Revised-Head Start Program Performance Standards:

Suspension and Expulsion

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Sangeeta Parikshak: We're here today to dive a little bit deeper into talking about Section 1302.17: Suspension and Expulsion. I'm really excited about this section actually. It's a new regulation, as you said, and what it does is it really modifies long standing practice to not expel children from Head Start programs. So, not only does it talk about prohibiting expulsion outright but it also talks about severely limiting suspension for our young children.

It's really important to highlight that it focuses on keeping children in the program. So, even if they're demonstrating challenging behaviors, which kids at this age sometimes do, we really want to do our best to help the programs to keep kids in these settings even if they have difficult behaviors. 

Catherine Hildum: Great. You mentioned that it's long-standing practice so why are we doing this now; why is it in the regulation, if the programs are doing this anyway?
Sangeeta: I think it's actually really timely that we are putting this new regulation out, because we actually have been researching suspension and expulsion for a while and now we have a lot of new research to demonstrate that actually pre-school kids are getting expelled at very high rates.

Oftentimes, when you think about expulsion or suspension you think about the kid in high school who is acting out.

Catherine: Or middle schooler kids.

Sangeeta: Right, but actually we're finding that pre-school kids are getting expelled at very high rates. The other piece of the research that we're finding is that boys of color are actually getting expelled and suspended at much higher rates than other children and that African-American girls are getting suspended at higher rates than other girls.

So, I think that it's really critical that Head Start take a lead and demonstrate, not just in long-standing practice, but also in regulations that we are going to come out very strong, not expel our children but really do the best we can to promote their social and emotional development and keep them in the program.

Catherine: Sure, making sure that they're safe and that they have the opportunity for high-quality services that Head Start provides. How does this standard address the safety of children and staff in the classroom?

Sangeeta: So, they discuss how programs must prohibit or severely limit the use of suspension due to a child's behavior but there is some flexibility. Throughout the standards, we tried to provide flexibility for every program's individual needs. So, this is an example of how we're doing that. If a child does pose a serious safety threat, then what we say is that a temporary suspension can be used as a last resort. And the focus here is really taking the steps to ensure that the child is safe, first and foremost, but also doing everything we can to help the kid remain in and benefit from program activities.  

Catherine: Okay, great. So, if a temporary suspension is necessary, what are some things programs can do to ensure that a child is able to return to the program and have the supports they need to be safe themselves and to keep the other children safe?

Sangeeta: So, through TA we have a lot of things we've been putting out and will continue to put out, but the standards actually do a nice job of highlighting what are the steps that programs must do. 

Catherine: What are some of those?

Sangeeta: Engaging with a variety of resources, that includes a mental health consultant; it includes parents; it includes other community resources such as psychologists--so really anyone that could be impacting the child in a positive way and kind of helping to support their development, we want to engage with them.

Also, it's important that programs document whatever actions and supports are needed. So, whatever they are finding out about that individual child, we want to carry it forward and have it written down in a place to help them along the way.

Catherine: So, if they continue to demonstrate behaviors then their caregivers or teachers down the road might--

Sangeeta: Might know what can be helpful for them.

Catherine: Might have some resources.

Sangeeta: Right, also providing other services, particularly, home visits. So, if a child is being suspended that means they're not in the program at that time; they're at home and so that can lead to a disconnect with the people that they see every day. So, it's important to provide those additional services, go into the home and make that connection to say you are not out of the program but you are going to be coming back soon. So, really working with them in the home environment is important. And also determining whether it may be appropriate to refer the child for an evaluation to see if they qualify for services under IDA which is the Individuals with Disabilities Education Act. 

Catherine: Okay, so that's really important. One of the things you said that I think is really important is the long-standing tie, is the family engagement and really working with the parents because they are a key part of the child's education and how they can help with challenging behaviors in particular. You also mentioned engaging mental health consultants. When should a program bring in a consultant? 

Sangeeta: That's a good question. So, within this section in 1302.17 we say that before a program determines that a temporary suspension is necessary that the program must first engage with the mental health consultant.

Catherine: Okay. 

Sangeeta: But in 1302.45 which is Child Mental Health and Social and Emotional Well-Being we actually talk more extensively about mental health consultation. And we talk about how mental health consultations should be used preventatively. Really, we talk about parental consent and how when a child is first enrolled in the program then they should be looking at mental health consultation as one of the services that are provided.

Catherine: Okay, so really from the beginning, mental health consultation is important. And that is kind of an important point as well that folks should read the Mental Health and Social Well-Being section along with Suspension and Expulsion to see how it goes together and how it's really preventing these behaviors.

You said explicitly that the standards prohibit expelling a child or unenrolling a child as some programs might do because of their behavior. What can programs do to address challenging behaviors? 

Sangeeta: The regulations also lay out steps for this as well which I think is really nice, and we are trying to be as helpful as possible. We're not trying to leave people out on the lurch.

Catherine: Sure, it's a big issue for some programs.

Sangeeta: So again, if they pose a serious safety threat we want to make sure that, at a minimum, we engage them and a health consultant; that we consider both whether a child qualifies for services under the IDA as I mentioned before but also under Section 504 of the Rehabilitation Act, because sometimes a child can qualify for services under a Section 504 and not under an IDA, due to different state definitions of what disability is.

Catherine: That's important for programs to know.

Sangeeta: Also, it's important for programs to make sure that they know whether a child has a current individualized education program or individualized family services plan. So they want to make sure if that's already in place those children are given the supports that they need upfront and that can also prevent those challenging behaviors from occurring.

Catherine: And are there cases? It seems there may be cases where there is a serious safety threat and the program has exhausted all of the steps that you mentioned and that are mentioned in the regulation and what can they do after they have exhausted all those steps? Are there options for programs?

Sangeeta: There are options; so again we want to make sure that programs collaborate and continue to collaborate with the mental health consultant, with the parents, first and foremost, with the teachers, and with maybe the agency that is responsible for implementing IDA, if that's appropriate in that particular case.

Catherine: Okay.

Sangeeta: So make sure that collaboration happens and then you come together as a group and if that group decides we've done everything we could do and this is really not the appropriate place for this particular child, then the language that we have in the regulations is that the program must directly facilitate the transition of the child from that one place to somewhere else that's more appropriate. 

Catherine: Okay, so not just saying you can't come to Head Start but making sure that the Head Start program works directly with another program so that the child is enrolled somewhere that is appropriate. 

Sangeeta: We really just don't want a lapse of services. We want to make sure that there is sort of what we call a warm hand-off.

Catherine: Oh, that makes sense.

Sangeeta: So that everybody can go and talk to whoever the new person is that is taking over the care of the child and say that these are all the supports that we have in place for them. These are the things that work; these are the things that don't work; and so it's not just the kid left alone to figure it out. 

Catherine: That's really important especially with some of the challenging behaviors that these children and families are dealing with. It's important that they get to the next place.

Sangeeta: Yeah and you've asked about when a child has a serious safety threat or challenging behaviors, what other things can programs do? So, I just want folks to know that on the ECLKC we do have a lot of resources around how to work with children with challenging behaviors and we will be rolling out more with the new regulations. I just want folks to know we're there; we're there to help you out. We're not going to leave you in the lurch.

Catherine: And as you mentioned before, there's also going to be technical assistance available on this section and other parts of the reg to help programs.

Sangeeta: Right, and I think when it comes to suspension and expulsion we really don't want to lose sight of the fact that we are here to help all of our kids around social development as well as emotional development and that's where this piece as well as the mental health piece that I talked about really fits in. So, if we think about the Head Start Early Learning Outcomes Framework we talk very extensively about social development and emotional development and so if we can work with kids when they're first enrolled in the program around these different areas, then hopefully we can prevent challenging behaviors from occurring and then we won't even have to think about resorting to something as dire as suspension or expulsion.

Catherine: I think that's a really good way to think about it, as preventing these behaviors before they happen if we can. Giving all kids a head start.

Sangeeta: That's right.

Catherine: Well thanks so much for describing this in detail; it's really helpful to hear more about this new regulation.

Sangeeta: Thanks.

Catherine: So, thank you.

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