The Head Start hiring process: policy council approval and personnel policies

Every Head Start agency has to have a policy council, and its membership is drawn from parents: parents of currently enrolled children must be proportionately represented, and program staff may not serve on it — the exception the rule names is parents who occasionally substitute as staff (45 CFR 1301.3(a)-(b)).

Delegate agencies run a parallel structure: the composition, term and personnel-policy approval rules each name the policy committee at the delegate level alongside the policy council.

The approval authority itself is statutory.

Under Section 642(c) of the Head Start Act, the Policy Council must approve and submit to the governing body program personnel policies and decisions regarding the employment of program staff.

A hiring decision, on that wording, carries two steps: the Policy Council approves it, and the decision is submitted to the governing body.

Members serve one-year terms and must stand for re-election to serve again, and a council's bylaws may allow no more than five one-year terms (45 CFR 1301.3(d)).

Turnover is the practical consequence for your hiring file: the parents who approved a hire this spring will not necessarily be on the council when the file is looked at again, so keep the approval record with the employee's file.

Parents can also be part of the funnel earlier than the approval vote.

Parent committees participate in the recruitment and screening of Head Start employees, within guidelines set by the governing body and the policy council (45 CFR 1301.4(b)(3)) — which is a reason to write those guidelines down before a vacancy opens, so the screening help arrives inside a framework rather than ad hoc.

No — the federal rule is a consideration requirement, not a hiring quota.

Under 45 CFR 1302.90(b)(6), a program must consider current and former program parents for employment vacancies for which such parents apply and are qualified.

The qualifier does the work: a current or former parent who applies and meets the qualifications for the vacancy is considered alongside the rest of the pool.

The consideration rule keeps its own conditions in place — a parent is considered for vacancies they apply for and are qualified for — and the background-check requirements at 45 CFR 1302.90(b) apply to every hire, parent or not, as the timeline below covers.

The pipeline behind the rule is real, though.

In 2023-24, Head Start programs employed and contracted with 251,000 staff, and parents of current or former Head Start children made up 24% of staff.

That share makes current and former parents a candidate pool Head Start programs already hire from.

Written personnel policies are a requirement, not an option. 45 CFR 1302.90(a) requires a program to establish written personnel policies and procedures approved by the governing body and the policy council (or the policy committee at the delegate level), and to make them available to all staff.

The Act adds a second, narrower track for leadership: the governing body approves personnel policies covering the hiring, evaluation, compensation and termination of the Executive Director, Head Start Director, HR Director, Chief Fiscal Officer and equivalent positions.

Both approval tracks exist — the Policy Council approves program personnel policies and employment decisions and submits them to the governing body, and the governing body holds the approval authority over the policies covering those top positions.

How a particular program sequences them is governance the program documents in its own policies; confirm the structure with the Office of Head Start.

Timing matters: the policies have to exist and be approved before they can govern a hire, so a grantee standing up a program — or revising its governance — writes them before the first vacancy is posted and keeps the approved version available to staff.

Compensation is one of the subjects those policies cover, and Head Start's pay rules have a pending change of their own: a May 12, 2026 proposed rule would remove the wage and benefit requirements at 45 CFR 1302.90(e) and (f), and as of October 2026 it remains a proposal — our Head Start wage requirements guide covers that rulemaking.

When the vacancy is the director's chair itself, the qualifications behind the role are their own subject — see our guide to hiring a Head Start director.

The federal timeline has three checkpoints:

• Before day one. Before a person is hired — directly or through contract, including transportation staff and contractors — the program must conduct an interview, verify references, run a sex offender registry check, and obtain either a state or tribal fingerprint criminal history check or an FBI check (45 CFR 1302.90(b)).
• Within 90 days of hire. The remaining fingerprint check and the child abuse and neglect state registry check, where a registry is available to query, are completed in the 90 days after an employee is hired. A new hire may not have unsupervised access to children until the full background check process is complete, so the first weeks' schedule is built around supervised coverage.
• Every five years. The complete background check is repeated for each employee, consultant or contractor at least once every five years.

Those checkpoints are the checks layer of the Head Start staffing rules.

What each check involves and how contractors are pulled in is its own topic, which we walk through in the guide to Head Start background checks.

The governance steps sit in front of the timeline: recruitment and screening, where parent committees can participate within the guidelines set, then the Policy Council's approval of the employment decision and the submission to the governing body.

One caveat belongs here. On August 7, 2026, ACF published a proposed rule that would rescind and replace the Head Start Program Performance Standards, and the proposal would drop the standards' own background-check procedures, on the reasoning that statutory requirements and state CCDBG-aligned background checks would still apply.

The comment period closed October 6, 2026, and the current standards remain the rules a grantee hires under as of October 2026.

Follow the rulemaking and confirm the current requirements with the Office of Head Start before you rebuild your hiring checklist around either version.

This page is employer information, not licensing or legal advice. Head Start hiring requirements come from the Head Start Act and the Head Start Program Performance Standards, administered by the Office of Head Start — confirm the current requirements with the Office of Head Start before you make hiring decisions, and check any state child care licensing rules that apply to your program with your state child care licensing agency.