United States Government Accountability Office

Washington, DC 20548 

November 17, 2006 

The Honorable George Miller 

Ranking Minority Member 

Committee on Education and the Workforce 

House of Representatives 

Subject: Head Start: Additional Information on Implementation of Transportation Regulations

The Head Start program, administered by the U. S. Department of Health and Human Services (HHS), 

provides grants to local organizations to offer comprehensive early childhood services to approximately 

900,000 poor children, ages 5 years or younger.1

 While transportation is not a required service, in order to 

make Head Start more widely available to very poor children, over 70 percent of Head Start grantees and 

delegates provide transportation to at least some of the children they enroll. 

To address concerns about transporting children safely, the 1992 Head Start Improvement Act directed 

the Office of Head Start (OHS) to develop transportation regulations to ensure the safety and 

effectiveness of transportation services made available to children by Head Start grantees and delegates. 

In 2001, citing safety concerns related to vehicles as well as the variation in states’ standards for pupil 

transport, Head Start issued regulations governing transportation services. Among other things, the 

regulations mandated that grantees and delegates use school buses or similar alternative vehicles and 

that children be placed in restraints and attended by bus monitors. 

Grantees and delegates were required to meet most provisions of the regulations shortly after issuance, 

except for the requirements regarding age-appropriate child restraints, bus monitors, and the use of 

school buses or alternative vehicles. Grantees and delegates were expected to comply with the restraint 

and monitor requirements in 2004, unless they requested a time extension, in which case they were

expected to comply by the end of the 2006 program year.2

 Grantees and delegates had two opportunities 

—one in January 2004 and one in December 2005––to request more time from OHS to implement the 

restraint and bus monitor requirements. Currently, the compliance date for vehicles is December 2006. 

In commenting on the 2001 regulations, grantees and delegates expressed concerns about potential 

unintended effects on Head Start programs of implementing these requirements, such as reducing the 

 1

 The total enrollment figure is from the Office of Head Start for fiscal year 2005 and includes enrollment for both Head Start 

and Early Head Start programs. Head Start generally serves children ages 3 to 5 years old, while Early Head Start serves 

children from birth to age 3 and low-income pregnant women. 

2

 The effective compliance dates for the restraint and monitor provisions were first extended to January 2006 via an interim final 

rule published in 2004. Then, Public Law 109-149, passed in 2005, extended the compliance date for the vehicle provision to 

June 30, 2006, and also allowed the Secretary of HHS to waive the restraint and monitor requirements through September 30, 

2006. Subsequent to this, Public Law 109-234 changed the compliance date for vehicles to December 2006. On October 4, 2006, 

HHS published a final rule allowing grantees and delegates to annually request a waiver from the restraint and monitor 

requirements based on good cause. 

Page 1 GAO-07-194R Head Start Transportation Information 
availability of transportation and thereby encouraging enrollees to use less safe modes of traveling to 

and from Head Start. GAO was asked to examine these concerns and in July 2006 issued a report, Head 

Start: Progress and Challenges in Implementing Transportation Regulations (GAO-06-767R), which 

found in part that many grantees and delegates had implemented the Head Start transportation 

regulations with some experiencing adverse program and budgetary effects in doing so. You 

subsequently asked us to provide additional analysis of some information that we obtained through our 

2006 study. Specifically, you asked us to 1) compare the characteristics of surveyed grantees and 

delegates that indicated they were facing challenges with implementing the regulations to those of 

grantees and delegates that did not, and 2) provide information on the numbers of children transported 

by grantees and delegates that submitted requests to OHS in 2006 for more time to implement the 

monitor and restraint provisions.3

For grantees and delegates included in our survey, we defined those reporting challenges as grantees 

and delegates that had (1) stopped providing transportation services at all of their sites wholly or in part 

due to implementing the regulations, (2) decreased or stopped transportation services at a portion of 

their sites wholly or in part because of the regulations, (3) filed an extension request in 2004 for more 

time to implement the monitor and child restraint requirements, or (4) not completed implementing the 

regulations. For grantees and delegates that reported that they currently provided some level of

transportation services when we surveyed them in early 2006, the survey collected additional 

information about the number of children enrolled and transported, the number of centers operated, use 

of contractors or other organizations to transport children, and the number of buses used on a daily 

basis. We used these data to determine if those reporting challenges in implementation had different 

characteristics than those that did not. We did not collect similar data on the characteristics of grantees 

and delegates that did not provide transportation, beyond asking whether they considered this a result of 

the Head Start regulations, a result of both Head Start regulations and other factors, a result of other 

reasons, or were not sure. 

The timing for our survey did not allow us to gather data on those grantees and delegates that applied for 

the 2006 extensions. Instead, to determine the number of children that these grantees and delegates 

transported, we analyzed additional information extracted from the requests that grantees and delegates 

submitted to OHS through March 10, 2006, for more time to implement the monitor and child restraint 

requirements. Some additional extension requests may have been submitted after that date. We did not 

have data to determine how those applying for the 2006 extensions compared to those that didn’t apply. 

We also estimated from our survey the number of children transported by grantees and delegates who 

applied for an extension request in 2004. We conducted the additional analysis for this report between 

October and November 2006, in accordance with generally accepted government auditing standards. 

Summary 

Briefly, we found that among grantees and delegates that offered transportation, a little less than a third 

reported challenges in implementing the regulations. These grantees and delegates did not enroll or 

transport larger numbers of children than grantees and delegates that did not report challenges, but had 

more centers and used more buses on a daily basis and were more likely to use another organization, 

usually a school system, to provide transportation services. Grantees and delegates requesting extended 

 3

We base our findings, in part, on our survey of a nationally representative sample of Head Start grantees and delegates and 

delegates. Our analysis resulted in estimates that are generalized to the larger population of Head Start programs. For other 

details of our scope and methodology see GAO-06-767R, encl. I. 

Page 2 GAO-07-194R Head Start Transportation Information 
time to comply by March 2006 reported transporting almost 75,000 children, which is about 22 percent of 

the total number of Head Start children transported based on estimates derived from our 2006 survey. 

Specifically, with regard to grantees and delegates facing challenges in implementation, we found that 

• Of the approximately 1890 grantees and delegates that GAO estimates were directly operating Head

Start programs as of February 2006, an estimated 29 percent—or 540 grantees and delegates—either 

did not provide transportation services or had decreased transportation services at some portion of 

their program sites wholly or party as a result of the regulations. Specifically we estimate that 190 

grantees and delegates did not provide transportation to the centers they were operating as a result 

of the regulations or a combination of the regulations and other factors. GAO estimates that an 

additional 350 grantees and delegates had decreased or stopped transportation services at some 

portion of their program sites (but continued to provide it to others) and attributed this wholly or 

partly to the regulations.4

• Based on the results of our survey, grantees and delegates that had filed extensions in 2004 did not 

differ in the numbers of children enrolled or transported from those that did not file for extensions, 

but had larger numbers of centers and used more buses on a daily basis. This same finding held true 

for grantees and delegates that had not finished implementing the regulations at the time of our 

survey compared to those that had. About 29 percent of the estimated 1,370 grantees and delegates 

that provided some level of transportation filed an extension in 2004 to delay the effective date of the 

restraint and monitor provisions. We estimate that 36 percent of grantees and delegates that were 

providing some level of transportation services had not completely finished implementing the 

regulations when we surveyed them in 2006. 

• Grantees and delegates that contracted with or used another organization to transport some or all of 

their Head Start children were more likely to have filed 2004 extension requests than grantees and 

delegates that did not. Specifically, an estimated 48 percent of grantees and delegates using another 

organization for transportation services filed an extension versus 19 percent of grantees and 

delegates that did not use another organization. Of those grantees and delegates that partnered with 

others to supply transportation, we estimate that 60 percent used a school system. 

With regard to grantees and delegates that filed an extension request in 2006, we found that 

• A total of 378 grantees and delegates submitted extension requests by March 2006, representing 19 

percent of all Head Start grantees and delegates or approximately 28 percent of grantees and 

delegates that we estimated were providing transportation services at the time of our survey. At the 

time they filed 2006 extensions, these grantees and delegates reported transporting almost 75,000 

children, or about 22 percent of the 346,000 Head Start children that we estimated were transported 

at the time of our survey.

• In contrast, GAO estimates that 2004 extension filers provided transportation services to about onethird of the total number of Head Start children transported in program year 2005, approximately 

109,000 children of the estimated total of 346,000.

5

 4

Of the estimated 1890 grantees and delegates operating a Head Start program, we estimate that approximately 330 grantees and 

delegates did not provide any transportation services because of factors other than the regulations. 

5

 Based on our survey, the 95 percent confidence interval for the estimated number of children transported by those agencies 

making 2004 extension requests is 77,000 to 140,000 out of an estimated total of 301,000 to 391,000. 

Page 3 GAO-07-194R Head Start Transportation Information 
Concluding Observations 

In most cases, the number of children transported did not seem to predict which grantees and delegates 

would report challenges with the regulations. This would suggest that other variables may be more 

responsible for the regulations’ posing challenges than the number of children a program is transporting. 

These could include the number of routes a Head Start program has, the amount of geographical 

dispersion among its centers, and whether it is a dedicated Head Start transportation system or one that 

provides services to other populations. 

Close to a third of grantees and delegates decreased or did not provide transportation services as a 

result, at least in part, of the regulations. Information provided in our earlier report suggests that 

grantees and delegates face difficult programmatic trade-offs in complying with the new regulations, and 

because there are safety advantages in transporting children by bus, our earlier report recommended 

that OHS track transportation services being provided by grantees and delegates so as to be able to

determine the effects that cuts in transportation services may be having on achieving program goals and 

maintaining children’s safety. 

Agency Comments 

OHS program officials provided technical comments on our draft report which we incorporated as 

appropriate. In commenting on the report, they emphasized that the October 2006 change to the

transportation regulations, which allows grantees and delegates to apply for annual waivers from the 

restraint and monitor requirements, could provide relief from these requirements for Head Start grantees 

and delegates who were struggling to meet these provisions, especially ones working with school 

systems or other partners to transport children. 

- - - - - 

As agreed with your office, unless you publicly announce its contents earlier, we plan no further 

distribution of this report until 30 days after its issue date. At that time, we will send copies of the report 

to the Department of Health and Human Services, relevant congressional committees, and other 

interested parties; we will also make copies available to others upon request. The report can also be 

obtained through GAO’s Web site at http://www.gao.gov. If you or your staff have any questions about 

this report, please contact me at (202) 512-7215. Betty Ward-Zukerman, Assistant Director; Janet L. 

Mascia, Analyst-in-Charge; and Nancy Hess made key contributions to this report. 

Sincerely yours, 

Cornelia M. Ashby 

Director, Education, Workforce, and

 Income Security Issues 

(130613) 

Page 4 GAO-07-194R Head Start Transportation Information 
This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and

distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. 

Page 5 GAO-07-194R Head Start Transportation Information 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER