One
of the major changes for FY 2005 is an increased emphasis on
describing interrelated areas of noncompliance among services and
systems. Interrelated areas of noncompliance may describe
system-to-service interrelationships (i.e., a systems failure
underlies a pervasive failure in service delivery) and
system-to-system interrelationships (i.e., a systems failure
underlies a pervasive failure in another system). Interrelationships
are discussed throughout the Guide, and the section on developing
the draft Head Start Review Report in the On-Site Activities chapter
provides detailed direction on writing interrelated areas of
noncompliance.
The Head Start Bureau (Bureau) continues its emphasis
on improving fiscal monitoring. The Fiscal Checklist
has been substantially revised for FY 2005 and uses
a "risk-based" approach. Using this framework,
the Fiscal Checklist now includes a set of prioritized
indicators (i.e., "red flags") designed
to identify underlying fiscal problems early. These
indicators focus first on those areas that, if irregularities
were present, would likely have the greatest adverse
impact on the fiscal health of the grantee. In addition
to the "red flag" indicators, the new
Fiscal Checklist includes an updated list of questions
that directly assess compliance with specific program
requirements. Finally, the checklist assesses fiscal
health in each of two major areas: internal controls
and governance.
In addition, the Bureau is encouraging review teams
to more closely examine several other areas during
PRISM reviews. These include: transportation services;
grantee compliance with other Federal, Tribal, State
and local licensing requirements; and enrollment
and income eligibility. These areas will be described
in more detail later in this section.
Also new for FY 2005, the Bureau is emphasizing
the conduct of grantee self-assessments. Grantees
are reminded that the conduct of self-assessments
help to ensure delivery of high-quality services
to children and their families, and assist the grantee
(and its delegates, when applicable) in preparing
for a Federal monitoring review.
REPORT WRITING AND COVER LETTER CHANGES
Report Writing Changes
In an effort to increase emphasis on the interrelatedness
of systems, services, and partnerships, and improve
the method for delivering review decisions to the
grantee, several changes have been made to the structure
and contents of Head Start Review Report for FY 2005.
The following is a list of these changes:
Renamed "Area Summary" to "Area
Strengths" and eliminated discussion of areas
of noncompliance in this section.
"Multiple methods and sources" are
no longer required when discussing a grantee's
strengths in the "Area Strengths" section
of the Head Start Review Report.
As part of the increased emphasis on system-to-service
and system-to-system interrelationships for FY 2005,
language about how to write and cite stand-alone
and interrelated areas of noncompliance in the Head
Start Review Report is included.
Deficiency decisions are now included within
the Head Start Review Report (as well as still in
the cover letter).
Starting in FY 2005, a list of all of the
citations constituting an area of noncompliance or
deficiency (as determined by the responsible HHS
official or designee) will automatically be generated
and placed at the end of each respective Core Question's
Areas of Noncompliance section. Next to each citation
will be the corresponding review decision - either "noncompliant" or "deficient".
Beginning in FY 2005, the responsible HHS
official (or designee) must, in addition to tracking
corrective action through the corrective action screen,
generate a follow-up report upon receipt and approval
of a certification of compliance letter. These actions
will help improve tracking of corrective action data.
Cover Letter Changes
Beginning in FY 2005, the web-based PRISM Software
will support the generation of cover letters (with
the exception of follow-up review and notice of
termination cover letters) to accompany the Head
Start Review Report sent to the grantee.
PROCEDURAL AND POLICY CHANGES
As part of the Head
Start Bureau's efforts
to identify potential income eligibility-related
areas of noncompliance, all review teams must complete
the new Income Eligibility Data Collection
Form through
the review of a sample of income eligibility determination
records.
Review teams will be asked to enter funded
and actual enrollment data into the PRISM software.
A greater emphasis will be placed on ascertaining
grantee compliance with other Federal, Tribal,
State and local requirements.
We will be providing more specific information about
the new initiative in the near future.
When possible, new reviewers will be
placed on teams with coach reviewers as the new reviewers
are learning their responsibilities.
CHANGES TO THE PRISM GUIDE
Term and Structure Changes
The term "applicable standards" has been
replaced with "program requirements" for
FY 2005. "Program requirements" refers
to requirements as specified in the Head Start Act,
the Head Start Program Performance Standards, and
other relevant Federal, State, and local regulations.
Additionally, the structure of the Guide was altered
with the addition of a new appendix, entitled "Reviewer
Information." This appendix, which appears
after the Forms Appendix and before the Resources
Appendix, includes information on reviewer job qualifications
and descriptions, and supplemental information for
certain reviewer processes as noted throughout the
Guide.
New and Revised Forms
For FY 2005, a Community Partnerships Information
Form has been added to the Forms Appendix. The
intent of this form is for reviewers to gain background
information and knowledge about the types and roles
of the community partnerships present in the Head
Start/Early Head Start programs before the interview
protocol so more time can be spent during the interview
protocol discussing the outcomes of the partnerships.
In addition, many of the forms in this appendix
have been revised slightly for FY 2005. Major changes
occurred in two forms - the Summary of Review Decisions
Worksheet and the Team Assignment Worksheet.
The Summary of Review Decisions form has been moved
from its previous location in the PRISM Instrument to the Forms Appendix. This form was revised to allow
the team leader to better map decision-making throughout
the week. The form tracks the following elements
for each Core Question as the review week progresses:
issues raised by team members, follow-up items, possible
citations, related citations and Core Questions,
and potential strengths. Instructions for the Summary
of Review Decisions Worksheet is located in front
of the worksheet.
FY 2005 revisions to the Team Assignment Worksheet
aims to better capture focus-child and family information.
The section of the form that addresses focus-children
and family assignments has been moved to the end
of the form and moved into a new table format that
includes columns for the grantee to write in background
information and for the review team to coordinate
logistical arrangements.
Additionally, the Grantee's Advance Activities
Checklist, Team Leader's Advance Activities
Checklist, and the Selection Process have been updated
with minor revisions for FY 2005.
Reviewer Information and Resources Appendix
The Reviewer Code of Conduct, previously located
in the Forms Appendix, has been updated for FY
2005 and moved to the new Reviewer Information
Appendix.
The URLs listed in the Resources Appendix were updated
to ensure that all are accurate and the websites
remain in working order.
CHANGES TO THE PRISM INSTRUMENT
Several changes were made to the PRISM Instrument,
including:
Each Core Question and its corresponding
notes page have been revised so they appear back-to-back
on the same page.
Addition of OMB Circular citations to Core
Question 8 (Fiscal Management).
Moved a revised version of the Summary
of Review Decisions Worksheet to the Forms Appendix.
Changes to the Content Area Experts Interview
Protocol, Staff Group Interview Protocol, Community
Partnerships Interview Protocol, and the Governing
Body Interview Protocol. Additionally, a What's
New for Interview Protocols was added following the
Core Question pages.
Added two new sign-in sheets to use for
the interviews. One sign-in sheet is for the Policy
Council and Family Group Interviews, while the other
is a general sign-in sheet to be used for all other
interviews. Instructions for using these sign-in
sheets are located immediately preceding the General
Sign-In Sheet.
Revised the Fiscal Checklist consistent
with the discussion appearing at the front of this
section.
Revised and renamed the Bus Ride Checklist
to the Transportation Services Checklist. The Transportation
Services Checklist now better reflects the scope
of Transportation Services and related program requirements.
It should be used on all PRISM reviews, whether the
grantee provides transportation services or not.
In addition, the checklist's broader focus
invites multiple reviewers to participate in information
gathering. This allows the review team to ascertain
compliance with transportation-related program requirements
in the context of the grantee's other systems
and services.
Added an Income Eligibility Data Collection
Form and accompanying instructions.
The Head Start Bureau will continue to make modifications to PRISM as we learn from our experiences. We appreciate the support of and efforts made by grantees, reviewers and regional office staff to implement the changes in the monitoring system over the last several years. As always, our goal in monitoring is to work with local programs to ensure that high quality services are provided to all Head Start children and their families.
