ADA opposes proposed removal of Head Start oral health standards

Association urges administration to retain toothbrushing, oral health and access-to-care requirements

The ADA is urging the federal government to retain Head Start requirements related to oral health, including supervised toothbrushing with fluoride toothpaste and provisions designed to help children access dental care. In comments to the Administration for Children and Families, the ADA opposed proposed changes to the Head Start Program Performance Standards that would remove requirements related to child health status and care and oral health practices.

“The ADA understands the need to reduce administrative burden in public programs, but we strongly oppose the proposed changes to the Head Start Program Performance Standards,” the Association wrote.

The comments were submitted in response to the 2026 proposed performance standards, Reducing Federal Burden for Head Start Programs. According to the letter, the proposed changes would remove standards related to facilitating access to care, providing oral hygiene instruction and supervising daily toothbrushing with fluoride toothpaste.

The ADA urged the administration to withdraw those proposed changes and retain evidence-based oral health and access provisions.

According to the letter, existing Head Start standards require children to brush their teeth with fluoride toothpaste at least once during the program day. The ADA said the requirement helps children establish consistent oral hygiene routines while providing a measure to prevent dental caries.

“Fluoride toothpaste is a cornerstone of childhood caries prevention,” the ADA wrote, noting that professional organizations recommend brushing with fluoride toothpaste beginning with the eruption of the first tooth.

The Association also cited research indicating that establishing toothbrushing habits early in life can reduce the risk of early childhood caries. Beyond the preventive effects of brushing and fluoride, the ADA said supervised toothbrushing can help children develop oral health habits and provide opportunities to reinforce oral health education with families and caregivers.

“Eliminating oral hygiene instruction and supervised toothbrushing requirements would move federal policy in the opposite direction of established science and public health practice,” the ADA wrote.

The letter also raised concerns about removing Head Start requirements to facilitate access to health care.

According to the ADA, Head Start programs serve children who may face barriers to dental care. The Association cited ADA Health Policy Institute data showing that 49% of children with Medicaid or Children’s Health Insurance Program coverage accessed dental care, compared with 67% of children with commercial insurance.

The ADA also cited its analysis finding that only seven states meet network adequacy standards for dental services within Medicaid. According to the letter, established partnerships between Head Start programs and dental clinics help families access oral health care when few options exist.

The Association said eliminating the standards could make it more difficult for families to access dental services and could increase preventable dental disease and treatment needs.

“The ADA respectfully urges the Department to maintain the existing Head Start oral health performance standard, including oral hygiene instruction, supervised daily brushing with fluoride toothpaste, along with referral services under the child health status and care performance standard,” the Association concluded.