The Administration for Children and Families proposed new rules this week that will shake up how Head Start is administered – and who does the administering -- in localities around the country. The agency plans to require the bottom 25 percent of Head Start organizations to re-apply for their grants and compete against other local organizations that until now have been effectively shut out.
The proposed rules, requested by Congress years ago, were released yesterday in the Federal Register. Comments are due on December 21.
The new rules are designed to promote accountability. In the past, many Head Start grantees – which can be non-profit organizations, municipalities or school districts – continued to receive funding even if they were found to be “underperforming” in federal reviews. The Office of Head Start has always had the power to shut down programs for highly egregious behavior but bad teaching or sloppy bookkeeping have not typically led to termination. In 2005, a report from the Governmental Accountability Office showed that ACF had been recommending refunding even when programs were not complying with financial management rules or were misusing federal money. “Poorly performing grantees … continue to receive federal grant funds for years without making the improvements to program design and management that are called for,” the report said.
Yesterday’s announcement means that those grantees will no longer be guaranteed a continuous funding stream. Instead, the field will be wide open for others to apply for the grant to provide preschool services. In the language of Head Start, grantees will have to “re-compete.”
The new rules go beyond ensuring sound finances. They also apply to Head Start programs that score poorly on indicators of how teachers interact with the children in their care. While debates on how to measure teacher quality in the traditional K-12 system have been making headlines, the Office of Head Start has been quietly cooking up a plan of its own to measure teachers of 3- and 4-year-olds.
Here at Early Ed Watch, we see this as more than simply sorting out the bad apples. It could also be a big win for children in the program, which serves about a million kids in poverty. Head Start programs must get serious about using good data and well-developed, well-researched tools to improve instruction and learning opportunities in their classrooms. The top-performing Head Start programs already do this (and in fact many elementary schools could learn from their work.) It’s encouraging to see these ideas codified in policy for Head Start as a whole.
More specifically, the proposal:
- Establishes a Designation Renewal System to determine if Head Start programs are meeting standards.
- Labels a grantee as “subject to an open competition” if it meets at least one of seven conditions (see page 57717 of yesterday’s Federal Register)
- Requires that a minimum of 25 percent of all grantees must re-compete. If fewer than 25 percent of grantees exhibit problems listed under the seven conditions, ACF will examine other indicators of poor performance. In other words, no matter what, at least 400 of the 1600 organizations and local school districts who run Head Start programs will have to submit new applications to receive a new round of funding and will likely be competing with other organizations.
- Sets a period of five years for all grants. Organizations that are not deemed to be in the bottom quarter of grantees will not be subject to open competition.
- Starts with a three-year transition before the rules go into full effect.
- Calls for the analysis of assessment data to individualize instruction and inform professional development and staffing
- Uses scores from an observation tool called the Classroom Assessment Scoring System, known as the CLASS, to determine how well teachers are interacting with students. (Head Start programs were supposed to have started training programs on the CLASS over the past year.) “A low score on the CLASS,” officials wrote, “is a reliable and valid indicator of poor performance in preparing Head Start children for school, the primary statutory purpose of Head Start.”
- Considers making public some of the data from re-competition as a “valuable service to parents” and anyone else wondering about the quality of the local Head Start program.
The recompetitions would also apply to Early Head Start, the center-and-home-based program for infants and toddlers up to age 3. But the proposal states that the CLASS, which was designed for pre-k and later grades, will not be the instrument used to assess quality and that the agency is looking for a suitable replacement.
Heated discussions are sure to follow on how the proposed rules may affect Head Start programs that struggle to recruit and retain staff with strong management skills and teaching credentials while typically paying salaries far lower than most public school teachers. It will be interesting to see what recommendations various groups submit in their responses to the proposed rules.
Others may wonder what took so long to propose these changes. More than five years ago, the GAO recommended re-competition as a way to hold Head Start programs accountable for deficiencies. In 2007, when Congress reauthorized the Head Start Act it directed ACF to put together a plan. It was due nearly 18 months ago.
But it was only last fall that HHS hired Yvette Sanchez Fuentes to direct the Office of Head Start, a position that had been held by an interim director for many years. Since her arrival, officials have not shied away from mentioning re-competition and have pressed for higher standards in the “Roadmap to Excellence,” the Office of Head Start’s plan to improve quality. The Office is also revising the Performance Standards, a list of hundreds of regulations related to children’s physical health, social and cognitive development, nutrition and safety as well as program and financial management.
Bad news still dogs Head Start. In January, researchers released a new installment in the Impact Study, which compared outcomes between Head Start and non-Head Start children. It showed that by first grade, there was little difference between the two groups, even though Head Start had made a few significant and positive differences among children when they immediately exited the program. Although many in early childhood field (including us) questioned what these results told us about the elementary schools that Head Start children attend, the results have revived debates over Head Start’s viability.
And in May, the GAO reported on Head Start employees willfully ignoring income-eligibility requirements to bring in more families. (Head Start is primarily open to families at the poverty line or below.) The Office of Head Start responded with a pledge to conduct unannounced visits.
We’ve been watching Head Start closely over the past year, and we’re encouraged by the changes so far. That’s not to say that the program won’t continue to have huge challenges or that there aren’t more efficient ways to administer a publicly funded program. For more context, check out our series from last year, “What’s Ahead for Head Start?” where we discussed what had changed in the program since the 2007 reauthorization, including the requirement to change the rules for grant competitions. A hint of the future might also be glimpsed in a guest-blogged report on “blending” Head Start and non-Head Start classrooms in D.C. You can also find previous posts that mention Head Start on our Head Start keyword page.