COVID-19 and the Head Start Community

Program Structure

The COVID-19 pandemic has impacted Head Start program options and schedules, service duration, group sizes, and staffing. These responses are designed to support Head Start program planning and decision-making for the 2020–2021 program year. This section is regularly updated with the most relevant guidance.

Program Structure FAQs from the Office of Head Start CAMP: Session 1

Q1: Are programs expected to operate the program options they are funded to operate? If the Office of Head Start (OHS) allows flexibility in program options, what is the accompanying waiver process? Determining program structure, 45 CFR §1302.20
A1: No, all programs should reassess the options they operated before the COVID-19 pandemic to determine what options or combination of options, including locally designed options, will work best for the 2020–2021 program year. Programs may determine it is not safe or feasible to provide center-based or home-based services at their pre-COVID-19 capacity. Since group sizes in centers will likely be smaller, programs may choose to provide home-based and virtual services for some or all enrolled children. Those service decisions could change throughout the 2020–2021 program year as local conditions improve and stabilize. Programs do not have to obtain a waiver before changing program options for the 2020–2021 program year. Instead, programs are required to notify their program specialists using the correspondence tab in the Head Start Enterprise System when changes in program structure are implemented.

Q2: To promote physical distancing and overall health and safety, what flexibilities will OHS allow for program schedules and service duration for center-based and family child care programs? Center-based option, 45 CFR §1302.21; Family child care option, 45 CFR §1302.23 
A2: Yes, OHS will allow flexibility in program schedules and service duration that ensure center-based and family child care programs meet physical distancing guidance and the overall health and safety needs of children. Such changes may include reducing the number of hours per day or days per week that children receive services. Programs should carefully consider state and local health and safety guidelines, as well as the individual needs of their children and families. For instance, programs that serve a large number of working families should balance health and safety with the needs of their families to have high-quality care for children during working hours. For enrolled children who cannot be served in the center, programs should provide alternative services, such as home-based, virtual, or other grantee-determined service delivery options.

Q3: Are there consequences if programs cannot conduct the required number of home visits in home-based programs? Home-based option, 45 CFR §1302.22
A3: No, due to the COVID-19 pandemic, home-based programs may not be able to conduct the required number of home visits in person during the 2020–2021 program year. To the extent possible, programs should provide the required number of home visits to each enrolled family. This can be done through virtual services, a combination of virtual and in-person services, or other creative options, such as conducting home visits in outdoor spaces, if safe and feasible. If programs conduct in-person visits, home visitors should comply with physical distancing and other related health and safety requirements. Programs will not be penalized if they are unable to achieve the required number of home visits during the upcoming program year, whether in person or virtual. This also applies to the required home visits for children in center-based programs.

Similarly, home-based programs may not be able to conduct all required group socializations in person. Programs are encouraged to be creative in conducting them. As they may be more difficult to conduct during the COVID-19 pandemic, programs will not be penalized if they are not able to achieve the required number of group socializations, whether in person or virtual, in the 2020–2021 program year.

Q4: Are center-based programs required to meet their typical service duration for the 2020–2021 program year? Center-based option, 45 CFR §1302.21(c) (Service duration)
A4: No, as programs adapt their program schedules in response to the COVID-19 pandemic, OHS does not expect that center-based programs will be able to meet their typical service duration for the 2020–2021 program year.

Q5: What are the OHS requirements or recommendations for center-based classroom group sizes during the COVID-19 pandemic? Center-based option, 45 CFR §1302.21(b) (Ratios and group size)
A5: Programs need to follow state and local guidance on physical distancing and must protect the health and safety of children and staff, which will very likely result in reduced group sizes in center-based programs. In general, programs should consult official state and local guidance to make decisions on appropriate group sizes. To safely serve children, programs have the flexibility to decide that group sizes need to be smaller than state or local guidance. When making decisions, programs should determine the square footage needed to maintain physical distancing between children. Programs must consider the additional square footage necessary for naptime when children are not wearing face coverings and need to be spaced farther apart.

Q6: If a program's state does not have specific guidelines in place regarding group sizes during the COVID-19 pandemic, how should the program implement a reduction in group sizes? Center-based option, 45 CFR §1302.21(b) (Ratios and group size)
A6: Programs should work with their health managers and Health Services Advisory Committees (HSAC) to explore different strategies and approaches to ensure they can adequately implement physical distancing in their classrooms. OHS encourages programs to consider the safety of children and staff when determining group sizes and the number of different contacts between children and staff throughout the day to reduce the risk of spreading COVID-19. Programs should consider ways they can alter their daily schedule and routines as needed to keep small groups of children and staff together during the entire program day. As much as possible, they should avoid mixing different groups of children and staff members with other groups. Programs should build in sufficient time for disinfecting procedures, as appropriate. These are difficult decisions for programs to make, and decisions will vary across states and communities. OHS remains informed on best practices and consults with experts. If necessary, we will return to this and other pressing program structure questions in future Collaborating Actively in Meaningful Planning (CAMP) Series webinars to offer additional guidance to programs.

Q7: If programs are operating with reduced group sizes, do they still need two qualified staff in each group? Center-based option, 45 CFR §1302.21(b) (Ratios and group size)
A7: Yes, two qualified staff are necessary to ensure high quality and safe environments for children in the vast majority of cases. While OHS will allow a waiver of the two-teacher provision for Early Head Start groups of four or fewer, it requires the grantee to have a second adult in the room. If a grantee believes they have a compelling reason that a teacher and teacher assistant are not necessary to ensure high-quality and safe environments in very small Head Start groups, they should discuss it with their Regional Office.
 

Q8: For family child care programs, are child development specialists still required to conduct regular visits to each family child care home at least once every two weeks? Family child care option, 45 CFR §1302.23(e)(1) (Child development specialist) 
A8: It is likely that child development specialists will be unable to conduct regular on-site visits to each family child care home during the 2020–2021 program year. Programs can choose to conduct these visits virtually. Programs should consider the preference of the family child care provider when making decisions about how to conduct these visits (in person or virtually). Keep in mind, the goal of small group sizes is to reduce exposure to other outside individuals. However, programs are expected to maintain the same frequency of visits to the greatest extent possible, whether in person or virtual.

Program Structure, 45 CFR §1302: FAQs from OHS CAMP Session 6

Q9: Would programs have to get permission from their Regional Office to use home-based services in place of center-based services during this time? Determining program structure, 45 CFR §1302.20 
A9: No, programs do not have to obtain permission from their Regional Offices to operate home-based services in place of center-based services during the 2020–2021 program year. However, programs should always document such changes and keep their Regional Office informed of changes in program services and operations. 

Q10: If programs are providing both in-person and virtual center-based services, can parents choose which days their child attends the program in person and which days children receive virtual services? Center-based option, 45 CFR §1302.21 
A10: Programs should work individually with families to make these decisions. It is important for programs offering both in-person and virtual services to communicate promptly and effectively with every parent. Parents should fully understand the services offered and the choices they have in selecting services that best meet the needs of their families. When making such decisions, programs should consider the preference of parents to the greatest extent possible. That way, they can support service delivery options that families are comfortable with during this time while continuing to provide high-quality learning opportunities for all enrolled children.

Q11: Can the grantee make decisions to reduce class size based on local data? Center-based option, 45 CFR §1302.21(b)
A11: In general, programs should consult official state and local guidance to make decisions on appropriate group size. However, programs have the flexibility to decide whether group sizes need to be smaller than recommended by state or local guidance to safely serve children. When making decisions, programs should work with their health managers and HSAC to explore different strategies and approaches for implementing safety precautions in the classroom, such as physical distancing. 

Q12: If class sizes are smaller, is it possible for the second staff person to be absent for brief periods from the classroom without interjecting a new person to the group? Center-based option, 45 CFR §1302.21(b)
A12: Yes. As has been the case during normal program operations, it is not necessary to bring in a substitute when the second staff member must be absent from the classroom for a brief period (e.g., using the restroom, walking children to the building exit). However, to ensure the health and safety of all children, if the second staff person must be absent from the classroom for a longer period of time, the program must ensure a floater or substitute staff is available to cover this absence in the classroom. We recognize that programs are working hard to implement rigorous health and safety practices to reduce exposure of children and staff to possible infection. Therefore, to minimize the number of additional staff that are introduced into any given classroom, programs are strongly encouraged to be consistent with the floaters or substitutes assigned to specific classrooms, to the greatest extent possible.

Q13: If a teacher gets sick and must leave the center midday, would the program be able to continue the day without a substitute or second adult in the classroom or would they need someone to immediately step in? Center-based option, 45 CFR §1302.21(b)
A13: In general, two staff are necessary in the classroom to ensure a high-quality and safe environment for children. Programs are reminded to consider what they would do in such a situation prior to the COVID-19 pandemic; programs should already have policies in place for ensuring safe, high-quality environments if a staff person must go home midday. We also recognize that programs are working hard to implement rigorous health and safety practices to reduce exposure of children and staff to possible infection. Therefore, to minimize the number of additional staff introduced into any given classroom while also ensuring classrooms remain safe for children, programs are strongly encouraged to be consistent with the floaters or substitutes assigned to specific classrooms, to the greatest extent possible.

Q14: If we divide the classroom space where one class is sharing the same space (e.g., dividing an Early Head Start room so that four children use one side of the room and four use the other side of the room), can each group have just one teacher if they are in the same room? Center-based option, 45 CFR §1302.21(b)
A14: Yes, this is allowable so long as the two teachers can see both groups of children through the divider. In this situation, the children on one side of the divider should not be left alone at any point, even if the teacher must step away from the classroom for a brief period. In these situations, the program should utilize floater staff to cover a brief absence by one teacher.

Q15: Will duration requirements still go into effect in August 2021? Center-based option, 45 CFR §1302.21(c)
A15: Yes, the requirement for Head Start programs to provide 1,020 annual hours of services to at least 45% of their center-based funded enrollment will still go into effect on Aug. 1, 2021. Programs are encouraged to review the Federal Register notice and Program Instruction that discuss this requirement in more detail. If we decide in the future to delay the implementation for this requirement, we will announce that to the grantee community.