Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
MIGRANT  HEAD  START  GRANTEES: 
PERSPECTIVES  AND  CHALLENGES 
DECEMBER  1993  OFFICE OF INSPE~OR  GENERAL 
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  and 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 three  OIG  operating  components:  the Office of Audit  Services,  the 
Office of Investigations,  and the  Office of Evaluation  and Inspections.  The  OIG  also informs 
the  Secretary  of HHS  of program  and management  problems  and recommends  courses  to 
correct  them. 
OFFICE OF AUDIT  SERVICES 
The  OIGS  Office of Audit  Services  (OAS)  provides  all 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  in order  to reduce  waste,  abuse,  and 
mismanagement  and to promote  economy  and efficiency throughout  the  Department. 
OFFICE OF INVESTIGATIONS 
The  OIGS  Office of Investigations  (01)  conducts  criminal,  civil, and administrative 
investigations  of allegations  of wrongdoing  in HHS  programs  or to HHS  beneficiaries  and of 
unjust  enrichment  by providers.  The  investigative  efforts  of 01  lead to criminal  convictions, 
administrative  sanctions,  or civil money  penalties.  The  01  also oversees  State  Medicaid  fraud 
control  units which investigate  and prosecute  fraud  and patient  abuse  in the Medicaid  program. 
OFFICE OF EVALUATION  AND  INSPECIIONS 
The  OIGS Office of Evaluation  and Inspections  (OEI)  conducts  short-term  management  and

program  evaluations  (called  inspections)  that  focus on issues of concern  to the  Department,

the  Congress,  and the  public.  The  findings  and recommendations  contained  in these  inspection

reports  generate  rapid,  accurate,  and up-to-date  information  on the  efficiency, vulnerability,

and effectiveness  of departmental  programs.  This report  was prepared  in the  San Francisco

regional  office under  the  direction  of Kaye D. Kidwell, Regional  Inspector  General,  and

Paul  A. Gottlober,  Deputy  Regional  Inspector  General.  Project  staff included:

Brad Rollin,  Project  Leader

Elizabeth  Bell

Ellen  Kotler

Donald  Loeb

Jennifer  Mallen

Brian  Pattison

Alan  Levine,  Program  Specialist,  Headquarters

For  additional  copies  of this report,  please  contact  the  San Francisco  office at (415) 556-6830.
 Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENEML 
MIGRANT  HEAD  START  GRANTEES: 
PERSPECTIVES  AND  CHALLENGES 
OEI-09-91-00761 
DECEWER  1993  EXECUTIVE  SUMMARY 
PURPOSE 
This  inspection  identified  and  assessed  the  expansion  experiences  and  challenges  of 
selected  migrant  Head  Start  grantees  and  delegates. 
BACKGROUND 
At  the  Federal  level,  the  Department  of Health  and  Human  Services  (HHS) 
Administration  for  Children  and  Families  (ACF)  is responsible  for  administering  Head 
Start.  The  ACF  awards  grants  to  a public  or  private  nonprofit  agency  (called  a 
grantee)  to operate  a Head  Start  program.  A grantee  may contract  with  one  or more 
other  public  or private  nonprofit  organizations  in the  community  (called  delegates)  to 
run  all or part  of its Head  Start  program.  The  Migrant  Programs  Branch  within 
ACFS Head  Start  Bureau  oversees  all migrant  grantees.  Nationally,  28 grantees  serve 
approximately  28,000 migrant  children  with a total  annual  budget  of $88.8 million. 
Migrant  Head  Start  provides  valuable  services  to a population  that  otherwise  might 
not  receive  them.  Migrant  families  lives are  complicated  by their  transitory  nature, 
language  and  cultural  barriers,  and  inexperience  navigating  the  system.  Migrant 
Head  Start  grantees  provide  children  with  a safe  place  to learn  while  their  parents 
work.  They  ensure  that  each  childs health,  nutrition,  and  other  basic  needs  are  met. 
Like  non-migrant  (hereafter  referred  to as regular)  Head  Start  grantees,  migrant 
grantees  also  are  required  to identify  and  address  the  needs  of the  entire  family. 
Migrant  grantees  are  very different  from  regular  Head  Start  grantees.  They  serve  a 
broader  age  range  of children--including  infants  and  toddlers--who  require  different 
facilities,  equipment,  and  staff  skills.  Grantees  must  be  able  to provide  setices  for 
children  whose  parents  work  10 to  14 hours  per  day and  6 to 7 days per  week.  In 
addition,  grantees  must  provide  services  in a shorter  timeframe,  because  families  may 
not  remain  in the  program  for more  than  a few weeks  before  leaving  the  area. 
Both  the  Administration  and  Congress  are  committed  to expanding  Head  Start.  Since 
Fiscal  Year  1990, Head  Start  total  funding  has  increased  more  than  $1 billion,  adding 
almost  300,000 children.  Based  on concerns  about  grantees  ability  to handle 
expansion,  ACF,  the  Assistant  Secretary  for Management  and  Budget,  and  the 
Assistant  Secretary  for Planning  and  Evaluation  requested  that  the  Office  of Inspector 
General  (OIG)  review  the  implementation  and  status  of Head  Start  expansion.  These 
Department  officials  were  concerned  that  rapid  expansion  might jeopardize  the  quality 
of services  that  grantees  provide  to children  and  families.  The  Head  Start  Migrant 
Programs  Branch  Chief  expressed  similar  concerns  about  the  impact  of expansion  on 
grantees  that  serve  migrant  children  and  families. 
i  This  report  is one  in a series  prepared  by the  OIG  on Head  Start  expansion.  Two 
other  reports  in the  series,  Head  Start  Expansion:  Grantee  Experiences 
(OEI-09-91-O0760)  and  Evaluating  Head  Start  Expansion  through  Performance 
Indicators  (OEI-09-91-00762),  describe  regular  Head  Start  grantees  experiences  with 
expansion. 
During  September  1992, we conducted  on-site  visits and  structured  intemiews  with  six 
migrant  Head  Start  grantees  and  delegates  whose  enrollment  totals  28 percent  of all 
children  in migrant  Head  Start  nationally.  We  selected  the  grantees  and  delegates 
based  on the  size of their  expansions  in 1990 and/or  1991.  During  the  interviews,  we 
asked  grantees  to describe  their  experiences  and  opinions  about  operating  a Head 
Start  program  and  their  predictions  about  the  future.  Our  goal was to obtain 
information  that  would  provide  a snapshot  of selected  migrant  grantees  ongoing 
operations  as well as their  experiences  with expansion.  In response  to ACFS 
comments  on the  draft  report,  we also conducted  brief  follow-up  interviews  with the 
grantees  and  delegates  in August  1993 to obtain  additional  information  about  their 
facilities.  We  did not  conduct  a comprehensive  management  or file review  to verify 
the  accuracy  of the  grantees  opinions  and  predictions.  Nevertheless,  we believe  our 
findings  will offer  policymakers  valuable  information  about  major  issues  and  problems 
facing  migrant  grantees. 
FINDINGS 
The  following  findings  reflect  the  experiences  and  opinions  of the  six migrant  grantees 
that  we interviewed, 
Some Herd Startper$onnancereqtiementr muy not be approphte for migrantgrantees 
The  sampled  grantees  expressed  concerns  about  many  of the  major  performance 
standards,  including  parent  involvement,  home  visits, medical  and  dental  screens,  and 
enrollment  and  education.  Although  ACF  recognizes  that  the  standards  should  not  be 
strictly  interpreted  for migrant  grantees,  specific  guidelines  have  not  been  developed 
and  disseminated. 
Some of theproposedinfantandtodkilerprogmmstandard maybe  u.nreaihtic 
Some  migrant  grantees  may not  be  able  to comply  with several  of the  requirements 
contained  in the  proposed  Head  Start  standards.  Grantees  are  particularly  concerned 
about  the  standards  concerning  child-to-staff  ratios  and  medical  examinations.  The 
ACF  is aware  of this  and  will consider  the  grantees  concerns  and  comments  before 
the  standards  are  finalized. 
ii  LM@ed jimdingand unrehhbletif~tion  about the migrantpopdahn  @IU@@ 
hiiader  grantees  abilitytoplan 
All sampled  grantees  reported  that  delayed  expansion  funds  inhibited  planning,  forced 
loans,  and  caused  carry-over  balances.  In addition,  the  grantees  experienced  planning 
problems  because  of the  lack of demographic  information  about  migrants  and  the 
migrant  stream. 
The  six grantees  described  difficulties  acquiring  adequate  and  affordable  facilities, 
providing  transportation  for children,  hiring  qualified  staff,  and  meeting  the  Federal 
match  requirement.  The  grantees  overcame  these  problems  but  are  concerned  that 
the  problems  will be  exacerbated  with future  expansions. 
Gmnteesareconcernedthatongoingandfdure changesinthenatureof m&rantwok 
mayhindertheuabilityto servemigrantfamilies 
New job  opportunities  and  conflicting  agency  definitions  of the  term  migrant  may 
present  barriers  to serving  migrant  families  in the  future. 
Sarnpkdgranteescitedprobkms withtheon-sitereviewprocm,  thestatisticarleprting 
req&men@  and the MigrantRograms Branch 
Some  grantees  have  a strained  relationship  and  difficulty  communicating  with the 
Migrant  Programs  Branch. 
RECOMMENDATION 
7%eACF shouldincludeprobkns  specificto the migrantprogramin the reviewof Head 
start%management 
In the  OIG  report  Evaluating  Head  Start  Expansion  through  Performance  Indicators, 
we recommended  that  the  Secretary  convene  a task  force  to review  ACFS 
management  of the  Head  Start  program.  On June  11, 1993, the  Secretary  appointed 
the  Advisory  Committee  on Head  Start  Quality  to conduct  an in-depth  study of the 
Head  Start  program  with particular  attention  to issues identified  in the  OIG  reports 
Head  Start  Expansion:  Grantee  Experiences  and  Evaluating  Head  Start  Expansion 
through  Performance  Indicators.  The  Secretary  asked  the  Advisory  Committee,  which 
is chaired  by the  Assistant  Secretary  for Children  and  Families,  to develop 
recommendations  to improve  and  strengthen  the  program  in a time  of expansion. 
As a result  of this inspection,  we recommend  that  the  Advisory  Committee  include 
migrant  Head  Start  in the  examination.  Because  the  migrant  program  is unique,  the 
review  also should: 
... 
111
 determine  whether  separate  performance  standards  for migrant  programs 
would  be  appropriate, 
assess  the  cost and  potential  impact  of the  proposed  infant  and  toddler 
program  standards  on both  ACF  and  grantees, 
determine  whether  funding  and  expansion  cycles should  be  tailored  to migrant 
grantees, 
address  the  changing  role  of migrant  work  and whether  changes  in ACFS 
definition  of migrant  are  necessary, 
determine  when  it would  be  appropriate  for migrant  grantees  to purchase 
property, 
evaluate  the  timing  of the  PIR  process  and  the  accuracy  of PIR  data, 
evaluate  the  role  and  effectiveness  of the  Migrant  Programs  Branch,  and 
identify  other  areas  where  ACF  should  grant  flexibility to grantees  who are 
experiencing  difficulties  serving  migrant ~amilies. 
AGENCY  COMMENTS  AND  OIG  RESPONSE 
We  received  written  comments  on the  draft  report  from  ACF.  The  ACF  noted  that 
the  migrant  program  would  be  reviewed  as  part  of the  overall  review  of the  Head 
Start  program  ordered  by the  Secretary.  The  full text  of ACFS comments  appears  in 
the  appendix.  In response  to ACFS comments,  we conducted  follow-up  interviews 
with grantees  to obtain  additional  information  about  their  facilities.  The  final  report 
incorporates  information  from  the  follow-up  interviews,  including  more  detail  about 
the  facility purchase  issue.  We  also made  technical  corrections  to the  findings, 
clarified  that  the  report  is based  on the  grantees  opinions  and  experiences,  and 
modified  the  recommendation  to ensure  that  it more  accurately  describes  the  issues 
that  the  Head  Start  task  force  should  study. 
iv  TABLE  OF  CONTENTS 
PAGE 
EXECUTIVE  suMMf=Y 
1 
INTRODUmON  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
7 
FINDINGS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
7 
  Performance  Requirements  for Migrant  Grantees  . . . . . . . . . . . . . . . . . . . . . . . 
.8

  Infant  and  Toddler  Progam  Standards  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
8 
  Grantees  Inability  to Plan....  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
..10

  Expansion  Problems  and  Concerns  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
.  12

  Changing  Nature  ofMigrantWork  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
  On-Site  Review  Process,  Statistical  Reporting  Requirements,  .  12 
and  the  Migrant  Programs  Branch  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
.  15 
RIZOMMENDAnON  .  . . . . . . . . . . . .  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
APPENDK.  ACFComments  INTRODUCTION 
PURPOSE 
This  inspection  identified  and  assessed  the  expansion  experiences  and  challenges  of 
selected  migrant  Head  Start  grantees  and  delegates. 
BACKGROUND 
Head  Start  operates  on the  premise  that  children  are  best  prepared  for success  in 
school  when  they  and  their  parents  participate  in a comprehensive  program  that 
addresses  their  educational,  economic,  social, physical,  and  emotional  needs.  In 
addition  to providing  children  with  classes  and  health  services,  Head  Start  addresses 
the  needs  of the  entire  family. 
lhe  Head StartI?ogram 
Head  Start  is a child  development  program  funded  primarily  by the  Federal 
government.  The  Administration  for  Children  and  Families  (ACF)  is responsible  for 
administering  Head  Start.  At the  headquarters  level, ACFS Head  Start  Bureau 
provides  leadership  and  develops  legislative  and  budgetary  proposals  for  Head  Start 
management  and  operations.  In each  regional  office,  ACFS Head  Start  and  Youth 
Branch  monitors  all Head  Start  programs,  except  migrant  and  Native  American 
programs,  which  are  monitored  by branches  within  headquarters.  According  to ACF, 
Head  Start  served  approximately  622,000 children  with Federal  support  of $2.2 billion 
in Fiscal  Year  (FY)  1992. 
Head  Start  programs  are  community-based,  so agencies  can  respond  to local  needs 
and  coordinate  with  other  community  organizations.  As a result,  program  options, 
locations,  and  hours  vary.  The  Federal  government  awards  grants  to  a public  or 
private  nonprofit  agency  (called  a grantee)  to operate  a Head  Start  program.  A 
grantee  may  contract  with one  or more  other  public  or private  nonprofit  organizations 
in the  community  (called  delegates)  to run  all or part  of its Head  Start  program.  For 
the  purposes  of this report,  we will refer  to both  grantees  and  delegates  as grantees 
unless  specific  differences  need  to be  noted. 
Head  Start  programs  consist  of four  major  components:  health, education,  social 
services, and parent  irzvolvenzent.  Specific  performance  standards,  which  have  been 
published  in the  Code  of Federal  Regulations,  require  among  other  things  that 
grantees: 
  develop  childrens  intellectual  skills  by encouraging  them  to  solve  problems, 
c  provide  children  medical  and  dental  examinations, 
1
   offer  children  nutritional  meals  and  snacks,  and 
	 identi@  families  social  service  needs  and  work  with  other  community  agencies 
to  meet  those  needs. 
All grantees  must  comply with the  performance  standards.  In addition,  ACF has 
issued  guidance  material  which  elaborates  on the  intent  of the  performance  standards 
and  provides  methods  and  procedures  for their  implementation.  The  guidance 
material,  however,  is not  mandated. 
Mi~nt  Head Start 
In  1969, Congress  funded  the  Indian  and  Migrant  Programs  Division  (IMPD)  to 
separate  Native  American  and  migrant  Head  Start  from  regular  Head  Start 
administration.  In  1984, IMPD  split into  two separate  branches.  Today,  ACFS 
Migrant  Programs  Branch  oversees  all migrant  Head  Start  grantees.  Nationally, 
28 grantees  serve  approximately  28,000 migrant  children  with  a total  annual  budget 
of $88.8 million. 
The  ACF  limits  eligibility for migrant  Head  Start  to families 
...with  children  under  the  age  of compulso~  school  attendance  who 
change  their  residence  by moving  from  one  geographic  location  to 
another,  either  intrastate  or interstate,  within  the  past  12 months,  for the 
purpose  of engaging  in agricultural  work  that  involves  the  production 
and  hawesting  of tree  and  field  crops  and  whose  family income  comes 
primarily  from  this activity  [45 CFR  1305.2(1)]. 
Migrant  grantees  may administer  hornestate and/or  upstream Head  Start  programs. 
Homestate  grantees  provide  services  from  6 to 9 months  per  year  in what  is 
considered  a migrant  familys home  State.  Upstream  grantees  provide  services  for 
3 to 7 months  to families  as they  travel  in search  of agricultural  work. 
Migrant  Head  Start  provides  valuable  services  to a population  that  might  not 
otherwise  receive  them.  Migrant  families  face  numerous  barriers  to obtaining  services 
on their  own.  Their  lives are  complicated  by their  transitory  nature,  language  and 
cultural  barriers,  and  inexperience  navigating  the  system.  Often  they  are  unable  to 
obtain  services  such  as housing  assistance  and  Medicaid,  because  they  are  not 
residents  of that  State  or locality.  Migrant  Head  Start  addresses  these  problems  and 
more.  Grantees  provide  children  with  a safe place  to learn  while  their  parents  work. 
They  ensure  that  each  childs health,  nutrition,  and  other  basic  needs  are  met.  Like 
regular  Head  Start,  migrant  grantees  also are  required  to identify  and  address  the 
needs  of the  entire  family. 
2
 Migrant  Head  Start  programs  face  unique  challenges.  For  example: 
Grantees  serve  children  O to 6 years  old, compared  to regular  Head  Start 
grantees  who serve  primarily  3- to 5-year-olds.  Serving  infants  and  toddlers 
requires  different  facilities,  equipment,  staff  skills, and  more  staff per  child. 
Grantees  sometimes  must  move  their  facilities  if the  migrant  stream  changes 
due  to weather  or crop  conditions, 
Grantees  often  must  provide  services  such as health  screenings  and  social 
sefice  referrals  in a shorter  timeframe  because  of the  short  program  year  and 
the  fact  that  families  may not  remain  in the  program  for more  than  a few 
weeks. 
Because  of the  nature  of agricultural  work,  grantees  often  must  provide  services 
for  10 to  14 hours  per  day and  6 to 7 days per  week. 
Grantees  must  have  qualified,  bilingual  staff to serve  migrant  families 
effectively. 
Grantees  must  heir) families  obtain  services--such  as Medicaid  and  State  or 
local  social  service~--that  are  difficult  to arrange  because  of migrant  families 
transitory  nature. 
To  assist with planning,  some  grantees  use  the  Department  of Educations  Migrant 
Student  Record  Transfer  System  (MSRTS).  The  MSRTS  is designed  to track  school-
age  children  through  the  migrant  stream.  Migrant  Head  Start  grantees  may find 
MSRTS  data  useful  when  attempting  to determine  how many  families  will enter  their 
service  areas  during  a particular  year. 
l%posed  Standard%for Infant$,T&ikKs, andl?egnant Women 
In June  1990, the  Department  issued  a Notice  of Proposed  Rulemaking  specifying 
requirements  that  govern  the  operation  of Head  Start  programs  serving  infants, 
toddlers,  and  pregnant  women.  Essentially,  the  proposed  regulations  are  intended  to 
ensure  quality  sewices  and  require  that: 
	 grantees  maintain  low child-to-staff  ratios  for toddlers  and  infants.  The  ratios 
vary  depending  upon  the  age of the  children  and  how many  are  in each  class. 
The  lowest  ratio  is 3-to-1, for children  less than  2 years  old in a classroom  of 
6 children  or less; 
	 grantees  obtain  physical  exams  for infants  and  toddlers  at ages  1 month, 
2 months,  4 months,  6 months,  12 months,  15 months,  18 months,  24 months, 
and  36 months; 
3
 	 each  teacher  obtain  a Child  Development  Associate  credential  to serve  infants 
and  toddlers  within  2 years; 
  each  grantee  provide  40 hours  of pre-semice  training  to  all teachers  aides;  and 
	 grantees  adapt  other  health,  education,  nutrition,  social  services,  and  parent 
involvement  requirements,  as appropriate,  to meet  the  unique  differences  of 
serving  infants,  toddlers,  and  pregnant  women. 
Head,Stat  Expansion 
Both  the  Administration  and  Congress  are  committed  to expanding  Head  Start.  The 
Head  Start  Supplemental  Authorization  Act of 1989 and  the  Dire  Emergency 
Supplemental  Appropriation  of 1990 marked  the  beginning  of expansion  for  all 
grantees  and  provided  funding  for the  first two expansions.  Since  FY  1990, Head 
Start  total  funding  has increased  more  than  $1 billion,  to an FY  1993 total  of 
$2.779 billion.  In addition  to the  funds  that  were  allocated  for expanding  enrollment, 
ACF  set  aside  approximately  $612 million  for, among  other  things,  quality 
improvement,  salary  enhancement,  cost-of-living  increases,  and  training  and  technical 
assistance  improvement. 
The  ACF  allocated  expansion  funds  differently  for migrant  grantees  than  for non-
migrant  programs.  Although  ACF  allocated  funds  differently  for  each  expansion,  in 
general,  it allocated  funds  (1) to existing grantees  in proportion  to each  grantees 
overall  budget,  (2) for grantees  to compete  to serve  previously  unsemed  areas,  and 
(3) to  existing  grantees  based  on a specific  areas  need,  The  following  chart  illustrates 
the  migrant  Head  Start  programs  first 3 years  of expansion: 
MIGRANT  HEAD  START  EXPANSION,  1990-1992 
1 
FundsAllocatedto: 
Fiscal
 Expand
 ImproveP
rogram
 ProvidCeo
 st-of-Living

Year
 Enrollment
 Quality
 Adjustments

1990
 $7,515,523
 None
 None

1991
 $9,766,305
 $3,723,636
 $117,522

1992
 $2,422,430
 $1,720,897
 $182,418

~TAL  $19,704S8
 $5,444933
 $299,940

&

MigrantI?ogramsBranchUvemigti 
The  Migrant  Programs  Branch  monitors  compliance  with Head  Start  performance 
standards  primarily  by conducting  on-site  reviews.  During  site visits, review  teams 
assess  compliance  with the  performance  standards  using the  On-Site  Performance 
Review  Instrument  (OSPRI).  The  Human  Services  Reauthorization  Act  of 
4  1990 amended  the  Head  Start  Act  and  requires  that  ACF  review  each  grantee  or 
delegate  at least  once  every  3 years  to measure  compliance  with the  performance 
standards.  The  Head  Start  Improvement  Act  of 1992 requires  that  ACF  also review 
each  new grantee  or delegate  after  its first year  and  conduct  follow-up  reviews  of all 
grantees  when  appropriate. 
In addition  to conducting  on-site  reviews,  ACF  requires  each  grantee  to report 
performance  data  annually  using the  Program  Information  Report  (PIR).  The  PIR 
contains  data  that  ACF  can  use to assess  individual  grantee  and  overall  program 
performance. 
Concerns aboutExpansibn 
The  ACF,  the  Assistant  Secretary  for Management  and  Budget,  and  the  Assistant 
Secreta~  for Planning  and  Evaluation  requested  that  the  Office  of Inspector  General 
(OIG)  review  the  implementation  and  status  of Head  Start  expansion.  Since  migrant 
grantees  were  not  included  in the  other  OIG  studies  on expansion  (see  the  following 
paragraph),  the  Chief  of the  Migrant  Programs  Branch  requested  that  we conduct  this 
inspection  to  assess  their  experiences. 
This  report  is one  in a series  prepared  by the  OIG  on Head  Start  expansion.  Head 
Start  Expansion:  Grantee  Experiences  (OEI-09-91-00760)  used  interviews  to describe 
the  experiences  of regular  Head  Start  grantees  and  ACF  staff  during  the  1990 and 
1991 expansions.  According  to the  grantees,  expansion  posed  problems  for them  in 
such areas  as child  enrollment,  facility acquisition,  staffing,  transportation,  and  social 
semices.  In a companion  report,  Evaluating  Head  Start  Expansion  through 
Performance  Indicators  (OEI-09-91-00762),  we assessed  the  impact  of expansion  on 
regular  grantees  using file reviews  and  selected  indicators.  While  we did not  find any 
statistically  significant  difference  in grantee  performance  as a result  of expansion,  we 
found  that  the  level  of grantee  performance  as measured  by our  indicators  was 
considerably  lower  than  the  level  of performance  reported  by grantees  and  published 
by ACF.  Because  of inadequate  grantee  record  keeping,  the  lack  of specificity  in the 
Head  Start  performance  standards,  and  the  fact  that  many  grantees  disregard  ACF 
policy guidance,  we were  unable  to determine  if the  program  and  performance  data 
weaknesses  that  we found  reflect  serious  deficiencies  in the  quality  of services 
provided  by Head  Start. 
METHODOLOGY 
We  selected  three  migrant  grantees  and  three  delegates  based  on the  size of their 
expansion  in 1990 and/or  1991.  To  establish  the  selection  brackets,  we divided  the 
amount  of each  grantees  expansion  by its total  budget.  We  divided  the  grantees  and 
delegates  into  thirds  based  on the  resulting  percentage  of expansion--small,  medium, 
and  large  expansion--and  selected  one  from  each  bracket.  In order  to achieve  a fairly 
representative  sample,  additional  selection  criteria  included  geographic  location  and 
the  overall  size of the  program.  The  total  funded  enrollment  of the  six grantees  was 
5  approximately  7,800.  This  represents  28 percent  of all  children  enrolled  in  migrant 
Head  Start  nationally. 
During  September  1992, we conducted  on-site  visits and  interviews  with  each  migrant 
Head  Start  program  director  and  other  appropriate  staff.  For  the  delegates  in our 
sample,  we also conducted  interviews  with their  parent  grantees.  At each  site, we 
visited  the  facility and  several  migrant  campsites.  In addition,  we briefly  examined  the 
grantees  records  and  file maintenance.  During  the  interviews,  we asked  grantees  to 
describe  their  experiences  and  opinions  about  operating  a Head  Start  program  and 
their  predictions  about  the  future.  Our  goal was to obtain  information  that  would 
provide  a snapshot  of six migrant  grantees  ongoing  operations  as well as their 
experiences  with  expansion.  In response  to ACFS comments  on the  draft  report,  we 
also conducted  brief  follow-up  interviews  with the  grantees  and  delegates  in August 
1993 to obtain  additional  information  about  their  facilities. 
We  did not  conduct  a comprehensive  management  or file review  to veri~  the  accuracy 
of the  grantees  opinions  and  predictions.  Nevertheless,  we believe  our  findings  will 
give policymakers  valuable  information  about  major  issues  and  problems  facing 
migrant  grantees. 
We  conducted  this  inspection  in  accordance  with  the  QwUy  Stan&r&for  Inspections 
issued  by the  Presidents  Council  on Integrity  and  Efficiency. 
6
 FINDINGS

7he folkwvingjindingsreflectthe experiencesand ophziimsof the six mipnt  granteesthat 
we inkwiewed 
SOME  HEAD  START  PERFORMANCE  REQ UIREMENTS  MAY  NOT  BE 
APPROPRIATE  FOR  MIGRANT  GRANTEES 
The  six migrant  grantees  that  we visited  have  difficulty  meeting  some  of the  Head 
Start  performance  requirements  because  of the  short  program  year,  large  client 
turnover,  and varied  ages  of enrolled  children.  In general,  grantees  believe  that  the 
performance  standards  should  be  flexible  and  take  into  account  the  length  of the 
school  year  and  the  short  period  of time  that  a family is involved  with the  program. 
The  grantees  expressed  concerns  about  several  of the  major  performance  standards, 
including  parent  involvement,  home  visits, medical  and  dental  screens,  and  enrollment 
and  education: 
Parent  Involvement  All six grantees  indicated  that  they  have  difficulty  meeting  the 
parent  involvement  requirements.  Long  work  days  and  little  time  off  prevent  parents 
from  becoming  involved  with  centers.  The  grantees  expressed  frustration  with their 
inability  to get parents  involved.  One  grantee  stated,  We realize  that  there  are  limits 
to what  we can  reasonably  expect  when  parents  are  working  hard  in the  fields for 
12 hours  a day and  then  have  to go home  and  feed  and  bathe  their  kids.  Only about 
3 to 4 percent  of parents  volunteer  in the  centers. 
Home  Visits:  Grantees  described  particular  problems  meeting  ACFS home  visit 
requirement.  Several  factors  present  difficult  barriers  for grantees  attempting  to 
complete  the  two required  home  visits: 
	 families  may be  in the  program  only briefly,  so it maybe  difficult  to  complete 
home  visits before  a family withdraws; 
	 migrant  programs  run  full-day  for fewer  months,  so there  is less time  in the  day 
to do home  visits; 
	 high enrollment  turnover  increases  the  number  of home  visits that  grantees 
need  to complete  overall;  and 
	 some  parents  dont have  time  or are  too  tired  to participate  in home  visits 
because  of their  long workdays. 
Medieal  and  Dental  %reenx  In general,  grantees--particularly  those  who  operate 
upstream  programs--try  to complete  health  and  dental  screens  within  30 days rather 
than  the  90 days recommended  in ACFS guidance  on the  performance  standards. 
7
 Two grantees  questioned  whether  they  should  have  the  same  health  and  dental 
screening  requirements  for infants  and  toddlers.  Toberequired  toensure  thata 
6-week-old  child  receive  adental  screen  doesnt  make  sense~ said  one  grantee. 
Enrollment  and  Education  Thenumber  of families  inagrantees  sefice  area 
fluctuates  throughout  the  season.  This  causes  problems  maintaining  consistent 
enrollment,  class sizes, and  average  daily attendance.  One  grantee  suggested  that 
ACF  allow grantees  flexibility to overenroll  by as much  as 100 percent  during  certain 
parts  of the  program  year  to compensate  for underenrollment  during  other  parts  of 
the  program  year.  Another  grantee  recommended  that  ACF  use  a formula  to prepare 
budgets  and  tabulate  average  daily attendance  that  is based  on the  sum  of children 
who  attended  the  program  each  day rather  than  the  funded  enrollment. 
The  ACF  Migrant  Programs  Branch  recognizes  that  migrant  grantees  experience 
difficulty  meeting  some  performance  standards.  Because  of this, branch  staff  are 
flexible  when  determining  if a grantee  is in compliance  with  certain  performance 
standards. 
SOME  OF  THE  PROPOSED  INFANT  AND  TODDLER  PROGRAM 
STANDARDS  MAY  BE  UNREALISTIC 
Grantees  expressed  concerns  about  the  proposed  standards  for infants,  toddlers,  and 
pregnant  women.  Three  grantees  expressed  concerns  about  the  lower  child-to-staff 
ratios.  One  grantee  stated,  We need  to get the  children  out  of the  camps  during  the 
day.  Its safer  to be with  us even  if our  facility doesnt  meet  child  care  licensing 
standards  than  if they  stayed  in the  camp,  unsupemised. 
In addition,  the  grantees  believe  that  the  Child  Development  Associate  (CDA) 
credential  requirement  for teachers  to serve  infants  would  compound  their  ongoing 
problems  hiring  staff.  Requiring  a CDA  may make  it impossible  to hire  people  who 
will work  in a summer  program  at minimum  wage, said one  grantee.  Two grantees 
argued  that  the  strict  physical  exam  schedule  for infants  and  toddlers  was prohibitive. 
One  grantee  stated,  There  are  so many  physicals  required.  Medical  exams  for infants 
are  important,  but  whos going to pay for this? 
The  ACF  is currently  evaluating  the  proposed  standards  based  on comments  it 
received  on the  Federal  Register  publication.  Some  of the  comments  reflect  the 
concerns  of the  migrant  grantees.  The  ACF  will take  these  concerns  into 
consideration  as it develops  the  final rule. 
DELAYED  FUNDING  AND  UNRELIABLE  INFORMATION  ABOUT  THE 
MIGRANT  POPULATION  FREQUENTLY  HINDER  GRANTEES  ABILITY 
TO  PLAN 
The  six grantees  described  problems  similar  to regular  Head  Start  in planning  for 
expansions  and  administering  services.  Because  of the  unique  nature  of their 
8  programs,  however,  delayed  expansion  funding  and  poor  demographic  information 
make  even  the  simplest  planning  a challenge. 
All sixgranteesreportedthat&layed qansion  funds ihhibitedpkmningforced kxm$ 
andcausedcany-overbalances 
Congress  determines  the  timing  of expansion  proposals  and  awards  and  bases  it on the

regular  Head  Start  program  year.  The  ACF  does  not  alter  the  cycle for migrant

grantees  who  administer  off-season--such  as summer-long--programs.  Migrant

grantees  are  required  to submit  expansion  and  other  grant  proposals  in March  and

April.  They  receive  their  funds  in August  or September,  which,  for some  programs,  is

the  middle  or end  of their  school  year.  As a result,  three  grantees  had  carry-over

balances  during  expansion,  and  two grantees  had  to secure  loans  in order  to open  on

time.  Grantee  comments  included:

	 We  have  to start  planning  more  than  a year  in advance.  This  is too 
early  for migrant  programs.  There  can be  major  changes  with  the 
migrant  population  in a short  time  frame. 
.	 The  timing  of the  funds  is atrocious,  as the  money  comes  in August  or 
September.  This  is too  late--our  program  starts  in June. 
.	 If we cant get  funded  in a more  timely  manner,  we may not  accept 
future  expansions  after  1993. 
None  of the  grantees  experienced  any difficulty  obtaining  ACFS approval  for carry-
over balances. 
%  lackof demographicinformationaboutrnigrantaindthemigrantstreamcauses 
pkmnihgproblemsfor allsixgrantetx 
Grantees  are  responsible  for estimating  the  number  of migrant  children  who will be  in 
their  area  in order  to plan  their  program  years  and  apply  for expansion.  They 
sometimes  rely on growers  and  migrant  team  leaders  to give them  any available 
information  about  the  number  of migrants  who will be  in the  area.  These  sources  are 
informal  and  are  not  always able  to provide  data  on children.  Grantees  tend  to 
estimate  future  needs  based  on prior  years  experiences.  One  grantee  stated,  We 
open  with  a guess,  and we close when  we are  no longer  cost-effective.  We  try to keep 
track  of the  pregnant  women,  and we do some  averaging. 
Grantees  find Migrant  Student  Record  Transfer  System  data  of limited  use for 
planning,  because  (1) it is not  up-to-date,  (2) its definition  of migrant  is different  from 
Head  Starts,  and  (3) it tracks  only school-aged  children.  Grantees  believe  the  Federal 
government  should  create  a national  database  among  all migrant  agencies.  This would 
allow grantees  to plan  3 to 5 years  in advance. 
9
 SAMPLED  MIGRANT  GRANTEES  EXPERIENCED  SOME  OF  THE  SAME 
PROBLEMS  WITH  EXPANSION  AS REGULAR  HEAD  START  GRANTEES 
The  OIG  report,  Head  Start  Expansion:  Grantee  Experiences;  described  the 
difficulties  that  non-migrant  Head  Start  grantees  encountered  during  expansion.  The 
six migrant  grantees  described  similar--and  sometimes  greater--problems  acquiring 
adequate  and  affordable  facilities,  providing  transportation  for children,  hiring 
qualified  staff, and  meeting  the  Federal  match  requirement. 
Facilities  Migrant  grantees  face  the  following barriers  to facility  acquisition: 
availability,  affordability,  inability  to purchase,  timing  of expansion  awards,  and 
licensing.  In addition,  community  prejudice,  the  transitory  nature  of the  migrant 
population,  and  different  licensing  requirements  for facilities  serving  infants  and 
toddlers  have  made  these  problems  more  difficult  to overcome.  We need  a break 
from  the  laws, said  one  grantee.  Right now we cant serve  infants  and  toddlers  in 
the  same  building  as preschoolers. 
Five  of the  six grantees  expressed  a desire  to purchase  property  for their  centers, 
which will be possible  under  the  provisions  of the  Head  Start  Improvement  Act  of 
1992.  Head  Start  has renovated  more  churches  than  we can  count,  said  one  grantee. 
Grantees  recognize  that  weather  and  other  factors  can  affect  the  migrant  streams,  but 
suggested  purchasing  facilities  in areas  with consistent  migrant  streams  and  using 
portables  in outlying  areas.  Grantees  further  indicated  that  they would  be  cautious 
when  using  the  purchase  option.  They  would  complete  long-term  demographic  studies 
to be  sure  that  the  migrant  stream  would  remain  consistent  and  the  facility would  be 
cost-effective. 
Grantees  cited  examples  of when  purchasing  facilities  would  be  appropriate  and  cost-
effective: 
~	 One  grantee  indicated  that  it would  share  purchased  facilities  with  regular 
Head  Start,  which would  allow it to offer  families  integrated  one-stop 
shopping  for services.  This  grantee  has never  had  to close  a facility. 
	 One  grantee  spent  $115,000 to renovate  a rented  center.  It has  not  had  to 
close  any of its centers  in 10 years. 
*	 One  grantee  has had  to close facilities  early  despite  families  needing  the 
services  because  the  landlord  insists. 
*	 One  grantee  runs  dozens  of centers  that  have  never  had  to move,  even  after 
15 years. 
Transportation:  Providing  adequate  transportation  is a problem  for several  grantees. 
Expansion  has resulted  in some  one-way  bus rides  in excess of 1-1/2 hours.  Grantees 
described  problems  with bus insurance  and  licensing  when  they  cross State  lines  and 
10  when  bus  rides  are  very long.  In addition,  grantees  have  difficulty  hiring  and  retaining 
qualified  bus drivers  because  of their  long hours,  short  program  year,  and  inability  to 
compete  with public  school wages.  One  grantee  summarized  the  transportation 
challenge:  Qualified  bus  drivers  are  hard  to find.  They  are  paid  more  in public 
school,  and  they  dont  have  to start  work  at 4:30 a.m. 
Staffing  Migrant  grantees  face  greater  problems  hiring  and  retaining  qualified  staff 
than  non-migrant  programs.  Long  hours,  short  school  years,  low salaries,  and 
inadequate  benefits  have  resulted  in severe  staffing  problems  for several  of the 
grantees.  Grantees  need  educated  staff who are  bilingual,  able  to handle  infants, 
toddlers,  and  youngsters,  and  able  to perform  multiple  duties.  Although  their  salaries 
are  comparable  to public  schools,  grantees  believe  supplemental  compensation  is 
necessary  to recruit  and  retain  staff who have  these  additional  skills. 
Matching  Funds:  While  grantees  have  been  able  to obtain  some  matching  funds,  they 
are  not  always able  to achieve  Head  Starts  20 percent  match  requirement.  Most  of 
the  six grantees  have  obtained  waivers  from  the  Migrant  Programs  Branch  that  allow 
them  to match  at a lower  rate.  Two grantees  are  able  to use State  funds  or donated 
property  to meet  the  20 percent  Federal  match  requirement.  The  other  grantees  have 
limited  success  relying  on donated  services  and volunteers.  Migrant  grantees  have 
difficulty  collecting  contributions,  because  they  often  are  viewed  as outsiders  by the 
local  community,  and  parent  participation  is low.  In addition,  professional  services  are 
not  readily  available  in rural  areas.  One  grantee  stated,  We are  tapped  out.  Even 
with a waiver  to  10 percent,  we might  not be  able  to expand  in 1993. 
Training  and  Technical  Assistance:  Like  regular  Head  Start  grantees,  migrant 
grantees  rely on in-house  or private  consultants  for training  needs,  because  they 
consider  the  training  more  appropriate  than  that  offered  by HHS  agencies  and  their 
contractors.  Although  grantees  have  attended  nationally-sponsored  training,  they 
believe  that  State  and  local training  agencies,  school  districts,  private  consultants,  and 
consortiums  best  seine  their  needs,  because  they better  understand  how to  serve 
migrant  families  in their  areas.  Grantees  believe  that  ACF  training  is most  useful 
when  it deals  with ACF  processes,  rather  than  service  delivery.  Migrant  grantees  also 
mentioned  that  they  frequently  do not  have  enough  time  to train  staff because  of their 
long program  hours  and  short  program  year.  One  grantee  is considering  closing  a 
center  briefly  during  the  school year  to conduct  staff  training. 
During  the  first 3 years  of expansion,  the  grantees  were  able  to overcome  their 
problems  with facilities,  transportation,  staffing,  matching  funds,  and  training  and 
technical  assistance.  A couple  of grantees,  however,  described  lengthy  delays  meeting 
expansion  goals  and  expressed  concerns  about  expansions  effect  on staff morale. 
Also,  some  grantees  anticipate  that  these  problems  will become  more  pronounced  with 
future  expansions. 
11
 GRANTEES  ARE  CONCERNED  THAT  ONGOING  AND  FUTURE  CHANGES

IN THE  NATURE  OF  MIGRANT  WORK  MAY  HINDER  THEIR  ABILITY

TO  SERVE  MIGRANT  FAMILIES

The  nature  of migrant  work  has  changed  over time  because  of mechanization  and  new

job  opportunities.  Some  migrants  now work  in fisheries  or canneries,  although  the

majority  still work  in field crops.  The  grantees  we visited  are  concerned  that  these

families  will be  excluded  from  participating  in Head  Start  in the  future,  because  they

do not  meet  the  regulatory  definition  of migrant.  They  argued  that  these  families

should  continue  to receive  Head  Start  services.  One  grantee  explained  the  problem:

Most  of the  migrant  families  we serve  now have jobs  working  in the  food 
processing  plants.  Were  concerned  that  these  people  may not  qualify 
for migrant  Head  Start  in the  future.  The  manager  of the  processing 
plant  told  me  that  if it were  not  for the  migrants,  he would  not  be  able 
to  operate  his plant.  And  these  families  are  experiencing  the  same 
problems  and  issues  as families  working  in the  fields. 
Grantees  expressed  concerns  about  service  agencies  that  use  a different  definition  of 
migrant.  Migrant  health  and  education  agencies  use  different  eligibility  rules  than 
migrant  Head  Start.  One  grantee  commented,  Various  definitions  of migrant  by 
different  agencies  tend  to break  families  apart  into  bureaucratic  pieces.  If we all 
worked  together,  the  whole  would  be greater  than  the  sum of the  parts. 
SAMPLED  GRANTEES  CITED PROBLEMS  WITH  THE  ON-SJTE  REVIEW 
PROCESS,  THE  STATISTICAL  REPORTING  REQUIREMENTS,  AND  THE 
MIGRANT  PROGRAMS  BRANCH 
All six grantees  provided  specific  details  about  problems  with the  Migrant  Programs 
Branchs  on-site  review  (OSPRI)  process,  difficulties  completing  ACFS Program 
Information  Report  (PIR),  and  communication  problems  with  the  Migrant  Programs 
Branch. 
Granteesdescribedcon.a  k  the OSPMprocess and complainedabout the kzckof 
timelyfeedback concemhg OSP~findings 
A majority  of the  six grantees  expressed  frustration  with OSPRI  teams  who they 
believed  were  unfair,  biased,  or out to find something.  According  to the  Migrant 
Programs  Branch,  some  of the  frustration  may have  resulted  from  the  vague 
performance  requirements  and  the  Branchs  recent  attempts  to provide  more  direct 
oversight  of migrant  programs. 
The  OSPRI  review  teams  include  staff from  other  Head  Start  grantees  as well as staff 
from  the  Migrant  Programs  Branch.  The  grantees  we intemiewed  said that  OSPRI 
team  members  often  have  preconceived  notions  about  how a migrant  Head  Start 
program  should  be  administered,  based  on the  way they  operate  their  own programs. 
12  This  occurred  despite  instructions  from  the  Migrant  Programs  Branch  to OSPRI  team 
members  emphasizing  that  they  must understand  there  are  several  ways and  styles of 
meeting  the  Performance  Standards,  One  grantee  explained,  The OSPRI  team 
members  say We dont  do it this way at  our  center.  In addition,  two grantees 
claimed  that  the  OSPRI  teams  either  lacked  knowledge  about  the  performance 
standards  or did not  understand  the  challenges  of seining  migrants. 
Grantees  also believe  that  delays  receiving  OSPRI  reports  and  feedback  cause 
uncertainty  about  whether  theyre  complying  with ACFS performance  requirements. 
One  grantee  stated,  We still havent  received  a reply  to our  response  to our 
1990 OSPRI.  We  dont  know whether  or not were  on the  right  track  with  our 
improvement  plan. 
%  PIR rnuynot to be an ~ective  informationgatheringtoolf~  rni~nt  Head Start 
The  OIG  report  entitled  Evaluating  Head  Start  Expansion  through  Performance 
Indicators  (OEI-09-91-O0762)  found  that  ACFS directions  for completing  the  PIR 
sometimes  conflict  with the  performance  standard  requirements.  Migrant  grantees 
offered  other  criticisms  about  the  substance  and  timing  of the  PIR.  In their  opinion, 
the  report  does  not  measure  quality,  and  the  timing  is unrealistic. 
Grantees  believe  that  if they  are  going  to  complete  a PIR,  it should  be  tailored  to

migrant  programs.  They  contend  that  certain  data,  such  as student-teacher  ratios  and

average  daily  attendance,  are  not  applicable  to  migrant  programs  because  of

enrollment  fluctuation  and  the  childrens  ages.  Grantees  also  believe  that  the  PIR

does  not  measure  program  quality.  One  grantee  summarized,  The  PIR  does  not

reflect  what  we  do.  It  only  says  that  we  provided  a service,  but  it does  not  address  the

quality  of the  service  provided.

Four  grantees  expressed  frustration  with  the  timing  of the  PIR.  The  ACF  requires 
grantees  to  submit  the  PIR  in May,  which  is the  end  of  the  program  year  for  regular 
Head  Start.  This  is unrealistic  for  many  migrant  grantees,  since  they  often  administer 
summer  programs,  and  May is in the  beginning  or middle  of their  school  year. 
Therefore,  these  grantees  may submit  PIR  data  that  is incomplete  or misleading, 
because  it (1) represents  only a small  part  of their  program  year,  (2) is derived  from 
parts  of two different  school  years,  or (3) represents  services  provided  during  the 
previous  school  year  which  may have  ended  several  months  before. 
Some granteesreprt comrnunicationproblemswiththeMigrantIYogramsBranch 
While  most  grantees  complimented  the  enthusiasm  of the  Migrant  Programs  Branch 
staff,  they  complained  about  communication  lapses,  the  inaccessibility  of staff,  and 
delays  in funding  approvals.  Although  grantees  believe  that  the  Migrant  Programs 
Branch  has improved  under  its current  leadership,  they  have  trouble  communicating 
with  staff on a day-to-day  basis.  Grantees  frequently  complained  about  the 
inaccessibility  of Migrant  Programs  Branch  staff when  immediate  technical  assistance 
13
 or approval  for  operating  decisions  is needed.  At  any given  time,  most  or all of the 
staff may be  unreachable,  because  they  are  conducting  on-site  reviews,  A big 
problem  has been  getting  approval  for renovations,  said  one  grantee  director.  Weve 
been  delayed  2 to 3 months.  We  try to call, but  their  voicemail  is often  full, because 
theyre  always in the  field  conducting  on-site  reviews. 
14
 RECOMMENDATION 
THE  ACF SHOULD INCLUDE PROBLEMS  SPECIFIC  TO  THE  MIGRANT 
PROGRAM  IN THE  REVIEW  OF  HEAD  STARTS  MANAGEMENT 
In the  OIG  report  Evaluating  Head  Start  Expansion  through  Performance  Indicators, 
we recommended  that  the  Secretary  convene  a task  force  to review  ACFS 
management  of the  Head  Start  program.  On June  11, 1993, the  Secretary  appointed 
the  Advisory  Committee  on Head  Start  Quality  to conduct  an in-depth  study  of the 
Head  Start  program  with particular  attention  to issues identified  in the  OIG  reports 
Head  Start  Expansion:  Grantee  Experiences  and  Evaluating  Head  Start  Expansion 
through  Performance  Indicators.  The  Secretary  asked  the  Advisory  Committee,  which 
is chaired  by the  Assistant  Secretary  for  Children  and  Families,  to develop 
recommendations  to improve  and  strengthen  the  program  in a time  of expansion. 
As a result  of this inspection,  we recommend  that  the  Advisory  Committee  include 
migrant  Head  Start  in the  examination.  Because  the  migrant  program  is unique,  the 
review  also should: 
determine  whether  separate  performance  standards  for migrant  programs 
would  be  appropriate, 
assess  the  cost  and  potential  impact  of the  proposed  infant  and  toddler 
program  standards  on both  ACF  and  grantees, 
determine  whether  funding  and  expansion  cycles should  be  tailored  to migrant 
grantees, 
address  the  changing  role  of migrant  work  and  whether  changes  in ACFS 
definition  of migrant  are  necessary, 
determine  when  it would  be  appropriate  for migrant  grantees  to purchase 
property, 
evaluate  the  timing  of the  PIR  process  and  the  accuracy  of PIR  data, 
evaluate  the  role  and  effectiveness  of the  Migrant  Programs  Branchj  and
identify  other  areas  where  ACF  should  grant  flexibility to grantees  who are 
.-
experiencing  difficulties  serving  migrant  families. 
AGENCY  COMMENTS 
We  received  written  comments  on the  draft  report  from  ACF.  The  ACF  noted  that 
the  migrant  program  would  be  reviewed  as part  of the  overall  review  of the  Head 
15  Start  program  ordered  by the  Secretary.  The  full text  of ACFS comments  appears  in 
the  appendix. 
OIG RESPONSE 
In response  to ACFS comments,  we conducted  follow-up  interviews  with grantees  to 
obtain  additional  information  about  their  facilities.  The  final report  incorporates 
information  from  the  follow-up  interviews,  including  more  detail  about  the  facility 
purchase  issue.  We  also made  technical  corrections  to the  findings,  clarified  that  the 
report  is based  on the  grantees  opinions  and  experiences,  and  modified  the 
recommendation  to ensure  that  it more  accurately  describes  the  issues  that  the  Head 
Start  task  force  should  study.  Specifically,  we now recommend  that  the  task  force  (1) 
examine  what  the  Federal  government  (rather  than  ACF  alone)  could  do to tailor 
funding  streams  to migrant  grantees  and  (2) assess  how the  Head  Start  facility 
purchase  provisions  should  apply  to migrant  grantees.  We  still believe  that  ACFS 
regulation  and  oversight  of migrant  grantees  using performance  standards  and  funding 
cycles that  are  not  tailored  to them  causes  problems. 
16
 APPENDIX

ACF COMMENTS 
DEPARTMENTOFHEALTH& HUMAN SSRVICES

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SUBJECT:  Commentson Draft Office of InspectorGeneral Report on 
Uigrant HeadStart Grantees (OEI-09-91-00761) 
Thank you for the opportunityto review the draft Office of 
inspectorGeneral  report entitledWXi.granHtead Start Grantees:

Perspectives and Challenges.W

We believe that the report highlights some of the unique 
conditions facing  Migrant  Head  Start grantees and sone of the 
problems they facebecauseof these conditions. For example,we 
recognize that the changingnatureof migrantwork must be 
addressed as Head Start expands, and that migrant  grantees,  like 
nany Head Start programs, have experiencedproblems dealing with 
the rapid expansionof Head Start. 
he with your report *Head Start Bxpansion: Grantee Experiencesn

(OEI-09-91-00760),however, we have concerns  about  the  way  in 
which the informationfor the reportwas gathered end the 
presentation of some of the findings. The general aomments which 
we made on the methodologyof that report apply to this reportas 
well. AS we didthen,we now suggestthatthereportprovide 
more descriptiveinformationon the methodologyused so that the 
reader will be aware that, in some instancee,opinions or 
predictions*were elicited from the interviewees*(March15, 
1993 memorandum from Laurence J. Love to  Bryan  B. Mitchell, 
included as AppendixA to the above-citedreport, page 2). me 
result of the methodologyused is a seriesof grantee opinions 
which are not balancedby informationprovidedby program 
officials which would put those opinions in context.  certain of 
the grantee opinions  reportedare not  factuallybased, and some 
reflect self-intereston  the part of the grantee or delegate 
agency.

In addition to the general comments noted above, we have several  . 
specific comments,as follows: 
:2 ;:.j<- J:; Q.; 
6E 
A-1
 Page 2 - Bryan B. Mitchell

	 With respectto your findingthatsomeHead Start 
PerformanceStandardsmay not  be  appropriatefOr 
 igrantgranteee,the Migrant  Programs  Branch and  the 
Head StartBureauwork plans for thisyear includea 
review of  selectedPerformance  Standards  whioh  will 
consider  the  comments  of migrantgrantees. Whilewe 
recognizethatsome grantees  aay  have  difficulties 
meetingthe PerformanceStandards,we do not envision 
dilutionof the Performance  Standards  for  migrant 
grantees. Rather,  we will focustrainingind technical 
assistanceeffortson thosegranteeswhichhave 
difficultymeetingthe Performance  Standards. 
	 On page 8,  with  regardto concernsaboutpending 
regulations,the infantand toddlerstandardsare in 
draft form and migrantprogramstviews are being 
activelyconsideredin developingthe finalrule. 
	 On pages 8  to  10, concerningthe fundingoyclaand 
demographicdata,we have severalcomments. Funding 
for the HigrantHead Start programs comes from the 
appropriation for all Head Start programs under the 
Head Start Act in an annual cycle determined by the 
Bxecutive Branch and the Congress.  The  finding 
concerning  fundingand planningis not clear, since 
migrantgranteeshave considerablynore  time to plan 
than othergranteesbecausetheir services  do  not begin 
until the Springmonths. (Ironically,on page 9 you 
includea commentfroma granteewhich complainsof

beinggiven too much tineto plan.) With respectto

demographicdata,we are fundinga studywhichwill

improveour data on migrantchildren. However,it

shouldbe notedthat allHead Startgranteesare

responsiblefor obtainingdemographicdata for their

particularserviceareas. Nationaldata are important

to providea frameworkfor assessingthe unmetneed for

MigrantHead Startservices,but no outside,broad

surveywill substitutefor localdata collectedby

grantees.

	 On pages 9 and 10, the discussionof facilitiesh 
lackingin contextand misleading. The purchaseof 
facilitiesby migrantgranteeswould, in  most 
instances,be inconsistentwith the natureand aim of 
the MigrantHead Startprogram. Migrantstreamschange 
due to changesin weather,growing  areas,  cropsand 
urbanizationpatterns. Furthermore,the use of 
A-2
 Page  3 - Bryan B. Mitchell 
portable  modulars  has.been  wall  supported  by the 
Nigrant  Branoh.  Since  Ootober  1991,  the  purohase  of 
approximately  20 portables  has  been  approved. 
9 On page  12,  the  discussion  of  monitoring  teams  also 
lacks  context  andcontainsunsupportedstatements. For 
SXample,  the repOrt  states  that A  BSjOdty  of  the  SiX 
grantees  expressedfrustration  and anger  with  OSpRI 
teams  who they  believed  were  unfair,  biased,  or  out  to 
find  something.tw  Monitoring  is  done  to  measure a 
granteets  compliance with  the  performance Standards  and 
other  applicable  policies  and to  find  if  the  grantee  is 
meeting  the  Performance Standards  and properly 
administering  the  program.  It  is  also  not  true  that 
Membersof  monitoring  teams  lack  knowledge about  the 
Performance Standards  or  do not  understmd  the 
challenges  of  serving  migrants.  Virtually  all  *rS 
of  monitoring  teams  are  qualified  staff  from other 
migrant  programs,  ohosen  for  their  knowledge  of  and 
experience  lnm@rantHeadS  tart.  Inaddit~on,  me 
Branch  has  developed  and distributed  to  programs  a 
manual governing  the  compliance reviews,  and has 
carefully  trained  selected  peer  reviewers. 
	 The points  made about  the  timing  of  thePIR  (page 12) 
are  valid,  and the  Head Start  Bureau  has  stated  in  this 
yearle  work plan  its  intentionto  solve  this  problem  by 
adjusting  the  reporting  dates  for migrant  program  data. 
	 With  regard  to  the  recommendations,  we note  that  the 
migrant  program  will  be  reviewed  as  part  of  the  overall 
review  of  the  Head Start  program  ordered  by  the 
Secretary. 
Thank you  again  for  the  opportunity  to  comment on this  draft 
report.  If  you  have  any questions  on this  memorandum, please 
contact  Joseph  Mottola  on  205-8347. 
A-3