JNCL-NCLIS Opposes HHS Notice to Mandate English Only in Head Start Classes

7 hours ago

6 min read

for immediate release

The Joint National Committee for Languages (JNCL) and the National Council for Languages and International Studies (NCLIS), writes in opposition to the Department of Health and Human Service’s (HHS) proposal (the Notice) to mandate English Only in Head Start classes in its proposed “Head Start Performance Standards”. We urge the Department not to move forward with implementing this new requirement and, instead, retain Head Start’s current regulations that require bilingual programs that allow dual language students to learn in English and their heritage languages. The proposed change to English-only in Head Start overturns well-founded dual language Head Start program requirements; ignores studies that demonstrate increased academic performance by dual language learners, including in learning English; does little to further efforts to meet the multilingual workforce needs of American business; and undermines parental efforts to sustain and build upon heritage languages spoken at home. Our full comments are below and can also be viewed online at regulations.gov.

JNCL-NCLIS Comments on Proposed Changes to Head Start Regulations

The proposal to limit Head Start programs, with the exception of Tribal programs, to English-only instruction marks a significant reversal from HHS’s previous regulations. Just two years ago, the Department promulgated Head Start Program Performance Standards that explicitly required programs serving dual language students to “recognize bilingualism and biliteracy as strengths and implement research-based teaching practices that support their development.” Amongst other things, the 2024 Head Start performance standards sought to foster the development of both home language and English language acquisition and required “having culturally and linguistically appropriate materials available and other evidence-based strategies” available for dual language learners when the program lacked staff who could speak the student’s home languages. These same standards called for involving parents in promoting their children’s development of home language and English skills and required assessments to measure progress. Essentially, the current rules see no problem with simultaneously learning English and maintaining home language skills.

The 2024 Head Start Program Performance Measures strong support for dual language instruction was grounded in decades of research that demonstrate the benefits of dual language instruction. According to a 2022 study by the National Committee for Effective Literacy, titled “Early Literacy Development and Instruction for Dual Language Learners in Early Childhood Education”:

“Unfortunately, misconceptions about bilingualism and acquiring English as a new language abound. The most prevalent of these is that young children “pick up” a new language very quickly, that more English is better, and that bilingualism confuses children leading them to develop weak skills in both their languages (Soltero, 2011). Research findings over the past six decades refute these ‘myths’ by demonstrating the cognitive, academic, socio-emotional, and economic benefits of bilingualism and biliteracy and of developing children’s home languages as an effective bridge to the new language (Callahan & Gándara, 2014; Grosjean, 2021; Lindholm-Leary, 2016; Krizman, Shook, Skoe, & Kraus, 2012). Neuroscientists and psycholinguists point to the positive effects of learning two languages during the infant-toddler years and also to the human brain’s overall capacity to learn multiple languages. In addition, young children learning two languages have more neural activity in the parts of the brain associated with language processing than monolingual children (Bialystok, 2011; Bialystok, Craik, & Luk, 2012).”

In addition, a 2021 report from the University of Chicago Consortium, titled English Learners in Chicago Public Schools, found that “ELs who received language supports through their schools’ Bilingual Education Services had higher attendance and academic outcomes in the long run than students who refused bilingual services in kindergarten.”

Unfortunately, this Notice traffics in the very same misconceptions about dual language instruction identified above and actually uses them as a rationale for the Department’s proposed change to English-only courses. Offering no evidence to counter research on the value of dual language instruction, the Notice justifies its proposed change by saying: “Non-quantifiable benefits of this proposed policy may include increases in children’s English language acquisition, particularly for children who are non-native speakers of English, which may facilitate enhanced participation in English-language classrooms in kindergarten and beyond.” In JNCL-NCLIS’s view, this very slender rationale for a massive change is unsupported by research and practice.

The Department’s proposed move away from supporting dual language instruction also ignores the nation’s long term economic needs. While pre-K students will not be entering the workforce for many years, early language education will serve them and American business well as multilingual and cultural skills are much in demand. A 2019 report from the American Council on the Teaching of Foreign Languages, entitled “Making Language Our Business,” found that:

● 9 out of 10 US employers rely on employees with world language skills.

● 1 in 3 foreign language-dependent employers reports a language skills gap.

● 1 in 4 employers lost business due to a lack of foreign language skill.

The Notice completely ignores the value to the economy of speaking more than just English; instead it focuses only on the value of learning English, declaring that“learning English opens doors economically for families and helps individuals better engage with their communities.”

Finally, we must note that this change to English-only will, as the Department’s own notice points out, impact roughly one-third of all Head Start students and, most particularly, programs “serving predominantly non-English-speaking communities (e.g.,Migrant and Seasonal Head Start programs)” and the territory of Puerto Rico. The Notice goes on to state that the Administration of Children and Families, which operates Head Start at the Department, “recognizes that this requirement may result in additional costs or operational challenges for programs serving dual language learners or operating in predominantly non-English-speaking communities.”

Indeed, the Notice itself demonstrates just how jaw-droppingly expensive it will be to convert all Head Start programs to English-only. It estimates $47 million to “replace curriculum and instructional materials and books that contain non-English content”; between $26 million and $77.5 million for teacher training; and between $69 million and $208 million for potential employment disruption costs. Even at the low end, it will cost more than $140 million to convert to English-only Head Start classrooms; at the high end, the total costs are north of $300 million. It does not take into account the costs to families of throwing instruction in heritage language skills and culture completely onto their shoulders.

The one sliver of hope on this English-only proposal is that it might allow programs to seek waivers from some or all of these requirements from the HHS Secretary. The Notice specifically seeks comments on the waiver process for English-only requirements but provides no suggestions on what would constitute sufficient grounds for granting a full or partial waiver in this context. JNCL would suggest here that programs that matriculate 50% or more English Learner students be exempt from all English-only requirements. This would ensure that programs in Spanish-speaking Puerto Rico would be spared. We would also suggest that programs experiencing teacher shortages or that can demonstrate inadequate available funds to pay the conversion costs, which would constitute an undue burden on their resources, should be eligible for full or partial waivers.

In conclusion, JNCL-NCLIS believes that the Department’s proposal to require that all Head Start programs be English-only moves in the wrong direction. It fails to follow decades of conclusive research on the value of dual language learning, neglects business needs, and ignores family interests in preserving heritage language and culture. We urge the Department to reverse course and maintain and bolster the current regulations, which value dual language learners and allow English and heritage language skills both to flourish.