For me, this is a dream assignment: review the proposed new Head Start Performance Standards! I love diving into regulations and analyzing how they may be interpreted and applied in real-world settings, and, equally, I love advocating for young children and their families, teachers, and caregivers.
We applaud the work of the Administration for Children and Families (ACF) and the Office of Head Start (OHS) in proposing the new program performance standards. And we appreciate the opportunity to submit comments and would love to hear from you about our thoughts, outlined below, on the Notice of Proposed Rulemaking (NPRM).
Below, I delve into Section 1302.91 Staff Qualification Requirements, and Section 1302.92, Training and Professional Development, as these are the most relevant to our passion at Teachstone.
Sec. 1302.91 Staff Qualification Requirements
Requirement that all center-based teachers demonstrate competency to provide effective and nurturing teacher-child interactions.
We applaud the specific reference here to teacher-child interactions and hope that the final rule will include this language for all staff, or, at a minimum, education staff, including home visitors, assistant teachers, and family child care providers.
Sec. 1302.92 Training and Professional Development
Requirement of a systematic approach to professional development with academic credit as applicable
We strive to support the field with a systemized approach to professional development instead of piecemeal approaches, and we applaud the use of this language in the NPRM. Likewise, as more pre-service teaching programs and offerings at institutes of higher education integrate the CLASS tool into coursework and practicum, we recognize the importance for academic credit where applicable.
Requirement of research-based approaches to professional development for teaching staff and home visitors focused on, among other important features of quality, providing effective and nurturing teacher-child interactions
We applaud the inclusion of research-based professional development, as it supports teachers in further developing scientifically proven effective practices leading to better child outcomes.
Research-based professional development is integral to our programs at Teachstone, such as the MyTeachingPartner (MTP) coaching program.
Requirement of a coordinated coaching strategy aligned with the program’s school readiness goals and curricula, as well as adequate coach training and experience to use assessment data in coaching.
This revision is critical and reflects documented evidence that coaches need and deserve adequate training, competencies, and ongoing support to engage in this important work for the field. We suggest “teachers” are added as a key person in the ongoing communication in any coaching program.
Requirement of an assessment to identify areas of needed support to achieve program performance goals and tailored approaches for staff who may need more or less support
We appreciate the language around intensive coaching for staff members who may need it the most. However, we strongly recommend that all education staff be given the opportunity for ongoing observation, feedback, and intensive coaching. We know that the feedback loop supports teacher improvement and teachers improving at all levels lead to gains in child outcomes.
Requirement of policies that ensure needs assessment results are not used to solely determine punitive actions for staff identified as needing support, without providing time and resources for staff to improve.
We strongly support the use of professional development needs assessments for providing resources (time, funding, materials, coaches, etc.) for improvement and not for punitive actions. Punitive approaches have not been documented to drive positive change in teacher behavior; conversely, a close and positive coaching relationship has been documented to best drive teacher improvement.
15 hours of training and professional development for all education staff, including home visitors
We are happy to see the inclusion of EHS and home visitor staff in this requirement.
At Teachstone, we support the field in implementing these requirements with services like myTeachstone, which includes many elements of the systematic approach to professional development: integration of observation, data assessment, feedback, individualized professional development and coaching support, and the facilitation of professional learning communities (similar to the “group coaching approach” articulated in the NPRM).
Sec. 1302.13 Recruitment of Children
We will actively support programs that actively locate, recruit, and provide high quality education to children with disabilities
Sec. 1302.14 Selection Process
Requires Head Start programs that operate in a service area with a high quality, publicly funded pre-K program to prioritize slots for younger children.
While we understand the need to prioritize services to 3-year-olds in communities that may have a high quality publicly funded pre-K program serving 4-year-olds, we are concerned about the lack of definition of high quality. We suggest OHS provide guidance around this, including consideration of the definition my colleague, Rebecca Berlin, wrote about in this blog with the inclusion of an eighth factor: comprehensive services.
Sec. 1302.17 Attendance, Suspension, and Expulsion
We commend the increased focus on minimizing suspension and prohibiting expulsion but also recognize the great need for programs to support teachers. We suggest including professional development around individualized strategies for children with challenging behaviors.
Sec. 1302.21 Center-Based Option
This section includes provisions for an increase in the days/year and hours/day for the center-based Head Start option. While we applaud ACF’s effort to increase the length of time of services for children and families, we also see a need for a provision that specifies how additional resources will allow for this and accommodate teachers’ needs for planning, training, and professional development. This requirement should be made commensurate with funding increases so we don’t compromise program reach and unintentionally force programs to serve fewer children and families.
Sec. 1302.31 Teaching and the Learning Environment
We strongly support this section, specifically the explicit recognition of nurturing and responsive interactions as a component of effective teaching practice, use of the HSELOF aligning learning outcomes for children birth to age 5, and, lastly, the clear language recognizing bilingualism as a strength and aligning the research on dual language learners and home language support with practical application.
Sec. 1302.52 Family Partnerships
We support the continued focus provided in this section for family engagement and family partnerships. We hope to support programs in providing education to parents about the importance of effective interactions between children and all the adults in their lives, both at home and at school.
Sec. 1302.70 Transitions from Early Head Start and Sec. 1302.71 Transitions from Head Start to Kindergarten
The new regulations include a requirement that programs implement strategies to improve the coordination when children transition between Early Head Start and Head Start programs, as well as from Head Start to kindergarten. Teachstone encourages ACF to provide specific guidance around best teaching practices, including a focus on effective teacher-child interactions aligned across age levels, as one strategy to improve children’s seamless transition between programs and schools.
Editor's Note: You can find Teachstone's official comments here.
