NCA Response – Reducing Federal Burden for Head Start Programs

NCA Comment on Reducing Federal Burden for Head Start Programs

Administrative Cost Cap Reduction Threatens Nutrition Quality and Access

One of NCA’s primary concerns is the proposed reduction of the allowable administrative cost cap from 15% to 5%. According to NCA, administrative funding supports essential functions including meal counting and reimbursement management, procurement, menu planning, food safety compliance, staff training, monitoring, and audit preparation. These activities are critical to successfully operating nutrition programs and maintaining compliance with federal requirements.

To better understand the potential impact, NCA surveyed more than 500 Head Start and Early Head Start programs. Survey results showed that a reduction in the administrative cost cap would have a negative impact on nutrition services:

• 60% reported that a reduction in the administrative cost cap would negatively affect the staff time dedicated to CACFP nutrition services.
• 30% indicated they would likely eliminate positions that support nutrition programs, including administrative staff, financial personnel, and nutrition consultants.
• 43% said it would reduce the variety of foods served.
• 32% said it would reduce the freshness of foods offered to children.

NCA cautioned that reducing administrative capacity could ultimately weaken nutrition oversight, limit menu variety, increase reliance on lower-cost processed foods, and make it more difficult for programs to accommodate special dietary needs.

Reduced Hours of Service and Increased Staff-to-Child Ratios Could Affect Children’s Access to Meals

NCA also expressed concern about proposed changes that could reduce service hours and eliminate staff-to-child ratio requirements. NCA noted that shorter hours could mean fewer meals and snacks for children who rely on Head Start programs for a substantial portion of their daily nutrition.

Similarly, reduced staffing levels could make it more difficult for programs to support children during meals, manage dietary accommodations, monitor food allergies, and foster positive mealtime experiences that encourage healthy eating habits.

Preserve Nutrition Best Practices in Teaching and Learning Environments

NCA supported the continuation of the requirement that Head Start programs participate in USDA Child Nutrition Programs and follow CACFP meal patterns. NCA also supported the continued use of qualified nutrition professionals and consultants to guide nutrition services.

Additionally, NCA urged the agency to preserve longstanding best practices that support healthy feeding environments, including adequate time for children to eat and protections against forcing children to finish foods they do not want to eat. NCA also opposed removing requirements related to accommodating children with special dietary needs and disabilities

Expanded Expectations Are Being Proposed with Little Consideration of Staffing Requirements

The proposed rule encourages programs to serve more nutrient-dense, whole foods and continue practices such as family-style dining and enhanced developmental experiences during mealtimes. NCA strongly supports these goals but emphasized that implementing them requires significant planning, food preparation, training, and administrative oversight.

NCA’s survey found that more than 74% of programs reported CACFP reimbursement alone does not fully cover their nutrition program expenses, including food and labor costs. Many programs rely on Head Start funding to fill that gap. As a result, reducing administrative resources while increasing program expectations may make it more difficult for providers to deliver the high-quality nutrition services the proposed rule seeks to encourage.

NCA’s Recommendations

NCA urges ACF to:

• Maintain the current 15% administrative cost cap allocation;
• Recognize the staffing resources necessary to support high-quality nutrition services;
• Retain provision that supports positive mealtime practices;
• Preserve and strengthen support for family style meal service;
• Provide clarity regarding expectations for nutrient-dense, whole foods;
• Evaluate how changes to service-hour requirements may affect children's access to meals and snacks; and
• Consider the cumulative financial impact of further nutrition-related requirements, including anticipated CACFP meal pattern updates, increased expectations for scratch and semi-scratch cooking, staff training requirements, food procurement, and menu planning responsibilities.