Assuring that Head Start Programs Provide High Quality Services

ACYF Administration on Children, Youth and Families	U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Administration for Children and Families
	1. Log No. ACYF-IM-HS-95-15	2. Issuance Date: 03/23/95
	3. Originating Office: Head Start Bureau
	4. Key Word: Assuring Program Quality

INFORMATION MEMORANDUM

TO: Head Start Grantees and Delegate Agencies

SUBJECT: Assuring that Head Start Programs Provide High Quality Services

SUMMARY:

In the recently revised Head Start Act, the Congress included a new section, 641A, titled, "Quality Standards; Monitoring of Head Start Agencies and Programs", the relevant portions of which are attached. This section contains new procedures that must be followed to correct any quality deficiencies which are identified in Head Start programs. This Information Memorandum explains these new procedures and discusses how they will affect grantees.

BACKGROUND: Head Start's success over the past 30 years has been due to the high quality and comprehensive services that local programs provide to the children and families of their communities, often in spite of difficult obstacles. This was recognized in the December 1993 Report on the Advisory Committee on Head Start Quality and Expansion; Creating a 21st Century Head Start , which stated as its first broad principle that:

We must ensure that every Head Start program can deliver on Head Start's vision, by striving for excellence in serving both children and families.

While the Report concluded that most programs are providing high quality services, it also found that some local programs need improvement. Today, more than ever, we need to assure that all Head Start grantees achieve and maintain high levels of program quality. This memorandum focuses on policies for assuring that performance problems are corrected.

NEW POLICIES:

The 1994 reauthorization of the Head Start Act confirms the Administration for Children and Families, (ACT) clear expectation that all grantees will provide high quality services to children and families based on the Quality Standards outlined in a new section of the Act, section 641A.(a)(1).

In section 641A.(d), "Corrective Action; Termination," procedures are outlined that must be followed when a grantee fails to meet the quality standards that have been established. Under these procedures:

ACF must notify the grantee that a deficiency exists.
ACF must determine whether the deficiency must be corrected immediately or whether a period of time can be allowed to correct the deficiency. In all cases, the deficiency must be corrected within one year of the date ACF notifies the grantee that a deficiency exists.
The grantee must correct the deficiency, either immediately or within the time specified in a Quality Improvement Plan that the grantee develops and ACP approves.
ACP must provide or arrange for appropriate training and technical assistance.
ACF must determine if the deficiency has been corrected and terminate the grant to the agency if it has not been corrected.

In most cases, problems associated with grantee quality will be identified as a result of an ACP on-site monitoring review, conducted at least once every three years. Although deficiencies may also be identified during follow-up reviews or during other reviews, the policies which are discussed in this memorandum will largely occur in connection with the on-site monitoring review.

A "non-compliance" vs. a "deficiency"

In carrying out the provisions of Section 641A.(d), a key decision that ACF must make will be whether or not a "deficiency" in program services exists.

Head Start's current Performance Standards and regulations are written in a form that results in a great many specific requirements. For example, the "On-Site Program Review Instrument" (OSPRI) used during monitoring visits contains 256 such specific standards. Because of this level of detail, monitoring reviews almost always find some specific items that need to be improved, even in otherwise excellent programs. Therefore, although a grantee may be found to be out of compliance with one or more of these requirements, that does not necessarily mean that a "deficiency" exits.

A deficiency would exist when there are a number of items of noncompliance with regulations that, when considered together, are of such a major scope or seriousness that they prevent the grantee from providing services of adequate quality to children and families or result in the program being operated in an unacceptable manner. Thus, deficiencies may exist when a grantee fails to meet related standards within or across program areas. Examples of such systemic deficiencies would include inadequate health services, ineffective parent participation in decision making, insufficient parent education activities, inadequate nutrition services, inadequate fiscal management, etc.

In some cases, there may be one specific item of non-compliance that is not related to a more systemic problem, but because of its nature constitutes such a serious problem in itself that it is determined to be a deficiency. Examples of such specific deficiencies could include a specific safety concern, a grantee's unwillingness to adhere to a specific requirement concerning the responsibilities of the Policy Council or requirements about minimum class size, etc.

In making its determination about whether or not a deficiency exists, ACF will consider the findings from the on-site monitoring review plus other relevant information that may be available.

Correcting "non-compliance" items

When grantees are notified that there are items of non-compliance with Head Start Performance Standards or other applicable regulations but that these items do not represent a deficiency they must correct these non-compliance items within 90 days, except in certain instances where additional time may be authorized by ACF. When the items of non-compliance have been corrected, the grantee must notify ACF by letter and provide whatever documentation may be needed to demonstrate compliance.

Correcting "deficiencies"

Grantees that are notified that they have one or more deficiencies are subject to the procedures explained in Section 641A(d) of the Act. Taking into account the seriousness of the deficiencies and the time reasonably required to correct the deficiencies, ACF will direct the grantee to either:

Correct the deficiencies immediately; or
Develop and implement a Quality Improvement Plan.

Quality Improvement Plans
The Quality Improvement Plan must be developed and submitted to ACF by the grantee in a timely manner. It is important that immediate attention be paid to developing the plan, since the plan must be developed, agreed to by ACF and implemented all within one year of the date that ACF notifies a grantee that a deficiency exists. We urge you to contact your Regional Office as soon as possible after being notified that a deficiency exists and work with ACF staff in developing the plan.

The Quality Improvement Plan must explain the actions that will be taken to correct the deficiencies. The plan must also explain the timetable for completing the corrective actions, including interim milestones when appropriate.

After receiving a grantee's Quality Improvement Plan, ACF has up to 30 days to approve the plan or indicate, in writing, why it was not approved, in which case the grantee will need to submit a revised plan.

ACF will provide or arrange for training and technical assistance to grantees with regard to both the development and the implementation of the Quality Improvement Plan to the extent that providing this assistance is feasible and appropriate, given available funding and other responsibilities. We expect that in the majority of cases grantees will be able to quickly and effectively correct deficiencies and continue providing high quality Head Start services. However, there may be a relatively small number of cases where the deficiencies are more serious and widespread and where the grantee may have great difficulty in correcting them. We intend to provide special attention to these seriously deficient grantees, tracking their progress closely, providing appropriate assistance.

Deficiencies must be corrected by the time specified in the plan and agreed to by ACF, which in no case shall be later than one year after the grantee received notice from ACF that the deficiencies existed. If it is determined by ACF that a deficiency has not been corrected within the agreed upon time, steps will immediately be taken to terminate the grant and to select a replacement agency to continue Head Start services to the community, following the procedures contained in Head Start regulations.

We look forward to working with you as we implement this new process and strive towards improving the quality of services Head Start is providing to our nation's most vulnerable children and families. Any questions on this process should be directed to your ACF Regional Office.

/S/
Olivia A. Golden,
Commissioner