The Designation Renewal System
August 27, 2020:
Head Start Cheers Final Rule Improving Quality Evaluation Standards for Programs
NHSA Has Advocated Against 10% and Single Deficiency Triggers Since 2013.
In December 2017, the administration released a request for information about potential changes to the way that the Classroom Assessment Scoring System (CLASS) is used in the Designation Renewa System (DRS). The request proposed that 4 changes, including the removal of the lowest 10% provision, the increase of the Emotional Support and Classroom Organization thresholds, and the ability for the Secretary to set thresholds for the Instructional Support domain annually.
Over the 60-day comment period, through more than 1,000 survey responses and countless conversation with those in and out of the Head Start community, NHSA wrote comments that supported the removal of the lowest 10% provision and a strong alternative proposal of a 15-point scoring system for CLASS scores. In the proposed system, no single domain would send a grant into competition. Instead, scores in each domain would be assigned 0, 3, or 5 points and the cumulative scores across all domains would fall into one of three zones (Competition Zone, Quality Improvement Zone, and High Quality Zone). NHSA also addressed other concerned with the use of CLASS and the broader DRS. Other recommendations included considering the use of video observations for reliablity and efficacy, the establishment of an appeals process, and more nuanced consideration of single-incident deficiency. Ultimately, more than 3,000 individuals, programs, state associations, national associations, and stakeholders signed on to the comments that NHSA submitted on February 6th.
In mid-February, the administration withdrew the December comment request, and issued a new, very similar request that posed 3 additional questions. NHSA adapted the original recommendations to explicitly address the new questions.
Thank you to everyone who participated in the process, and stay tuned as the rulemaking process continues!
The Head Start for School Readiness Act of 2007 called for Head Start and Early Head Start programs of “low-quality” to compete with other early learning providers for continued funding in their communities. In 2011, the Office of Head Start released a Final Rule on Designation Renewal and launched the Designation Renewal System (DRS). The DRS is based on seven triggers that could cause programs to have to compete for continued funding:
- A Deficiency on a Program Review
- Failure to create School Readiness goals or not taking steps to reach those goals
- Low scores on the Classroom Assessment Scoring System (CLASS), EITHER: 1) Below a set of thresholds (4 for Emotional Support, 3 for Classroom Organization, 2 for Instructional Support on a 7-point scale) OR 2) In the lowest 10% of all Head Start programs nationally in any domain
- Revocation of License
- Suspension by the Office of Head Start
- Debarred from receiving state or federal funds or Disqualified from the Child and Adult Care Food Program (CACFP)
- Audit finding of being at risk of failing to continue functioning as a Going Concern
American Indian/Alaska Native programs are not subject to competition through this system; the Office of Head Start supports them through other means when concerns arise.
Implementation of DRS
The first four cohorts of competed programs were notified in December 2011, January 2013, February 2014, and December 2014. The first cohort differed from the others because review of programs' deficiencies was retroactive several years and the School Readiness and CLASS triggers were not yet in effect. The first cohort included 129 programs, the second cohort 126, the third cohort 103, and the fourth cohort 90. As the breakdown of triggers reflects, the 10% CLASS cut-off now contributes to a majority of programs competing each year. Per the Office of Head Start, the cut-off for the lowest 10% has reached as high as 5.7 on a 7 point scale in some domains.
Twelve grantees were notified in May 2016 that they would compete as part of the fifth cohort, but because DRS will be implemented differently now that all grantees are on a five year grant, the full course of their competition process remains unclear. Triggers below are based on public monitoring data from the Office of Head Start.
|Trigger||Cohort 1||Cohort 2||Cohort 3||Cohort 4|
|School Readiness Goals||0||0||0||0|
|CLASS Scores Below Thresholds||0||9||18||8|
|CLASS Scores in the Lowest 10%||0||46||50||55|
|Revocation of License||0||1||0||0|
|Suspension by the Office of Head Start||0||0||0||0|
|Debarment from Federal Funds||0||0||0||0|
|Failure as a Going Concern||0||2||4||0|
As of 2015, about 31% of programs nationally had gone into the DRS, though there is considerable state and regional variation in the percentage of programs that have competed. The Designation Renewal System takes approximately 18 months for each cohort, beginning in the winter and ending July 1st of the following year, when each program either regains their grant or transitions services to a new provider. Both the incumbent grantee and other eligible entities may apply for the grants, including neighboring agencies, national Head Start and Early Head Start providers, school systems, non-profit agencies, community action organizations, and county or city government agencies. Cohort one completed the Designation Renewal process in summer 2013, cohort two in summer 2014, cohort three in summer 2015, and cohort four in summer 2016.
Outcomes of Competitions
In September 2015, NHSA released Analysis of the Designation Renewal System: Cohorts One to Three, which examined the experiences and results of competition for both grantees and their communities. Across the first three cohorts of programs who went into competition, 74% had their grants restored in full or in part. There was variation in the rate at which grants were restored depending on which trigger led to the program competing. For example, 83% of programs competing due the CLASS 10% trigger had their grants restored while only 63% of programs with multiple deficiencies got their grants back. The report provides additional analyses by causes of competition, program demographics, and geographic region. For many reasons, the high rate of grants being restored is not surprising. First, since some programs compete for less systemic concerns, those programs are able to demonstrate high quality on their applications. Second, long commitment and familiarity with Head Start make Head Start programs better able to deliver services and engage families and communities than other competitors for grants.
From the point of view of communities, across the first three cycles of DRS about 74% of awards went to an incumbent grantee or delegate agency and 19% of awards went to other established Head Start grantees or delegates, including a mix of neighboring agencies and Head Start providers with a national footprint. Approximately 7% of awards went to providers with no previous experience operating Head Start.
Advocacy for Reform
While the Head Start field welcomed the idea that poor quality grantees would be replaced by alternate, stronger providers, implementation of the DRS has failed to live up to this aim. The biggest obstacle in the design and implementation of the Designation Renewal System rests on the idea that the triggers of competition are related to quality. By far the most common triggers that have caused programs to compete to date are the Deficiency trigger and the CLASS trigger, but because of unequal deficiencies and fluctuating CLASS scores leading to competition, the perception that any program can be thrown into competition at any time has been damaging to morale across the country. NHSA's analysis of DRS outcomes reached three conclusions:
- The Designation Renewal System does not yet fully meet Congressional intent of targeting competition at poor quality grantees.
- Basic reforms are needed to make the Designation Renewal System consistent, reasonable, and predictable.
- Conceptual reforms are needed to support programs in working toward high-quality, not compliance.
The National Head Start Association is actively advocating for reforms to the Designation Renewal System and has submitted recommendations to Secretary Burwell. We welcome dialogue and discussion.
Resources for Programs
NHSA maintains a listserv for member organizations who are or have ever been in competition, to support the sharing of insights and practical lessons across cohorts and the distribution of resources and information. To find out more and be added to the listserv, contact Victoria Jones.