# Presentation: 840846

## Clarifying Select Standards

**Julianne Crevatin**
**Lee Gooding**

## Child health status

**1304.20(a)(1)(ii)**
- Determining child health status. (1)
- 			           and as quickly as possible, but
- 						  (with the exception noted in paragraph (a)(2) of this section) from the child's entry into the program (for the purposes of 45 CFR 1304.20(a)(1), 45 CFR 1304.20(a)(2), and 45 CFR 1304.20(b)(1), “entry” means the first day that Early Head Start or Head Start services are provided to the child), grantee and delegate agencies must:

- WHAT MUST GRANTEES DO IN 90 DAYS?

- 					   In collaboration
- with the parents

- 							  no
- later than 90 calendar days

## Obtain from a health care professional a

- ii)
**	**** ** 		              as to whether the child is
- 	on a schedule of age appropriate preventive and primary health care which includes _medical_, _dental_ and _mental health._ Such a schedule must incorporate the requirements for a schedule of well child care utilized by the
- 				    program of the Medicaid agency of the State in which they operate, and the latest 			                 recommendations issued by the Centers for Disease Control and Prevention, as well as any additional                   recommendations from the local Health Services Advisory Committee that are based on prevalent community health problems:

- Obtain from a*** ***_health care professional_ a

**DETERMINATION**

- up-to-date

-        Early and Periodic Screening, Diagnosis, and Treatment (EPSDT)

- immunization

## WHO MEETS THE DEFINITION OF

-  A HEALTH CARE
-  PROFESSIONAL ?

- AND WHAT MUST BE INCLUDED
- IN THE DETERMINATION?

**Notes:**
PI to follow

PI to follow

Promotion of effective dental hygiene = practice of tooth brushing at least ONCE daily in conjunction with meals while in Head Start = breakfast, or lunch, or snack

## Slide 5

## 1304.20  Child health and developmental services. (b) Screening for developmental, sensory, and behavioral concerns. (1) In collaboration with each child's parent, and 

- 1304.20  Child health and developmental services. (b) Screening for developmental, sensory, and behavioral concerns. (1) In collaboration with each child's parent, and
- 			     of the child's entry into the program, grantee and delegate agencies
- linguistically and age appropriate screening procedures to identify concerns regarding a child's _developmental, sensory (visual and auditory), behavioral, motor, language, social, cognitive, perceptual, and emotional skills (_see 45 CFR 1308.6(b)(3) for additional information). To the greatest extent possible, these screening procedures must be sensitive to the child's cultural background.
- Note:
- For infants and toddlers, a separate behavioral screen is NOT required. For this age group, a developmental screen done in collaboration with parents is sufficient for compliance with this regulation.

- within 45 calendar days

- must perform or obtain

**Notes:**
For infants and toddlers, a separate behavioral screen is NOT required. For this age group, a developmental screen done in collaboration with parents is sufficient for compliance with this regulation.

In determining potential gravity of a finding, it is important to note if the screens were not done in 45 days, were they done in 48 days, 60 days, or not until 6 months after date of entry!
For infants and toddlers, a separate behavioral screen is NOT required. For this age group, a developmental screen done in collaboration with parents is sufficient for compliance with this regulation.

In determining potential gravity of a finding, it is important to note if the screens were not done in 45 days, were they done in 48 days, 60 days, or not until 6 months after date of entry!

## WHAT IS EFFECTIVE DENTAL HYGIENE?

- Sec. 1304.23 Child nutrition.
- (b) Nutritional services.
- (3) Staff must promote effective dental hygiene among children in conjunction with meals.

**Notes:**
PI to follow

PI to follow

Promotion of effective dental hygiene = practice of tooth brushing at least ONCE daily in conjunction with meals while in Head Start = breakfast, or lunch, or snack

## WHAT IS EFFECTIVE DENTAL HYGIENE?

- THE OFFICE OF HEAD START HAS CONCLUDED THAT ALL CHILDREN IN A CENTER-BASED PROGRAM SHOULD BE GIVEN THE  OPPORTUNITY TO BRUSH THEIR TEETH AT LEAST ONCE A DAY IN CONJUCTION WITH MEALS.

- YES – THIS MEANS TOOTHBRUSHING

**Notes:**
PI to follow

PI to follow

Promotion of effective dental hygiene = practice of tooth brushing at least ONCE daily in conjunction with meals while in Head Start = breakfast, or lunch, or snack

## 1306.32(b)(2)(3)  DAYS OF SERVICE. (b) Center-based program option requirements. (1) Classes must operate for four or five days per week or some combination of four and five days per week. (3) The annual number of required days of planned class operations (days when children are scheduled to attend) is determined by the number of days per week each program operates. Programs that operate for four days per week must provide

- 	    of planned class operations. Programs that operate for five days per week must provide at least 160 days per year of planned class operations. Grantees implementing a combination of four and five days per week must plan to operate between 128 and 160 days per year. The minimum number of planned days of service per year can be determined by computing the relative number of four and five day weeks that the program is in operation. All center-based program options must provide a minimum of 32 weeks of scheduled days of class operations over an eight or nine month period.

- 						 at least 128 days per year

## FOR FULL YEAR PROGRAMS:   WHAT IS THE MINIMUM NUMBER OF DAYS OF SERVICE?

- FOR _FULL DAY_ PROGRAMS:   WHAT IS THE MINIMUM NUMBER OF HOURS?

**Notes:**
PI to follow

PI to follow

Promotion of effective dental hygiene = practice of tooth brushing at least ONCE daily in conjunction with meals while in Head Start = breakfast, or lunch, or snack

## What is the minimum number of hours / per day of service a program can provide?

**What is the minimum number of hours / per day of service a program can provide?**

**Notes:**
PI to follow

PI to follow

Promotion of effective dental hygiene = practice of tooth brushing at least ONCE daily in conjunction with meals while in Head Start = breakfast, or lunch, or snack

## Key:  Three hours if total number of hours is met for option
	Ex: A 4-day-a-week option under 1306.32 must have 128 service days minimum; 3.5 hours = 448; if you operated this option for 3 hours a day, you would need to extend your days to 150 days to meet total hours

- (k)(1)The secretary shall allow center-based Head Start programs the flexibility to satisfy the total number of hours of service required by the regulations in effect on the date of enrollment of the Human Services Amendments of 1994, to be provided to children by Head Start Programs so long as such agencies do not—
- (A) provide less than 3 hours of service per day
- (B) reduce the number of days of service per week, or
- (C) reduce the number of days of service per year

- Key:  _Three hours_ if total number of hours is met for option
- 	Ex: A 4-day-a-week option under 1306.32 must have 128 service days minimum; 3.5 hours = 448; if you operated this option for 3 hours a day, you would need to extend your days to 150 days to meet total hours

## 1304.40(a)(1)(2)

- Sec. 1304.40 (1)*Family goal setting. *(1) Grantee and delegate agencies must engage in a 	         of collaborative partnership building with parents to establish mutual trust and to identify family goals, strengths, and necessary services and other supports.  This               must be initiated as early after enrollment as possible and it must take into consideration each family’s readiness and willingness to participate in the

- process

- process

- process.

**Notes:**
MUST ENGAGE in a process of collaborative partnership

Must OFFER parents opportunities to develop FPA:
Grantees may choose to have a form BUT CANNOT BE requirement
A family that CHOOSES to develop and implement an FPA may do so in writing but does not have to do so in writing

Talking to parents:	
Talk to those assigned to engaged families
Record checks

## family partnership agreements

- Sec. 1304.40 (2) As part of this ongoing partnership, grantee and delegate agencies 		    parents 		  to develop and implement individualized 					        that describe family goals, responsibilities, timetables and strategies for achieving these goals as well as progress in achieving them. In home-based program options, this agreement must include the above information as well as the specific roles of parents in home visits and group socialization activities (see 45 CFR 1306.33(b)).

- must offer

- opportunities

**Notes:**
MUST ENGAGE in a process of collaborative partnership

Must OFFER parents opportunities to develop FPA:
Grantees may choose to have a form BUT CANNOT BE requirement
A family that CHOOSES to develop and implement an FPA may do so in writing but does not have to do so in writing

Talking to parents:	
Talk to those assigned to engaged families
Record checks

## 1304.40(a)(1)(2)

- Sec. 1304.40  Family Partnerships.
-       PARTNERSHIP AGREEMENT ≠  WRITTEN DOCUMENT

- IF A GRANTEE IS ENGAGED IN A PARTNERSHIP THERE MUST BE GOALS, TIMELINES, STRATEGIES AND PROGRESS IN MEETING THE GOALS......***  ***

- The Question for you is– How is this documented,  How do you demonstrate you are assisting families in meeting their goals.***  ***

**Notes:**
MUST ENGAGE in a process of collaborative partnership

Must OFFER parents opportunities to develop FPA:
Grantees may choose to have a form BUT CANNOT BE requirement
A family that CHOOSES to develop and implement an FPA may do so in writing but does not have to do so in writing

Talking to parents:	
Talk to those assigned to engaged families
Record checks

## ongoing monitoring

- (2) **Grantees** must establish and implement procedures for the 			          of their own Early Head Start and Head Start operations, as well as those of each of their delegate agencies, to ensure that these operations effectively implement Federal regulations.

**ongoing monitoring**

**Notes:**
This is a grantee responsibility

Ask questions first:
Process
System
Approach

## 1304.53 (a)(9)

- Sec. 1304.53  Facilities, materials, and equipment.
- Head Start physical environment and facilities. (1) Grantee and delegate agencies must provide a physical environment and facilities conducive to learning and reflective of the different stages of development of each child. (9) Outdoor play areas at center-based programs must be
- 	and getting into _unsafe and unsupervised areas_. Enroute to play areas, children must not be exposed to vehicular traffic without supervision.

- 				         arranged so as to
- prevent any child from leaving the premises

**Notes:**
Key – Unsafe and unsupervised

## What must grantees do to ensure children do not leave the premises and how do you ensure safety?  

- What must grantees do to ensure children do not leave the premises and how do you ensure safety?***  ***

**Notes:**
Key – Unsafe and unsupervised

## Slide 19

**Notes:**
Key – Unsafe and unsupervised

## What additional items do EHS grantees need to budget for?

- 1304.53(b)(1)(iii)
**Head Start equipment, toys, materials, and furniture.Grantee and delegate agencies must provide and arrange sufficient equipment, toys, materials, and furniture to meet the needs and facilitate the participation of children and adults.**

**What additional items do EHS grantees need to budget for?**

**Notes:**
Key – Unsafe and unsupervised

## Diapers and formula are an allowable expense for center-based EHS programs and should be available at NO cost to parents– Program must not prescribe any fee or charge any fees for participation in the program

**Diapers and formula are an allowable expense for center-based EHS programs and should be available at NO cost to parents– Program must not prescribe any fee or charge any fees for participation in the program**

**Notes:**
Key – Unsafe and unsupervised

## EARLY HEAD START TEACHER REQUIREMENTS:

- WHAT ARE THE MINIMUM QUALIFICATIONS OF A
- CENTER BASED TEACHER IN AN EARLY HEAD START
- CLASSROOM?

- DO EHS STAFF HAVE TO MEET THE TEACHER CREDENTIAL REQUIREMENT?*** ***

- DO GRANTEES NEED TO REQUEST A WAIVER FOR EHS TEACHERS WHO DO NOT HAVE A CDA?

**Notes:**
Key – Unsafe and unsupervised

## Head Start Act:  at least 50% of all center-based teachers nationwide must have an:

*CREDENTIALS:*
*1304.52(F) WITHIN ONE YEAR OF HIRE, TEACHERS OF INFANTS AND TODDLERS *_*:*_
_*A Child Development Associate (CDA) credential for Infant and Toddler*_
*OR  An equivalent credential ; *
- Associate; Baccalaureate; Advanced degree in early childhood education; OR A degree in related field + 6 courses in early childhood education

**Notes:**
Key – Unsafe and unsupervised

## 						 enrollment opportunities  

**Sec. 1305.6  Selection process.**
- (c) At least                   of the total number of** **
**	****	****      **in each grantee and each delegate agency during an enrollment year must be made available to children with disabilities who meet the definition for children with disabilities in Sec. 1305.2(a). An exception to this requirement will be granted only if the responsible HHS official determines, based on such supporting evidence he or she may require, that the _grantee made a reasonable effort to comply with this_ requirement but was unable to do so because there was an insufficient number of children with disabilities in the recruitment area who wished to attend the program and for whom the program was an appropriate placement based on their Individual Education Plans (IEP) or Individualized Family Service Plans (IFSP), with services provided directly by Head Start or Early Head Start in conjunction with other providers.

- 10 percent

**	****	****	****	****	****	**** **_**enrollment opportunities  **_

**Notes:**

Percentage of enrolled children with disabilities
Key = reasonable effort

## What is an “enrollment opportunity”?  

- If you have CHILD FIND activity at the beginning of the year and you make 10% of enrollment opportunities available to children with special needs and only 8% of children are identified with special needs; is the program out of compliance?

- If you offer both Head Start and EHS do the requirements regarding enrollment of at least 10% of children with disabilities apply?

**Notes:**
Key – Unsafe and unsupervised

## 1305.7(b)

- Sec. 1305.7  Enrollment and re-enrollment.
- (b) A Head Start grantee 			its funded enrollment level. When a program determines that a vacancy exists, no more than 30 calendar days may elapse before the vacancy is filled. A program may elect not to fill a vacancy when 60 calendar days or less remain in the program's enrollment year.

- must maintain

**Notes:**
Historical data matters only when it supports chronic under enrollment, and they are under enrolled at the time of the review.

Under enrollment requires vacancies for 30 days or more.

## Tuberculosis Screening Requirements  1304.52(j)(1)

*Each staff member has an initial health examination (including screening for tuberculosis) and periodic re-examinations. *
**“****It has come to the attention of the Office of Head Start (OHS) that there is some confusion around the requirements for tuberculosis screening of Head Start Staff. Recently OHS noticed various and sometimes conflicting approaches being applied in the field regarding these screening requirements. This indicates a need for clarification.”**

**Notes:**
Key – Unsafe and unsupervised

## Acceptable screening for tuberculosis can be achieved by documentation of EITHER of the following:

*Acceptable screening for tuberculosis *can be achieved by documentation of *EITHER *of the following:
- • ***Completion of a screening assessment*, usually a list of questions, to determine those who are at high risk.
- This can be done by the grantee or through assessment by their health care provider during the health care examination.
- Those determined to be high risk should have documented follow-up with a skin test for tuberculosis (PPD).
- • *Actual skin testing (PPD placement) for tuberculosis*
*****Completion of a screening assessment such as a questionnaire to determine risk status is considered best***
***practice by the Centers for Disease Control and Prevention***

**Notes:**
Key – Unsafe and unsupervised

## Can Head Start programs enroll three-year-old children who were not three years of age by the date which the local school system uses to determine kindergarten eligibility?

**Notes:**
Key – Unsafe and unsupervised

## YES

- A program with a **midyear** vacancy may fill that vacancy with a child who is three years of age but who was younger than three on the date used by the school system to determine kindergarten eligibility and, therefore, not considered for enrollment at the beginning of the program year.

**Notes:**
Key – Unsafe and unsupervised

## However, programs should consider several factors when deciding whether to enroll this child:

- However, programs should consider several factors when deciding whether to enroll this child:

- If there are un-served older children on the waiting list, grantees should give serious consideration to enrolling these children so that they receive the benefit of some Head Start experience before entering school.*** ***

- Grantees are, in effect, committing to providing that child 21⁄2 years of service—that is, the remainder of the current program year plus the next two program years—because the child will not be eligible for kindergarten until the fall two years after he/she has been enrolled.*** ***

**Notes:**
Key – Unsafe and unsupervised

## Grantees must also be able to assure that the curriculum they are using would be appropriate for a younger child. If, after considering these factors, the grantee determines its best (or perhaps only) choice is to enroll the now-three-year-old, it has the authority to do so.

- Grantees must also be able to assure that the **curriculum** they are using would be appropriate for a younger child. If, after considering these factors, the grantee determines its best (or perhaps only) choice is to enroll the now-three-year-old, it has the authority to do so.

- Grantees should also consider that **placement** of this child may mean that the child will probably be the youngest in his/her classroom and may well be in class with many children who could be nearly two years older than the child.*** ***

**Notes:**
Key – Unsafe and unsupervised

## Question:

**Question:**
- Which military pay and allowances should be counted when determining Head Start eligibility and which should not?

**Notes:**
Key – Unsafe and unsupervised

## Answer:

- For purposes of determining income eligibility, Head Start regulations count as
- Basically, this is all
- that is taxable.
- For military personnel, there are numerous
- categories of pay and allowances. Some of these are counted as gross cash income and others are not. To further complicate things, some pay and allowances which are otherwise counted as gross cash income, fall out of that category if they are received for service in a combat zone.

- “income” as all gross cash income.

- income — earned and unearned —

**Notes:**
Key – Unsafe and unsupervised

## The following are included in gross cash income unless it is paid for service in a combat zone:

**The following ****are included**** in gross cash income unless it is paid for service in a combat zone****:**

- • _**Basic Pay**_: active duty, back wages, drills, reserve training,   training duty, CONUS COLA

- • _**Special Pay:**_ aviation career incentives, diving duty, foreign duty, foreign language proficiency, hardship duty, hostile file or imminent danger, medical and dental officers, nuclear-qualified officers, optometry, pharmacy, veterinarian

- • _**Bonuses:**_ career status, enlistment, officer, overseas extension, re-enlistment

- • _**Incentive Pay:**_ submarine, flight, hazardous duty, High Altitude/Low Altitude (HALO)

- • _**Other payments**_: accrued leave, high deployment per diem, personal money allowances paid to high ranking officers, specified Student loan repayment programs,

**Notes:**
Key – Unsafe and unsupervised

## The following are NOT included as gross cash income:

- The following are NOT included as gross cash income:

- • Other payments: disability, group-term life insurance, professional education, ROTC educational and subsistence allowances, uniform allowances, survivor and retirement protection plan premiums.

- • Living Allowances: Basic Allowance for Housing (BAH)*, BAS (Basic Allowance for Subsistence), housing and cost of living allowances abroad, OHA (Overseas Housing

- • Moving Allowances: moving household and personal items, storage, moving trailers or mobile homes, temporary lodging, dislocation, military base realignment and closure benefit.

- • Travel Allowances: annual roundtrip for dependent students, leave between overseas tours, reassignment in a dependent restricted status, transportation during ship overhaul and inactivation, per diem

- • Family Allowances: specified educational expenses for dependents, emergencies, evacuation to a place of safety, separation

- • Death Allowances: burial services, death gratuity payments to eligible survivors, travel of dependents to burial site

- • In-kind Benefits: dependent-care assistance, legal assistance, medical/dental care,
- commissary/exchange discounts, space-available travel on government carriers

**Notes:**
Key – Unsafe and unsupervised

## Office of Head Start 

***Office of Head Start ***
***Division of Policy Interpretation ***
***and Accountability – Craig Turner***
***GOAL-- to improve consistency and to ensure quality services ***

**Notes:**
Key – Unsafe and unsupervised