Deregulation has been one of the hottest topics in ECE this year, most recently in conversations about the future of Head Start, but also throughout the country as states desperately try to address their own child care shortages. The idea is appealing: cut through the administrative red tape, remove the layers of bureaucracy, and let local communities and child care providers make their own decisions about how to run their programs. But does it work? Can students really make more progress and enter kindergarten more ready when providers are freed from the regulatory ball and chain that program standards seem to represent?  

Licensing Is the Floor

The debate about Head Start gives us a good opportunity to explore the two different layers of so-called red tape: licensing and quality standards. As the Children’s Equity Project stated in a recent report, “State licensing answers one question: What is the minimum set of standards required so children are not in danger? By contrast, Head Start asks: What conditions produce lifelong improvements for children’s development, health, learning, and family well-being?”

Licensing comes with plenty of baggage of its own: outdated, burdensome processes, scattered accountability, and the occasional conflict with common sense. One might reasonably debate about the most effective child-staff ratios, the appropriate separation of age groups, or which bathroom layouts make the most sense, but the intent behind the regulations is the same—can the state certify, based on all available evidence, that the child care facility and staff meet the minimum requirements necessary on paper to safely care for children?

Read: Child Care Licensing Doesn’t Have to Suck

One apt analogy from our March look at educator credentials and training is the Child Development Associate (CDA) credential. The CDA is an “agreement for what an entry-level early childhood educator needs to demonstrate to be able to do that job at a basic, foundational level.” It doesn’t mean someone is “good at” the job, it just means they have the requisite skills needed to do it. That's what licensing requirements are.

Why does this distinction matter so much? Because we have decades of research showing that it’s not enough for children to just attend child care or preschool—any potential gains in kindergarten readiness and long-term outcomes are entirely dependent on the quality of those environments. Head Start’s program standards are analogous to the highest levels of quality standards, not licensing standards. This is why the administration’s attempt to strip out the standards and default to state licensing requirements has been so controversial. 

Program Standards and QRIS

While Head Start’s Program Performance Standards (HSPPS) already set a high bar for quality, those new to the conversation might not realize that, for the past ten years, one of those standards has been a requirement for Head Start locations to participate in state or local Quality Rating and Improvement Systems (QRIS) when feasible. The NPRM would rescind that requirement. The administration points to “weak or inconsistent association between QRIS ratings and children’s developmental outcomes,” but does not make the crucial distinction between structural and process-based models. 

Today, nearly all (93%) QRIS programs accommodate Head Start participation. Of these, 40% recognize Head Start and Early Head Start standards through either reciprocity (states give credit for some or all of the QRIS standards when they can be reasonably mapped to program performance standards), or through alternative pathways to ratings. For example: 

• In Minnesota, eligible Head Start programs can receive an automatic four-star Parent Aware rating, the highest attainable level in the program.
• Illinois gives Head Start programs a floor of Silver in their ExceleRate Illinois rating system, one step down from the highest level of Gold. Head Start programs can move up to Gold with an additional on-site assessment.
• Ohio’s Step Up to Quality (SUTQ) offers Head Start programs an expedited path to ratings based on clear mapping of HSPPS to SUTQ award tiers.
• Arkansas’ Better Beginnings program automatically enrolls Head Start programs at a Level 4 (out of 6), with the option to rise based on CLASS assessment scores.

The HSPPS are not the only set of national standards to receive this treatment. Other common standards that show up in QRIS programs throughout the country include NAEYC (typically the default for centers), NECPA, NAC, Cognia Early Learning (successor to AdvancED), NAFCC (for Family Child Care), and a variety of philosophy-specific programs such as the American Montessori Society, the Association for Christian Schools International, and the Association of Waldorf Schools of North America. 

Listen to Episode 6 of the  Child Care Matters: Built to Break Podcast - How Do We Define Quality Child Care

This integration of QRIS with third-party standards is vital because of the amount of time and effort providers are putting into the processes and the overlap that would otherwise lead to duplicative application, assessment, monitoring, and renewal efforts. If a trusted organization is saying that a provider meets a certain standard, a state QRIS specialist shouldn’t have to double-check that work. This approach frees up resources in historically understaffed agencies and reduces the administrative burden on providers. 

Should the HSPPS or any other nationally recognized standards suddenly go away, it stands to reason that many of these programs will need to start over from the ground floor, resulting in both an uncomfortable period of inconsistencies in the way parents evaluate preschool programs for quality—which could itself lead to enrollment problems—and a larger workload for program administrators who don’t want to lose the ratings they’ve already earned.

Looking Ahead

Nationally recognized quality standards, including the HSPPS, are an important part of the quality landscape in early care and education today. Families can confidently enroll their children knowing that the learning environment they’re leaving them in has been rigorously vetted for the factors that have been proven by research to have a positive impact on student academic, social, and emotional success. 

Consistency is also an important part of the conversation. For example, while Head Start implementation quality varies, and not all Head Start classrooms are created equal, at least they’re all working from the same baseline. The HSPPS ensure that all Head Start locations share the same foundation, and even local differences are still just variants of the same set of baseline expectations. Without the standards, Head Start is just Buffalo Wild Wings—a franchise brand where the experience will be different for every child based on where they live. Achievement gaps will widen. Enrollment will plummet. 

Remember: state licensing standards are the floor. They aren’t remotely a stand-in for quality measurements. State QRIS programs could fill some of the gaps over time, but participation and fidelity will both be entirely dependent on the leadership and resources available at each individual location. It’s hard to imagine a world where removing standards does not result in a rapid and measurable drop in program quality.