I - Eligibility, Recruitment, Selection, Enrollment and Attendance

I – 001 Can three year old children be enrolled in the middle of the school year?

I – 002 Which government programs qualify as public assistance for determining Head Start eligibility?

I – 003 Is it appropriate for a kindergarten-eligible child with a disability to stay in Head Start an additional year?

I – 004 Are there enrollment opportunities for an "over-income" family with a child with a disability to participate in Head Start or Early Head Start?

I – 005 When a child's divorced mother and father have been given joint custody of the child, how is the child's income eligibility for Head Start determined?

I – 006 How is income eligibility determined if a family claims it has no income?

I – 007 How is eligibility determined if the family is unable to provide income documentation?

I – 008 Can a Head Start program enroll, as income eligible, a child whose family’s income was above the poverty line in both the preceding twelve months and in the preceding calendar year, but whose situation has significantly changed so that looking at current income, the family is income eligible?

I – 009 When income is verified, does a copy of the proof of income need to be kept on file?

I – 010 Is Veterans Disability considered the same way that SSI or Social Security is when determining income?

I – 011 Are we supposed to count everyone that lives in the household and their income as family?

I – 012 If a child will be absent from the Head Start program for an extended period of time because, for example, the child is traveling out of the country with his family to visit the child’s grandparents, can the Head Start program keep that child’s enrollment slot vacant so the child will be able to return to Head Start upon his/her return?

I – 013 Do disabled children from families not in poverty count against the 10% limitation on the number of “over-income” children that can be served in any Head Start program?  (American Indian and Alaska Native programs may, in certain situations, enroll up to 49% of their children from families not meeting the income eligibility requirements.)

I – 014 If a program is funded to serve both Head Start and Early Head Start children, is the 10% “over-income” limitation applied to the program’s total enrollment or to separate Head Start and EHS enrollments?

I – 015 What age must a child be in order to be considered eligible for Head Start?

I – 016 How is eligibility for Head Start based on SSI determined?

I – 017 How can a Head Start program determine whether it is meeting the requirement that at least 90 percent (51 percent of programs operated by Indian tribes) of eligible children meet the income-eligibility guidelines?

I – 018 Under what conditions may a Head Start agency terminate the enrollment of a child due to sporadic attendance or extended absences?

I – 019 What is the relationship between the 10% limit on enrollment of over-income families and the requirement to make at least 10% of enrollment opportunities available for children with disabilities?

I – 020 How is income eligibility determined for children that are in foster care?

I – 021 If a child is accepted for enrollment in May as a foster child and, as such, is categorically eligible for Head Start, must the program re-verify the child’s foster care status prior to the beginning of the program year?

I – 022 Does the family income of children entering Head Start for a third year need to be re-verified?

I – 023 If an income eligible child is enrolled but leaves the program after a short time (say two months), are they still income eligible in the next program year or do they need to re-apply and have their income re-verified?

I – 024 Head Start classrooms with a majority of 4 year olds can have a maximum enrollment of 20 children. If in such a class a 4 year old leaves the program must the vacancy be filled with another 4 year old?

I – 025 For the purpose of determining eligibility based on family income how is a pregnant woman counted? An IM from 2002 says to count the pregnant woman as 2 members of the household – can you please clarify?

I – 026 An 18 year old is still living at home and being supported by his/her parent(s). Can this 18 year old be counted as a family member for purposes of determining Head Start eligibility?

I – 027 Is it acceptable for a Head Start agency to make “direct contact” with parents by telephone when offering family support to parents of children with sporadic attendance or extended absences (see OHS – PC – I – 018)?

I – 028 Is there a requirement that parents sign a statement attesting to the accuracy of the family’s submitted income information?

I – 029 If a family was determined to be income eligible last year but the child was not enrolled, must the Head Start program again determine the family’s income eligibility for the current program year or can the child still be considered as income eligible?

I – 030 Can a Head Start program increase its enrollment if it moves to a new facility which will allow it to have a larger class size than it had in its old facility?

I – 031 Can a child be enrolled in more than one Head Start program at the same time?

I – 032 How does a Head Start program determine household size for a family in which one or both parents are deployed out of the country in the military?

I – 033 If a woman is living with a boyfriend and he is not the father of her child who would be in Head Start but is the father of her youngest child, do you use his income when determining eligibility?

I – 034 If a child lives with and is supported solely by the child’s grandparents whose income is used to determine Head Start eligibility, under what circumstances can a Head Start program release the child to the grandparents and allow the grandparents to make health decisions for the child?

I – 035 Should a Head Start program remove a child from the program when, despite a mental health intervention, the child continues to display very aggressive behaviors toward other children and program staff?

I – 036 Are military families automatically eligible for Head Start?

I – 037 Is supplemental subsistence allowance paid to a member of the armed forces counted in determining eligibility?

I – 038 How long does an application for Head Start enrollment remain in effect?

I – 039 If an enrolled Head Start family moves out of the Head Start program’s service area, can the family continue services with that Head Start program?

I – 040 Is there a maximum income limitation for families that exceed the low-income guidelines but fall within the up to ten percent of children that may also be selected for Head Start?

I – 041 Are Head Start programs allowed to verify whether all members of a family applying for Head Start services possess Social Security numbers?

I – 042 If a child is determined to be Head Start eligible because the child is in foster care and subsequent to enrolling the child, the child is reunited with his/her parents, can the child remain in Head Start as an income eligible child?

I – 043 Does Head Start require proof of residency?

I – 044 If a Head Start program enrolls an income eligible child as a three year old that child remains income eligible in the following year. However, if, in that second year, that child’s family wishes to enroll the child’s 3 year old sibling, must the program determine the younger child’s income eligibility?

I – 045 May a Head Start program accept the enrollment of a child with a disability or special health need and delay their attendance at the program center until the program can collect necessary information from medical or early intervention providers on how to accommodate the child’s special needs and assure the health and safety of the child?

I – 046 If we count half of each parent’s income for children whose parents have joint custody, how is family size counted—including new spouses and unrelated children as part of one or both parents’ families?

I – 047 If a child lived with his parent until April of this year but is now living with his aunt, who is the child’s legal guardian, whose income is used to determine eligibility?

I – 048 If a Head Start child who was enrolled as an "over-income" child returns to Head Start for a second year and the child’s family has seen a change in its economic status so that the family’s income is now below the poverty level, can that child now be considered as income eligible?

I – 049 Is an agency allowed to accept children of staff as part of the 10% over income slots if that is written into the agency’s selection criteria?

I – 050 What income should be used if the legal guardian of a child receives TANF and also has an income. Is this a family of one or two?

I – 051 Does a child who was enrolled in a Head Start program and then had to drop out because the child has moved retain his/her income eligibility through the remainder of the current program year?

I – 052 If a foster child has been adopted prior to applying for Head Start is the child considered eligible?

I – 053 If a "single parent" family is found income eligible and that family’s child is enrolled in a Head Start program and during the Head Start year the single parent marries, does the Head Start program need to re-verify income eligibility, including the new spouse’s income in the determination of eligibility?

I – 054 Does Head Start have to use a child’s name as it appears on their birth certificate, Social Security Card, and health records when enrolling the child, or can the program use a different name; i.e. a parent’s preferred name?

I – 055 If a family is receiving kinship care for the Head Start child, is the child automatically deemed income eligible for Head Start?

I – 056 Can a Head Start program’s selection criteria include a requirement that children be up-to-date on their immunizations and other health screenings (such as tuberculosis)?

I – 057 Can a child be denied entry into Head Start if they are not up to date on their physical or immunizations?

I – 058 If a Head Start child does not receive their physical examination within one year of their last physical (as required by Medicaid/EPSDT), can the child be expelled from Head Start?

I – 059 Can a child be temporarily excluded from attending Head Start classes until they show proof of an appointment for their annual medical or dental exam required by the State Medicaid\EPSDT periodicity schedule?

I – 060 If a 16 year old is pregnant, not working and living at home with her parents, how do we determine income and family size?

I – 061 If a child has been in Head Start for two years, if that child is age eligible for a third year income eligibility must be re-verified. If the family’s income is now above the poverty line, must we serve these children as "over-income" or can the program choose not to provide a third year of service and, instead, enroll a child who is income eligible?

I – 062 Can a parent who is not regularly living in the household of the Head Start child be counted as part of that child’s family for purposes of determining income eligibility?

I – 063 If a family seeking to enroll their child in Head Start has just started receiving TANF benefits, how does a program determine that child’s income eligibility?

I – 064 In calculating average daily attendance does a program use funded or actual enrollment?

I – 065 Can a child who is eligible for kindergarten attend Head Start half-day while attending kindergarten the other half of the day?

I – 066 A child, living with his mother, was enrolled last year as an income-eligible child, based on the child’s mother’s income. Over the summer, the child’s father received custody of the child. Does the child’s family income need to be re-verified?

I – 067 If a foster family receives $2,900 a month for the care of an 18-year-old girl with a disability and the girl has a child that she wants to enroll in Head Start, do you count the income received by the foster family in determining Head Start eligibility?

I – 068 A family receiving SSI benefits is categorically eligible for Head Start. Is this true for all Social Security programs; i.e. Retirement, Survivors and Disability Insurance, etc.?

I – 069 If a Head Start program enrolls two children from an "over-income" family are both children counted against the 10% over-income limitation?

I – 070 In the beginning of the program year, a Head Start program takes two days that are used as a gradual entry for children starting the program. Half of the children come one day for 3.5 hours and the other half come the other day for 3.5 hours. Can we count those two days as service days to children?

I – 071 Sometimes, a prospective child’s situation changes in the 12 months prior to the time the child is being considered for enrollment. For example, a child’s guardian may change, or the child may be placed in or removed from foster care. How does a program determine income eligibility in these situations?

I – 072 If a Head Start sibling receives Social Security survivor benefits, does this need to be included as income in determining the family’s income eligibility for Head Start?

I – 073 If the number of 4-year-olds in our Head Start program has declined because many families are enrolling their child in the state pre-K program, can a program request an enrollment reduction given the maximum class size for three-year-olds is less than that for four-year-olds?

I – 074 Where parents have joint custody of a child, the parents live in different communities and the child spends alternating months with each parent, can we enroll the child knowing the child will be absent 50% of the time?

I – 075 If we have a single parent who is not working, can we use a full-day slot for their child?

I – 076 A parent has decided to hold their child back a year from entering kindergarten. Can such a child be enrolled in a Head Start program?

I – 077 If an Early Head Start child’s mother becomes pregnant, does the mother have to reapply for her second child?

I – 078 If a Head Start mother is married, but separated, does the income of the child’s father need to be counted in determining eligibility?

I – 079 Is there anything in the Head Start Act or Performance Standards that prevents a child from being enrolled in both Head Start and their State-funded preschool program?

I – 080 Are “homeless children” eligible for Head Start?

I – 081 What is the definition of “homeless children”?

I – 082 What kinds of pay and allowances of members of the uniformed services are not counted for purposes of determining the eligibility of dependents for Head Start programs?

I – 083 Am I to understand then that a 3-year-old who is income eligible (below poverty) would automatically have priority over a 4-year-old who falls into the 130% category?  If, as determined by the agency’s priority point system, an over-income child has more points than an income-eligible child then does an income-eligible child automatically have priority above the over-income child despite the points? (Assuming, of course, that the point system assigns higher points to children who meet poverty guidelines.)    

I – 084 What is the process for converting HS slots to EHS slots?

I – 085 What is required for documenting/proving homelessness?

I – 086 What type of living situation typically qualifies a child to be "homeless"? Also, what is the definition of "substandard housing"?

I – 087 We have some families that either lack documentation that could be used to determine family income or have documentation that does not seem to be accurate. How should we handle this type of situation?

I – 088 Are Migrant and Seasonal Head Start programs responsible for prioritizing homeless children?

I – 089 What are the general eligibility requirements for Early Head Start and Head Start?

I – 090 Who should grantees include in their monthly enrollment reports?



OHS – PC – I – 001

Can three year old children be enrolled in the middle of the school year?

A program with a mid-year vacancy may fill that vacancy with a child who is three years of age. However, programs should consider several factors when deciding whether or not to enroll this child.

The regulations at 45 CFR 1305.6(b) authorize consideration of a child’s age in programs’ selection criteria. Grantees should consider that by enrolling this child in early spring, for example, they are in effect committing to providing that child 2 ½ years of service (i.e. the remainder of the current program year and the next two program years) as the child will not be kindergarten eligible until the fall two years after he/she has been enrolled.

If there are unserved older children on the waiting list, grantees should give serious consideration to enrolling these children so that they receive the benefit of some Head Start experience before entering school. Grantees should also consider the appropriate placement of a child who will probably be the youngest in the classroom and may well be in a class with many children who could be nearly two years older. Grantees must also be able to assure the curriculum they are using would be appropriate for a younger child. However, if after considering these factors the grantee determines its best (or perhaps only) choice is to enroll the now-three year old, it has the authority to do so.

Requirement

45 CFR 1305.6(b)

March 15, 2007
Revised April 30, 2007

OHS – PC – I – 002

Which government programs qualify as public assistance for determining Head Start eligibility?

Temporary Assistance to Needy Families (TANF) and Supplemental Security Income (SSI) are the only two programs which qualify as public assistance for determining Head Start eligibility. For more information on TANF please see Program Instruction ACYF-PI-99-06. For additional information on SSI please see OHS – PC – I – 016.

Requirement

Sec. 645(a) of the Head Start Act

March 15, 2007
Revised April 27, 2007

OHS – PC – I – 003

Is it appropriate for a kindergarten-eligible child with a disability to stay in Head Start an additional year?

An additional year in Head Start may be an appropriate placement for a kindergarten-eligible child with a disability if this decision is supported by the parent and the IEP team. However, this should be an infrequent event, designed to meet the individual needs of a child and consistent with the recommendations of the IEP team including, of course, the parent/guardian.

This situation requires a close look to assure that it represents a sincere effort to individualize for a specific child and does not encourage routinely delaying kindergarten enrollment for Head Start children with disabilities. There should be a clear rationale offered for the placement in terms of benefits to the child's development.

Parents should be presented with a clear choice of viable options, i.e., a description of how the kindergarten placement would be structured in comparison to an additional Head Start year. Parents should recognize that they have the right to revisit their decision for Head Start placement during the next school year. They have the right to reopen the IEP at any time and may wish to plan for reconsideration at regular intervals. The LEA must be continuously involved in creating a carefully individualized placement. Also, careful consideration must be given to the fact that by providing one child in Head Start an extra year, an opening for another child in the community is made unavailable.

Informal Guidance

July 11, 2006

This Policy Clarification is currently under review.

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