Youngest – 4
Middle – 4
Eldest – 4

KSA:
What do you need to know?: knowledge
What do you need to do?: skills
What do you need to value?: attitudes

• Meet 10% mandate
• State Budget cuts – can’t find svcs
• Wait list for therapy
• No service – HS pays to provide therapy
• Dev. Therapy – providing speech svcs, EHS providing srvcs
• Federal Review
• What defines a deficiency?

1. Train in DV

• Crisis Centers
• Local Police
• YWCA
• Mental Health
• EAP
• Community College or University
• Extension

Books on Tape

Picture Books

Lend Lib

Parent meet at Lib

Story board and Flannel Puppet

Storytelling

Funding Budget

Staffing

Federal Review – XX

Resources – XX

Recomp – X

Including Fam Svc – not just Educ

Lack of Participation

In Kind

Change in Gov.

Union

Positive In the End

Teach Kids How to Study = Parents

• Parents more involved – X
• Positive effective experiences and opportunities for children and families – X
• Federal Review – xxx
• Economic Challenges
• GSW materials
• Opportunities
• Monitoring Process Helps
• More Parent Involvement
• Renee – ELC Spec Pops
• IDPH Reporting
• PIR Training
• Procedures / EHS Programs
  • Baby Talk
• Julie Jansen
• Preg. Moms

Comments on Notice of Proposed Rules for Designation Renewal System

Area of Concern: Citation: 1307.1 -Purpose and Scope –
Why: The Head Start Act requires the process to be “fair, consistent and transparent” and the system’s criteria must be applied in a manner that is “transparent, reliable, and valid.”

We Believe:

The Illinois Head Start community believes that the process outlined within the Notice of Proposed Rules on the Designation Renewal System does not support the requirements established within the Head Start Act. “Reliable and valid in terms of indicators” suggests that the CLASS tool would have reliability and validity as a federal monitoring tool. “Transparent”, some of the suggested indicators to reach a twenty five percent quota are not transparent and leave many guessing what might become a standard or criteria.

We wonder where the Proposed Designation Renewal System establishes indicators to meet the comprehensive services of Head Start and Early Head Start, like health, nutritional and social needs of the children/families they serve. The Advisory Panel recommended that “Comprehensive Services: Particular elements in this area should include: (1) immunization;

(2) screening and follow-up; (3) services to children with disabilities; and (4) parent involvement. We appreciate Head Start’s long-standing commitment to meeting the comprehensive needs of young children and their families and believe this should be represented in Key Quality Indicators”. Key Quality Indicators and criteria need to be developed and integrated into the Proposed Rules so that the Designation Renewal process reflects Head Start’s comprehensive services.

The Head Start community agrees with the Director of the Office of Head Start on her recommendations made to the Advisory Committee in 2008. “We suggest that the definition of quality services be broad enough to assign due significance to the provision of culturally and linguistically appropriate services to children and their families, including the encouragement of parents and staff to support the acquisition of a strong home language base for children birth to three years of age. The consideration of quality for Head Start programs should be broader than education and classrooms only. Any definition of quality should include the level to which programs are providing health, nutrition, social and education services to children and families. Every program must be able to demonstrate the level of quality through the empowerment of families and the children in attaining their goals. Standards and criteria should be in place to be applied fairly but with flexibility across the board”. Yvette Sanchez, comments written for the Secretary’s Advisory Committee on Redesignation of Head Start Grantees, April 2008.

Illinois Head Start and Early Head Start programs serve many children who speak a language other than English, enter Head Start and Early Head Start with many more needs than just the classroom experience, represent a diverse range of size and complexity of programs from a super grantee (City of Chicago Family Support Services) and large urban programs to small rural programs and also a Migrant and Seasonal Head Start program.

Suggestion On How To Improve: Create a strength based system that values programs who demonstrate programmatic improvement throughout the five year period of review. A strength based system would acknowledge areas where a program is doing well and value a program’s commitment towards improvement. We value a Head Start/Early Head Start accreditation system and believe this would be a better investment.

Area of Concern: Citation: 1307.3 -Minimum of 25% of all HS/EHS grantees reviewed in the same year will be required to compete for their next 5 years of funding.

Why: We believe in no quota. Setting an arbitrary goal is unfair, and would lead to recompetition of quality programs to meet the quota. The result would be an unnecessary and a costly burden on programs, taxpayers, and the Office of Head Start. More importantly it would undermine program quality leading to lack of continuity, consistency, and stability for children and families within local communities. In addition, Head Start and Early Head Start programs reflect their individual communities. Programs that provide different options/models would be ranked with different communities providing another option/model. There would be no consistency and reliability with this approach.

We believe that recompetition should only be based on criteria and the results of criteria during the annual review process. An arbitrary number or percentage will only become a quota to meet and does not meet the full intent or purpose of the Designation Renewal System. The Illinois Head Start community believes that quality programs will suffer because of a rule and or person(s) who are or may be focused on a quota. Good, high quality programs would eventually be eliminated just to reach the quota.

According to the Advisory Committee Report the Committee members expected this “quota number to decrease over time as program quality improves”. There is not language to support this expectation in the Proposed Rules and we strongly support adding additional language to support the decrease if a quota is utilized, which we do not support.

In addition, we believe that there should be an annual evaluation of the accepted criteria “Building on the Act’s requirement that the Secretary periodically evaluate whether the criteria of the system are being applied in a manner that is transparent, reliable, and valid, we agreed that the Secretary should re-evaluate the designation renewal system criteria after each cycle. Reevaluating the criteria after each cycle allows the Secretary to ensure that the selected Key Quality Indicators and Automatic Indicators continue to be the best gauge of program quality and to incorporate other tools to measure program quality as they become available. Re-evaluating would provide an opportunity to insert state-of–the-art measures and indicators of import to: (1) child outcomes; (2) classroom quality; and (3) parent involvement as they become available and are ready for program wide use. It is critical that OHS continue to press for adequate quality indicators in these critical areas related to Head Start’s primary goal of school readiness”.

Suggestion On How To Improve: We believe that a set of clear criteria should be utilized and if a Head Start program meets these established, transparent indicators then they should not be re-competed. Clear, clean and simple!

Area of Concern: Citation: 1307.3 (b) (1) -Agency has 1 or more deficiencies on a single federal review (triennial, follow up, unannounced, etc.)

Why: Grantees should be allowed time to correct deficiencies before being re-competed. Many concerns have been raised about the transparency and accuracy of the monitoring system. Thus, until a fair, transparent and reliable system is developed and consistently implemented programs should have the opportunity to correct a deficiency. The Advisory Panel recommended that grantees should be automatically required to compete if they are found to have deficiencies far more than the average grantee. The Committee recommends defining this as having a number of deficiencies that is two standard deviations from the mean. This seems to make more sense than just one deficiency.

We also support the current Director of the Office of Head Start and her recommendations made to the Advisory Committee in 2008. “A key measure of delivering a high quality and comprehensive program is the ability to correct non-compliance and deficiency findings through the corrective action period. If a program is unable or unwilling to correct a deficiency within a prescribed timeframe the grant should be subject to re-competition. Yvette Sanchez, comments written for the Secretary’s Advisory Committee on Redesignation of Head Start Grantees, April 2008.

Suggestion On How To Improve: Grantees should be able to correct a deficiency. Follow the Advisory Panel’s recommendation that the process should be “Integrated into ongoing systems for program improvement in such a way as to add value.’’ A Grantee should be allowed to correct the deficiency first and if not corrected by a specified time then the grant could be re-competed.

The Office of Head Start should let every program know what a deficiency is and the process for making a determination; each year OHS should publish a list of deficiencies found on triennial reviews and make it available to the public on its website; and OHS should develop a clear appeals process for programs. Head Start Performance Standards should clearly identify programs standards.

Area of Concern: Citation: 1307.3 -To examine relevant records about the grantee’s performance since June 12, 2009

Why: We believe in no retro active process. Programs should be held to the proposed conditions only when the final rule is published. To start the process earlier would mean that programs would be judged by different standards, requirements, and monitoring systems, spanning two different Administrations.

The Advisory Committee Panel recommended that the designation renewal system, including its criteria, data sources, and thresholds, be applied equitably for all grantees. For example, evaluation of grantees should be based on the same number of monitoring reviews and Program Information Reports for all grantees, and determinations should be made during the same year of the grant cycle for all grantees. Additionally, the Panel indicated that the Secretary should further ensure that the data used in assessing Key Quality Indicators is as current as possible (no more than one year old except for special cause). Using up-to-date data will ensure that designation renewal determinations are based on data that reflects the current, and not past, performance of grantees. We considered the advantages to using multiple years of data to examine patterns of performance over time but decided that the simplicity gained through a single point in time system outweighed the benefits of basing decisions on multiple years of data.

Suggestion On How To Improve: Lets all start on the same day and support equality across the system.

Area of Concern: Citation: 1307.3 (b) (3) -Low scores on the Classroom Assessment Scoring System: Pre-K (“CLASS: Pre-K”)

Why: We believe that Head Start and Early Head Start is a comprehensive program providing much more than the classroom experience. Using the CLASS Assessment tool does not provide a complete picture of the comprehensive nature of Head Start.

We also believe that interactions are central to classroom quality and child outcomes. But two basic principles must be met.

Principle 1: The assessment process will include measures of child development across multiple domains. The assessment process should provide a holistic view of child development, including strategies that address the five areas proposed by the National Education Goals Panel: health and physical development, emotional well being and social competence, approaches to learning, communication and language skills, and cognition and general knowledge. Understanding children’s proficiency across each of these domains is critical for effective planning to support their development and growth.

Principle 2: Assessment methods will be psychometrically sound. Assessment instruments must meet psychometric standards of reliability and validity and reflect best practices for assessing young children as outlined by national research bodies (e.g. NAEYC; National Research Council). Instruments must only be used for the specific purposes for which they were developed and validated. Precautions must be taken to ensure that all assessment instruments are suited to the objectives of the assessment process, are appropriate for the populations being assessed, and are administered reliably.

Based on this information we are concerned about validity of CLASS as a federal monitoring tool and not using equal measures from year to year. We believe it is an excellent professional development tool and just that a tool to enhance child outcomes. Plus, a CLASS negative climate domain should be a low score and this is a direct contradiction to the Proposed Rules. Additionally, CLASS PreK is not developed for and will not be used in either EHS or Home Based programs. This leaves too many complications in the review process. Additionally, the CLASS sample should be a statistically representative amount of the entire grantee’s classes observed.

Suggestion On How To Improve: Again we support the current Director of the Office of Head Start views and her recommendations made to the Advisory Committee in 2008. “In developing a system of re-designation, the Committee should rely on valid and reliable research-based observational measures of classroom quality, drawn from the overall program that takes into account such measures as a balanced daily program of child-initiated and adult-directed activities in a manner that is culturally and linguistically appropriate, the use of positive methods of child guidance, and individualized approaches to support each child’s learning including experimentation, inquiry, observation, play and exploration as evidenced by observation and children’s progress in learning documented over time by the Head Start Child Outcomes Framework. Until such measures are considered reliable and valid, we suggest that the use of classroom quality in determining recompetition be delayed for the first five years of the process while research-based measures are being piloted and validated. In addition, the evaluation of any pilot on classroom assessments should be conducted by an independent panel to make recommendations for measuring classroom quality in the system of re-designation. The Committee should ensure that any measure of classroom quality is aligned with the Study on Developmental Outcomes and Assessments for Young Children by the National Academy of Sciences”. Yvette Sanchez, comments written for the Secretary’s Advisory Committee on Redesignation of Head Start Grantees, April 2008

Area of Concern: Citation: 1307.3 (b) (4) -Revocation of an agency’s license to operate by a state or local licensing agency

Why: We believe that the lack of consistency of licensing systems across the nation lead to inequality in the process. Even in Illinois not all Head Start programs are required to be licensed. Programs located with our Public Schools are not required to be licensed. This sets up an unequal indicator or criteria within our state. Plus, there are tremendous differences in state licensing standards across the country.

A program that has a revocation pending should not have to recompete. Requiring a program to recompete in such a situation would violate the due process rights of grantees and penalize programs during the investigation or appeal process.

Suggestion On How To Improve: We suggest that OHS have its own review process, as circumstances for revocations may differ from state to state. OHS may want to have the authority to make exceptions to this condition in certain cases based on their own internal reviews. Ensure that the system is applied equitably and uniformly across all grantees.

Area of Concern: Citation: 1307.3 (b) (6) -Debarment by any federal or state agency from receiving federal or state funds or if the agency is disqualified from the Child and Adult Care Food Program (CACFP)

Why: We believe that the Child and Adult Care Food Program should not be included. Again, insure that the system is applied equitably and uniformly across all grantees. Systems vary from agency to agency and some programs do not utilize the CACFP. Monitors of the CACFP are not trained by OHS but trained by states and vary in skill level and lack consistency in monitoring the CACFP. Even in our own state among CACFP monitors there are tremendous differences and perceptions. Thus, a uniform process is currently not in place leading to an inconsistent and inequitable process.

Suggestion On How To Improve: Remove Child and Adult Care Food Program. OHS may want to have the authority to make exceptions to this condition in certain cases based on their own internal reviews.

Area of Concern: Citation: 1307.3 (b)(7) -A determination by an independent auditor, a state agency, the National External Audit Review Center, or the HHS Office of Inspector General that the agency has one or more “material weaknesses”or is determined to be unable to ensure that it can continue as a “going concern”

Why: In a large agency or agencies within broader organizations the umbrella organization may have a material weakness cited that has nothing to do with Head Start or Early Head Start funds. The established audit finding should be directly linked to the inability to operate the Head Start or Early Head Start program. Findings vary greatly from Auditor to Auditor and build a lack of consistency into the proposed system.

The Office of Head Start should conduct a secondary review of the audit to ensure that the issues outlined by the auditor were sufficient to justify recompetition of the grant. Under this scenario the Office of Head Start would appoint fiscal staff to review an audit with a material weakness and OHS would make the final determination as to whether a program has met or not met the fiscal obligations of their grant and would thus have to recompete.

Suggestion On How To Improve: Establish a secondary review process on audit findings.

Area of Concern: Citation: 1307.3 -If a minimum of 25% of all HS/EHS grantees reviewed in the same year are not required to compete for their next 5 years of funding based on the above 7 conditions, then additional grantees up to that threshold, identified by the HHS Secretary through established criteria, will be required to compete.

Why: We believe that there is no transparency whatsoever with this citation. Until Performance Standards are revised and indicate the criteria or standard then the rule should not exist.

While IHSA does not support the 25% quota, we did want to weigh in on the additional criteria proposed by the Office of Head Start. We believe the “perfect” tool does not exist and support the Advisory Panels comments. “When OHS is satisfied that it has a valid, reliable, and practical classroom observation tool, and effective measures of child outcomes and of individualization, then such tools and measures should be incorporated into the designation renewal system”. In addition, in the event that the Head Start Program Performance Standards are revised, we would expect OHS to have appropriate tools to assess progress in school readiness upon publication of those final regulations”.

Suggestion On How To Improve: Members strongly discourage the Office of Head Start from utilizing non-compliances, as improvements are still being made to the current monitoring system and the consistency of reviews. There are over 1,700 regulations that Head Start programs must follow. Being found out-of-compliance for minor violations or a “parking ticket” should not have an outcome of jeopardizing the grant. A Head Start/Early Head Start program accreditation system would be a much stronger, strength based system to invest in.

Area of Concern: Citation: 1307.4 -HS/EHS agencies must report in writing to the designated ACF official w/in 10 working days of occurrence any of the following:

• License revocation
  
• Bankruptcy filing or agreement to a reorg plan as part of bankruptcy settlement
  
• Debarment or disqualification from CACFP
  
• Audit/inspection/investigation report containing determination that agency has 1 or more material weaknesses or is at risk for ceasing to be a going concern

Why: We believe that the 10 working days is not reasonable and reporting should be integrated within the Risk Management meetings. If Policy Council and Board approval/signature are required then 10 days is not reasonable for reporting.

Suggestion On How To Improve: Integrate reporting as part of the Grantee Risk Management meeting. Follow the Advisory Panel’s recommendation that the process should be “Integrated into ongoing systems for program improvement in such a way as to add value.’’

Notice of Proposed Rules on Designation Renewal System

Docket Folder Summary - Head Start Program

By Lauri Morrison-Frichtl

Some things you have heard about the recent Head Start Notice of Proposed Rule Making on the Designation Renewal System may not be true. Let’s check the facts –

First and foremost Head Start and Early Head Start are committed to the highest standards of quality services for children and families and support a fair, transparent and equitable system of monitoring. Did you know that currently the Office of Head Start federal monitoring system reviews a Head Start program every three years on over one thousand and five hundred standards? This intensive, federal review was designed to “weed out” low performing programs.

The Propose Rules are just that – PROPOSED! They propose -

• At least 25 percent of all Head start and Early Head Start grantees reviewed in a year will be re-competed.
• The 25 percent pool is determined by seven specific performance conditions and criteria (“triggers”) in three categories – Quality, Licensing and Operation, Fiscal and Internal Controls.
• If a program has any or more of the triggers, its grant would automatically be re-competed.
• IF the seven triggers capture less than 25 percent of all grants to be competed, OHS plans to use additional, un-clarified not yet specified triggers.

The proposed Seven Triggers or Performance Conditions includes:

1. A determination by ACF that the agency has one or more deficiencies during a single monitoring review.
2. A determination by ACF that an Agency has not established and taken steps to achieve its goals for improving school-readiness and has not analyzed individual child-level assessment data in accordance with the Head Start Child Outcomes Framework or the Child Competencies in the Early Head Start Performance Measures Framework”.
3. Low scores on the Classroom Assessment Scoring System: Pre-K (“CLASS: Pre-K”)
4. Revocation of an agency’s license to operate by a state or local licensing agency
5. Suspension by ACF of an agency to operate a Head Start and Early Head Start program.
6. Debarment by any federal or state agency from receiving federal or state funds or if the agency is disqualified from the Child and Adult Care Food Program (CACFP).
7. A determination by an independent auditor, a state agency, the National External Audit Review Center, or the HHS Office of Inspector General that the agency has one or more “material weaknesses” or is determined to be unable to ensure that it can continue as a “going concern”.

Did you know that this impacts all Head Start programs, big, small and super?

Did you know that best practice indicates that the proposed CLASS Instrument should only be used for the specific purposes for which it was developed and validated for? Precautions must be taken to ensure that all assessment instruments are suited to the objectives of the assessment process, are appropriate for the populations being assessed, and are administered reliably. And the measure to be used for Early Head Start, since CLASS is not an appropriate instrument for children birth to age three, is not yet specified.

Did you know that Head Start programs located within school districts do not need to be licensed by DCFS?

Let’s get the facts straight! The Illinois Head Start community will be establishing a statewide position and post this on our website by December 1st, 2010. We ask that each of our partners review this position and support the Head Start community.

This Proposal is just that – a Proposal! We must help improve the proposed regulations by reading the Notice of Proposed Rules on Designation Renewal System, reviewing the Illinois Head Start Association Response and submitting comments. Comments may be submitted to http://www.regulations.gov by December 21st, 2010. Legally, OHS must respond to comments it receives and indicate in the preamble to the final rule what actions it took in response to the comments.

The Head Start community looks forward to the dialog over the next month and hopes that if you have any questions regarding the Proposed Rules that you will contact Lauri Morrison-Frichtl at lfrichtl@ilheadstart.org.