NPRM/Changes to the Head Start Program Performance
Notice of Proposed Rule Making = Changes to the Head Start Program Performance Standards
How do I submit comments or recommendations? Why is it important?Guidance for Commenting:Comment link, look for the green box:
Federal Register• The most important thing is to share your thoughts.
• It doesn’t have to be a perfectly polished letter or comment. YOU can speak from the heart. Your heart can use bullet points.
• You can copy and paste from the text attached.
• You can comment on every section, or the sections that you feel most passionate about. The most important thing is to comment.
• Stories and data can help shape your comments.
• Consider breaking your comments apart by section
• Consider asking managers for different areas to comment on related areas
• You may need to clear your cache or reopen the link in incognito mode to submit multiple comments.
NPRM = Workforce and Benefits
Section 1: Workforce Supports/Overview of this section- Increase wages for lead teachers, assistant teachers, home visitors and family child care staff
- Make minimum pay or salary floor sufficient to cover basic costs of living; full time, full year work schedule
- Defines a full-time position as 30 hours or more per week
- Must offer the following benefits: access to high quality and affordable health care; paid sick leave, paid family leave regardless of employer size; facilitate access t affordable child care for all staff; 3-5 outpatient behavioral health visits annually at no cost or minimal cost; facilitate access to the Public Service Loan Forgiveness program; accrual of paid vacation or personal leave if the program operates longer than a typical school year
- Minimum staff breaks of one 15 min. break for staff working 4-6 hours; 5 minute wellness breaks for teaching staff; adult sized chairs and desks if the classroom allows
>> See attached for IHSA Support for Submitting Comments <<
NPRM = Health and Mental Health Services
Section 2: Health and Mental Health Services/Overview of this section- Expulsion is still prohibited and server limitations on the use of suspension; however, it does include that suspension can be used as a last resort; Programs must implement the intervention and supports recommended by the mental health consultant before making a suspension; If determined a more appropriate placement for the child, the program must work to directly facilitate the transition to a more appropriate placement that can immediately enroll and provide services
- Must establish a Multidisciplinary Team; must be consulted before a program suspends a child
- Mental health services will need to be provided no less than once a month; programs will be allowed to hire mental health professionals who are in the process of obtaining appropriate licensure as long as they are under the supervision of a licensed professional;
- Newborn visits must include discussion of postpartum mental and physical health, infant help, and support basic needs; require identification and reduction of barriers to healthy pregnancy outcomes
NPRM = Program Planning, Program Types and Eligibility
Section 3: Program Planning, Program Types, and Eligibility/Overview of this section
- Changes to community assessment; still be required to collect information on eligible children and expectant mothers but not required to get exact counts in specific demographic categories
- EHS Centerbase classrooms will be encouraged to lover teacher-child ratio from 4:1 to 3:1 with a group size of 3:9
- Family Child Care – replaces family child care assistant with family child care provider which means both staff would have the same qualifications required for Family Child Care Providers.
- Transportation – programs must ensure transportation is included in the community assessment; must identify when a child cannot attend due to lack of transportation; must examine barriers to regular attendance
- Serving children with disabilities – revises language regarding meeting 10% of funded enrollment to 10% “actual enrollment”; 10% is a floor and encourages program to serve as many children with disabilities as possible; not a requirement but a strong message
- Adjustment for Housing Costs for eligibility determination – allows programs to adjust families’ income level to account for excessive housing costs (including rent, taxes, mortgage, utilities, and insurance); the amount of housing costs in excess of 30% of family income can be subtracted from a family’s income when calculating eligibility
- Definition of income – revises the definition of income with the intent to provide a clear and final list of what is considered income and will promote consistent interpretation on what to include in calculating incomes; it also includes what is not considered income as it relates to military income and refundable tax credits and public assistance
- Proposes that programs limit Family Service Worker caseloads not to exceed 40:1.
NPRM = Facilities and Safety
Section 4: Facilities and Safety/Overview of this section
- Lead exposure in water – applicable to programs in facilities built before 2014 unless a program can demonstrate that all of the lead-based features no longer exist; must annually test water for lead in fixtures used for human consumption; test water fixtures for lead after remediation actions are completed; endure water tester is adequately trained to collect samples; ensure that water samples are analyzed in a certified lab; consider remediation even when detectable lead levels are below 5 parts per billion; use point of use devices that are certified by third party consistent with NSFI/ANSI
- Lead exposure in paint – required of facilities constructed prior to 1978, unless the program can demonstrate that lead-based paint no longer exists; must work with a certified risk assessor when inspecting paint; must implement immediate restrictions to areas where lead has been detected in paint until abatement occurs by an EPA certified abatement contractor; Reassess every two years after abatement by a certified risk assessor; Notification to parents and staff about lead results and remediation
- Facilities evaluation - Proposed Changes: In section 1303.44, the term “fair market” is replaced with “cost” because cost valuation is most relevant in determining fair cost of a facility acquisition action under this section; Definition of Major Renovations and Federal Interest - proposes to clarify what constitutes a major renovation. Major renovation means any individual or collective group of renovations related to the same facility that: have a cost equal to or exceeding $250,000 in Head Start funds: renovation activities are intended to occur concurrently or consecutively, or all together address a specific part of the facility; and are considered a collective group of renovation activities unless included in a purchase application, minor renovations and repairs are excluded from major renovation; Proposed revision for Federal Interest
- Standards of Conduct and Staff Training to Support Child Safety - The current language in 1302.90(c) (1)(ii) will be replaced with: “staff do not engage in behaviors that would be reasonably suspected to negatively impact the health, mental health, or safety of children.”; Significantly more descriptive language around the definitions of corporal punishment or physically abusive behavior, sexually abusive behavior, emotionally harmful or abusive behaviors, and neglectful behavior; All staff, consultants, volunteers, and contractors are mandatory reporters; they all have the responsibility to report an incident they witness or are made aware of; All staff must be trained on reporting procedures; All staff must be trained annually on positive strategies to understand and support children’s social and emotional development and tools for preventing and managing challenging behavior
- Incident Reporting - Programs will be required to report: Child health and safety incidents within 3 business days, unless a natural disaster prevents reporting within this time; Any incidents involving mandated reporter responsibilities to the Office of Head Start as well as the appropriate state/local/tribal authority, independent of the status of the investigation or outcome of the report] Significant incidents that may be associated with reasonably suspected or known lack of appropriate supervision or failure to carry out reasonably expected maintenance, such as maintenance of playground equipment; Incidents involving the unauthorized release of children; The definition of a reportable incident is “any significant incident that affects the health, mental health or safety of a child that occurs in a setting where HS services are provided, such as a Head Start program, playground, or transportation utilized by a Head Start program.” This definition is for any event that involves either a staff member, contractor, volunteer, or other adult that participates in a program or classroom, or a child in a classroom at least partially funded by Head Start
- Safety Practices - Proposed changes: The NPRM clarifies that volunteers cannot be left alone to supervise children anywhere anytime