If a member of the Policy Council completes three years of service on a Policy Council for one program, it should prevent the individual from serving on another Policy Council if that individual should relocate to another area.

The Head Start Program Performance Standards at 45 CFR 1304.50(b)(5) has determined that Policy Councils and Policy Committees must limit the number of one-year terms any individual may serve on either body to a combined total of three terms.

Requirement

45 CFR 1304.50(b)(5)

July 11, 2006

Programs have flexibility when deciding Board and Policy Council membership procedures and rules. The regulations state that the Board and Policy Council cannot have identical membership but that does not mean that a member of the Board is prohibited from being a voting member of the Policy Council and conversely a Policy Council member could also be a voting member of the Board as long as such an arrangement is in the by-laws of the Board and the Policy Council.

Informal Guidance

March 15, 2007

With the increase of Head Start – State Pre-Kindergarten partnerships, there have been numerous instances of shared human, fiscal and material resources by Head Start agencies and local school districts. In some cases, these partnerships pose new challenges for the implementation of shared governance.

The Head Start philosophy and regulations support the participation of parents through shared governance in decisions about their local Head Start program. For example, the Policy Council must approve decisions to hire or terminate any person who “works primarily for the Early Head Start or Head Start program of the grantee or delegate agency”. If a Head Start agency pays the school district for the services of the district’s employees (or claims the value of their services as non-federal share), the Head Start agency should determine whether the dollar amount constitutes more than half of the particular individual’s compensation. If it does, the Policy Council shares approval authority with the governing body and key management staff over the hiring and termination of the school district employee’s employment, in so far as it involves working in the Head Start program.

In addition, whether or not the employee meets the “works primarily for” criteria, a Policy Council still has a role to play in participating in decisions about the status of school district employees playing significant roles in the Head Start program. When a Head Start agency transfers the performance of substantive programmatic work, such as teaching or administration, to a third party, such as a school district, that transfer constitutes a “change in scope”. A “change of scope” requires the prior approval of the Regional Office. In order to obtain prior approval, a grantee must submit to the Regional Office in its annual grant application (or proposed modification) a description of proposed collaboration. Consistent with the provisions of 45 CFR Part 1304.50(d), this grant application must be approved by the Policy Council. Grantees that are pursuing cooperative relationships with school districts are encouraged to involve the Policy Council early on in any discussions with the school so that issues can be addressed as the agreement is being developed and all parties involved will have a clear understanding of the nature of the collaboration.

Requirement

45 CFR 1304.50(d)(1)(x); 45 CFR 1304.50(d)(1)(xi); 45 CFR 92.30(d); and 2 CFR 215.25(c)

April 23, 2007

A decision by a Head Start grantee (or delegate agency) to hire or terminate any person who works primarily for the Head Start program requires the approval of the program’s Policy Council (or Policy Committee). However, there may occasionally be situations that necessitate a program finding a suitable replacement for an important staff position before it is possible to obtain Policy Council approval. For example, a key member of the staff who performs critical functions for the program might be involved in a serious accident during a weekend. Such situations, although uncommon, do occur and pose risks to the continuing capacity of the Head Start program to provide uninterrupted services to children and families. The Office of Head Start expects all Early Head Start and Head Start grantees and delegate agencies to develop policies and procedures for the emergency hiring of personnel. These policies and procedures should be included in the agency’s personnel policies or by-laws, or both. The policies and procedures should address emergency hiring procedures, including a discussion of how to assure the Policy Council is afforded a timely opportunity to fulfill their staff hiring and termination approval responsibilities.

Informal Guidance

April 23, 2007

There are no mandated time requirements for either of the two activities noted above.

However, when teachers schedule the two required home visits to each enrolled child’s family, they should allow sufficient time to learn about the child's family and allow adequate time for parents to ask questions about the program and inquire about their child's participation. While it seems reasonable that most home visits conducted by teachers could be done in sixty - ninety minutes, teachers need to be responsive and flexible to families' needs during the time of the visit.

When scheduling the required socialization activities for children enrolled in home-based programs (at least two such activities per month must be provided) programs are encouraged to schedule these for a period of approximately 3 ½ hours. This will afford the grantee ample time to plan and implement meaningful activities for both the parents and children.

Programs are encouraged to discuss their plans to meet these requirements with their Policy Council (Committee).

Informal Guidance

May 23, 2007

Under 2 CFR 215.23(d), 45 CFR 92.24(b)(7), and 92.24(c)(1), the value of the time should be equal to what it would have cost the program to employ someone to do the task for which the parent had volunteered. (It is important to note that for something to be allowable as non-federal it needs to be something for which grant funds could have been used). For example, if a parent is volunteering in the classroom, that parent is, in effect, functioning as a second teacher assistant and the average hourly rate for an assistant in that program (salary and benefits) would be a reasonable charge. If a parent volunteered to help paint the exterior of a Head Start center, than the program can fairly charge as non-federal what it would have cost to hire a painter to do the same work. Programs must ensure that all parent volunteer time is adequately documented.

Requirement

2 CFR 215.23(d); 45 CFR 92.24(b)(7); and 92.24(c)(1)

June 12, 2007

There are many low-income children in this country who are being raised by their grandparent(s). In these situations it is important for a Head Start program to gather as much information as it can in making a decision about enrolling a child. Programs should speak to the child’s grandparent(s) and gather as much information as possible about the child and the specific circumstances that resulted in the child being with his/her grandparent(s). Programs should determine whether they believe the current arrangement will be temporary or is likely to be long term. Programs also need to determine if a conversation with the child’s parents would be both possible and beneficial. If the program determines that the child is, for all intents and purposes, being raised by the child’s grandparent(s) the Head Start program should consider the income of the grandparent(s) when determining income eligibility. All of the information relevant to this process should be included in the child’s folder.

If a Head Start program enrolls a child who is living with the child’s grandparent(s) who has not been designated as the child’s guardian(s), the Head Start program must help that family work with child welfare and other social service agencies to determine the best course of action for that family. Head Start programs that conclude the child is, for all intents and purposes, being raised by the child’s grandparents may release the child to the grandparents and allow the grandparents to make decisions about the health services for the child.

Informal Guidance

June 12, 2007

No, there is no specific regulation that requires menus be reviewed and approved by a registered dietician or qualified child nutritionist. However, 1304.23(b)(1) requires that "grantee and delegate agencies must design and implement a nutrition program that meets the nutritional needs and feeding requirements of each child, including those with special dietary needs and children with disabilities. Also, the nutrition program must serve a variety of foods which consider cultural and ethnic preferences and which broaden the child’s food experience." Further, 1304.52(d)(3) specifies that "Nutrition services must be supported by staff or consultants who are registered dieticians or nutritionists."

One way for a grantee to meet this requirement is to have a registered dietician or qualified child nutritionist regularly review menus and modify them, if necessary, in order to meet the individual nutritional needs of children in the program. Another way is to establish partnerships with community agencies with expertise in this area to assist the program to meet this requirement, such as WIC. The Health Services Advisory Committee can also play a role in making referrals to providers that can assist the program in meeting the requirement as well.

Informal Guidance

June 19, 2007

If State, Tribal or local law does not include a definition for "regular volunteers", the Head Start program is expected to establish policy or procedures covering "regular volunteer" requirements locally. 45 CFR 1304.52(j)(2) requires that "regular volunteers must be screened for tuberculosis in accordance with State, Tribal, or local laws. In the absence of State, Tribal or local law, the Health Services Advisory Committee must be consulted regarding the need for such screenings". 45 CFR 1304.3(a)(20) defines a volunteer as "an unpaid person who is trained to assist in implementing ongoing program activities on a regular basis under the supervision of a staff person…"

Requirement

45 CFR 1304.52(j)(2); 45 CFR 1304.3(a)(20)

June 19, 2007

No. Programs are mandated to provide reimbursement only to low-income families. Programs, at their discretion, may, however, provide reasonable reimbursement to all members.

Requirement

45 CFR 1304.50(f)

June 19, 2007

Programs need to develop their own policies about transporting parents to and from the Head Start center. Such policies should consider whether the bus or transportation insurance allows for this. A parent needing transportation, for example, to participate in a socialization visit or to volunteer at the center may be provided such transportation. This transportation could be arranged by having the parent accompany his/her child on the bus or, if necessary, by having an employee drive to the parent’s home to pick up the parent and transport the parent to the center. Grantees are not mandated to provide such transportation, but are encouraged to do so when it will better enable the parent to participate in activities that are designed to improve the Head Start program and/or improve the parent’s ability to act as their child’s primary educator (for example, transporting a parent to attend an adult literacy class at the Head Start center).

Informal Guidance

July 3, 2007

In accordance with Section 642A of the Head Start Act and 45 CFR 1304.40(h), all Head Start programs are required to take steps to coordinate with their local schools and involve Head Start parents and staff in planning and implementing the transition of Head Start children to kindergarten. Programs should provide parents and staff with the education and training necessary to ensure that they have the necessary knowledge and skills to advocate for their children by participating effectively in transition activities with the school. Transition activities include promoting the continued involvement of parents in obtaining the treatment that their child needs for their healthy development. To accomplish transition goals, Head Start programs should develop on-going channels of communication, including face-to-face meetings that enable parents and Head Start staff to discuss the child’s ongoing needs, including health needs, with kindergarten teachers and other appropriate staff. With parental consent, the Head Start program should also transfer copies of appropriate health records to the kindergarten.

Requirement

42 U.S.C. 9837A; 45 CFR 1304.40(h)

July 3, 2007

It would be sufficient to simply categorize the parent’s activity as ‘Teacher’s Assistant’, assuming there is a ‘Teacher Assistant’s’ job description maintained by the Head Start program. Grantees should use the same procedure for any of the jobs for which there are paid employees and, therefore, job descriptions. For volunteer activities for which there is not a job description, grantees that anticipate using those volunteer services on an ongoing basis should establish a position description for that volunteer activity and in the description explain the basis for arriving at the hourly compensation level that will be used for claiming non-federal share. For example, if a grantee twice a year has a volunteer Saturday Center Clean-up Day that grantee might create a position description for a maintenance worker (assuming it does not already have one) and describe the duties and basis for valuing the service. Then on the individual timesheets for all the volunteers the grantee would only have to put Activity: Maintenance Worker (Volunteer). When a grantee does not have a valid position description it will have to create individual documentation for a particular volunteer activity, including a description of the work, the basis for valuation etc. As an alternative to developing job descriptions for all of the volunteer donated activity, programs may choose to identify and describe the activity on the volunteer time sheet.

Grantees are reminded that irrespective of how they determine the type of work performed by the volunteer (and, therefore, its value to the program), the use of volunteer time as match must include the establishment of a wage scale based upon the grantee agency’s internal scale or prevailing wages in the area. All volunteer time needs to be carefully documented by time sheets with the hours recorded and be verifiable from the grantee’s records; i.e. the date, times and location of the volunteer service and corroborated by the signature of both the volunteer and the volunteer’s supervisor. Programs may choose to use a monthly time sheet for regular volunteers or daily time sheets for occasional volunteers.

Requirement

2 CFR 215.23(d), 45 CFR 92.24(c)(1)

July 3, 2007

The mental health professional should help programs address the Head Start Program Performance Standards requiring collaborative work with parents to access, either directly or through referrals, services and resources responsive to the family’s goals (1304.40(b)(1)). This includes providing parents with information or services addressing mental health issues (1304.40(b)(1)(ii)). Early Head Start programs enrolling pregnant women must help them access, as part of comprehensive prenatal and postpartum care, any needed mental health intervention and follow-up (1304.40(c)(iii)).

The mental health professional’s work with program staff focuses on supporting the staff’s performance of professional duties in serving children and families (e.g., consulting with teachers to promote positive social behaviors among children, or providing information for home visitors on common parenting issues raised by families). Regarding the personal mental health needs of the staff, programs must “make mental health and wellness information available to staff with concerns that may affect their job performance” (1304.52(j)(3)).

Please also refer to OHS – PC – B – 050.

Requirement

45 CFR 1304.40(b)(1); 1304.40(b)(1)(ii); 1304.40(c)(iii); 1304.52(j)(3)

July 3, 2007
Revised May 11, 2009

Young children’s development occurs rapidly, making it necessary for Head Start staff to record observations of changes in children’s health and development on an ongoing basis. If this is not done, children are at risk because health and developmental concerns that can adversely impact the child’s ability to learn will not be detected in a timely manner.

Head Start programs must develop and implement procedures for ongoing care in order to ensure that children remain healthy and ready to learn. The procedures should clearly identify staff responsible for observing, communicating and recording information about any concerns regarding each child’s ongoing health and development. Parents have a very important role in ongoing care and must be trained and integrally involved in all aspects of the process. Programs should ensure that staff and parents are trained in how to observe children for signs and symptoms of disease and illness or changes in emotional or behavioral patterns. Training should also include use of observation tools, and the protocols for communication (including recording as appropriate). There should also be a process for reviewing information recorded on each child and for making decisions regarding referrals for further evaluation and treatment as needed. There are a number of ways that a program can demonstrate compliance with ongoing care requirements, including: recording information about individual children’s developmental progress, changes in physical appearance, and changes in emotional and behavioral patterns in health records and/or children’s classroom files; agency policies and procedures; minutes from staff meetings and case conferences; notes from home visits and meetings with parents; observation forms; and staff training and parent workshop materials. Most programs help address the requirement for "ongoing care" through multiple methods, including a system for ongoing assessment of child progress.

Requirement

45 CFR 1304.20(d)

July 13, 2007

Yes, once a child has been enrolled into the program, the program can provide services to a child. This could include screenings or immunizations at a Health Fair, an initial home visit by Head Start staff, or other pre-entry services.

Informal Guidance

July 13, 2007

In accordance with 45 CFR 1304.20(b), Head Start programs, in collaboration with parents, are required to begin completing screenings within 45 days of the child’s entry into the program. Entry into the program is defined as the first day the child enters the Head Start classroom, or begins to participate in a home based or family child care program.

Requirement

45 CFR 1304.20(b)

July 13, 2007

Head Start agencies may use funds to reimburse families for transporting their children to and from socialization activities in the home-based program option.

Transportation services to children served under the home-based option for Head Start and Early Head Start services are excluded from the requirements of 45 CFR 1310.12, 1310.15(c), and 1310.16 related to the use of school buses and allowable alternate vehicles, child restraint systems, and bus monitors.

Requirement

45 CFR 1310.12; 45 CFR 1310.15(c); 45 CFR 1310.16

July 19, 2007

No. If a Head Start/Early Head Start program transports a Head Start child to a center, that child becomes Head Start’s responsibility from the time the child boards the bus. If a program is not providing transportation, the child becomes Head Start’s responsibility at the time the child enters the Head Start center. Any activities prior to either of these times is not considered to be part of the Head Start day and, therefore, not chargeable to the Head Start grant, as either federal or non-federal share.

Informal Guidance

July 31, 2007

Yes. Admission costs for a parent volunteer on a field trip are an allowable charge against the Head Start grant. Programs, however, are cautioned to be aware of potential cost implications related to having more parents along on a field trip than is necessary to assure appropriate oversight of the children on the field trip.

Requirement

2 CFR 225, Appendix A(C)(1); 2 CFR 230, Appendix A(A)(2)

August 8, 2007

If the activities are part of the Head Start program’s curriculum and if the home visitor has given the parent, in writing, instructions as to what that parent can do at home to better implement that program’s curriculum, such time can be counted as non-federal share.

Informal Guidance

August 8, 2007

Currently, there is nothing in the Head Start statute that would preclude a program from hiring an individual who has only a CDA credential (i.e. no ECE degree) as a teacher. Should Head Start requirements change in terms of teacher qualifications, that teacher, as, of course, all other teachers would have to meet those new requirements.

Informal Guidance

September 17, 2007

45 CFR 1304.41(b) requires Head Start grantee and delegate agencies to establish and maintain a Health Services Advisory Committee (HSAC) which includes Head Start parents, professionals and other volunteers from the community. While this regulation does not prohibit a staff person from serving on the committee, the intent of the regulation is for local Head Start programs to have a structure in place that brings community members and Head Start parents together to advise the Head Start program about pertinent health issues impacting the children and families they serve. Some Head Start programs invite Head Start staff members to observe HSAC meetings so they may have a first hand understanding of the issues being addressed by the HSAC and/or to provide background information about the program to the committee. Others invite staff members to give presentations to the HSAC to request their guidance about health issues and/or policies that the program is developing. The HSAC is a valuable resource to a Head Start program and its membership should reflect the various local resources available to Head Start children and families as well as other children in the community.

Requirement

45 CFR 1304.41(b)

December 13, 2007

The purpose of home visits is to help parents and staff learn more about each other and the behavior and development of the children in the different environments, home and Head Start (HS) or Early Head Start (EHS). Hopefully, staff will gain an understanding of the family and home environment where the child lives, and the parents will gain an understanding of how they can maximize their roles as the first and most important educators of their children, and they will be able to work together to support the development of the child(ren).

Though HS and EHS programs are directed in 45 CFR 1304.40(i) to make two home visits a year to each child’s family, exceptions are made for parents who expressly forbid such visits. Parent participation in Early Head Start and Head Start cannot be a condition of the child’s participation, and children cannot be dropped from HS enrollment if their parents choose to not have home visits. In such cases, the HS program should continue to try to work with the parents, and look to increase the number of parent-teacher contacts to four, in place of the required two home visits and two parent-teacher contacts. These contacts can take place at the program site, or in other neutral places that afford some privacy, such as a library or a park.

Documentation of these efforts should be kept at the program to show that the program has done all it can to encourage the parent(s) to participate in home visits and/or four parent teacher contacts.

Requirement

45 CFR 1304.40(i); 45 CFR 1306.32(b)(8)

January 7, 2008