From the OHS CAMP: Session 2
Q1: If state or local fingerprinting offices have been closed indefinitely due to COVID-19, do grantees still need to comply with background check requirements? Personnel policies, 45 CFR §1302.90(b) (Background checks and selection procedures)
A1: At a minimum, grantees must comply with current Head Start Act requirements found in Section 648A(g), which states grantees must complete a criminal record check prior to hiring a new individual. Although many state and local fingerprinting offices may still be closed, a 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 that are required to follow their state licensing regulations to comply with the updated Child Care and Development Block Grant Act requirement on background checks should check with their individual state licensing department about additional requirements. At this time, the federal Office of Child Care has approved waivers on various components of the comprehensive background checks for nearly half the states and territories. Child Care and Development Fund (CCDF) 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 internet background check referenced above, in addition to a check of the National Sex Offender Public Website.
Q2: Are programs expected to continue to meet coaching requirements? Training and professional development, 45 CFR §1302.92(c)
A2: Yes, programs must continue to meet the intensive coaching requirements of the HSPPS, which require programs to identify staff who need intensive coaching. Implementing these intensive coaching requirements might look different during the 2020–2021 program year, as some programs may modify their program options and schedules. Programs providing center-based, home-based, and family child care services should consider how to continue coaching while limiting exposure of other adults to children and teaching staff. To reduce the risk of spreading COVID-19, programs may want to consider other ways to provide coaching, such as remote or virtual coaching for individuals or groups. If programs provide virtual education services to children, they could also consider providing virtual observations of education staff and virtual coaching visits.
OHS continues to provide strategies and resources to support programs in this area and encourages programs to reference the Head Start Coaching Companion. The ECLKC also provides professional development resource topics (e.g., practice-based coaching, teaching, home visiting strategies) that can support all staff, including education staff that does not receive intensive coaching.
Q3: If staff are at increased risk for severe illness from COVID-19, how can programs prioritize their safety?
A3: This is a very challenging time for staff and staff whose family members are part of populations identified by CDC as being at a higher risk of serious illness or needing extra precautions from COVID-19. For staff who are at a higher risk, programs should carefully consider whether those staff can continue to fulfill their duties if they are unable to return to in-person work environments or can perform needed and necessary work in alternative environments. For instance, if programs provide some virtual services, they could assign those staff to teach or provide home visits or other services in the virtual environment. Programs should make every effort to align available positions with the strengths and needs of existing staff.
Q4: If programs are providing virtual services to enrolled children and families, how can they continue to promote effective communication with families with limited English proficiency? Personnel policies, 45 CFR §1302.90(d) (Communication with dual language learners and their families)
A4: Programs must continue to ensure staff are able to communicate effectively with children who are dual language learners (DLL), either directly or through interpretation and translation. Families may have limited English proficiency, and no staff members speak the family's home language. In these cases, programs should ensure effective communication with the family in their home language through use of community partners, consultants, interpreters, and virtual technology options. Culturally and linguistically appropriate communication plans must address services to meet the unique needs of each family within the program.
Q5: Must programs ensure that all staff members receive the required 15 clock hours of professional development during the 2020–2021 program year? Training and professional development, 45 CFR §1302.92(b)(1)
A5: Yes, programs should ensure all staff members receive the required 15 hours of professional development during the 2020–2021 program year. Programs must continue to provide ongoing training and professional development to support staff in fulfilling their roles and responsibilities. Programs may consider modifying individual and programwide professional development plans in response to programmatic changes.
OHS offers many online learning modules on the ECLKC where staff can earn continuing education units (CEUs) and certificates of participation through the Individualized Professional Development (iPD) Portfolio and Early Educator Central. Resources on culture and language (including webinars) are available to support staff in their efforts to effectively communicate with families who are DLLs.
Q6: Programs may have fewer staff members or new staff. How can we mitigate incidents of maltreatment or children being left unattended? Personnel policies, 45 CFR §1302.90(c) (Standards of conduct)
A6: Programs must ensure sufficient supports exist to detect and mitigate inappropriate teacher-child interactions that could result in maltreatment or a child being left alone. Incidents of maltreatment or a child being left unattended are often related to insufficient support of staff who are overwhelmed or lack the skills necessary to consistently implement positive strategies to support children's well-being and safety. Programs must recognize this coming year will be challenging, particularly as centers open and staff, parents, and children learn new health and safety procedures. Programs need to plan to support staff accordingly.
Q7: May programs hire staff if they are not able to get required health screenings? Staff health and wellness, 45 CFR §1302.93(a)
A7: If it is a sensible decision for the grantee, a candidate for hire may begin working virtually, even if they are not able to get required health screenings. 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.
Human Resources Management, 45 CFR §1302: FAQ from OHS CAMP Session 3
Q8: If a center-based program transitions to home-based due to COVID-19, will center-based teachers be required to have a home-based CDA credential? Staff qualifications and competency requirements, 45 CFR §1302.91(e)(6)
A8: No. During the 2020–2021 program year, a center-based teacher who provides home-based services does not need to obtain a home-based CDA credential. Programs are encouraged support teachers who recently started working with families in a home-based environment. There are free online courses that highlight best practices for connecting with families in the home-visiting environment.
For additional resources to support teachers providing home-based services, refer to Staff Resources for Remote Services.
Human Resources Management, 45 CFR §1302: FAQ from OHS CAMP Session 6
Q9: For programs with teaching staff completing their Child Development Associate (CDA) credential and needing observations, how can they complete this requirement if in-person observations cannot be completed at this time? Staff qualifications and competency requirements, 45 CFR §1302.91
A9: Programs should seek out information from the Council for Professional Recognition, the agency that administers the CDA, to obtain details on the process for completion of the CDA requirements. If observations cannot be done, the program should document why the completion of the CDA has been delayed.
Last Updated: December 9, 2020