KEY POINTS
- Most Head Start programs operate within existing state child care licensing infrastructure.
- About 74 percent of Head Start's 17,000 service locations reported having a state license to operate.
- Early Head Start-Child Care Partnership Programs provide Head Start services in child care centers or family child care homes that are state-licensed, representing about 17 percent of Early Head Start funded enrollment.
- In Fiscal Year 2024 (FY24), states reported approximately 232,054 licensed providers across child care centers and family child care homes.
- The estimated number of unlicensed Head Start service locations is about two percent of the licensed child care provider universe.
- State child care licensing agencies maintain the core administrative systems and functions required to license new providers.
- Head Start Collaboration Offices (HSCOs) support coordination between Head Start entities and state entities and are well-positioned to help Head Start grant recipients navigate state child care licensing and other requirements.
- Further alignment of Head Start within state licensing systems would build on rather than duplicate or create new child care licensing infrastructure.
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BACKGROUND
States play a central coordinating role in an early childhood mixed-delivery system that includes Head Start, child care programs, and state pre-K programs. Licensing is one important aspect of accountability across this system. Child care and early childhood education licensing regulations are set by state and territory governments and identify minimum standards that programs must meet to be licensed to operate. Many Head Start programs operate within existing state licensing infrastructure.
Some programs can be exempt from state licensing (license-exempt), meaning they can legally operate without a license. Examples can include center-based programs already regulated by a different government agency (such as programs operated by public schools or military child care programs), faith-based programs, or certain home-based programs. States and territories may still require license-exempt programs to meet certain health and safety standards.
MOST HEAD START FACILITIES ARE ALREADY SUBJECT TO STATE LICENSING
According to the most recent Administration for Children and Families (ACF) administrative data, there are approximately 17,000 Head Start service locations nationwide. These include primarily center-based Head Start Preschool, Early Head Start (EHS), American Indian and Alaska Native (AIAN), and Migrant and Seasonal Head Start (MSHS) service locations, along with a small subset of non-center-based locations such as family child care providers and group socialization sites.
Of these service locations, about 74 percent (around 12,700 locations) reported having a state license to operate (Figure 1). The remaining 26 percent of unlicensed service locations (around 4,500 locations) were reported as exempt from licensing (18 percent) or not licensed for another reason (8 percent).
Many Head Start programs also receive child care subsidies, including through the Child Care and Development Fund (CCDF), that subject them to state licensing requirements. A preliminary internal ACF analysis of nationally representative data found that 36 percent of Head Start programs received child care subsidies.
State licensing systems also interact with a substantial network of providers through the Early Head Start-Child Care Partnership (EHS-CCP) program, in which EHS grant recipients partner with child care programs to provide high-quality child care services to infants, toddlers, and their families in state-licensed child care centers or family child care homes. In December 2017, ACF reported EHS-CCP partnerships involving approximately 1,600 child care centers and 1,070 family child care homes. Since FY16, EHS-CCP has supported about 32,000 slots annually, equivalent to roughly 17 percent of funded EHS slots.
STATES ALREADY LICENSE LARGE NUMBERS OF PROGRAMS, SO RELEVANT ADMINISTRATIVE STRUCTURES AND FUNCTIONS ARE ALREADY IN PLACE
States are responsible for licensing a substantial number of child care programs. In the FY24 Quality Progress Report (QPR), states reported approximately 232,054 licensed providers. About 52 percent of all licensed providers are child care centers and 48 percent are family child care providers.
In the context of the state child care licensing universe, the estimated number of Head Start service locations that are currently unlicensed (about 4,500) makes up about two percent of the existing licensed child care provider universe.
Licensing a small percentage of additional facilities is not likely to be burdensome for states. State licensing systems routinely accommodate changes in the number of regulated providers: between FY23 and FY24, the total number of licensed providers reported on the QPR increased by about one percent (licensed child care centers increased by 0.2 percent and licensed family child care homes increased by 1.7 percent). These year-to-year changes in licensed child care supply are about half of the estimated number of Head Start facilities that are currently unlicensed.
State child care licensing agencies already maintain the core administrative systems and functions required to license new providers, including receiving and reviewing licensing applications, evaluating compliance with health and safety standards, conducting inspections and monitoring, maintaining provider records, and overseeing child care providers on an ongoing basis. States typically charge fees to cover costs associated with these functions, often structured as initial application fees and recurring renewal fees.
EXISTING HEAD START INFRASTRUCTURE SUPPORTS STATE-LEVEL COLLABORATION
Section 642B of the Head Start Act requires collaboration between Head Start and state early care and education systems. Since the 1990s, Head Start Collaboration Office (HSCO) grants have supported coordination between Head Start entities and state entities that provide services to low-income children and families, including the state agency responsible for administering the Child Care and Development Block Grant (CCDBG) and entities providing child care resources and referral in the states. The Head Start Act specifically authorizes HSCOs to facilitate coordination to promote better linkages between Head Start agencies and other child and family agencies, including agencies that provide health, mental health, family services, disability services, and other child or family supportive services.
According to the FY23 HSCO Annual Performance Reports, about half of HSCOs are housed in the state education, early learning, or early childhood agency, and about 20 percent are housed in the state health, human, and/or social services agency. HSCOs are therefore an established infrastructure that can facilitate communication between Head Start programs and state child care licensing agencies, identify and resolve implementation issues, and support alignment across systems.
CONCLUSION
The majority of Head Start service locations nationwide are already licensed by states, and states already license and oversee a large universe of child care providers. Head Start grant recipients and states can build on their experience meeting state license requirements through the EHS-CCP program, and HSCO offices provide infrastructure that supports coordination between Head Start grant recipients and state early care and education systems. Further alignment of Head Start within state licensing systems would build on rather than duplicate or create new child care licensing infrastructure.
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