Designation Renewal System
Frequently Asked Questions (FAQs)

These Frequently Asked Questions provide information about the implementation phase of the Designation Renewal System.

General FAQs

1. When will the Office of Head Start post the funding opportunity announcements (FOAs)?

   Interested applicants are encouraged to visit www.Grants.gov or the ACF funding opportunities website at http://www.acf.hhs.gov/grants/open/foa/office/ohs to locate funding opportunities. Additionally, interested applicants may sign up for email updates from Grants.gov to be notified when the funding opportunity announcements (FOAs) are posted. To receive email alerts, visit www.grants.gov, select “Find Grant Opportunities” from the red box on the left, and follow the instructions below.

   • Select the “Subscriptions” link from the bottom of the page.
   • Select the “Notices Based on Advanced Criteria” option.
   • Type in your email address and the CFDA Number, 93.600.
   • Select “Subscribe to Mailing List” to complete the registration process.

2. If both Head Start and Early Head Start grants have been designated for competition in a service area, will FOAs be released for both grants at the same time?

   Yes. For service areas where both types of grants are subject to competition, two funding opportunity announcements – one for Head Start and another for Early Head Start – will be released at the same time. Instructions for applying under one or both of the announcements will be included in each FOA. In five service areas, a birth-to-five pilot funding opportunity announcement is available that allows applicants to apply for funding to serve children from birth to age five and pregnant women in one application. These five service areas are listed under Types of Funding Opportunity Announcements at: http://eclkc.ohs.acf.hhs.gov/hslc/hs/grants/funding.html.
   

3. Who is eligible to apply for Head Start and Early Head Start funding?

   The HHS Grants Forecast website and each FOA list eligible entities for Head Start and Early Head Start funding. Public or private nonprofit organizations, including community-based and faith-based organizations, or for-profit agencies within a community that wish to compete for funds are eligible to apply for Head Start funding. The same categories of organizations are eligible to apply for Early Head Start, except that applicants need not be from the community they will be serving.

   Entities that have, within the last five years, been terminated from the Head Start or Early Head Start program for cause or been issued a “denial of refunding” under 45 CFR 1303.15 by the Office of Head Start (OHS) are not eligible for funding. Grantees that have been required to compete by the Designation Renewal System are eligible to apply.

4. When are applications due?

   Each funding opportunity announcement will include a due date of  not less than 60 days from the posting date of that FOA. Applications must be submitted electronically and received and validated through the Grants.gov system by the due date and time to be considered in the competitive process.

5. Will current grantees that have been designated for competition be automatically disadvantaged under the evaluation criteria based on having a past deficiency?

   We do not intend to include any provisions in the FOA evaluation criteria that would provide for an automatic deduction of points for current grantees either for having past deficiencies or for being designated for competition.

6. In my service area, the HHS Grants Forecast indicates an “estimated number of awards” that is higher than the current number of grantees in the area.

   The HHS Grants Forecast format allows OHS to enter only a single number for the estimated number of awards. The number represents a range of awards that OHS may make as a result of the competition. For example, if six (6) is listed under “estimated number of awards,” OHS may award between one and six awards.

   The Administration for Children and Families (ACF) also has authority to award more than the number listed as the estimated number of awards. 

7. What happens if there is only one applicant in a given service area? Will they automatically get the grant?

   In accordance with HHS Grants Policy, all eligible applications will be evaluated based on the criteria established in the funding opportunity announcement. Only fundable applications, as evaluated by a panel of non-federal reviewers, will be considered for a federal award.

8. Is it permissible for an applicant to require another entity or individual to agree not to compete for a Head Start or Early Head Start grant as a condition of being named as one of the applicant’s delegate agencies?

   In the interest of ensuring a robust competition for high-quality, comprehensive early education providers, OHS believes that applicants should not dissuade other entities from applying for Head Start or Early Head Start grants. Therefore, we intend to award bonus points in the FOA evaluation criteria for applicants who attest that they do not have a non-compete agreement (at the time of application) with another entity that restricts or disadvantages the entity’s ability to apply for a Head Start grant on its own.

9. Who will review the grant applications?

   The HHS Grants Policy requires that a panel of independent, non-federal reviewers evaluate applications for competitive discretionary grants. The reviewer panel will consist of individuals with expertise in early childhood development; family support services; education or a related field; and fiscal and organizational operations.

   The scores from the reviewer panel are just one factor in making an award decision. ACF may elect not to fund applicants with management or financial problems that would indicate an inability to successfully complete the proposed project. Furthermore, applications may be funded in whole or in part. Successful applicants may be funded at an amount lower than that requested.

   ACF also reserves the right to consider preferences to fund organizations serving emerging, un-served, or under-served populations, including those populations located in pockets of poverty. ACF will also consider the geographic distribution of federal funds in its award decisions. ACF may refuse funding for projects with what it regards as unreasonably high start-up costs for facilities or equipment, or for projects with unreasonably high operating costs. ACF is ultimately responsible for making the funding decisions.

10. Suppose an entity applies as the grantee and proposes to work with a number of organizations as delegates, including some organizations that need to improve the quality of the early education services they currently provide. Can the applicant include in the application a discussion of the strengths and challenges of the proposed delegates and the steps that the lead agency is proposing to take to improve the quality of services provided by the delegate agencies?

    In the interests of ensuring that competition effectively raises the level of quality for all children enrolled in Head Start, applications should demonstrate an entity’s ability to provide high-quality, comprehensive early education services.

    Organizations may decide, at their own discretion, to expand their efforts by working with other organizations that will serve as delegates and that may benefit from the lead agency’s efforts to support higher quality early education services. In such cases, the applicant should explicitly describe the partnership and agreement among the proposed agencies; discuss the applicant’s intentions around quality improvement for the delegate, where needed; and outline the steps the applicant will take to improve those aspects of the program that are identified for quality improvements.

11. Is there data available to applicants that will allow us to examine the patterns of progress and outcomes (achieved goals) for groups of children served by the previous program? For example, is it possible to release the previous grantee's most recent Program Information Report (PIR) data so that we can examine progress by language groups, by child, family, or community risk factors?

    PIR data, reports and prior year’s PIR forms are available at http://hses.ohs.acf.hhs.gov/pir. PIR data provides comprehensive data on the services, staff, children, and families served by Head Start and Early Head Start programs.

    The public may contact the HSES Help Desk for an account to access PIR data.

    HSES Help Desk
    Toll Free: (866) 771-4737
    Local: (703) 528-0591
    hseshelp@acf.hhs.gov
    Monday through Friday
    8:30 a.m. to 5 p.m. ET

    Existing HSES users can access PIR data directly in HSES (reports menu) or through the PIR reports website using their current access account.

Fiscal FAQs

1. What is the difference between the applicant's Authorized Organization Representative (AOR) and Point of Contact (POC)?

   The signature of the Authorized Organization Representative (AOR) is required on the original copy of the application submission. Consistent with the instructions from the SF-424, the individual(s) named by the applicant/recipient organization as the AOR is authorized to act for the applicant/recipient and to assume the obligations imposed by the federal laws, regulations, requirements, and conditions that apply to grant applications or awards.

   Consistent with the instruction for Grants.gov for electronic submissions, the AOR is the person that uploads and electronically submits the application.

   The Point of Contact (POC) (sometimes also known as the project director or principal investigator) is the person the applicant has assigned to oversee the project and should not be the same person identified as the AOR.

   Consistent with the instruction on the SF-424, the POC is the person to be contacted on matters involving the application and must be available to answer questions pertaining to the application. This person should not be identified as the project director or the principal investigator.

   Consistent with the instructions for electronic submission on Grants.gov, the POC is the E-Biz designee who provides credentials to the person that organization has designated to upload and electronically submit the application, also known as the AOR.

2. Can a disallowance of federal funds be taken against a grantee agency if it exceeds the 15 percent administrative cost limitation?

   Yes, a disallowance can be taken against the grantee agency for the amount of administrative costs that exceed the 15 percent limit. In addition, a disallowance may be taken on administrative costs that are considered excessive even if the administrative costs limitation is not exceeded.

   Section 644(b) of the Head Start Act and Section 45 CFR 1301.32 of the Head Start Program Performance Standards limit the amount of funds that may be charged as development and administrative costs to 15 percent of the total cost of the program. Grantee agencies must have a system in place, including adequate procedures, to ensure that the 15 percent administrative cost limitation requirement is met to avoid non-compliance. However, there are some exceptions.

   Waiver

   The Office of Head Start may grant a waiver of the 15 percent administrative costs limitation for a specified period of time not to exceed 12 months. The grantee agency should ensure that such approval is obtained in writing before proceeding.

   There are certain conditions under which a waiver can be granted, such as when:

   1. A new Head Start grantee or delegate agency is being established;
   2. Services are being expanded by an existing grantee or delegate agency;
   3. Delivery of component services to children and families is delayed until program development and planning is well underway or completed; and
   4. Component services are disrupted or suspended in an existing Head Start program due to circumstances beyond the grantee agency’s control, such as fire, flood, or tornado.

3. How do you allocate the costs of a staff member who serves as both the Head Start director and education coordinator in a small program?

   This would be considered a dual benefit cost and should be appropriately allocated.  Dual benefit costs relate to both administrative functions and program component services and can be designated as either personnel or non-personnel costs. Therefore, they must be allocated on a rational basis between administrative and program service delivery.

4. What types of costs are considered program costs?

   Program costs are those costs directly associated with the delivery of program services through the direction, coordination, or implementation of a specific component. Program components include education, disabilities, health, nutrition, parent involvement, social services, and transportation. 

   Program costs include, but are not limited to, the following:

   1. Personnel and non-personnel costs directly related to the provision of program services and component training and transportation for staff, parents, and volunteers;
   2. Costs of the functions directly associated with the delivery of program services through the direction, coordination, or implementation of a specific component;
   3. Salary costs for program coordinators and staff, janitorial staff, and transportation staff involved in program component efforts.
   4. Costs associated with parent involvement and volunteer services; and
   5. Expenses related to program staff functions, such as the allocable costs of fringe benefits; travel; transportation; training; food; center and classroom supplies and equipment; funds for parent activities; insurance; and the occupation, operation, and maintenance of the program facility, including utilities.

   Section 45 CFR 1301.32 of the Head Start Program Performance Standards provides additional information related to program costs.

5. What is “federal interest” and when is it established in a facility?

   Federal interest is the acquisition of real property, equipment, or supplies under an award, whether paid by federal funds, or satisfying some or all of a matching cost sharing requirement. The dollar amount that is the product of the federal share of project costs  multiplied by the current fair market value of the property.

   When real property, equipment, and supplies are acquired or improved with federal funds, the federal interest is established, per 45 CFR Parts 74.32–74.35 and 1309.21(a). 

   The standard forms approved by the Office of Management and Budget (OMB) for recipient reporting of inventory for Tangible Personal Property and Real Property Status Report are SF-428 and SF-429 respectively.

6. How do you categorize and allocate facilities costs?

   Section 45 CFR Part 1309 of the Head Start Program Performance Standards outlines the application procedures for the purchase, construction, and major renovations of facilities. Grant applicants must determine the use of the facility. If the facility contains space for both administrative functions and program component functions, it would be classified as a dual benefit cost and the grantee agency must then allocate costs between administrative and program.

7. The funding opportunity announcement references "indirect costs" in Phase Two. Is ACF referring to indirect costs for organizations with an indirect cost rate in place or is it also referring to allocated shared costs (such as Fiscal/HR Department costs) for organizations without an approved indirect cost rate?

   “Indirect cost rate” in this context refers to the rate agreement established for the non-profit agency and approved by the cognizant Federal agency.

8. Is ACF providing access to the Internal Control-Integrated Framework (COSO Report) as referenced in the Phase Two information?

   The COSO Internal Control - Integrated Framework is referenced in the OMB Circular A-133 compliance supplement - Part 6. Applicants should visit http://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2011 to view Part 6 regarding the compliance supplement and the related framework.

9. Must start-up/pre-award costs costs be included in the Award Ceiling amount or may additional funds be requested in the proposal?

   Pre-award costs, including start-up costs, may be requested by an applicant in addition to the base operating and T/TA grant funds. If requested, applicants must provide a separate budget for start-up/pre-award costs in addition to a 12-month budget for the base funding awarded, within the page limitations stated for the Budget and Budget Justification in Section IV.2. Content and Form of Application Submission. If awarded, start-up/pre-award costs would apply to costs incurred up to 90 days prior to the award start date. Examples of start-up activities are facility renovations, purchase of classroom supplies, building purchase, licensing, background checks, etc.

   Estimates for start-up/pre-award costs must be separately identified on the SF-424, Application for Federal Assistance, and in the Budget and Budget Justification section of the application. Start-up/pre-award funding amount must not be included in the funding amount listed on Line 18a (federal) of the SF-424. The funding amount listed in Line 18a of the SF-424 must represent only the total annual Federal funding the applicant is requesting for base and T/TA funding. Start-up/pre-award costs, if requested, should be included only on the Other Estimated Funding line (Line 18e) and clearly labeled as "Start-up/Pre-Award Costs" in a separate line item on the SF-424A, Budget Information - Non-Construction Programs. Additionally, if applicants are requesting start-up/pre-award costs, these costs must be easily identified as a separate budget in the Budget and Budget Justification section of the application.

   Inclusion of start-up/pre-award costs in the application submission is not subject to the “Award Ceiling Disqualification” that is explained in Section II. Award Information and in Section III.3. Other, Disqualification Factors. However, if an applicant does not segregate start-up/pre-award costs from the base funding award request (SF-424, line 18a, Federal), the “Award Ceiling Disqualification” will apply.

   Specific details on the inclusion of start-up/pre-award costs in the project budget and budget justification are found in Section IV.2. The Project Budget and Budget Justification.