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Responding to Head Start Grantee Questions on COVID-19: Volume May 21, 2020

The Office of Head Start (OHS) is empowering grantee leadership to make decisions that support Head Start children and families first, and also help others in need. OHS has received many questions from grantees seeking approval for local decisions about operations. OHS provides general guidance below. Grantees may join the MyPeers community to discuss particular situations with their colleagues.

Q1: Will stimulus payments authorized under the Coronavirus Aid, Relief, and Economic Security (CARES) Act and unemployment compensation payments made to individuals who have lost employment during COVID-19 count as income for Head Start eligibility purposes?
A1: OHS does not consider CARES Act payments or "stimulus payments," officially called recovery rebates, as income for program eligibility determination.The CARES Act recovery rebates are refundable tax credits paid in advance and, therefore, not considered income. Emergency unemployment compensation payments established by the CARES Act are also excluded when establishing Head Start income eligibility. The CARES Act payments are new short-term, federally funded assistance directly related to the COVID-19 pandemic and thus are treated differently than regular unemployment compensation for purposes of Head Start eligibility.

Q2: Should Head Start grantees continue to pay partners in Early Head Start-Child Care (EHS-CC) Partnership grants? Should they continue making payments to child care contractors?
A2: Head Start grantees should continue making payments to child care partners. While Head Start grantees continue to receive full grant funding, grantees are expected to abide by existing agreements, including all previously agreed-upon payments. Head Start children will need an enrollment space to return to upon resumption of services. Continuation of payments to child care partners will support EHS-CC Partnership programs in ensuring the availability of Head Start slots when programs re-open. Grantees should review their partnership agreements, and unless the agreements contain prohibition language, continue to pay partners.

Q3: What if staff are shared with other programs and Head Start only pays part of an employee's wages and benefits?
A3: Under normal operations, the cost of wages and benefits for agency staff whose services are shared between Head Start and other funding sources is allocated to the various funding sources based on the extent of benefit each program receives from the work. While sites are closed due to COVID-19, Head Start funds can only be used to pay the portion of staff wages and benefits that would have been paid prior to closure, unless the employee takes on additional Head Start duties on account of site closure. If additional Head Start duties are assigned, wages and benefits charged to Head Start should be adjusted accordingly. Grantees should review their own policies and procedures, consult state wage and hour requirements, and review the Family and Medical Leave Act (FMLA) and the CARES Act regarding ongoing availability of benefits to employees whose wages and benefits are not fully allocable to Head Start. If the non-Head Start portion of wages and benefits cannot be paid by another source, it may be in the employee's interests to apply for unemployment benefits. In most states, an employee can receive both wages and unemployment benefits if the wages do not exceed applicable thresholds and are disclosed to the unemployment provider.

Q4: Can staff continue to be paid with Maternal, Infant, and Early Childhood Home Visiting (MIECHV) funds as well as Head Start funds?
A4: Yes, MIECHV funds can be used to pay staff wages and benefits during this time. Please refer to previous OHS guidance and U.S. Health Resources and Services Administration's (HRSA) MIECHV guidance.

Q5: May programs hire staff if they are not able to get required health screenings?
A5: A candidate for hire may begin working virtually, even if they are not able to get required health screenings, if it is a sensible decision for the grantee. However, all required health screenings for new hires must be completed prior to the employee coming into in-person contact with children, families, and staff.

Q6: If state or local fingerprinting offices have been closed indefinitely due to COVID-19, do grantees still need to comply with background check requirements?
A6: To comply with current Head Start Act requirements found at Section 648A(g), grantees must continue to complete a criminal record check prior to hiring a new individual. Despite the current closures of state and local fingerprinting offices, the name-based check can be completed using an internet-based background check service. The comprehensive background check requirements found in the Head Start Program Performance Standards(HSPPS), which include fingerprinting, are scheduled to go into effect Sept. 30, 2021.

Grantees required to comply with the updated Child Care and Development Block Grant Act requirement on background checks should check with their individual states. State Child Care and Development Fund administrators are making state-based decisions about waivers of background checks for licensed programs during the COVID-19 pandemic. Many states are accepting the same name-based checks referenced above, in addition to encouraging providers to check the National Sex Offender Public Website.

Q7: How will programs be held accountable for requirements such as screenings, assessments, data collections, and enrollment?
A7: Most Head Start sites and communities have been closed for several weeks and may remain closed for some time. OHS expects programs to take actions that are feasible, reasonable, and safe in terms of continuing to provide services and implementing management and oversight systems. OHS will not hold programs accountable for requirements that are not possible or reasonable for them to achieve during the current closures. OHS expects programs to maintain records of services they provided and those that were not provided. Many grantees have found it helpful to join the MyPeers community to discuss particular situations with their colleagues.

Please be advised that no Head Start requirement or HSPPS will be waived where failure to comply results in unreasonable risk to the health and safety of children, or constitutes fraud or misuse of federal funds. Grantees must be able to assure the safety of children in their care and financial accountability for funds and property.