COVID-19 and the Head Start Community

Funding and Administrative Flexibilities

Most Head Start sites and communities have been closed for several weeks and may remain closed for some time. The Office of Head Start (OHS) expects programs to take actions that are feasible, reasonable, and safe in terms to continue providing services and implementing management and oversight systems. The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided $750 million for programs under the Head Start Act to support preventative, preparedness, and responsive activities during the pandemic. Several administrative flexibilities are available to Head Start grantees during the COVID-19 pandemic. Programs should maintain documentation to address any variations in their normal fiscal practices made in response to the COVID-19 outbreak. This section is regularly updated with the most relevant guidance and resources. Recent Updates lists all published resources.

Funding

The CARES Act, 2020 (P.L. 116-136), provided $750 million for programs under the Head Start Act, including up to $500 million for supplemental summer programs. All CARES Act funding, including for voluntary summer programs, will be distributed as one-time funding by formula based on each grantee's funded enrollment. OHS provides updated guidance so all grantees can respond to the unique and constantly evolving circumstances within their communities during the COVID-19 pandemic in ACF-PI-HS-20-04 Update to Funding for FY 2020 Supplemental Funds in Response to the Coronavirus Disease 2019 (COVID-19).

Administrative Flexibilities

Due to the impacts of COVID-19 during the program year, OHS eliminated the reporting burden of the 2019–2020 Program Information Report (PIR). It was not required. The submission of the 2020–2021 PIR is still required. To address concerns about how to report certain program data, a guidance document for completing the 2020–2021 PIR in response to COVID-19 is now available.

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 Head Start Program Performance Standards (HSPPS) requirement will be waived where failure to comply either 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.

ACF-IM-HS-20-03 Coronavirus Disease 2019 (COVID-19) Fiscal Flexibilities provides guidance related to fiscal flexibilities and waivers affecting grant applications, no-cost extensions, allowable costs, an extension of certain deadlines, procurement, prior approvals, indirect cost rates, and single audit submissions.

Fiscal Management During the COVID-19 Emergency (Webinar: 5/22/2020)
OHS leadership discusses the dissemination of the CARES Act supplemental funds. They also address strategies and flexibilities for fiscal management programs should employ while responding to the COVID-19 pandemic.

Fiscal Management During the COVID-19 Emergency: A Follow-Up Conversation (Webinar: 5/29/2020)
In this follow-up presentation, OHS leadership responds to grantee questions regarding fiscal management during the COVID-19 pandemic. There is a special focus on ACF-IM-HS-20-03 COVID-19 Fiscal Flexibilities and ACF-PI-HS-20-04 Update to Funding for FY 2020 Supplemental Funds in Response to the COVID-19.

In addition, the guidance from ACF-HS-IM-19-01 General Disaster Recovery Flexibilities applies to programs impacted by COVID-19. Although there are no formal waivers for the number of days of service provided via center-based programs, or number of home visits and socializations provided via home-based programs, programs will not be expected to make up the days missed due to COVID-19.

The following waivers are available, as provided in the Head Start Act:

  • Programs may request a waiver of all or part of their 20% non-federal share based on emergency or disaster because other organizations may not be able to provide the usual contributions to Head Start grantees during this time.
  • Programs may request a waiver of the 15% administrative cost limitation if additional program management attention is needed to respond to the COVID-19 outbreak.
  • Procurement may be undertaken without utilizing the grantee's usual competitive practices if necessary to respond to COVID-19.

Subpart A – Financial Requirements, 45 CFR §1303: FAQs from OHS CAMP Session 6

Q1: What costs are allowable during the COVID-19 pandemic? For example, can programs purchase thermometers for temperature checks, reimburse staff for internet services, or reimburse the Policy Council for paper and internet used for virtual meetings? Factors affecting allowability of costs, 45 CFR §75.403 
A1: The principles for establishing the allowability of costs has not changed due to the COVID-19 pandemic. The cost principles require programs to ensure their costs are reasonable considering the circumstances at the time of their spending decisions. Given the circumstance, an expense is reasonable if it is necessary to deliver services to enrolled children and families. All goods and services noted above may be allowable if they relate to the delivery of services to enrolled children and families, whether center-based, remote, or some combination of the two. Adequate documentation must always be maintained to demonstrate compliance with cost principles.

Q2: If high-risk staff work remotely and it results in a diminishment of duties and responsibilities, is their pay expected to be adjusted accordingly? Compensation – personal services, 45 CFR §75.430 
A2: Staffing decisions should be made in consideration of current and projected service delivery options and associated staffing needs. Staff work assignments and compensation are locally determined decisions. Programs need to review applicable wage and hour laws and their approved personnel policies and procedures. Programs should work with human-resource and legal professionals to make reasonable and legally sound decisions about staff salaries and benefits. Programs must take responsibility for making staffing decisions that meet the needs of enrolled children and families.

Q3: Is furlough an option? We don't want to lose the effort and funds expended on the development of the employee. Compensation – fringe benefits, 45 CFR §75.431
A3: Before a program makes a determination to furlough staff (meaning the program is requiring staff to take unpaid leave while still considered employees), the program must review its personnel policies and procedures to assess whether furloughs are currently addressed. The availability of unemployment compensation benefits for employees placed on forced leave without pay should also be considered. Programs that do have policies governing the use of furloughs should ensure there is full adherence to the legal requirements and an understanding of other consequences that could result.

Q4: If programs have bus drivers or kitchen staff whose jobs cannot be done from home, should they place them on unemployment insurance? Compensation – fringe benefits, 45 CFR §75.431
A4: We recognize that staff wages and benefits are a major cost in any Head Start or Early Head Start budget. In making staffing decisions, the first question a grantee must ask is what staffing is needed to support program services, now and in the upcoming months. For example, could the program make a planned shift from remote to center-based services without cooks and bus drivers? Important decisions — such as work assignments, hours worked, payment of wages and benefits, layoff, or separation from employment — impact the program, its budget, and individual employees. They should be made in consultation with fiscal, human-resource, and legal professionals.

Q5: Would hazard pay come from the program's current budget? What if the current program budget is unable to support the costs of hazard pay? Will additional funds be available to programs to apply for? Compensation – personal services, 45 CFR §75.430; Compensation – fringe benefits, 45 CFR §75.431
A5: If a grantee believes that a salary incentive such as hazard pay is warranted, the hazard pay must be supported by the grantee's written policies and procedures and comply with the compensation requirements of the Uniform Guidance within 45 CFR §§75.430 and 431. If the hazard pay is necessary to prepare for, respond to, or recover from the COVID-19 pandemic, it can be paid with CARES Act one-time funds or with base grant funds. No additional COVID-19 funding opportunities are anticipated.

Q6: Must grantees pay staff salaries if they test positive for COVID-19 or require them to use sick leave? Compensation – personal services, 45 CFR §75.430; Compensation – fringe benefits, 45 CFR §75.431
A6: Programs should have pre-existing policies and procedures to address leave and wages for staff diagnosed with communicable diseases. Programs must follow (or develop if needed) their own personnel policies and procedures to address how the program will address employees testing positive for COVID-19. Consider local, state, and federal laws, rules, and regulations applicable to staff illness and pay.

Q7: What does the in-kind requirement look like for 2020–2021 program year? Will programs be mandated to meet the 20% non-federal match requirement? Federal financial assistance, non-federal match, and waiver requirements, 45 CFR §1303.4 
A7: The ways programs have often met the in-kind requirement may not be available at this time. For example, many programs have relied on parent volunteer hours to support their match requirement, and those hours could be significantly lower this program year. We encourage programs to be innovative in how they contribute to the match requirement during the 2020–2021 program year. However, under the existing authority from the HSPPS, programs can always request a waiver of all or a portion of the match requirement at any time during their current budget period.

Q8: When parents volunteer virtually, what is the best way to document in-kind for their time? Federal financial assistance, non-federal match, and waiver requirements, 45 CFR §1303.4
A8: Existing guidance on the valuation of in-kind contributions remains a helpful reference even when volunteer time is spent virtually. Volunteer hours must be calculated at the rates of other employees who perform similar work, such as a teacher's aide or teacher's assistant, for documenting in-kind contributions. Additional information is available on the Volunteer Services page, which includes an excerpt from HHS Grants Policy Statement.