Policy Agenda
National Head Start Association 2012 Policy Agenda
(Adopted on January 20, 2012)
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NHSA’s Vision
Because we believe that
- All Children should reach their full potential,
- Every child can succeed,
- We can impact the success of “at-risk” children, and
- Quality early education fundamentally transforms children and families
Our vision is
To lead. To be the untiring voice that will not be quiet until every vulnerable child is served with the Head Start model of support for the whole child, the family and community.
To advocate. To work diligently for policy and institutional changes that ensure all vulnerable children and families have what they need to succeed.
About NHSA’s Agenda
This 2012 Policy Agenda is a roadmap for educating policy makers, guiding NHSA’s strategic decision-making, and advocating for changes in current law, regulation, and practice.
NHSA sought input into the formulation of the policy agenda in a variety of ways, including surveying the NHSA Board of Directors and NHSA’s State and Regional Affiliates, convening a diverse group of leaders from nearly every region, Head Start demographic, and different program models at the 2011 28th Annual Parent Conference, reviewing survey responses from 728 Head Start directors, staff, parents and leaders, and listening attentively to the concerns of the Head Start and Early Head Start community. NHSA’s 2012 policy agenda reflects feedback from member programs, state and regional Head Start associations, and Head Start parents, teachers, and staff. In addition, research-based best practices and effective innovations informed the development of this policy agenda.
This policy agenda is a statement of policy changes that the Head Start community would like to see implemented in 2012. These changes can be implemented through the enactment of federal legislation or the implementation of federal regulations or guidance. The policy changes in this agenda fall into three categories: 1) policy changes requiring federal legislation, 2) policy changes requiring administrative action (regulatory or guidance), and 3) mix of policy changes requiring a mix of legislative and administrative actions.
FEDERAL LEGISLATION
This section contains policy changes that can be made through the enactment of federal legislation.
Maintain Access to Quality Head Start Programs
Current federally-funded Head Start and Early Head Start enrollment is 967,125 spaces for vulnerable children and their families. (1) The recently-approved FY 2012 Appropriation signed by President Obama on Dec. 23, 2011 funded Head Start and Early Head Start at $7.984 billion. This funding level included a slight investment in quality improvements and sustained all currently funded children and families, including the 61,000 children recently added through the American Recovery and Reinvestment Act of 2009.
In contrast, there is a real possibility that Head Start and Early Head Start funding would be facing a 7 – 10% cut as part of the sequestration set to take place in January 2013. The sequestration is a result of the 12-Member Joint Select Committee on Deficit Reduction failing to reach agreement on a deficit reduction plan. Although many important federal programs are exempt from these cuts, Head Start and Early Head Start are funded through discretionary spending and, thus, are not currently exempted from the automatic cuts.
From FY 2002 to FY 2008, Head Start and Early Head Start experienced a 13 percent real cut in funding. This cut resulted in teacher and staff layoffs, reduced programming and services, and produced high teacher and staff turnover. Programs have just recently begun to make progress in recovering from these cuts. Meanwhile, the demand for Head Start and Early Head Start services grows at an alarming rate with over 25 % of children under age 6 in the United States living in poverty.
If funding is cut as a result of sequestration, the result would be no new training and technical assistance funds and quality funds. Presumably, the Office of Head Start would then be forced either to reduce current enrollment significantly or provide programs with less funding per child – which would lead to programs being forced to reduce either the quality of their service or the number of children and families they serve. Other options may also exist, but these seem the most likely from NHSA’s perspective.
NHSA recommends that the U.S. Congress and President Obama:
- Make Head Start and Early Head Start a funding priority with robust investments in the President’s FY 2013 federal budget proposal and in the final FY 2013 appropriation. Subsequent funding levels would allow local community-based programs to enroll all currently funded children and provide adequate funding for much-needed quality improvements.
- Protect or exempt Head Start and Early Head Start funding from any possible sequestration cuts set to take place on January 1, 2013 as part of the 2011 Budget Control Act.
The Child Care Development Fund is authorized by the Child Care and Development Block Grant Act (CCDBG) and Section 418 of the Social Security Act. Through the CCDF, the federal government provides additional funds to states, American Indian/Alaskan Native tribes, and U.S. territories to help low-income families’ access child care through grants, certificates, and contracts with child care providers. Federal lawmakers are considering legislation to reauthorize the CCDF in 2012 although it is currently unknown if such legislation is politically-feasible.
Working parents and guardians of children in Head Start have expressed concerns about the impracticability of the CCDF eligibility determination period and about the amount of family co-payments during the current recession. In addition, because of the low funding levels available to families who receive the child care subsidy, a more cost-effective approach would be to maximize the use of these funds by funding wrap-around care for low-income families also receiving services at high-quality Head Start or pre-k programs.
NHSA recommends that Congress and President Obama:
> Support the passage of legislation to--
- Extend the child care subsidy eligibility determination period from 6 to 12 months for families and from 6 to 24 months for Head Start families using the child care subsidy to fund wrap-around services to coincide with the period of annual eligibility for the Head Start or pre-k program that their child attends.
- Cap family co-payments at 10 percent of income.
- Establish minimum base reimbursement rates for providers caring for children receiving federally funded child care assistance at no less than the 75th percentile of the current market rate.
- Encourage and provide incentives for states to dedicate a significant portion of the CCDF funds for exclusive use to fund wrap-around services at Head Start programs (as Nevada currently does).
- Eliminate barriers to families using child care subsidy funds for wrap around services at Head Start programs by allowing Head Start agencies the option to submit applications on behalf of families.
Federal lawmakers have begun considering the reauthorization of the Elementary and Secondary Act (ESEA). ESEA reauthorization provides an opportunity for the Head Start community to advocate for legislation to enhance the collaboration and coordination between school districts and Head Start programs.
NHSA recommends:
- Congress and President Obama support the approval of ESEA legislation to authorize funds and to provide incentives to school districts to work toward the provision of seamless, comprehensive, and continuous early childhood education services for children from birth to age eight.
- Congress and President Obama support the passage of legislation to require that local education authorities (LEAs) provide timely and comprehensive child evaluations of children attending Head Start programs so that Head Start and Early Head Start programs can more efficiently meet their 10% disability requirements. For Migrant/Seasonal Head Start programs, the issues is not just the LEA’s normal difficulties with Head Start and Early Head Start programs, but Migrant/Seasonal Head Start programs face several hurdles challenges to meeting this requirement: schools are closed during the harvest seasons, a dual language population, lack of trained assessors, high percentages of infant and toddlers in the service area, and the disincentives of LEA’s to identify special needs when it might affect their local special education funding.
- Congress and President Obama support the approval of ESEA legislation that includes the flexible use of funds for collaborations between Head Start and the LEA after the child/family enters the k-12 school system. This flexibility would help provide enhanced support services often needed by at-risk low-income families whose children graduate from Head Start and encourage continued success in school. Within the Head Start program, these families receive many critical support services, yet when they enter primary schools, they often find few, if any, resources allocated for their additional support services needs
This section contains policy changes that can be implemented through the enactment of federal regulations, which have the force of law. Guidance is not a regulation and does not carry the force of law.
Implement an Objective, Accountable, and Transparent Designation Renewal System for Head Start and Early Head Start Grant Renewal
In November 2011, President Obama issued and announced the final rule on the Designation Renewal System (DRS) for Head Start and Early Head Start grant renewal. In issuing the final rule, the administration listened to NHSA and the Head Start community by removing the proposal to re-compete 25 % of all Head Start grantees reviewed in a year – a crucial and important change. However, the DRS or re-competition process is still being developed and many potential, perhaps unintended, outcomes to the system are possible. In 2012, NHSA will focus on getting the best ideas, concerns, and suggestions from the Head Start community regarding the implementation of the DRS. Based on this input, NHSA expects to develop recommendations for implementation and to work closely with OHS and ACF in developing the most just and equitable system ultimately resulting in the smallest number of grantees being caught in the web of re-competition.
NHSA recommends:
- OHS and ACF maintain transparency while implementing the DRS by listening to NHSA and adopting the Head Start community’s suggestions to smooth out the process of implementation;
- Continue to evaluate and streamline the Head Start monitoring system, known as Approach 360, by ensuring that it remains consistent, objective, and effective;
- Continue to develop the T/TA system so that it provides impactful, no/low-cost, relevant and easily accessible trainings to the Head Start community specifically around CLASS and school readiness goals.
- OHS and ACF explore the establishment of a formal appeals or challenge process for programs that are included in the competition pool.
Make Sure that the Revision of the Head Start Program Performance Standards Reflects Best Practices and the Perspectives of the Head Start and Early Head Start Community
The Office of Head Start has not revised the Head Start Program Performance Standards since the mid-1990s. A revision is long overdue.
NHSA recommends that the Office of Head Start review and revise the Head Start Program Performance Standards by--
- Taking into account the latest evidence-based research and best practices and perspectives of the Head Start and Early Head Start community;
- Streamlining elements that no longer allow programs to work efficiently in this day and age; and
- Strengthening elements that provide the unique supports Head Start and Early Head Start programs need to best serve their at-risk children and families.
By statute, Head Start programs receive 80 percent of their funding from the federal government and must provide a non-federal share of not more than 20 percent. The non-federal share may be in cash or in kind, fairly evaluated, including plant, equipment, or services (Sec. 640(b)). Unfortunately, Head Start programs are having difficulties meeting the 20 percent match because the economy has decreased donations to Head Start programs from community partners, such as businesses and individuals, and these programs are losing additional funding streams due to severe state and local budget cuts.
NHSA recommends that the Office of Head Start:
- Review and revise its regulations and Policy Clarifications on matching share to allow programs as much flexibility to define what is counted as a match.
- Make a practice of granting matching share waivers (allowable under the Head Start Act) regularly and speedily.
This section contains policy changes that would require changes to be made through the implementation of legislation as well as federal regulations or guidance.
Ensure that Head Start and Early Head Start Programs Have Appropriate Facilities
Maintenance and replacement of Head Start and Early Head Start facilities is a pressing need in the Head Start community. In fact, over 80 percent of respondents to a recent NHSA survey indicated that additional funding for facilities should be among the Top 7 NHSA priorities – the second highest priority.
NHSA recommends that Congress and President Obama:
- Request a U.S. Government Accountability Office (GAO) study to research and review aging facilities issues in Head Start and Early Head Start to set the stage for important reauthorization discussions.
- And, that the Office of Head Start:
- Make it easier for Head Start and Early Head Start programs to maintain and replace their facilities by streamlining the 45 CFR Part 1309 process.
- Work with relevant departments and agencies in the Obama Administration to leverage capital and streamline regulations to foster community collaborations and more effective utilization of resources to build, maintain, and replace Head Start facilities.
Human resource managers in business and governmental organizations have long recognized the importance of having excellent human capital to enable their organizations to thrive. Federal lawmakers recognized this need when they enacted the Improving Head Start for School Readiness Act of 2007. The Act mandated that Head Start programs require their teachers and staff to have certain educational degrees and credentials and to undergo background checks prior to the start of work. The Act at Sec. 648A(a)(2)(A)(ii) also permits Head Start programs to provide financial assistance to Head Start teachers to pursue a baccalaureate or advanced degree in early education or a baccalaureate or advanced degree. After completing their Head Start-funded degrees, these individuals must teach or work in a Head Start program for a minimum of 3 years or repay the total or a prorated amount of the funds received based on the length of service to the Head Start program (Sec. 648A(a)(6)). In addition, many Head Start teachers and staff have a high student loan debt load because they have borrowed funds through federal student loan programs to help them obtain baccalaureate degrees, and they are eligible for federal loan forgiveness programs. Unfortunately, these programs are not well-funded.
NHSA recommends that the Office of Head Start:
- Provide training to teachers and staff on how to work with special populations.
- Define a maximum caseload for a full-time family service worker that is practical and reasonable and allows the FSW flexibility to work with differing needs of families. Also provide guidance on family service worker training, such as for case management, crisis management, experience working with adults/adult education, cultural competency, reflective practice, mentoring/coaching skills, motivational interviewing, dealing with the change process, and working with special populations.
- Offer flexibility and grant waivers to programs who have demonstrated a commitment to but have not yet reached teacher/staff degree requirements set forth in the 2007 Head Start Act - particularly those in Migrant Seasonal, American Indian Alaska Native, and rural communities.
- Expand access for Head Start teachers and staff to participate in federal student loan forgiveness programs by appropriating adequate funds.
We strongly support increased collaboration and coordination among Head Start programs and Local Educational Agencies. Increased collaboration and coordination can lead to more efficient uses of community resources and encourage policies that strengthen the ability of parents to transition their children from Head Start to kindergarten. The Head Start reauthorization intended to accomplish this by requiring Head Start programs to enter into MOU’s with LEAs. If, however, the LEA is “unable or unwilling to enter into such a memorandum,” then the Head Start agency is required to notify ACF and the State Collaboration Director (Sec. 642(e)(5)(B(ii)). However, there is no corresponding requirement for LEAs and consequently, the MOUs do not always work as intended.
NHSA recommends that the Office of Head Start:
- Explain in guidance how and when notification to the Office of Head Start must occur and what criteria it will consider in its determination of unable or unwilling.
- A reciprocal requirement for school districts receiving Title 1 funding regarding entering into MOUs with local Head Start agencies.
President Obama has proposed that the federal government create Early Learning Challenge Fund (ELCF) grants to provide competitive grants to states to develop or strengthen state early education and learning systems. Although the ELCF legislation failed to be enacted, Congress and the President authorized and funded an Early Learning Challenge component of Race To The Top – the President’s marquee education reform program – through the FY2011 Final Continuing Resolution. The Race To The Top Early Learning Challenge (RTTT-ELC) competition was run during calendar year 2011 and resulted in 9 states receiving funding to advance their state early learning systems in adherence to the grant’s framework. Despite the RTTT-ELC grant competition being a major advancement in early learning state system development, there is still significant room and need for further federal investment in state early learning systems.
NHSA recommends that:
- Congress and President Obama support a second round of Race To The Top Early Learning Challenge competition.
- The Office of Head Start provides leadership and technical assistance to the Head Start community on how to position Head Start Program Performance Standards favorably within state QRSs.
- Congress and President Obama support increased funding for Head Start State Collaboration Offices who, if properly funded, play a critical and important role in defining and advancing Head Start’s position in State Early Learning Systems.
Although Head Start is technically up for reauthorization in 2012, specific recommendations for a Head Start Reauthorization are not included in this agenda for a variety of reasons. With the new designation renewal system as well as the need for a revision of the performance standards to be in accordance with the 2007 Head Start Act – the last Head Start reauthorization, NHSA maintains that significant changes to the program prior to realizing the full impact of these new changes/additions would be ill-advised and potentially harmful. Additionally, in conversations with Capitol Hill and the Obama Administration, a reauthorization of Head Start looks politically impossible and unpractical. NHSA will continue to consider options for reauthorization, listen to the perspectives in the early learning community, and develop more specific recommendations for when a reauthorization is feasible.
Nevertheless, we intend to advocate during the Reauthorization of Head Start the broadening of Head Start and Early Head Start’s programmatic goal of school readiness to include improved family functioning. The creators of Head Start and Early Head Start programs envisioned and designed Head Start and Early Head Start as two-generational programs. In recent decades, the implementation of this vision has been diminished as the emphasis has been on the school readiness of children. We strongly support Head Start’s school readiness goal, and we believe that a corollary of Head Start’s school readiness goal is improved family functioning since this impacts a child’s school readiness. More attention and resources are needed to improve the lives of parents and other family members since there is strong evidence of a direct correlation of family success to child success.
Given this, NHSA recommends
- Congress and President Obama do not move forward with a full reauthorization of Head Start and Early Head Start in 2012.
HEAD START VOTER REGISTRATION
NHSA recognizes and believes that a core value of Head Start and Early Head Start is to empower and involve Head Start and Early Head Start parents and grandparents in the education of their children, the program decision-making process, and the advancement of their own successes. The encouragement and empowerment of Head Start and Early Head Start parents to be civically engaged and responsible is a key part of this value and can be actualized through the encouragement of voter registration at Head Start agencies. The Head Start Act says explicitly in 42 USC 9851 sec. 656 (b) (2) that it is acceptable for Head Start and Early Head Start facilities to be available during hours of operation for the use of any nonpartisan organization to register voters.
As 2012 is an election year with several important federal elections, NHSA will commit to encouraging the registration of voters by working with nonpartisan organizations willing to partner in order to register voters at Head Start and early Head Start facilities.
1. This number, from the 2011 PIR released by the Office of Head Start, includes Migrant and Seasonal, American Indian Alaska Native, and regular regional Head Start and Early Head Start.
Because we remain committed to serving all segments of the Head Start community including the Migrant/Seasonal Head Start and American Indian/Alaskan Native Head Start programs, the National Head Start Association thanks all of its members and others who were involved in the formulation of this policy agenda. For any questions or comments concerning the agenda, please contact Yasmina Vinci at yvinci@nhsa.org, or Tommy Sheridan at tsheridan@nhsa.org.
About NHSA
The National Head Start Association is a non-partisan, not-for-profit membership organization that believes that every child, regardless of circumstances at birth, has the ability to succeed in life if given the opportunity that Head Start offers to children and their families. It is the national voice of more than 1.1 million children, 225,000 staff and 2,800 Head Start/Early Head Start programs in the United States.