Department of Health & Human Services 
OFFICE OF 
   
INSPECTOR GENERAL 
 
 
 
 
 
 
M E H S
OST  ARLY  EAD  TART 
 
T   H R
EACHERS  AVE THE  EQUIRED 
 
C , B
 REDENTIALS   UT 
 
C E  
HALLENGES  XIST
 
 
 
 
 
   
 
 
 
 
 
 
 
 
Daniel R. Levinson  
Inspector General 
 
August 2011 
OEI-05-10-00240   
  
   
 E X E C U T I V E   S U M M A R Y  
OBJECTIVES
 
1.  To determine the extent to which Early Head Start teachers had the 
required credentials. 
2.  To determine the extent to which Early Head Start programs 
employed only teachers with the required credentials. 
3.  To describe the activities and challenges of Early Head Start 
programs in employing credentialed and trained teachers. 
BACKGROUND 
In 2007, Congress reauthorized the Head Start Act and created the first 
law governing the credentialing and training of center-based Early 
Head Start teachers.  The Head Start Act requires that all center-based 
Early Head Start teachers have a minimum of a child development 
associate (CDA) credential and have been trained (or have completed 
equivalent coursework) in early childhood development by 
September 30, 2010.  It also requires that all Early Head Start teachers 
have training (or have completed equivalent coursework) in early 
childhood development with a focus on infant and toddler development 
by September 30, 2012.   
Federal funding of Early Head Start dramatically increased in 2009.  
The American Recovery and Reinvestment Act of 2009 (Recovery Act) 
gave the Administration for Children & Families (ACF) an additional 
$1.1 billion to expand Early Head Start services.  ACF allocated the 
Recovery Act funds to both new and established grantees, resulting in 
an increase from 714 grantees in the 20082009 program year to 
992 grantees in the 20092010 program year.   
For this study, we reviewed credentials from a sample of 221 Early 
Head Start programs operating in the 20102011 program year.  In 
addition, we surveyed the same sample of programs about the 
challenges to meeting the education and training requirements for 
teachers. 
FINDINGS 
Overall, 81 percent of Early Head Start teachers had the required 
credentials.  Although 19 percent of teachers did not have the required 
credentials, more than half of these teachers were pursuing them.  
Teachers from preexisting programs were more likely to have the 
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E X E C U T I V E   S U M M A R Y  
required credentials than teachers from new programs developed using 
Recovery Act funds.   
Approximately one-third of Early Head Start programs employed 
only teachers with the required credentials.  Thirty-five percent of 
programs employed only teachers with the required credentials, 
whereas 65 percent of programs employed at least one teacher without 
the required credentials.  Overall, more than half of the teachers 
employed by 89 percent of programs had the required credentials.  In 
3 percent of programs, 25 percent of teachers or fewer had the required 
credentials. 
Nearly all Early Head Start programs reported requiring teachers to 
complete training.  Ninety-six percent of programs reported requiring 
teachers to complete ongoing training.  Programs identified training 
topics in the areas of infant and toddler development, safety, and 
communication methods.   
Early Head Start programs reported challenges to employing only 
teachers with the required credentials and to training teachers.  
Most programs reported challenges to either employing only teachers 
with the required credentials or to training teachers.                     
Eighty-three percent reported challenges to employing only teachers 
with the required credentials because they could not find teachers with 
credentials.  In addition, programs most commonly reported finding 
substitutes and managing work schedules as challenges to training 
teachers.  In rural areas, other challenges to training teachers appeared 
to be more prevalent. 
RECOMMENDATIONS 
Work with Early Head Start programs to ensure that all teachers 
have the required credentials.  ACF should ensure that all Early Head 
Start programs employ only teachers with the required credentials.  
ACF could: 
  provide additional support to programs that were newly 
developed using Recovery Act funds, 
  identify and share strategies used by programs that employed 
only teachers with the required credentials, or 
  work with programs that employ teachers without the required 
credentials to develop and implement an action plan. 
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E X E C U T I V E   S U M M A R Y  
Provide guidance to programs about training teachers. 
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
ACF concurred with our recommendations.  ACF stated that it plans to 
issue an information memorandum to provide additional guidance for 
programs on teacher credentials and qualifications.  In addition, ACF 
stated that it could provide guidance about teacher training, but that it 
could not require a certain number of training hours without a 
regulatory change.  We encourage ACF to issue both the planned 
information memorandum and guidance about teacher training.  We did 
not make any changes to the report based on ACFs comments.  For the 
full text of ACFs comments, see Appendix B.
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 T A B L E   O F   C O N T E N T S  
EX ECUT I VE  SUM M ARY  .....................................i 
 
 
I NT RO DU CT I O N  ............................................ 1 
 
 
F I NDI NG S  ................................................. 13 
Overall, 81 percent of Early Head Start teachers had the 
required credentials  .................................... 13 
Approximately one-third of Early Head Start programs 
employed only teachers with the required credentials.......... 14 
Nearly all Early Head Start programs reported requiring 
teachers to complete training  ............................. 15 
Early Head Start programs reported challenges to employing only 
teachers with the required credentials and to training teachers  . 16 
 
 
RECO M M END AT I O N S  .....................................  20 
Agency Comments and Office of Inspector General Response ....  21 
APP EN DI X  ................................................  22 
  A:  Estimates and Confidence Intervals .....................  22 
  B:  Agency Comments ...................................  26 
 
 
ACKNO WL E DG M E N T S .....................................  31   
  
   
I N TI NR OT DR UO CD TU I CO TN I  O N  
OBJECTIVES 
1.  To determine the extent to which Early Head Start teachers had the 
required credentials. 
2.  To determine the extent to which Early Head Start programs 
employed only teachers with the required credentials. 
3.  To describe the activities and challenges of Early Head Start 
programs in employing credentialed and trained teachers. 
BACKGROUND 
In 2007, Congress reauthorized the Head Start Act and created the first 
law governing the credentialing and training of center-based Early 
Head Start teachers.1  The Head Start Act requires that all teachers 
working for center-based Early Head Start grantees have a minimum of 
a child development associate (CDA) credential and have been trained 
(or have completed equivalent coursework) in early childhood 
development by September 30, 2010.2  It also requires that all Early 
Head Start teachers have training (or have completed equivalent 
coursework) in early childhood development with a focus on infant and 
toddler development by September 30, 2012.3  Hereinafter, the part of 
the law referring to teacher credentials will be called the education 
requirement and the parts of the law referring to teacher training will 
be called the training requirement.    
Overview of the Early Head Start Program 
Established in 1994, Early Head Start provides comprehensive services 
to low-income pregnant mothers and infants and toddlers from birth to 
age 3.  Early Head Starts mission is to promote healthy prenatal 
outcomes, enhance the development of infants and toddlers, and 
promote healthy family functioning.  In the 20092010 program year, 
the Administration for Children & Families (ACF) served more than 
 
 
1 Improving Head Start for School Readiness Act of 2007, P.L. 110-134 (Head Start Act) 
 645A(h), 42 U.S.C.  9840a. 
2 Ibid. 
3 Ibid. 
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100,000 infants and toddlers through almost 1,000 Early Head Start 
grantees.4, 5 
Early Head Start grantees may include local public agencies, private 
nonprofit and for-profit organizations, Native American tribes, and 
school systems.  Many Early Head Start grantees subcontract to 
delegate agencies.  Grantees have a formal contractual relationship 
with delegate agencies and allow delegate agencies to independently 
manage Early Head Start centers.  However, grantees are ultimately 
responsible for overseeing and managing the Early Head Start centers, 
including ensuring the credentialing and training of teachers.  
Early Head Start grantees and delegate agencies may deliver:  
(1) center-based services, (2) home-based services, (3) both center- and 
home-based services, or (4) alternative services.  In center-based 
services, teachers work with children in a traditional classroom setting.  
In home-based services, staff members support children and families in 
their homes by meeting language development, health, and 
developmental needs.  Alternative services may include a local option 
that tests new approaches to delivering Early Head Start services or a 
family childcare option. 
In the 20092010 program year, approximately 54 percent of Early 
Head Start grantees delivered both center- and home-based services, 
approximately 23 percent delivered solely center-based services, and 
approximately 16 percent delivered solely home-based services.6  The 
remaining 7 percent of grantees delivered alternative services.7 
Federal funding of Early Head Start dramatically increased in 2009.  
The American Recovery and Reinvestment Act of 2009 (Recovery Act) 
gave ACF an additional $1.1 billion to expand Early Head Start 
services.8  This money was distributed through the end of fiscal year 
(FY) 2010.  In comparison, Early Head Starts original FY 2009 budget 
was $710 million.9 
 
4 Office of Inspector General (OIG) analysis of 2010 ACF administrative data. 
5 The program year is the 12-month period in which Early Head Start provides services.  
Program years can start at any time from August 1 through September 15. 
6 OIG analysis of 2010 ACF administrative data. 
7 Ibid. 
8 Recovery Act, P.L. 111-5, (Feb. 17, 2009), Title VII. 
9 Department of Health & Human Services (HHS), Fiscal Year 2010 Budget in Brief, 
May 7, 2009.  Accessed at http://www.dhhs.gov on February 10, 2011. 
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ACF allocated the Recovery Act funds to both established and new 
Early Head Start grantees, resulting in an increase from 714 grantees 
and delegate agencies in the 20082009 program year to 992 grantees 
and delegate agencies in the 20092010 program year.10  Using these 
funds, Early Head Start grantees and delegate agencies served 
approximately 48,000 new children.11  Overall, the Recovery Act allowed 
Head Start and Early Head Start grantees and delegate agencies to hire 
an estimated 7,000 new teachers.12 
Hereinafter, Early Head Start grantees and delegate agencies that 
existed prior to the Recovery Act are referred to as preexisting.  Early 
Head Start grantees and delegate agencies created through Recovery 
Act funds are referred to as new. 
Early Head Start Teacher Qualification Requirements  
Education requirement.  ACF promulgated regulations exclusive to Early 
Head Start teachers in 1996.  The regulations state that any teacher 
working with infants and toddlers must obtain a CDA specializing in 
infants and toddlers within 1 year of hire.13   
These regulations were superseded by the Head Start reauthorization.  
The reauthorization had language that was specific to Early Head Start 
teachers and removed the 1-year grace period.  While the 
reauthorization is clear that teachers must receive a CDA, it removed 
the specialization of an infant and toddler CDA.14  After the 
reauthorization, Early Head Start programs had to either ensure that 
teachers currently employed had or would receive credentials by the 
2010 deadline or hire new teachers who already had credentials.   
Teachers pursuing a CDA must meet specific requirements.  The 
Council for Professional Recognition (the Council) administers the CDA 
national credentialing program.  Teachers are eligible for a CDA from 
the Council if they have a high school diploma or equivalent, 480 hours 
of childcare experience, and 120 hours of childcare education.   
 
10 OIG analysis of 2009 and 2010 ACF administrative data. 
11 HHS, FY 2012, ACF, Justification of Estimates for Appropriations Committees.  
Accessed at http://www.acf.hhs.gov on May 4, 2011. 
12 Ibid. 
13 45 CFR  1304.52(f). 
14 The Head Start reauthorization also addressed training requirements for Early Head 
Start home-based staff and education requirements for Head Start teachers, teaching 
assistants, and education coordinators. 
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Applicants must submit proof of their childcare experience and 
recommendations from students parents to the Council.  After 
reviewing applications, Council staff interview applicants and 
administer a written test before awarding the CDA.15    
ACF recognizes other credentials as having met the education 
requirement if they are equivalent to or more advanced than a CDA.  
For example, some States or universities may award diplomas or 
certificates in early childhood education.  ACF refers to these diplomas 
and certificates as alternative credentials and recognizes them if they 
are approved by an expert panel within ACF.16  In addition, ACF 
considers associates, bachelors, or advanced degrees in early childhood 
education (or a related field with equivalent coursework) as credentials 
that equal or exceed a CDA.17  Hereinafter, any credential that meets or 
exceeds a CDA will be referred to as a required credential. 
Training requirements.  ACF has not provided guidance on the requirement 
that all teachers have training in early childhood education by 
September 2010 or the requirement that all teachers have training in 
infant and toddler development by September 2012.  In the 1996 
regulations, ACF offered general guidance on training for Early Head 
Start teachers.18  The regulations state that Early Head Start teachers 
must be trained in subject areas such as infant and toddler development, 
safety issues, and communication methods.19  However, ACF has not 
provided guidance regarding the number of hours or frequency of training.   
ACF Support for Teacher Qualifications 
ACF provides funds to help improve teacher qualifications.  ACF 
provides a training budget and additional quality improvement funds to 
grantees when available.  Grantees may use this money to fund the 
credentialing or training of Early Head Start teachers.  The Recovery 
Act made nearly $354 million available in quality improvement 
 
15 Council for Professional Recognition, CDA Credential, CDA Assessment System.  
Accessed at http://www.cdacouncil.org on June 22, 2010. 
16 ACF, Review and Approval of Child Development Associate (CDA) 
Equivalent/Alternative Training Programs by State, December 20, 2006.  Accessed at 
http://www.acf.hhs.gov on February 25, 2011.  
17 ACF, Policy Clarifications-J-Staffing and Program Options-OHS-PC-J-033, 
April 29, 2008.  Accessed at http://www.acf.hhs.gov on February 10, 2011. 
18 45 CFR  1304.52(f). 
19 Ibid. 
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funding.20  In addition, ACF funds Higher Education Partnership grants 
for colleges and universities.  These grants help develop early education 
programs in colleges and universities and provide educational 
opportunities for Early Head Start teachers working toward credentials.  
Finally, Early Head Start teachers can apply for a student loan 
forgiveness program.   
ACF Oversight of Teacher Qualifications 
ACF monitors Early Head Start teacher qualifications through the 
Program Information Report (PIR), onsite monitoring, and the risk 
management process.  
The PIR.  Annually, grantees report to ACF the highest degree or 
credential of each teacher, as well as other program information.21  In 
addition, grantees report the number of staff enrolled in the degree or 
credential program above what they currently hold (e.g., of teachers 
that have a CDA, the number enrolled in an associates or bachelors 
degree program).  However, ACF does not require grantees to report 
training that teachers received outside a credential or degree program. 
Onsite monitoring.  The Head Start Act established monitoring 
requirements for all Head Start agencies, including Early Head Start.22  
The Head Start Act states that all grantees should receive a full review 
at least once every 3 years and that new grantees should be reviewed 
after their first year.   
As part of the onsite monitoring visit, ACF reviews credential and 
training documents.  If a grantee has teachers without credentials 
during the 20102011 monitoring cycle, ACF will indicate a concern in 
the report and will review those grantees again at a later date.23    
Risk management process.  ACF conducts the risk management process 
annually with each grantee.24  ACF staff and grantees use this process 
 
20 ACF, Head Start Funding Increase, ACF-PI-HS-09-06, May 12, 2009.  Accessed at 
http://www.acf.hhs.gov on May 4, 2011. 
21 ACF, Early Childhood Learning and Knowledge Center, Program Information Report 
(PIR).  Accessed at http://eclkc.ohs.acf.hhs.gov on March 31, 2010. 
22 Head Start Act  641A(c)(1)(A) and (B); 42 U.S.C.  9836a(c)(1)(A) and (B). 
23 ACF, Qualifications for Early Head Start Infant and Toddler Center-Based Staff,  
ACF-IM-HS-10-06, October 27, 2010.  Accessed at http://www.acf.hhs.gov on 
February 10, 2011. 
24 ACF, Head Start Risk Management Process, ACF-IM-HS-08-06, February 5, 2008.  
Accessed at http://www.acf.hhs.gov on February 15, 2011. 
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to identify grantees areas of strengths and needs for improvement.  
ACF staff also work with grantees to develop an action plan for 
identified areas of weakness, including the education requirement. 
Related Reports 
In a 2010 report responding to Recovery Act mandates, the Government 
Accountability Office (GAO) found that the percentage of Early Head 
Start teachers with credentials decreased between 2009 and 2010.25  In 
addition, GAO reported that grantees cited finding and developing staff 
as a significant challenge.26 
Both OIG and GAO have completed work related to qualifications of 
Head Start teachers.  A 2004 OIG report found that Head Start teacher 
qualifications had increased over the years, but that disparities among 
grantees existed in the percentage of degreed teachers.27  In a 
2003 report, GAO found that Head Start appeared to meet a 1998 
mandate that 50 percent of Head Start teachers nationwide have a 
minimum of an associate degree in early childhood education or a 
related field by September 30, 2003.28  However, GAO found that the 
PIR data did not capture whether a teacher with the required 
credentials was in each classroom.29  These reports did not focus on 
Early Head Start teachers. 
METHODOLOGY 
Through a review of teacher credentials from a sample of randomly 
selected Early Head Start grantees and their delegate agencies 
(hereinafter referred to as programs), this study determined the extent 
to which:  (1) teachers had the required credentials and (2) programs 
employed only teachers with the required credentials.  In addition, we 
conducted a survey of the same programs to describe the activities and 
 
25 GAO, Recovery Act:  Head Start Grantees Expand Services, but More Consistent 
Communication Could Improve Accountability and Decisions About Spending, GAO-11-166, 
December 2010. 
26 Ibid. 
27 OIG, Status of Efforts to Increase the Qualifications of Head Start Teachers,          
OEI-07-01-00560, January 2004. 
28 GAO, Head Start:  Increased Percentage of Teachers Nationwide Have Required 
Degrees, but Better Information on Classroom Teachers Qualifications Needed, GAO-04-05, 
October 2003. 
29 Ibid. 
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challenges of Early Head Start programs trying to meet the education 
and training requirements. 
Scope 
This study focused only on Early Head Start center-based programs 
within the 50 States and the District of Columbia operating in the 
20102011 program year.  It excluded Early Head Start programs from 
U.S. territories.  It also excluded Head Start programs, as Head Start 
teachers have separate education requirements. 
In addition, this study focused on whether Early Head Start          
center-based teachers had credentials.  It did not focus on the 
credentials of other Early Head Start staff, including home-based staff, 
as the education requirements do not apply to them. 
Finally, because of limited ACF guidance about the training 
requirement, this study did not determine whether grantees complied 
with the 2010 training requirement in early childhood development.  
However, we surveyed programs to identify activities and challenges in 
meeting the training requirement. 
Sample Selection 
Program sampling frame.  We developed a sampling frame of programs 
that offered center-based Early Head Start services and were operating 
in the 20102011 program year.  ACF provided a list of 763 programs 
that matched these criteria.  We removed 20 programs from the 
sampling frame because of their location in territories, 1 program 
because it did not match the ZIP Code approximation file we used for 
stratifying samples, and 5 programs that pretested our instruments in 
the early stages of the study.  Our final sampling frame consisted of 
737 programs offering Early Head Start center-based services. 
Sample selection.  After creating the sampling frame of 737 programs, we 
selected a stratified random sample of 223 programs.  We stratified by 
rural and urban status and by number of teachers per program.  We 
stratified by rural and urban status because anecdotal evidence 
suggested that urban programs might be more likely to meet the 
education requirement than rural programs.  We stratified by number 
of teachers to improve the precision of our estimates. 
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To stratify by rural and urban status, we used the 2004 Rural Urban 
Commuting Area (RUCA) codes.30  We matched the ZIP Code of each 
Early Head Start program to 1 of 10 primary codes using RUCAs ZIP 
Code approximation file.  We considered programs to be rural if they 
were located in an area with a population less than or equal to 49,999 
(RUCA primary codes 410).  We considered programs to be urban if 
they were located in an area with a population greater than 49,999 
(RUCA primary codes 13).  This is considered the standard split for 
rural and urban areas according to the RUCA definitions.  Thirty-three 
percent of programs in the sampling frame were rural and 67 percent 
were urban. 
To stratify by number of teachers, we obtained data about funded 
enrollment for the 20102011 program year from ACF.  Then, to 
estimate the number of teachers, we assumed a 1:4 teacher-student 
ratio in classrooms, based on program requirements.31  Table 1 shows 
the population of programs within the sampling frame, the four strata, 
and the final number of programs selected in each stratum.  
   
 
30 RUCA codes classify U.S. Census tracts by population density, urbanization, and daily 
commuting.  The ZIP Code approximation file was developed for use with health care data 
sets.  The 2004 version is the most recent version available.  Rural Health Research Center, 
About Us:  RUCA Origins.  Accessed at https://depts.washington.edu/uwruca/ruca-
about.php on February 22, 2011. 
31 45 CFR 1304.52(g)(4) describes the Early Head Start teacher-student ratio.  In 
summary, it states that programs must ensure that each teacher has responsibility for no 
more than four infants and toddlers. 
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Table 1:  Sample Stratification 
Number of 
Stratum  Program 
Stratum Description  Programs 
Number  Population 
Selected 
1  Urban programs with estimated number of teachers < 150  481  110 
2  Urban programs with estimated number of teachers (cid:127) 150  14  14 
3  Rural programs with estimated number of teachers < 70  238  95 
4  Rural programs with estimated number of teachers (cid:127) 70  4  4 
Total  737  223 
  
Source:  OIG sample stratification, 2010. 
 
Although we did not stratify based on whether a program received 
Recovery Act funds, we collected these data from ACF.                  
Seventy-seven percent of the programs in the sampling frame were 
preexisting programs and the remaining 23 percent were new programs. 
Data Collection 
We emailed the request for teacher credentials and the survey 
regarding training to the 223 sampled programs in October 2010.  We 
made at least two followup attempts by telephone and one by  
signature-required certified mail.  Data collection lasted through 
November 2010.  During data collection, we learned that one program 
no longer offered center-based services and another was not yet in 
operation.  Our final sample consisted of 221 programs. 
To ensure a timely and accurate analysis, we requested teacher 
credentials directly from programs rather than relying on PIR.  PIR 
data for the 20102011 program year will not be available until late 
2011 or early 2012.  In addition, previous OIG reports cited concerns 
about PIR data.32, 33   
Teacher credentials.  From each program, we requested a master list of 
all Early Head Start teachers and one document supporting one of the 
following for each teacher:  (1) highest level of completed education; or 
(2) proof of enrollment in a CDA, certificate, or degree program.  
 
32 OIG, Enrollment Levels in Head Start, OEI-05-06-00250, April 2007. 
33 OIG, Status of Efforts to Increase the Qualifications of Head Start Teachers. 
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Documents to support the highest level of completed education could 
include:  diploma, transcript indicating degree received, CDA, or 
alternative credential.  Documents to support a teachers pursuit of a 
degree or certificate could include:  transcript, CDA application, or 
receipt of paid tuition.  Of the 221 programs, 209 responded to the 
request for teacher credentials, for a program response rate of 
95 percent.   
We estimate that the teacher response rate was 98 percent.  The 
209 programs that responded indicated that they collectively employed 
3,799 teachers.  Using 2010 PIR data, we estimated that, collectively, 
75 teachers were employed at the 12 programs that did not respond to 
our request, for a total of 3,874 teachers.   
Survey.  We also requested that each program complete a survey 
regarding the activities and challenges to ensuring the credentialing 
and training of teachers.  Of the 221 programs, 215, or 97 percent, 
responded.  
Data Analysis 
Teacher credentials.  To determine the extent to which Early Head Start 
teachers had the required credentials and programs employed only 
teachers with required credentials, we reviewed teacher credential 
documents.   
We determined the types of credentials that teachers had.  Our analysis 
included all 3,799 teachers working for the 209 programs that 
responded to the request.  We considered a teacher to have a credential 
if the teacher had a CDA, a college degree, or any alternative credential.  
We considered a teacher as not having a credential if the program did 
not submit documentation for an individual teacher or if the teacher 
had only a high school equivalency.  We calculated the overall 
percentage of teachers that had credentials.  
When teachers did not have credentials, we determined whether they 
were pursuing them.  We considered teachers to be pursuing credentials 
if the documents provided indicated that they had applied for a CDA or 
were enrolled in a certificate or degree program in 2010.   
We considered a program to have met the requirement if all of its 
teachers had credentials.  Our analysis of programs included the 
209 programs that responded to our documentation request.  We 
calculated the percentage of programs that employed only teachers with 
required credentials and the percentage that did not.  For programs 
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that did not employ only teachers with required credentials, we 
determined the percentage of teachers within those programs that had 
required credentials.   
Survey.  To analyze programs responses, we tallied responses to identify 
what programs were doing to meet the education and training 
requirements and any challenges that programs faced.  We also 
reviewed programs open-ended responses to identify approaches to 
training.  We used the results of this analysis to describe the activities 
and challenges of Early Head Start programs trying to meet the 
education and training requirements.     
Statistical tests and projections.  For both teacher credentials and the 
training survey, we determined whether there were any differences by 
rural and urban status and by new and preexisting status.  We used 
appropriate tests to determine whether any differences were 
statistically significant.  We determined statistical significance based on 
a 95-percent confidence level. 
In addition, we projected all results to all 737 Early Head Start    
center-based programs operating in the 20102011 program year and 
all teachers within those programs.  See Appendix A for a list of               
95-percent confidence intervals for all statistical projections. 
Data Limitations  
We did not determine whether alternative credentials met or exceeded 
the CDA requirement.  Although ACF publishes a list of credentials 
that meet or exceed the CDA requirement, ACF staff acknowledge that 
this list is not up to date.  Therefore, we accepted all alternative 
credentials. 
In addition, we did not determine whether the subject area of a college 
degree was related to early childhood education.  ACF has not defined 
what subject areas are related to early childhood education.  To be as 
inclusive as possible, we accepted all degrees as meeting and exceeding 
a CDA, regardless of the subject areas.  
Finally, we based our analysis of teacher credentials on documents 
submitted by the program.  Some teachers may not have provided 
their credentials to their program.  During onsite monitoring visits, 
ACF reviews only credentials that programs keep on file.  We 
assumed that programs sent us all the teachers credentials that were 
on file. 
 
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Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors 
General on Integrity and Efficiency. 
   
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 FF II NN DD II NN GG SS   
Overall, 81 percent of Early Head Start teachers  Eighty-one percent of Early Head 
had the required credentials   Start teachers had credentials that 
were equivalent to or exceeded a 
 
CDA.  The Head Start Act required all Early Head Start teachers to 
have credentials that were equivalent to or exceeded a CDA by 
September 30, 2010.   
Teachers from preexisting Early Head Start programs were more likely 
to have the required credentials than teachers from new programs, at 
82 percent and 73 percent, respectively.34  This difference may be due in 
part to the shorter time between new programs start dates and the 
deadline.  When the Head Start reauthorization was enacted in 2007, 
preexisting programs had nearly 3 years either to hire teachers with the 
required credentials or to ensure that teachers without credentials 
obtained them by the deadline.  However, new programs had less than a 
year to ensure that all teachers had the required credentials, as the first 
distribution of Recovery Act funds occurred in November 2009. 
Teachers had a variety of credentials.  Twenty-one percent had CDAs.  
Forty-five percent had college degrees that were more advanced than a 
CDA, such as associates, bachelors, or advanced degrees.  
Fifteen percent had alternative credentials aside from a college degree 
or a CDA.  See Chart 1 for a breakdown of the education credentials. 
Chart 1:  Education Credentials of Early Head Start Teachers 
30
rs 24
e 25
h 21
c 19 19
a 20
e 15
T
f  15
o
e  10
g
a
t 5 2
n
e
c 0
r
e
P No Credential CDA Alternative  Associate's  Bachelor's  Advanced 
Credential Degree Degree Degree
Source:  OIG analysis of Early Head Start teacher credentials, 2011. 
 
 
34 The difference was statistically significant at the 95-percent confidence level based on 
a Wald chi-square test, p = 0.04. 
  OEI-05-10-00240  MOST EARLY HEAD START TEACHERS HAVE THE REQUIRED CREDENTIALS BUT CHALLENGES EXIST  13   
  
   
F I N D I N G S  
More than half of teachers without the required credentials were 
pursuing them 
Although 19 percent of teachers did not have the required credentials, 
56 percent of these teachers were pursuing them (11 percent of 
teachers overall).  Teachers were considered to be pursuing 
credentials if they were enrolled in a degree program or applying for a 
CDA.  The remaining 44 percent of teachers without credentials were 
not pursuing them (8 percent of teachers overall).   
Teachers who were pursuing credentials may receive them in the near 
future.  For example, 21 percent of teachers without credentials were 
applying for a CDA through the Council (4 percent of teachers 
overall).  This means that they will most likely receive their CDA 
within a years time, assuming that they submitted all of the 
paperwork correctly and that the Council awards the CDA in a timely 
fashion.   
 
Approximately one-third of Early Head Start  Thirty-five percent of programs 
programs employed only teachers with the  employed only teachers with the 
required credentials  required credentials, whereas 
65 percent employed at least 
one teacher without the required credentials.   
Overall, more than half of the teachers at 89 percent of programs had 
the required credentials.  While approximately one-third of programs 
employed only teachers with the required credentials, 7699 percent 
of teachers employed by another third of programs had the required 
credentials.  In 3 percent of programs, 25 percent or fewer teachers 
had the required credentials, including 1 percent that did not employ 
any teachers with the required credentials.  See Chart 2 for a 
breakdown of programs by percentage of teachers with the required 
credentials.  
 
 
 
 
 
 
  OEI-05-10-00240  MOST EARLY HEAD START TEACHERS HAVE THE REQUIRED CREDENTIALS BUT CHALLENGES EXIST  14   
  
   
F I N D I N G S  
Chart 2:  Programs by Percentage of Teachers With Required Credentials  
40
35
s 35 32
m
a 30
r
g
o
r 25 22
P
f 
o 20
e 
g
a 15
t
n
ce 10 8
r
e
P 5 3
0
025%  2650% 5175%  7699%  100%
Percentage of Teachers With Credentials
Source:  OIG analysis of Early Head Start teacher credentials, 2011.  
 
Nearly all Early Head Start programs reported  Ninety-six percent of programs 
reported requiring teachers to 
requiring teachers to complete training 
complete ongoing training.  This 
 
indicates that almost all programs were attempting to ensure that all 
teachers met the training requirements, which are:  (1) that all teachers 
have training in early childhood development by September 30, 2010; 
and (2) that all teachers have training in infant and toddler 
development by September 30, 2012.   
In general, programs identified training topics that included early 
childhood development, infant and toddler development, safety, and 
communication methods.  These topics correspond to the subject areas 
identified in the 1996 regulations.  In addition, the topics appear to 
cover the broad areas outlined in the 2010 and 2012 training 
requirements.  Some specific examples provided by programs included:  
developmentally appropriate curriculum, early literacy, sudden infant 
death syndrome, first aid, cardiopulmonary resuscitation, 
parent/teacher interaction, and responding to cultural diversity.   
In addition, some programs also identified a variety of training topics 
focused on administering the Early Head Start program.  These topics 
included State policies, procedures, and licensing requirements; 
performance standards; and records management.  
  OEI-05-10-00240  MOST EARLY HEAD START TEACHERS HAVE THE REQUIRED CREDENTIALS BUT CHALLENGES EXIST  15   
  
   
F I N D I N G S  
Although most programs required training for teachers, the number of 
hours required varied widely.  For example, programs survey responses 
indicated a range of 0 to 140 hours per year, with a median of 15 hours 
per year.  Only 3 of the 184 programs indicated that they did not expect 
teachers to receive any training hours in a year.  This variation could 
occur, in part, because ACF has not provided guidance to programs 
regarding the amount of training that Early Head Start teachers must 
have.   
Early Head Start programs may look to Head Start requirements for 
guidance about training.  The Head Start Act defines the number of 
hours of training that Head Start teachers must receive.  Head Start 
teachers have a yearly 15-hour in-service requirement.35  In fact, 
40 percent of Early Head Start programs required 15 hours of training 
per year.   
Early Head Start programs reported challenges  Most programs reported 
challenges either to employing 
to employing only teachers with the required 
only teachers with the required 
credentials and to training teachers 
credentials or to training 
teachers.  In fact, 85 percent of pro grams identified at least one 
challenge to employing all teachers with the required credentials, and 
87 percent of programs identified at least one challenge to training 
teachers.  In particular, programs reported challenges to credentialing 
and training teachers because of problems with the workforce. 
Eighty-three percent of Early Head Start programs reported challenges to 
employing only teachers with the required credentials 
Many programs reported that they could not find teachers with 
credentials.  In fact, there may not be a sufficient supply of teachers 
with credentials.  In an October 2010 information memorandum, ACF 
recognized that Early Head Start programs may have difficulties 
finding qualified teachers.  ACF recognized that the additional pressure 
to expand Early Head Start programs while finding teachers with 
credentials may create a demand-supply imbalance.  In particular, new 
programs may have experienced challenges to finding teachers with 
credentials as a result of this imbalance. 
Programs described some of their challenges to finding teachers with 
the required credentials.  One program provided the following example: 
 
35 Head Start Act  648A(a)(5), 42 U.S.C.  9843a(a)(5). 
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F I N D I N G S  
We could not find qualified applicants that came to us with the 
required credentials.  We hired staff that had experience in Early 
Childhood infants and toddlers who already had some documented 
hours of training and some of the required hours for the CDA 
process.  
Early Head Start programs most commonly identified finding substitutes 
and managing work schedules as challenges to training teachers 
Programs identified several challenges to training teachers.  Most 
commonly, programs reported difficulties finding substitutes and 
managing work schedules as challenges to providing training, at 
80 percent and 66 percent, respectively.36  
Programs indicated that if teachers attend training during the workday, 
they must either close the program for the day or find substitute 
teachers.  Closing for the day can cause problems for parents who 
depend on full-day services.  On the other hand, hiring substitutes 
raises concerns about continuity of care for the children.  However, if 
training is offered during evening or weekend hours to lessen the need 
for substitutes, this creates a work-life imbalance for teachers.  In many 
cases, programs indicated that they must pay overtime for training 
outside the scheduled workdays.  In fact, 52 percent of programs stated 
that they did not have the funds to pay teachers overtime to attend 
training. 
Programs described some of their challenges related to scheduling and 
finding substitutes.  One clearly described its difficulties in finding 
substitutes and concerns about overtime pay:  Our pool of substitutes is 
not adequate for staffing EHS [Early Head Start] classrooms when 
[training] classes are offered during center hours of operation.  
Therefore, we would have to pay overtime that would adversely impact 
our budget. 
Another program discussed its concern that scheduling training causes 
work schedule problems: 
Basically, classroom coverage is always a challenge.  We want to 
have consistency and continuity of care for our children, so 
substitutes are not appropriate, unless they are regular and 
familiar with the children.  Also, teachers are tired and have 
families.  They want to go home in the evenings.  Too many 
evening classes causes stress for them and their families. 
 
36 Programs reported these challenges more frequently than others.  This difference is 
statistically significant at the 95-percent confidence level. 
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F I N D I N G S  
Other challenges to training teachers appeared to be more prevalent in rural 
areas 
Although most programs identified at least one training challenge, some 
appeared to be more prevalent in rural areas.  For example, overall, 
18 percent of programs reported challenges to identifying trainers for 
infant and toddler development in their areas.  However, this challenge 
was heightened for programs in rural areas.  Thirty-four percent of 
rural programs identified this as a challenge compared to 11 percent of 
urban programs.  Table 2 compares challenges faced by rural and urban 
programs. 
Table 2:  Programs That Identified Challenges, Overall and by Rural and Urban Status 
Challenge  Overall  Rural  Urban 
Difficulty finding substitute teachers  80%  80%  80% 
F I N D I N G S  
Difficulty managing training around work schedules  66%  71%  64% 
Inadequate funds to pay teachers overtime to attend training  52%  59%  49% 
Difficulty finding appropriate programs  30%  44%*  23% 
Lack of funds to pay outside trainers  23%  34%*  17% 
Lack of trainers for infant and toddler development  18%  34%*  11% 
Lack of trainers for early childhood development  12%  24%*  6% 
Trainers refusal to travel to area  10%  17%*  6% 
* Indicates a statistically significant difference between rural and urban programs at the 95-percent confidence level. 
Source:  OIG analysis of program survey responses, 2011. 
Rural programs discussed unique challenges to providing training, such 
as distance between programs, travel time, and additional expenses 
related to travel.  One program in particular provided a good overview 
of its difficulties trying to ensure that teachers receive training:  
Our program has EHS [Early Head Start] in 5 rural counties and 
getting staff together for any training event is difficult due to 
distances that staff have to travel.  We often get hotel rooms for 
these staff members to come to trainings.  This is an extra expense 
to the program.  The travel takes time and therefore time away 
from work with children and families.  Our in house component 
trainers are also limited in making individualized visits to EHS 
sites again due to travel, distance and time.  One of our sites is 
2 hours away from the central office and to get to this site it 
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F I N D I N G S  
requires traveling over a mountain which is not always safe in 
winter weather. 
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R E RRC EEO MCC MOO EMM NMM DEE ANNT DDI AAO TTN IIS OO  NN SS   
Overall, 81 percent of Early Head Start teachers had credentials that 
were equivalent to or exceeded a CDA.  Approximately one-third of 
programs employed only teachers who met the education requirement 
that all teachers have a minimum of a CDA.  Nearly all programs 
reported requiring teachers to complete training.  However, most 
reported challenges either to employing only teachers with the required 
credentials or to training teachers.  In particular, challenges related to 
the lack of a workforce and, in rural areas, finding appropriate training. 
To increase the percentage of programs that employed only teachers 
with the required credentials and to help programs meet the 
requirements, we make the following recommendations to ACF: 
Work with Early Head Start programs to ensure that all teachers have the 
required credentials 
ACF should work to ensure that all Early Head Start programs employ 
only teachers with the required credentials.  ACF could pursue a variety 
of options.  For example, ACF could: 
Provide additional support to Early Head Start programs that were newly 
developed with Recovery Act funds.  Teachers from new programs were 
less likely to have credentials than teachers from preexisting programs.   
Identify and share strategies used by programs that employed only teachers 
with the required credentials.  Approximately one-third of programs 
employed only teachers with the required credentials.  Their 
experiences and strategies may be useful to programs that do not 
employ only teachers with the required credentials. 
Work with programs that employ teachers without the required credentials to 
develop and implement an action plan.  Approximately two-thirds of 
programs did not employ only teachers with the required credentials.  
ACF could work with programs to develop an action plan to ensure that 
all teachers obtain the required credentials.  This action plan may 
include ensuring that all teachers without credentials are pursuing 
them and that there is at least one credentialed teacher in each 
classroom.   
Provide guidance to programs about training teachers 
ACF should develop guidance regarding training, which may include an 
expected number of training hours or a list of suggested online 
coursework.  It may also include guidance on what needs to be done to 
meet the training requirements for future teachers hired.  Programs 
survey responses varied widely in the amount of training they provided 
  OEI-05-10-00240  MOST EARLY HEAD START TEACHERS HAVE THE REQUIRED CREDENTIALS BUT CHALLENGES EXIST  20   
  
   
R E C O M M E N D A T I O N S  
to teachers, with a range from 0 to 140 hours per year and a median of 
15 hours per year.  Further, ACF has not provided guidance to 
programs regarding the amount of training that Early Head Start 
teachers must have.   
In addition, because 87 percent of programs identified at least one 
challenge to training teachers, ACFs guidance should include 
suggestions for overcoming such challenges.  This could include 
compiling a list of teachers, training, or courses available online.  ACF 
could also work with programs to determine any lessons learned or 
successful strategies that could be shared with other programs.  
Particular attention should be paid to rural programs because 
challenges to training teachers appeared to be more prevalent in rural 
areas.  
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
ACF concurred with our recommendations.  ACF described ongoing 
initiatives to increase the number of Early Head Start teachers with 
credentials, such as partnerships with educational institutions.  It also 
stated that it plans to issue an information memorandum in the 
summer of 2011 to provide additional guidance for programs on teacher 
credentials and qualifications.  In addition, ACF stated that it could 
provide guidance about teacher training, but that it could not require a 
certain number of training hours without a regulatory change.   
We encourage ACF to issue both the planned information memorandum 
about teacher credentials and qualifications and guidance about teacher 
training. We did not make any changes to the report based on ACFs 
comments.  For the full text of ACFs comments, see Appendix B.       
   
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   A P P E N D I X ~ A  
Estimates and Confidence Intervals 
Table A-1:  Estimates of Teachers With the Required Credentials   
95-Percent 
Estimate Description  Sample Size  Percentage 
Confidence Interval 
Teachers with the required credentials  3,799  81.1%   77.6%84.6%  
Teachers from preexisting programs with the required credentials  3,257  82.5%*  78.7%86.3%  
Teachers from new programs with the required credentials  542  73.1%   65.6%80.6%  
* Actual result is 82.489 percent, which we rounded to 82.5 percent in this table and 82 percent in the findings.   
Source:  Office of Inspector General (OIG) analysis of Early Head Start teacher credentials, 2011.   
 
Table A-2:  Estimates of Teachers by Type of Credential   
Sample  95-Percent 
Estimate Description  Percentage 
Size  Confidence Interval 
Teachers with a child development associate (CDA) credential  3,799  21.4%   18.2%24.6%  
Teachers with any degree (i.e., associates, bachelors, or advanced 
3,799  44.6%   40.8%48.5% 
degree) 
Teachers with alternative credentials  3,799  15.2%   11.4%18.9%  
Teachers with no credentials  3,799  18.9%   15.4%22.4%  
Teachers with associates degrees  3,799  23.9%   20.8%26.9%  
Teachers with bachelors degrees  3,799  18.8%   16.3%21.3%  
Teachers with advanced degrees  3,799  2.0%   1.5%2.4%  
Source:  OIG analysis of Early Head Start teacher credentials, 2011.   
 
 
 
 
 
 
 
 
 
 
 
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A P P E N D I X   ~   A  
 
Table A-3:  Estimates of Teachers Pursuing Credentials 
Sample Size  Sample Size 
Percentage 
Percentage 
of Teachers 
Estimate Description  of All 
Without 
95-Percent  Teachers  95-Percent 
Credentials 
Confidence Interval  Confidence Interval 
706  3,799 
Teachers who were pursuing credentials  56.4%  10.7% 
46.8% 66.0%  8.1%13.2% 
706  3,799 
Teachers who were not pursuing credentials  43.6%  8.3% 
34.0%53.2%  5.8%10.7% 
706  3,799 
Teachers in the process of applying for CDAs  20.8%  3.9% 
14.1%27.4%  2.6%5.3% 
Source:  OIG analysis of Early Head Start teacher credentials, 2011.     
 
Table A-4:  Estimates of Programs Hiring Only Teachers With Required Credentials 
Sample  95-Percent 
Estimate Description  Percentage 
Size  Confidence Interval 
Programs that had only teachers with the required credentials  209  35.1%  29.2%41.1% 
Programs that did not have only teachers with the required credentials  209  64.9%   58.9% 70.8%  
Source:  OIG analysis of Early Head Start teacher credentials, 2011.   
 
Table A-5:  Estimates of Programs With Teachers Who Had the Required Credentials 
Sample  95-Percent 
Estimate Description  Percentage 
Size  Confidence Interval 
Programs in which the majority of teachers had the required credentials   209  88.8%  84.9%92.7% 
Programs in which 7699% of teachers had the required credentials  209  32.2%   26.3%38.0% 
Programs in which 025% of teachers had the required credentials  209  3.2%   0.9%5.5% 
Programs in which 0% of teachers had the required credentials  209  1.0%  0.3%3.4% 
Programs in which 2650% of teachers had the required credentials  209  8.0%   4.7%11.3%  
Programs in which 5175% of teachers had the required credentials  209  21.5%   16.5%26.6% 
Source:  OIG analysis of Early Head Start teacher credentials, 2011.   
 
 
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A P P E N D I X   ~   A  
 
Table A-6:  Estimates of Survey Responses Regarding Teacher Credentials and 
Training 
Sample  95-Percent 
Estimate Description  Percentage 
Size  Confidence Interval 
Programs that require teachers to complete ongoing training  212  95.5%  92.9%98.1% 
Programs that require 15 hours of training per year  184  40.0%  33.7%46.4% 
Programs that identified at least one challenge to having only teachers 
98  84.7%  77.9%91.5% 
with the required credentials  
Programs that identified at least one challenge to training teachers  215  87.4%  83.3%91.6% 
Programs that could not find teachers with the required credentials  98  83.1%  76.1%90.0% 
Programs that reported finding substitutes as a challenge  213  80.3%  75.3%85.2% 
Programs that reported managing work schedules as a challenge  213  66.0%  60.2%71.9% 
Programs that reported not having funds to pay teachers overtime to 
213  52.4%  46.2%58.5% 
attend training as a challenge 
Programs that reported challenges to identifying trainers for infant and 
213  18.4%  14.2%22.7% 
toddler development in their areas 
Rural programs that reported challenges to identifying trainers for infant 
95  34.3%  26.8%41.9% 
and toddler development in their areas  
Urban programs that reported challenges to identifying trainers for 
118  10.6%  5.5%15.7% 
infant and toddler development in their areas 
Rural programs that reported finding substitutes as a challenge  95  80.1%  73.8%86.5% 
Urban programs that reported finding substitutes as a challenge  118  80.3%  73.7%87.0% 
Rural programs that reported managing work schedules as a challenge  95  71.1%  63.8%78.3% 
Urban programs that reported managing work schedules as a challenge  118  63.5%  55.6%71.5% 
Rural programs that reported not having funds to pay teachers overtime 
95  58.5%  50.6%66.4% 
to attend training as a challenge 
Urban programs that reported not having funds to pay teachers 
118  49.4%  41.1%57.7% 
overtime to attend training as a challenge 
Programs that reported finding appropriate training programs as a 
210  30.2%  24.8%35.6% 
challenge 
Rural programs that reported finding appropriate training programs as a 
93  44.4%  36.3%52.4% 
challenge 
Urban programs that reported finding appropriate training programs as 
117  23.3%  16.3%30.3% 
a challenge 
Programs that reported not having funds to pay outside trainers as a 
211  22.5%  17.6%27.4% 
challenge 
Rural programs that reported not having funds to pay outside trainers 
93  34.2%  26.5%41.9% 
as a challenge 
continued on next page 
 
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A P P E N D I X   ~   A  
 
Table A-6:  Estimates of Survey Responses Regarding Teacher Credentials and 
Training (Continued)  
Sample  95-Percent 
Estimate Description  Percentage 
Size  Confidence Interval 
Urban programs that reported not having funds to pay outside trainers 
118  16.9%  10.6%23.1% 
as a challenge 
Programs that reported challenges to identifying trainers for early 
213  11.7%  8.3%15.1% 
childhood development 
Rural programs that reported challenges to identifying trainers for early 
95  24.2%  17.3%31.0% 
childhood development  
Urban programs that reported challenges to identifying trainers for 
118  5.6%  1.7%9.4% 
infant and toddler development in their areas 
Programs that reported trainers refusal to travel to their areas as a 
207  9.6%  6.3%13.0% 
challenge 
Rural programs that reported trainers refusal to travel to their areas as 
92  17.2%  11.1%23.3% 
a challenge 
Urban programs that reported trainers refusal to travel to their areas as 
115  5.9%  2.0%9.9% 
a challenge 
Note:  The number of respondents varies because survey respondents did not answer every question.   
Source:  OIG analysis of program survey responses, 2011. 
 
   
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Agency Comments 
DEPARTMENT OF HEALTH &. HUMAN SERVICES 
ADMINISTRATION FOR CHILDREN AND FAMILIES 
Office of the Assistant Secretary, Suite 600 
370 L'Enfant Promenade, S.W. 
Washington, D.C..20447 
JUN  1 52011 
TO:  Daniel R. Levinson 
Inspector General 
FROM:  David A. Hansell 
Acting Assistant Secretary 
for Children and Families 
SUBJECT:  Office of Inspector General (OIG) Draft Report titled, "Most Early Head 
Start Teachers Have the Required Credentials, But Challenges Exist" 
(OEI-05-10-00240) 
Attached is the Administration for Children and Families comments on the above-referenced 
OIG draft report. 
Should you have questions or need additional infonnation, please contact Yvette Sanchez 
Fuentes, Director, Office ofHead Start, at 202-205-8573. 
Attachment 
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A P P E N D I X   ~   B  
   
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A P P E N D I X   ~   B  
 
 
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 A C K N O W L E D G M E N T S  
  
This report was prepared under the direction of Ann Maxwell, Regional 
Inspector General for Evaluation and Inspections in the Chicago 
regional office, and Thomas F. Komaniecki, Deputy Regional Inspector 
General. 
Nicole Hrycyk served as the team leader for this study.  Beth McDowell 
served as the lead analyst.  Other principal Office of Evaluation and 
Inspections staff from the Chicago regional office who contributed to the 
report include Ericka Kilburn and Margarita Rodriguez; other central 
office staff who contributed include Talisha Searcy and Kevin Farber. 
  OEI-05-10-00240  MOST EARLY HEAD START TEACHERS HAVE THE REQUIRED CREDENTIALS BUT CHALLENGES EXIST  31   
  
Office of Inspector General 
http://oig.hhs.gov 
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 
amended, is to protect the integrity of the Department of Health & Human Services (HHS) 
programs, as well as the health and welfare of beneficiaries served by those programs.  This 
statutory mission is carried out through a nationwide network of audits, investigations, and 
inspections conducted by the following operating components: 
Office of Audit Services 
The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting 
audits with its own audit resources or by overseeing audit work done by others.  Audits 
examine the performance of HHS programs and/or its grantees and contractors in carrying 
out their respective responsibilities and are intended to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and 
mismanagement and promote economy and efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud, waste, or abuse and promoting 
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 
of fraud and misconduct related to HHS programs, operations, and beneficiaries.  With 
investigators working in all 50 States and the District of Columbia, OI utilizes its resources 
by actively coordinating with the Department of Justice and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to criminal 
convictions, administrative sanctions, and/or civil monetary penalties. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to 
OIG, rendering advice and opinions on HHS programs and operations and providing all 
legal support for OIGs internal operations.  OCIG represents OIG in all civil and 
administrative fraud and abuse cases involving HHS programs, including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program guidance, publishes fraud alerts, and provides other 
guidance to the health care industry concerning the anti-kickback statute and other OIG 
enforcement authorities.