Directed by Executive Order: Reconsideration of the Regulatory Costs of Head Start’s 2016 Final Rule

• The 2016 Head Start Program Performance Standards final regulation anticipated that improved quality would justify potential reductions in access. Executive Orders 13563 and 13610 direct agencies to measure actual regulatory results and periodically review existing significant regulations, modifying, streamlining, expanding, or repealing them in accordance with what has been learned.
• The tradeoffs posited in the 2016 final rule were not observed. That rule forecasted costs per slot to be a static $10 increase from 2015 costs, while in fact they rose by 49 percent through Fiscal Year 2024. In 2024 dollars, regular Head Start per slot costs were $15,752, relative to $10,575 as projected by the Regulatory Impact Analyses (RIA).
• The 2016 rule forecasted rising costs would lead to the loss of 123,614 Head Start slots by 2025. In fact, the number of slots fell by 277,658 over that time.
• The 2016 rule forecasted that quality measures, as measured by the Classroom Assessment Scoring System, would increase, when in fact, through Fiscal Year 2026, they hardly changed.

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