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Head Start Policy and Regulations

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Policy Clarifications for Family Child Care Staff Requirements

The Office of Head Start (OHS) acknowledges the challenges family child care staff members may face to meet qualification requirements. This resource outlines flexibilities that are responsive to these challenges so family child care can remain a viable and important program option for Head Start grant recipients.

For the family child care option, the Head Start Program Performance Standards (Performance Standards) — specifically 45 CFR §1302.23(b)(2–4) — no longer include the term “assistant provider.” The Performance Standards now require that all staff in a family child care setting who count toward ratios must meet the qualification requirements for a family child care provider as described in 45 CFR §1302.91(e)(4)(i). The compliance date for the changes to 1302.23(b)(2–4) is Aug. 1, 2025.

In other words, to meet this requirement, all staff counting toward ratio in a family child care program option would need to be enrolled in a family child care Child Development Associate® (CDA) program or state equivalent by Aug. 1, 2025, to be completed within 18 months, or be enrolled in another degree-granting program in child development or early childhood education.

Policy Intention

The intention of shifting away from the term “assistant provider” in the Performance Standards was to clarify the expectation that all staff who have primary responsibility for children in a family child care setting have the necessary training to ensure quality services to enrolled children.

The intention was not to disrupt services or discourage grant recipients from providing family child care services as part of their Head Start grant due to challenges staff might face in obtaining the required credentials. OHS recognizes the critical importance of the family child care program option in communities and wants to ensure that this remains a viable option for Head Start grant recipients. Ensuring family child care settings continue to be available aligns with OHS’ commitment to support family choice.

Flexibilities

The following flexibilities are intended to support grant recipients in implementing this policy requirement and continuing to provide quality Head Start services through family child care settings.

  • Timeline: The requirement that all staff in a family child care setting meet the family child care provider qualifications has a compliance date of Aug. 1, 2025. To meet the requirement by that date, staff only need to be in the process of achieving a family child care CDA or state equivalent with a plan to earn one of these credentials. Staff do not have to have obtained a CDA or state equivalent by Aug. 1, 2025. Family child care providers have 18 months after Aug. 1, 2025, to complete the credential.
  • Terminology: The Performance Standards require that, when there are two staff in a family child care home counting toward ratios, both meet the family child care provider qualification requirements outlined in §1302.91(e)(4)(i). However, both staff are not required to have the same functional titles or job descriptions. If job descriptions, licensing requirements, contractual requirements, or other factors require that the two staff members have different functional titles (such as “provider” and “assistant”), it would not conflict with the Performance Standards. The Performance Standards requirement is that both staff meet the minimum qualifications in §1302.91(e)(4)(i).
  • Monitoring: In the fiscal year 2026 monitoring cycle for program year 2025–2026, OHS will not assess the requirement that both providers (or staff members) in a family child care setting, if applicable based on group size, meet the qualifications specified in §1302.91(e)(4)(i). The requirement for at least one provider in each family child care setting to meet these qualifications remains in effect and may be included in the monitoring process.

Resources

  • Office of Head Start: If grant recipients are considering shifting away from the family child care program option because of this requirement, please reach out to OHS to discuss before taking any action, including putting together a formal change in scope application. You can reach out directly to your regional office or to OHS_policy@acf.hhs.gov.
  • Support for Staff Seeking a Child Development Associate or State Equivalent:
    • The Individualized Professional Development (iPD) Portfolio learning management system has free courses that align to the CDA subject areas. Successful completion of these courses can count toward the required 120 educational clock hours needed to earn or renew the national CDA credential. Check back often for iPD courses to help Head Start staff earn the core 80 educational clock hours for the family child care CDA.
    • Local agencies have flexibility in determining and justifying how their providers meet the CDA equivalency qualification requirement, and they are not required to get pre-approval from OHS. The national family child care CDA credential covers the growth and development of children ages birth to 5 years. A comparable credential may be issued by state, territory, and Tribal agencies, boards, and commissions, as well as accredited colleges and universities and other early childhood organizations that offer certificates and degree programs.
  • Support for Programs: The following resources are available to help programs work with staff to ensure they have the right qualifications or are on the path to acquire the right qualifications:

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,  Policy