This Information Memorandum (IM) is intended to support timely and consistent decision-making while preserving the availability of Head Start Preschool (HSP) and Early Head Start (EHS) enrollment slots. The Head Start Act allows programs to propose a reduction of their funded enrollment to maintain quality services (Section 640(g)(3)).

In recent years, the Office of Head Start (OHS) received a substantial increase in Change in Scope requests for enrollment reductions. The volume of submissions has contributed to prolonged review times. 

This IM establishes a clearer review process and identifies the information non-Tribal grant recipients should submit. OHS will use these standards to evaluate and approve or deny Change in Scope requests for enrollment reductions in a timely, consistent, and transparent manner. While grant recipients may submit Change in Scope requests for a variety of purposes this IM only addresses requests for enrollment reductions for non-Tribal grantees. This IM does not address conversion of HSP slots to EHS slots and encourages grantees to communicate with OHS for the most up to date guidance on submission guidelines for these requests.

Background

The Trump Administration is committed to ensuring that children and families have access to high-quality child care and early learning services. Consistent with congressional appropriations, the Administration supports maximizing the availability, effectiveness, and efficiency of Head Start agencies.

Actions taken during the previous administration contributed to the largest reduction in the number of HSP and EHS slots available to children and families in the history of the United States. This reduction occurred primarily through two mechanisms:

1. In 2024, the final rule titled Supporting the Head Start Workforce and Consistent Quality Programming (89 FR 67720) imposed mandatory compensation-related requirements. The rule was estimated to place more than 100,000 Head Start slots at risk nationally, including approximately 84,000 HSP slots and 22,000 EHS slots.
2. Change in Scope requests increased substantially from FY2022 to FY2024, with many requests proposing reductions in funded enrollment (Figure 1). ACF received 746 requests for reductions in enrollment in FY2024 as compared to just 39 in FY2021, an increase of over 1,800 percent. A recent Assistant Secretary for Planning and Evaluation (ASPE) report¹ found that these actions between FY2022 and FY2024 resulted in the elimination of more than 97,000 slots.

Together, these developments contributed to a reduction in access to Head Start services at a rate unprecedented in the program’s 61-year history (Figure 2).

Change in Scope requests can be necessary to protect program quality, financial stability, and long-term viability. However, requests that would reduce enrollment should be evaluated carefully to ensure that grant recipients continue to address demonstrated community needs and preserve access for eligible children and families.

This memorandum is intended to balance those objectives by establishing a consistent process for evaluating program viability, community need, service quality, and the effect of proposed changes on the availability of HSP and EHS slots.

Figure 1. Head Start Change in Scope Requests (2021-2026)

Figure 2. Head Start Funded Slots vs. Annual Operations Funding (FY 2016-2024)

Grant Recipient Application Review Pathway for Change in Scope Requests

To help ensure that Head Start agencies continue to meet community needs, ACF will use either an expedited or comprehensive review pathway for select Change in Scope requests. The two pathways are explained below and in Figure 3.

Proposed Enrollment Reductions

A request that pairs a reduction in funded enrollment with a proportional reduction in federal funding will receive expedited consideration with an intended timeline of no more than 30 days.

A request that proposes a reduction in funded enrollment without a proportional reduction in federal funding will undergo comprehensive review.

Documentation Requirements

All Change in Scope requests should be submitted, at a minimum, 90 days before planned implementation. The application is submitted via the Head Start Enterprise System (HSES) as an Amendment: change in scope. The application must include the following documents:

• SF-424
• SF-424A
• Governing board and Policy Council approvals
• Program narrative
• Budget narrative
• Proposed program schedule
• Supporting documents

All applications must address the key requirements in the Enrollment Reduction and Conversion Considerations Appendix.

Comprehensive Reviews

Grant recipients subject to comprehensive review should submit the following additional documentation addressing community need and community support.

1. Community Needs Assessment

A clear demonstration of community need is essential to the review of a Change in Scope request. The grant recipient should provide a concise explanation of why the proposed change is in the best interests of the community and how it is responsive to identified community needs.

The grant recipient should also include a cover sheet as the first page of its submission. The cover sheet should provide the following information:

• The number of current funded slots, the number of proposed funded slots following the Change in Scope request, and the resulting percentage change.
• The current budget, the proposed budget following the Change in Scope request, and the resulting percentage change.
• The current per-slot funding and the proposed per-slot funding (federal funding only) following the Change in Scope request and how this compares to the ASPE-reported state-specific medians.
• The estimated number of children in the community who are within the applicable age range and need care.
• The estimated number of children in the community who are eligible for Head Start services.
• The number of children on the program’s waiting list.
• An attestation that the proposed action will not create barriers for parents or children, including an inability to locate or obtain child care services.
• All other information as required by Sec. 645(a)(5)(A) of the Head Start Act.

The documentation should explain the data sources, assumptions, and methodology used to develop each estimate. Grant recipients should submit the most recent reliable data available.

2. Demonstration of Community Support

Evidence of community support is also essential to the comprehensive review process. Grant recipients should include letters or other written evidence demonstrating support for the proposed change from relevant community stakeholders.

Relevant stakeholders may include:

• The Governor.
• Members of Congress representing the affected service area.
• State, Tribal, or locally elected officials.
• The Head Start Collaboration Office Director.
• The State or Tribal Child Care and Development Fund (CCDF) administrator.
• Community organizations and service providers.
• Parents or caregivers who may be affected by the proposed change.

This list is illustrative and not exhaustive. OHS may consider other written statements or documentation that demonstrate community support or assist OHS in assessing the likely effects of the request.

Letters and other supporting materials should identify the stakeholder’s relationship to the affected community, indicate whether the stakeholder supports or opposes the proposed change, and explain the basis for that position. Letters should also include an acknowledgment of the percent change in slots, budget, and per-slot spending.

Figure 3. Review Pathway for Proposed Reductions in Funded Enrollment

OHS Review and Determination

OHS may request additional information when a submission is incomplete or when additional documentation is necessary to evaluate the effects of the proposed change. In reviewing a request, OHS may consider:

• The completeness and reliability of the information submitted.
• The extent to which the proposal addresses demonstrated community needs.
• The effect of the proposal on eligible children and families.
• The availability of alternative child care and early learning services.
• The grant recipient’s financial and operational viability.
• The level of community support for the proposed change.
• The grant recipient’s compliance and performance history.
• Any other information relevant to protecting access to HSP and EHS services and ensuring responsible stewardship of federal funds.

An expedited review does not guarantee approval. All Change in Scope requests remain subject to applicable statutory, regulatory, programmatic, and grants-management requirements.

OHS will provide the grant recipient with written notice of its determination.

Thank you for the work you do on behalf of children and families.

Sincerely,

/Lizbeth Casco White /

Lizbeth Casco White
Director
Office of Head Start