INew Head Start Program Performance Standards:
Safety Practices

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Sangeeta Parikshak: Hi, I'm Sangeeta Parikshak.

Marco Beltran: And I'm Marco Beltran.

Sangeeta: We're here today to talk to you all about the safety practices section of the Head Start Program Performance Standards. So Marco, why don't you kick us off today? We all care a lot about keeping our children safe and secure. The overall goal of the safety practices section is to provide the foundation on which programs build safe, high quality environments Could you let us know what the overarching major change is that strengthens safety practices for children and the new standards are, and where we can find them?

Marco: Sure. The safety practices standards can be found in 1302 Subpart D, specifically 1302.47. In general, we feel that basic health and safety practices are essential to ensuring high-quality care, so we propose strong safety practices and procedures that will ensure the health and safety of all children. In some instances, we moved away from prescribing extensive detail when such level regulation is unnecessary in order to maintain a high standard of safety, and too inflexible to allow program's  growth as it relates to maintaining quality care. This flexibility allows programs to adjust their policies and procedures according to the most up to date information about how to keep children safe. Good examples of that are medication administration, hygiene, and first aid. In addition, this section includes health and safety requirements for facilities, equipment, background checks, safety training, safety practices, administrative safety procedures, and disaster preparedness plans. Sangeeta, can you tell us how safety practices standards address ongoing administrative oversight, and staff training, as it relates to safety practices?

Marco: Sure, so the standards actually place greater emphasis on administrative oversight and staff training than in previous standards. Particularly, if you look at 1302.47, paragraph A, the standards require that programs establish and train staff on, implement, and enforce, health and safety practices that ensure children are safe at all times. So like I said earlier, this places greater emphasis on the ongoing administrative oversight and staff training, and should lead to better systems and practice when implemented. Before we talk about what a program must do to ensure child safety, Marco, I know that the Performance Standards make reference to Caring for Our Children Basics. Can you tell us what that means for programs?

Marco: To ensure programs are equipped with adequate instruction on how to keep children safe at all times, we indicated that programs should consult Caring for Our Children's Basics. Caring for Our Children Basics is a set of recommendations which is intended to create a common framework to align basic health and safety efforts across all early childhood settings. Caring for Our Children Basics seeks to reduce the conflicts and redundancy found in program standards linked to multiple funding streams.

Caring for Our Children Basics should not be construed to represent all standards that should be present to achieve the highest quality of care in early learning. For example, the caregiving training requirements outlined in these standards are designed only to prevent harm to children, not to ensure the optimal developmental learning. Caring for Our Children Basics is based on the Caring for Our Children National Health and Safety Performance Standards, Guidelines for Early Care and Education Programs. Caring for Our Children Basics contains only a subset of the recommendations included in the third edition of Caring for Our Children.

Sangeeta: I know that programs are eager to get a copy of Caring for Our Children Basics, can you let our viewers know how they can find that?

Marco: Sure. There's no cost associated with purchasing anything related to Caring for Our Children 

Basics. Caring for Our Children Basics can be downloaded from the ACF website, or from the ECLKC.

Sangeeta: Thanks, Marco.

Marco: So Sangeeta, what must a program do to ensure health and safety?

Sangeeta: So the requirements are informed by the latest research and best practice. If you look at 1302.47, paragraph B, we require that a program develop and implement a system of management, including ongoing training, oversight correction, and a continuous improvement that includes policies and practices to ensure all health and safety requirements for facilities, equipment and materials, background checks, staff safety training, safety practices staff must follow, hygiene practices, administrative safety procedures, and disaster preparedness plans are adequate to ensure child safety. I know that a lot of what I just mentioned has been required in the past, so Marco could you let our viewers know what are some examples of how things are different in the new standards? 

Marco: Sure. One of the biggest difference is that the standards related to health and safety are now in the same place. Before, we had two very distinct sections, one that addressed health and safety as it relates to children, and one that was titled Facilities, Materials, and Equipment. We feel that this reorganization is less confusing and clearly delineates the steps programs are required to take to provide safe environments for all children. Another difference is that we eliminated the overly prescriptive requirements in favor of flexibility for programs to adjust their policies and procedures as they see fit.

Sangeeta: Actually, Marco, the medication administration has been used as an example recently, of how safety practices have been developed to be less restrictive. Can you give us some more information?

Marco: Right, previously we instructed programs to establish and maintain reading procedures regarding the administration, the handling, and the storage of medication for every child throughout the program. We weren't giving them any flexibility. Now, we give them a little bit of that flexibility, so that they're able to assess the regulations as they see fit, according to their state requirements, so it makes it a lot easier for programs to do what the need to as it relates to medication administration. Sangeeta, why are background checks now included in the safety practices? They weren't included there in the past. 

Sangeeta: So like medication administration, background checks are just as important to ensure child safety. I want to let programs know that they have until September 30th, 2017, to comply with all new background check requirements in the Head Start program performance standards. This new effective date, we hope, will be beneficial in many ways. It aligns with the background check requirement deadlines for systems in the Childcare and Development Block Grant, or CCDBG Act of 2014. It also will  afford programs more time to implement systems in accordance with these requirements. If you have more questions or you want to learn more about the background checks, we actually have some more information in a different video, so check it out in the personnel policies video under Human Resources in the showcase. Marco, I mention CCDBG earlier. We know that state licensing requirements are regulatory requirements established under state law necessary for a provider to legally operate and provide childcare services. What does this mean for Head Start programs?

Marco: What this means is that for the past several years, we know that many states have made changes to the licensing regulations for center-based and for family childcare programs. It was always a bit confusing for our Head Start programs, as to what these changes meant for them. In order to address the confusion, we want to be clear in the standards, so we require that all facilities for center-based programs meet licensing requirements, and all family childcare programs be licensed, to maintain a minimum level of safety. This section references the proposed requirements, which are found in 1302.21(d)1, for center-based programs, and 1302.23(d) for family childcare programs. Sangeeta, can you tell us about the safety training that staff and programs must have?

Sangeeta: Sure, Marco, so since we take the safety of our children very seriously, we also take the training of our staff incredibly seriously as well. Staff with regular contact with children must have an initial orientation training, within three months of hire, and ongoing training in all state, local, tribal, federal, and program developed health, safety, and childcare requirements to really ensure the safety of children in their care. The standards actually include a pretty lengthy list. Some examples of some  of the trainings that are required have to do with the prevention of shaken baby syndrome, abusive head trauma, and child maltreatment. Please check out that list to make sure that all of the training is covered.

Marco: You mentioned staff with regular contact with children. What about staff in the programs that do not have regular contact with children?

Sangeeta: So staff with no regular responsibility for contact with children need to have an initial orientation training within three months of hire, so similar to those that do have regular contact with children. They also have to have ongoing training in all state, local, tribal, federal, and program developed health and safety requirements that are applicable to their work, and training in the program's emergency and disaster preparedness procedures. Finally, Marco, do the standards require safety incidence reporting?

Marco: Yes, in paragraph C, the standards require all programs to report any safety incidents, that the program must submit reports, as appropriate, to the responsible Health and Human Services official immediately or as soon as practical, relating to any incidents affecting the health and safety of program participants. Additionally, safety practices related to background checks, standards of conduct including the Head Start specific supervision requirement, and prohibitions on seclusion and restraint, the
vaccination and transportation are retained and strengthened in the appropriate sub-parts throughout the proposed standards, to ensure child safety.

Sangeeta: Thank you, Marco. This concludes our safety practices video. We hope that this has been very informative for all of you. We really appreciate you tuning in. Thank you so much for being here with me, Marco.

Marco: Thank you, Sangeeta.

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