F - Management Systems and Procedures

OHS – PC – F – 001

What are the requirements for record retention?

Head Start grantees and delegates are required to retain their financial records, supporting documents, statistical records, and all other records (including children’s records) pertinent to their award for three years from the date of submission of the final annual expenditure report. However, the following are exceptions to the three year retention requirement:

  1. If any litigation, claim, financial management review, or audit starts before the expiration of the 3-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
  2. When records are transferred to or retained by ACF or OHS, the 3-year requirement for those records is no longer applicable to the grantee or delegate.
  3. When indirect cost rate proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable are submitted to the Federal government, the 3-year retention period starts on the date of submission to the Federal government.
  4. Copies of original records may be substituted for the original records if authorized by ACF or OHS.
  5. When ACF or OHS requests transfer of records to its custody when it determines the records have long term retention value, or arranges for grantee to retain the records beyond the usual 3-year period, the period of retention for those records will be determined by ACF or OHS.  
  6. All records pertinent to the acquisition of, or major renovation of, a facility must be retained for the period of ownership (or occupancy in the case of leased facilities) plus an additional three years.


45 CFR 74.53, 92.42, and 1309.41

April 23, 2007

OHS – PC – F – 002

Can a Head Start program begin to provide services to a child, including screenings at a Health Fair, before the program year begins?

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

OHS – PC – F – 003

When does the 45 day requirement for completing screenings begin?

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.


45 CFR 1304.20(b)

July 13, 2007

OHS – PC – F – 004

Are "policies", "plans" and "procedures" interchangeable terms in the Program Performance Standards, or do they have different meanings? Are programs required to have separate documents on file to demonstrate compliance with requirements for these three activities when the Program Performance Standards say they must be "written"? Please explain

The terms "policies", "plans" and "procedures" are all concerned with directing or guiding present and future action by the governing body and Policy Council, management, and staff of the Head Start program. These terms are not interchangeable. Although they have some similarity, the three terms are progressively more specific in their focus.

The governing body and Policy Council have responsibility for developing or approving policies for a Head Start program. When the program leadership decides what organizational goals to achieve and chooses a definite course of action, they explain through policy what the program’s course of action is and will be. Policy determines or guides future decisions important to the Head Start mission. Policies are statements of ways that an organization intends to achieve its mission and various goals.

Plans may be the responsibility of the governing body and Policy Council, management or staff. Plans are concerned with breaking down what needs to be done to accomplish a goal into a series of steps to be carried out over a specified period of time, by particular assigned individuals, in a particular location(s). Plans typically include schedules of events or activities. They tend to focus on when, where and who will carry out the series of steps necessary to achieve the goal.

Procedures may be the responsibility of the governing body and Policy Council, management or staff. Procedures focus on how individuals and groups are to perform their responsibilities, in carrying out specific steps or protocols. A set of instructions may detail the sequence, timing and execution of specified actions necessary to complete a task(s) or step(s). Procedures are a particular way to get something done for the organization.

A particular policy may require a plan(s) and procedures. The Program Performance Standards do not prescribe that these be separate or integrated documents. Written policies, plans, and procedures may be separate documents, or they may be integrated, at the discretion of each program.

Informal Guidance

July 31, 2007

OHS – PC – F – 005

In the Grantee's Privacy Policy, in the section where it indicates who has access to the records of children, families, and staff, and access to mechanical systems, should it also include members of the Governing Board and the Policy Council's Executive Committee?

Determining those to whom a grantee’s privacy or confidentiality policy applies—beyond children, families, and staff—is a local decision. Head Start regulations regarding record-keeping systems require grantees and delegate agencies to establish and maintain efficient and effective record-keeping systems that provide accurate and timely information regarding children, families, and staff and to ensure that appropriate confidentiality is provided for this information. To the extent members of the Policy Council’s Executive Committee are parents of Head Start children, they are covered by Head Start regulations and covered by the confidentiality requirement. Inclusion of members of the grantee’s governing body and non-parent members of the Policy Council Executive Committee within the scope of the grantee’s confidentiality policy is up to the discretion of the grantee. There also may be State or local laws governing confidential records that may be applicable and grantees are encouraged to contact their local government agencies to find out how they may or may not be covered.


45 CFR 1304.51(g)

November 20, 2007

OHS – PC – F – 006

What type of documentation is required by Head Start in order to determine if a child is up to date on a schedule of well child care?

45 CFR 1304.51(g) requires Head Start programs to establish and maintain efficient and effective record-keeping systems to provide accurate and timely information regarding children, families and staff. In order to document that a child is up to date on a schedule of well child care and to comply with the requirement that they establish and maintain efficient and effective record keeping systems, Head Start programs must keep written documentation about each child’s health status. This documentation should be from the child’s health care provider. Parental reports regarding examinations or treatment is not considered to be efficient and effective record keeping.


45 CFR 1304.51(g)

December 13, 2007

OHS – PC – F – 007

If the Head Start agency’s service plan is written comprehensively enough to include all procedures that are required by the Performance Standards and other state and federal guidelines, is it still necessary to develop a separate disability service plan?

The plan for disabilities services may be integrated into your program’s comprehensive plan for services across all program areas in accordance with 45 CFR 1304.51(a)(1)(iii).  However, the comprehensive plan must address all of the disabilities service plan requirements listed under 45 CFR 1308.4(e)-(o); and in accordance with 45 CFR 1308.4(d), the agency must use the relevant parts of the plan as a working document that guides all aspects of the agency's effort to serve Head Start children with disabilities. Agencies are reminded that the 45 CFR 1308 requirements apply to Head Start programs, but do not apply to Early Head Start programs.


45 CFR 1304.51(a)(1)(iii); 45 CFR 1308.4(d)-(o)

July 1, 2008

This is a Historical Document.