In July, the U.S. Department of Health and Human Services issued a notice to reclassify thirteen new programs – including Head Start – as a “federal public benefit” under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). This change will prevent access to essential services supporting families with young children, including Head Start services for some immigrant children and families. ECIC has submitted a public comment on FR Doc #2025-13118 to the U.S. Department of Health and Human Services opposing the change. The comment text is included below and can be found as an official submission here.
Re: Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA);
Interpretation of “Federal Public Benefit,” RIN: 0991-ZA57
Dear Secretary Kennedy:
The Early Childhood Investment Corporation (ECIC) is Michigan’s only statewide organization committed to ensuring that all children are healthy, thriving, and developmentally on track from birth through age five. We work closely with families, early childhood education and care providers, public sector leaders, and community partners across the state to promote high-quality early learning and child development. Head Start and Early Head Start are essential partners in this mission.
ECIC appreciates the opportunity to comment on the U.S. Department of Health and Human Services (HHS) notice entitled “Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA); Interpretation of ‘Federal Public Benefit” [Docket No: AHRQ-2025-0002]. We urge HHS to immediately withdraw this proposed reinterpretation, which would have a harmful effect on immigrant families’ access to Head Start programs, jeopardizing the health, well-being, and school readiness of thousands of young children in Michigan supported by Head Start each year.
This proposed change to reclassify Head Start as a “federal public benefit,” runs counter to nearly 30 years of precedent and is in violation of the Head Start Act of 1965. Head Start has never in its 60-year history conditioned eligibility on citizenship or immigration status, and this notice would create a chilling effect that will deter families from participating in Head Start with many unintended consequences, endangering the stability of Michigan’s mixed-delivery early care and education system.
The impacts on Michigan families would be profound and far-reaching:
- Decline in program enrollment: Immigrant families, even those with children who are U.S. citizens, would be discouraged from enrolling in Head Start due to fear, confusion, and stigma. This would reduce participation in a program that has proven long-term benefits in education, health, and family stability.
- Increased administrative burden and operational challenges: The proposed reinterpretation imposes unnecessary barriers on Head Start grantees, adding layers of additional documentation and verification that interfere with outreach, enrollment, and service delivery. Many families in Michigan, particularly those who are unhoused, in the foster care system, or living in rural areas, already face challenges obtaining identification documents. This change would compound those barriers, including for U.S. born parents and children.
- Conflict with Head Start’s legal mandate: The Head Start Act prioritizes serving children from families with low incomes, those experiencing homelessness, and children in foster care, criteria that are race-, status-, and immigration-neutral by law.
- Long-term harm to Michigan’s children and communities: Children’s early experiences shape lifelong outcomes in learning, health, and economic mobility. Excluding children from early learning programs such as Head Start risks generational harm. In Michigan, immigrant children represent a growing share of our population. The overwhelming majority are U.S. citizens whose development, safety, and future success are directly tied to our shared prosperity.
- This notice threatens to shift the cost of critical early childhood services to already overburdened state and local systems. It arrives on the heels of other benefit cuts, such as food and health care, further eroding the safety net for children. This is not in the best interest of Michigan or our nation.
Head Start is not only a school readiness program. It is a whole-child, whole-family approach that connects families to health care, developmental screenings, mental health support, nutrition, and stability. It is often a child’s first trusted connection to the broader system of care. Denying or delaying access for any population undermines the very purpose of this investment.
In closing, ECIC stands with a broad coalition of early childhood advocates in strongly opposing this proposed reinterpretation. We urge HHS to withdraw the notice and uphold long-standing guidance that preserves access to Head Start programs. Michigan’s future depends on the well-being and development of all our youngest residents, and we cannot afford to create policies that exclude or marginalize them.
Sincerely,
Alicia S. Guevara, Chief Executive Officer
Early Childhood Investment Corporation (ECIC)