us to President Trump’s recent proposal to overhaul Head Start. Here again, what looks like a bold move—and it contains some real good actions—there’s a poison pill. Specifically, Trump is cutting regulations massively in the proposed Head Start Rule, but when it comes to parental control, he just might be throwing out the baby with the bathwater.

Earlier, Trump was considering cutting funding for the bloated program entirely, but he backed down after Democrats—and some Republicans—howled. So now the rule is intended to deregulate rather than demolish, and the thinking is that somehow that drops control of the program into the laps of families. It does not.

More specifically, the August 2026 proposed rule would preserve federal funding while reducing numerous regulatory requirements, relaxing staffing and student-ratio rules, and giving local providers greater discretion in delivering services. All of that is pretty good as far as it goes because the Head Start program consumes resources like a pack of dogs running loose in a butcher shop.

HHS secretary Robert F. Kennedy, Jr., put it this way in announcing the proposed rule:

According to the Notice of Proposed Rulemaking, the rule would preserve or expand as many as 236,000 Head Start slots nationwide and save $2.2 billion, what the administration says is the largest reinvestment in the program since its creation 61 years ago. It would also preserve the federal-to-local program model, allowing the Administration of Children and Families (ACF) to refocus compliance and accountability on core statutory priorities while upholding the local decision-making.

Or so the administration says. Of course, the Democrats pushed right back. Gov. Tony Evers has warned that approximately 12,000 Wisconsin children could be affected, while the Wisconsin Department of Children and Families has raised concerns about reduced staff-to-child ratios and weakened health protections.

On October 6, Evers wrote a letter to Kennedy articulating those concerns.

“Head Start provides an array of family support services that assist families in reaching their goals and meet their unique needs,” Evers wrote. “During the 2024-25 program year, Head Start served 12,565 families in Wisconsin. This figure includes the 1,055 children identified as experiencing homelessness at the time of their eligibility verification. Over 11,000 Wisconsin families received at least one family service.”

But nowhere in the letter, nor in DHS’s public comment on the proposed rule, do the governor and the agency explain exactly how cutting massive overhead while not cutting the program’s overall spending would actually hurt rather than help those kids. But that’s Democrats.

The truth is, it’s been an underreported story for a long, long time, but Head Start does not have a good track record, either in improving economic performance or in fulfilling its real mission, which was to lift people out of ongoing cycles of generational poverty. It was established in 1965 as part of President Lyndon Johnson’s War on Poverty; its founders believed that disadvantaged children often entered elementary school already behind their more affluent peers and that early intervention could improve their educational achievement, health, social development and long-term economic prospects.

Of course, none of that has happened, and some experts, like Heather Mac Donald, writing in August in City Journal, say the $240-plus billion program doesn’t work at all....

Ouch.

HHS’s 2012 Head Start Impact Study did indeed challenge the prevailing consensus that preschool intervention necessarily produced lasting improvements in educational achievement:

“Looking across the full study period, from the beginning of Head Start through 3rd grade, the evidence is clear that access to Head Start improved children’s preschool outcomes across developmental domains but had few impacts on children in kindergarten through 3rd grade,” the study stated.

It wasn’t just in pre-school experience where the great fade-out happened, either.

“In terms of children’s well-being, there is also clear evidence that access to Head Start had an impact on children’s language and literacy development while children were in Head Start,” the study stated. “These effects, albeit modest in magnitude, were found for both age cohorts during their first year of admission to the Head Start program. However, these early effects rapidly dissipated in elementary school, with only a single impact remaining at the end of 3rd grade for children in each age cohort.”

Ditto with social-emotional development, depending on the age and who you were talking to. Indeed, the report asserted, there were sometimes unfavorable impacts reported.

Still, the statement that Head Start is completely a failure is a foul ball bouncing around in the bleachers, trying to find a glove to make it stop making noise. The 2012 report clearly identifies some benefits, albeit mostly temporary, while other studies have identified possible long-term benefits.

A 2021 study published in the American Economic Review, examining children exposed to Head Start during its early expansion, found higher educational attainment and improvements in adult economic self-sufficiency, including lower rates of poverty and receipt of public assistance.

“Participating children achieved 0.65 more years of education, were 2.7 percent more likely to complete high school, and were 8.5 percent more likely to enroll in college,” that report stated.

Children in Head Start were 4 percent more likely to work as adults; they also worked 2 more weeks per year and 3 more hours per week on average.

However, those positive studies do not establish that today’s programs produce justifiable results, all things considered, given their high taxpayer costs and their comparability to students in public pre-school programs.

To say it another way, it does not relieve government officials of the responsibility to demonstrate that taxpayers are receiving reasonable value for the money spent—or that families could not obtain comparable services through a different funding or institutional arrangement (including a lack of any institutional arrangement, by the way).

Even giving Head Start the benefit of the doubt, there’s no question that there’s room for dramatic improvement, and no question that administrative bloat, incompetence, neglect bordering on criminality, and even fraud have made this a sketchy program at best.

And that’s where Trump’s proposal is so significant. He keeps the infrastructure but targets administrative overhead and regulatory strangulation.

Most critically, the rule would cap administrative spending at 5 percent, down from today’s 15 percent. The administration says that change alone could redirect $754 million a year toward program services, while broader regulatory changes would complete the march to $2.2 billion in annual financial benefits, and preserve or expand as many as 236,000 enrollment slots nationwide.

Head Start’s own cost structure provides a starting point for evaluating the administration’s proposal. National spending figures place median annual costs at approximately $15,000 per preschool child and $20,000 per preschool child for Early Head Start, which serves infants, toddlers, and pregnant women.

Cost comparisons in Wisconsin raise eyebrows, too. The National Institute for Early Education Research placed the state’s public prekindergarten spending at approximately $6,953 per child in 2022-23, compared with approximately $16,239 for Head Start.

It’s not quite apples-to-apples, to be sure. Wisconsin’a public four-year-old kindergarten provides fewer instructional hours than Head Start, and Head Start includes other health, nutrition and family services. Still, a spending figure that is 2.34 times as large cannot be dismissed.

The program also imposes detailed federal rules governing staffing and operations, including a cap on the number of young children a teacher may supervise. The administration argues that these requirements increase operating expenses and reduce the number of children providers can serve.

The devil is in the details, but the rule would pare back the program’s 133 pages of regulations by dropping 1,400 costly rules.

It’s not just those pages of regulations that are ramping up the overhead. It’s also inefficiency, incompetence, waste and even fraud. As the GAO found in a December 2024 report, more than 200 Head Start programs have been under interim management since 2000, and a fair number still are.

“As of September 2024, 18 of 1,600 Head Start programs nationwide were under interim management,” the report stated.

What’s more, OHS had neither assessed classroom quality nor monitored finances for all programs under interim management—both of which are required under the Head Start Act.

“Lastly, OHS officials stated that they had never enforced enrollment standards or required Head Start funds to be returned for children not served,” the report stated. “In the 2022-2023 school year, GAO found that fewer than half of the nearly 4,000 Head Start seats available in programs under interim management were filled. Local staff from all three Head Start programs GAO visited shared concerns about their experiences during interim management, including unqualified staff, unsafe facilities, and poor fiscal stewardship.”

Staff at two programs cited facility hazards, including mold, that were not properly remediated.

“Staff at all three programs expressed concerns about fiscal management—from expensive and unnecessary equipment orders in one program to a lack of essential supplies, like diapers and wipes, in another,” the GAO reported.

And this is the program Democrats tell us helps poor kids. If that’s helping the kids, I hate to see what they think harm is. Seems to me we should applaud the redirection of those dollars to where they belong and away from the administrative overhead.

Trump, of course, sees administrative spending as a significant opportunity for reform. Head Start providers have historically devoted approximately 11 percent of expenditures to administration, below the existing 15 percent ceiling but substantially above the proposed 5 percent limit. In the administration’s view, reduced reporting requirements, simplified facilities applications, relaxed staffing mandates, and elimination of duplicative federal standards would allow providers to redirect resources toward children.

All that said, simply shifting resources is not about to solve the problem called Head Start, just as shifting money away from government-school administrators into government-controlled classrooms won’t solve the problem known as government schools.

It’s a start, but it’s not the solution. Not only that, but it is in the trenches of deregulation where the Trump proposal slams into its own headwinds. Indeed, some say Trump’s proposal could actually weaken parental participation in the program.

That’s because the administration believes that deregulation by itself will empower parents. In fact, that’s a central justification for the proposed reforms. By reducing federal prescriptions governing family engagement and local program operations, the administration argues that parents and providers would gain greater flexibility to tailor services to individual circumstances.

But there is a fundamental difference between giving Head Start organizations greater discretion over their operations and giving parents greater control over their children’s education. The administration’s proposal accomplishes the former but stops short of the latter.

For example, critics contend that eliminating certain federal requirements, such as parent committees, family goal-setting, and parent-teacher conferences, could gut the very mechanisms through which parents influence Head Start programs. That wouldn’t be true in every community. But with such local control—that is, control of the program by local institutions—it will most certainly be true somewhere, and likely in many wheres.

The point is, deregulation does not automatically translate into increased parental authority.

True reform: Vouchers

Here’s a question. If the goal is to serve disadvantaged children and their families, why must federal funding necessarily flow through existing Head Start organizations rather than follow eligible children to qualified providers selected by their parents?

In 2021, a coalition of Republican senators, led by Sen. Mike Lee of Arizona, launched an effort to take us in that direction: the Head Start Improvement Act. The money would have given Head Start money directly to the state to administer. More important, under the bill, grant recipients could use funds to set up portable voucher systems (for private pre-K programs) and education savings accounts for low-income parents to pay for pre-K expenses.

“Underprivileged children need access to high-quality education, but the evidence shows that, in its current form, the Head Start program is failing to provide it,” Lee said at the time. “Education reform should empower parents, principals, and teachers, instead of centralizing power and money in political bureaucracies. This bill would allow states, communities, schools, and families to better tailor pre-K programs to the specific needs.”

None of this is to say that implementing a Head Start voucher system would be easy. For starters, Head Start provides nutrition, developmental screenings, health services, disability accommodations, and family assistance in addition to those pre-school education programs. A voucher system would have to protect those services for eligible children.

Rural communities would present another challenge. In northern Wisconsin, a voucher would offer little practical choice if only one qualified provider were available. Transportation and the financial viability of small programs would all require attention, as would children with disabilities and other significant needs.

Yet by themselves these difficulties do not mean that a choice system is any more impractical than an incompetent and arbitrary government program. Likely it is a lot less so. Indeed, Wisconsin already imposes accountability and participation requirements on private schools receiving public funds through its school choice programs.

The question for the Trump administration is why it has chosen to reform the existing Head Start provider system without seriously considering a model that would put control in parents’ hands. If the administration believes that federal rules are unnecessarily restrictive, why not examine whether qualified providers could meet only the essential standards while competing for families’ participation?

The debate over Head Start has become another contest over federal regulations, government spending and the future of a longstanding public program. Its ultimate ambition was to interrupt the cycle of intergenerational poverty, not merely to maintain a permanent network of federally funded preschool providers. And that’s the problem with both Democratic and Trump administration approaches to Head Start: They view it as an institution, another government program, a name even, rather than as a community of constituents.

Head Start should not be viewed as being any of that. What it is, once the leathery skin of government is peeled away, is the universe of children and their families who participate in it, regardless of the institutional arrangements. They are the real institution and the only one that matters.

If government Head Start organizations can compete in a market environment, so be it. If other qualified providers can offer comparable or better services, families should have the right to make that choice. And if certain health, nutrition, educational, and disability protections are essential, policymakers should examine how to preserve them without restricting education freedom.

Ultimately, the central question whether the next generation of reforms will continue to concentrate power in archaic centralized institutions that administer public programs—or explore ways to redefine institutions democratically and from the bottom up by placing more decision-making authority in parents’ hands.