Head Start staffing rules for grantees: qualifications, ratios, checks and wages

Head Start personnel policies are governance documents, not just HR paperwork.

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

The governing body has its own list.

It approves the personnel policies covering hiring, evaluation, compensation and termination for the Executive Director, the Head Start Director, the HR Director, the Chief Fiscal Officer and equivalent positions.

In practice, that makes your employee handbook, pay scale and hiring and termination procedures something the Policy Council acts on before you post a job or change a wage — and, for the policies covering the Executive Director, Head Start Director, HR Director, Chief Fiscal Officer and equivalent roles, the governing body too.

Write the approval step into the process itself, so a policy change never reaches staff before the governance trail behind it is complete.

The standards add one duty your policies must carry: programs must ensure staff report suspected or known child abuse and neglect as defined by CAPTA and by federal, state, local and tribal law.

Your personnel policies are where that obligation becomes procedure — who makes the report, and how — and the annual training on mandatory reporting (below) is where staff learn it.

Confirm before you write policy: the Office of Head Start administers the Performance Standards, and the Policy Council requirement sits in the Head Start Act itself.

Where your grantee's bylaws or your state's rules add requirements on top, confirm the current text with the Office of Head Start at headstart.gov before you publish a policy.

The qualification rules at 45 CFR 1302.91 set a floor by role, and the floors differ by position:

• Head Start directors hired after November 7, 2016 need at least a bachelor's degree and experience in staff supervision, fiscal management and administration.
• Fiscal officers hired after that date need to be a CPA or hold at least a bachelor's degree in accounting, business, fiscal management or a related field. Family, health and disabilities managers need at least a bachelor's.
• Education managers and coordinators, including curriculum specialists, need a bachelor's or advanced degree in early childhood education — or a bachelor's or advanced degree plus equivalent ECE coursework and early education teaching experience.
• Head Start Preschool center-based teachers need at least an associate or bachelor's degree in child development or early childhood education, or equivalent coursework — and at least 50% of Head Start Preschool teachers nationwide must hold a bachelor's.
• Preschool assistant teachers need, at minimum, a CDA — the Child Development Associate credential awarded by the Council for Professional Recognition — or a state certificate that meets or exceeds it, or enrollment in an associate or bachelor's program, or enrollment in a CDA program they will finish within two years of hire.
• Early Head Start center-based teachers need at least a CDA or comparable credential, plus training or coursework in infant-toddler development.
• Head Start family child care providers must be enrolled in a Family Child Care CDA program (or a state equivalent) or an ECE degree program before serving, and earn the credential within 18 months. Home visitors need at least a home-based CDA or comparable credential.
• Coaches need at least a bachelor's degree in early childhood education or a related field.

One caveat over the whole list: it is the current rule, and it is under proposal.

ACF's August 7, 2026 NPRM to rescind and replace the Performance Standards would keep only the qualifications the Head Start Act itself requires — education managers, mentor teachers, preschool teachers and assistants, and Early Head Start teachers — and drop the regulatory ones for directors, family child care providers, coaches, family services staff and health professionals.

Its comment period closes October 6, 2026, so it is not final and the requirements above still govern; check the rulemaking's status before you build a multi-year credential plan on any single line of it.

For the classroom roles in detail — the degree, CDA and enrollment pathways the rule accepts for teachers and assistants — see our Head Start teacher quals breakdown.

The hiring gate at 45 CFR 1302.90(b) starts before the offer.

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 one.

The remaining steps run after the start date, on a 90-day clock.

The program has 90 days after hire to obtain the remaining fingerprint check and the child abuse and neglect state registry check, where one is available.

Until the full process is complete, the new hire may not have unsupervised access to children — so build supervised coverage into the schedule before the first day, not after a component comes back.

Clearance is not one-and-done.

Each employee, consultant and contractor needs a complete background check at least once every five years, which makes the recheck date a line in your staff file from the day someone starts.

Watch the rulemaking: the August 7, 2026 proposal would drop the Performance Standards' own background-check procedures, including the five-year recheck, on the reasoning that statutory requirements and state CCDBG-aligned background checks would still apply.

It is a proposal — the rules above are current law as of October 2026 — so confirm the structure you are hiring against with the Office of Head Start before you redesign the file.

Two training rules run in parallel.

The first is per person: Head Start requires all staff to complete at least 15 clock hours of professional development per year, plus annual training on mandatory child abuse reporting and on positive strategies for social-emotional development.

The 15 clock hours do not rest on the regulation alone — the Head Start Act itself requires each Head Start teacher to attend at least 15 clock hours of professional development per year, which is why the Act's requirement is expected to survive a proposal that would rescind and replace the regulation it sits in.

The second rule is program-wide: 45 CFR 1302.92 requires a research-based, coordinated coaching strategy.

The program assesses all education staff, offers intensive coaching — observation, feedback and modeling — to those identified for it, and uses a coach with adequate training in adult learning and data use.

That makes coaching a staffing decision as much as a development one: someone on your roster, or under contract, has to be qualified to deliver it.

One scheduling note from wage law: under the FLSA, required training is generally paid work time.

The unpaid-training carve-out only applies when the time is outside regular hours, truly voluntary, not directly job-related and free of productive work.

Confirm wage-hour questions with the Department of Labor or employment counsel.

The newest part of the subpart is also the part ACF has proposed to remove.

A 2024 rule — still in the CFR as of October 2026 — requires programs to pay each Head Start teacher a salary at least comparable to public-school preschool teachers in the local district, adjusted for responsibilities, qualifications, experience and hours, by August 1, 2031.

The same rule adds benefits: by August 1, 2028, full-time Head Start staff working 30 or more hours a week must have health care access, paid leave and short-term behavioral health services.

Agencies with 200 or fewer funded slots are exempt from the specific wage and benefit rules.

Both deadlines are in motion.

On May 12, 2026, ACF proposed removing the wage and benefit requirements entirely; the comment period closed June 11, 2026, and no final rule had been published as of October 5, 2026.

A broader proposal, also from ACF, would rescind and replace the entire Performance Standards — that one was published on August 7, 2026, with comments closing October 6, 2026.

Until a final rule changes the text, the requirements above are current law, and neither proposal is settled — the wage rule has not been repealed and the qualification rules have not been narrowed.

Confirm where the rulemaking stands with the Office of Head Start before you commit to a multi-year pay scale, and check with employment counsel or the Department of Labor on how the Head Start rules interact with your FLSA obligations.

This page is employer information, not licensing or legal advice. Head Start staffing rules changed in 2024 and are being rewritten in 2026 — confirm the current requirements with the Office of Head Start at headstart.gov before you set policy, hire or change pay, and check the state rules that also apply to your classrooms with your state child care licensing agency.