In recognition of the unique circumstances associated with COVID-19, OHS is directing programs to continue to pay wages and provide benefits for staff unable to report to work during center closures necessary to address COVID-19. Programs do not have the discretion to deny staff their regular wages and health benefits. Regardless of what staff can do remotely, all staff should be paid for hours they normally worked before the closure.
Supporting your Head Start staff by continuing to pay them is a critical factor in mitigating the fiscal crisis, recognizing their valuable work, and ensuring that staff are in place when services resume. This emergency response flexibility is also important to ensure critical grants management activities can continue during closures. While we understand some staff may need to come into their office or center for essential and critical work, it is irresponsible for any grantee to require most staff to report to work during program closures as it heightens the risk of spreading the COVID-19.
This flexibility remains in effect through June 30 or the date upon which programs reopen for center-based services, and employees return to regularly scheduled onsite work, if sooner. This directive does not apply to non-COVID-19 related program closures during which employees would not otherwise be paid, such as summer breaks. OHS will continue to monitor program closures and may adjust the effective date of this flexibility as needed.
To the extent possible, employees should continue to engage families and to deliver critical services remotely during center closures. However, we understand that some staff are able to be more engaged than others when centers are closed. Continuing payment of wages and benefits are not contingent on the ability to work during this crisis.
Q1: 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?
A1: 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.
Q2: What if staff are shared with other programs and Head Start only pays part of an employee's wages and benefits?
A2: 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.
Q3: Can staff continue to be paid with Maternal, Infant, and Early Childhood Home Visiting (MIECHV) funds as well as Head Start funds?
A3: 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.
Topic: About Us
National Centers:Office of Head Start
Last Updated: May 27, 2020