United States Government Accountability Office

Washington, DC 20548 

July 27, 2006

Congressional Requesters

Subject: Head Start: Progress and Challenges in Implementing Transportation Regulations

The leading cause of death for children ages 3 to 7 is motor vehicle traffic crashes. Head Start, a 

federal early care and education program run by local grantees and targeted at low-income 

children, currently serves approximately 900,000 children, and transports many of them to and 

from Head Start centers across the country. While not required to do so, many Head Start 

grantees offer transportation as a way to make Head Start more widely available to the eligible

population, especially very poor children. To address concerns about transporting children 

safely, the 1992 Head Start Improvement Act directed the Office of Head Start,1

 housed within the 

U. S. Department of Health and Human Services (HHS), to develop transportation regulations to 

ensure the safety and effectiveness of transportation services made available to children by Head

Start grantees. Head Start issued these regulations in 2001. 

Grantees were required to meet most provisions of the transportation regulations shortly after 

their issuance in January 2001; however, the compliance date for the provisions regarding 

passenger restraints and bus monitors was 3 years later, and the provision regarding vehicles was 

5 years later. In addition, grantees had two opportunities—in 2004 and in 2005—to delay or seek 

a waiver from implementing the restraint and monitor provisions by requesting extensions 

through the Office of Head Start.2

 Further, when grantees annually renew their funding, the 

transportation regulations also permit them to request a waiver3

 for good cause from any 

 1

At the time of our briefing in May 2006, the Office of Head Start was called the Head Start Bureau. Hence, the briefing 

slides enclosed with this report refer to the office by its former name. 

2

The effective compliance dates for the restraint and monitor provisions were first extended 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. The vehicle, restraint, and monitor provisions are effective until these respective dates or the date 

of enactment of a statute that authorizes appropriations for fiscal year 2006 to carry out the Head Start Act, whichever 

date is earlier. Head Start has issued guidance stating that waivers granted for restraints and monitors would cover the 

remainder of a grantee's program year, thus making that date the effective compliance date for a grantee. In June 2006, 

Pub.L. No.109-234 changed the compliance date for vehicles to December 30, 2006. 

3

 The general waiver authority is outlined under 45 C.F.R. § 1310.2(c).

Page 1 GAO-06-767R Head Start Transportation
provision of the regulations—which the Office of Head Start may approve or deny.4

 For purposes 

of this report, we refer to extensions as implementation delays resulting from the 2004 and 2005

provisions and waivers as those submitted under the general waiver authority provided for in the 

regulations. 

In commenting on the regulations, grantees expressed concern about the cost of complying with 

the regulations and cautioned that, since transportation was an optional service, these costs 

might lead some grantees to discontinue offering it at some sites. They also noted that the 

regulations might jeopardize long-standing partnerships with groups, such as schools and transit 

agencies, which some grantees use or contract with to provide transportation to their Head Start 

children. Controversy has also surrounded the requirement for child safety restraints, which 

typically are not standard on school buses.5

 Restraints reduce seating capacity, which could 

result in fewer school age children being transported on school buses in favor of other modes of 

transportation—such as cars–that are less safe. Additionally, given the safety record of school 

buses, some school systems have questioned whether the costs of installing restraints outweigh 

their benefits.

6

 Currently, most states do not require child safety restraints on school buses. 

To provide you with information that you requested on the regulations and their implementation, 

we determined: 

1. The research and cost information Head Start considered in establishing the 

transportation regulations. 

2. The actions Head Start grantees have taken to implement the vehicle, restraint, and 

bus monitor requirements of the regulations and the number of grantees that have

sought waivers and extensions. 

3. The associated expenses and effects of implementing the regulations on grantees and 

their transportation partners. 

To determine the research and cost information Head Start considered, we reviewed relevant 

research and regulations and interviewed officials from the Office of Head Start and the 

 4

On May 30, 2006, Head Start issued a Notice of Proposed Rulemaking (NPRM) that, if finalized, would expand the 

definition of “good cause” under the regulations to allow for a waiver of the restraint and monitor requirements if the 

grantee demonstrates that compliance with these requirements would result in a significant disruption to the grantee’s 

program and that waiving these requirements would be in the best interest of the children involved. This provision 

differs from the earlier waiver process in that the cost of complying could be considered when determining whether 

good cause exists for a waiver. 

5

Traditionally, large school buses have relied on compartmentalization—a system of closely spaced and padded seats 

that absorb and cushion riders from impact—as opposed to belts or restraints to protect school age children during a

crash. However, NHTSA is considering requirements for lap/shoulder belts in small school buses and standards for 

voluntarily installing lap/shoulder belts in large school buses. See glossary in encl. II for additional information on 

child safety restraints. 

6

Some grantee, school district, and transit officials have raised concerns about using restraints in the event of a fire or

a bus being submerged in water. National Highway Traffic Safety Administration (NHTSA) and National 

Transportation Safety Board (NTSB) officials indicated that only two fatal accidents have occurred that involved fire 

or water and that current school bus safety standards for fuel tanks and emergency exits are more stringent. NHTSA

officials also explained that having preschool children in restraints would keep them in their seats in the event of an

accident, resulting in fewer injuries and facilitating the evacuation of the bus as the children would be able to walk out 

unassisted. 

Page 2 GAO-06-767R Head Start Transportation
Department of Transportation’s (DOT) National Highway Traffic Safety Administration (NHTSA) 

and Federal Transit Administration (FTA). To describe the actions grantees have taken, we 

surveyed a nationally representative sample of Head Start grantees and their delegates, obtaining 

a response rate of 77 percent. We also analyzed requests for extended time to implement the 

child restraint and monitor provisions and interviewed officials from the Office of Head Start and 

HHS Regional Offices about the process for receiving an extension or waiver and other aspects 

of implementing the regulations. Information to describe the regulations’ effects on grantees was 

gathered through our survey and visits we made to seven grantees and their transportation 

partners, as appropriate. The states and HHS Regions in which the selected grantees operated 

were Indiana (Region 5), Iowa (Region 7), Kentucky (Region 4), Massachusetts (Region 1), and 

Washington (Region 10). Overall, the grantees were selected based on geographical diversity; size 

(e.g., funded enrollment); organization type; and to achieve a mix of grantees that filed requests 

in 2004 for more time to implement the restraint and monitor requirements and those that did 

not. We analyzed this information in combination with information collected from transportation 

providers to describe the expenses grantees incurred and the operational changes they made to 

implement the regulations. Enclosure I contains more details on our scope and methodology. We 

conducted our review between July 2005 and May 2006 in accordance with generally accepted

government auditing standards. 

On May 16, 2006, we briefed your staff on the results of our review. This report formally conveys

the information provided during that briefing. (See encl. II for the briefing slides.) 

BACKGROUND 

Head Start issued transportation regulations in 2001 that included requirements covering 

equipment, personnel, and training (e.g., for bus drivers) for transporting Head Start children; in 

particular, the regulations mandated that grantees use some type of school bus—or an 

alternative vehicle that is similar to a school bus—and required that children be placed in child 

restraints and accompanied by bus monitors. Head Start worked with two agencies within the 

U.S. DOT—NHTSA and FTA—to develop the regulations. NHTSA is responsible for developing

transportation safety standards that protect children in an accident, including those for school 

buses. These standards include, for example, roll over protection and joint strengthening, and 

require crash testing to ensure school buses meet them. FTA provides financial assistance to 

states to develop new transportation services and improve, maintain, and operate existing 

systems that serve multiple populations, including older adults and people with disabilities. 

Transit agencies receiving FTA funding must use buses that meet NHTSA standards for buses, 

pass FTA’s performance testing, and comply with ADA requirements, among other requirements. 

However, these buses do not meet NHTSA’s school bus safety standards and most cannot 

accommodate child safety restraints;7

 as such, the Head Start transportation regulations do not 

include public transit buses among the vehicles allowed to transport children. 

To ensure that transportation is as widely available as possible, other provisions of the Head 

Start regulations require that grantees coordinate transportation with other human services 

 7

For additional information on transit buses, see the glossary in encl. II. 

Page 3 GAO-06-767R Head Start Transportation
programs, many of which also provide transportation services.8

 Head Start grantees—particularly 

those in rural areas—have relied on school systems and, to a lesser extent, public transit 

agencies to transport children. Coordinating transportation services has also been a priority of 

Congress and the White House in recent years. For example, in 2005, Congress passed the Safe, 

Accountable, Flexible, and Efficient Transportation Equity Act–A Legacy for Users (SAFETEALU), which requires that human services organizations receiving FTA funding targeted to older 

adults, persons with disabilities, and persons with lower incomes provide transportation services 

derived from a locally-developed coordinated public transit human services transportation plan. 

SUMMARY OF FINDINGS 

Concerning the research and cost information that Head Start considered, we found that: 

The Office of Head Start considered safety research and data in developing the 

regulations. Research and safety data from NHTSA, the National Transportation Safety 

Board (NTSB)—an independent federal agency charged with investigating transportation 

accidents and identifying safety improvements—and the National Academy of Science’s 

Transportation Research Board shows that buses—both school buses and other types,

such as transit buses–have lower fatality rates than other modes of transportation. For 

example, NHTSA data indicates school buses have 0.2 fatalities per 100 million vehicle

miles traveled as compared to cars carrying children, which have 1.5 fatalities per 100

million vehicle miles traveled. NTSB also recommended to Head Start that children be 

transported in vehicles meeting NHTSA’s school bus standards. NHTSA data also shows 

that children of all ages are safer when wearing height- and age-appropriate restraints 

when traveling on school buses. NHTSA’s crash testing of small school buses in 1997 and 

1999 demonstrated that the severity of head injuries exceeded acceptable levels when

preschool age children were not restrained compared with when they were restrained; 

this led NHTSA to conclude that compartmentalization did not sufficiently protect 

preschool-age children and that they were safer using restraints. The NTSB concurred 

with NHTSA’s recommendation. NHTSA’s 2002 report to Congress on school bus safety9

--

which addresses large school buses—indicates that lap/shoulder belts offer some benefit 

in reducing the risk of serious injury to older children.10 NHTSA’s research, however, has 

been limited to school buses as NHTSA has not conducted crash testing to assess the risk 

for preschool age children using restraints on transit buses. 

The requirement for a bus monitor was based on Head Start’s conclusion that

young children on a bus should be supervised. Although the Office of Head Start did 

not research the need for monitors, it based this requirement on the belief that preschool-

 8

For example, in 2003, GAO reported that 62 federal programs funded transportation services and that many of them

did not coordinate with each other. See GAO, Transportation-Disadvantaged Populations: Some Coordination

Efforts among Programs Providing Transportation Services, but Obstacles Persist, GAO-03-697 (Washington, D.C.: 

June 30, 2003). 

9

National Highway Traffic Safety Administration, Report to Congress: School Bus Safety: Crashworthiness Research, 

(Washington, D.C.: April 2002). 

10NHTSA has found, however, that lap/shoulder belts are not appropriate for preschool-age children. Consequently, 

these younger children would require child safety restraints on large buses to achieve the same benefits in reducing 

serious injuries as older children using lap/shoulder belts. 

Page 4 GAO-06-767R Head Start Transportation
age children and younger who ride a bus should be supervised by an adult monitor in 

case the driver becomes disabled. 

The Office of Head Start no longer has supporting documentation for its cost 

estimate of $18.9 million for implementing the regulations. Without this 

documentation, we cannot determine the reliability of the data Head Start used to 

develop its estimates. However, Head Start has lacked the basic information about 

transportation services offered by its grantees necessary to have calculated a reliable 

estimate when developing the regulations or to answer future questions about the 

regulations’ costs or effects. This is because the Office of Head Start has not 

systematically gathered information on the transportation services that grantees provide. 

ACF regional offices were able to provide us with some information about the 

transportation services of their grantees, but the information was neither standardized 

nor in any type of database that could be aggregated for purposes of analysis. 

Regarding grantees’ actions to implement the regulations and the extent to which they sought 

extensions and waivers, we found that: 

Grantees have made progress in implementing the regulations. Approximately 64 

percent report that they have finished implementing the regulations while 18 percent 

reported being almost finished. The remaining 18 percent reported being either half-way 

or less than half-way finished, or not sure. 

Almost all grantees reported primarily using a vehicle type that complies with 

the regulations. Ninety-seven percent of grantees reported primarily using either a

school bus (93 percent) or the alternative vehicle allowed by the regulations (4 percent) 

to transport Head Start children on a daily basis. Bureau officials stated that they 

purposefully provided a long period of time—approximately 5 years—to implement the 

vehicle provisions in order to help ensure that grantees had adequate time to replace their 

old vehicles with ones that would be in compliance with the regulations. 

Grantees reported taking a variety of actions to meet the restraint and monitor 

requirements. Most grantees reported (1) either buying restraints and retrofitting their 

buses with them, or having had vehicles with restraints already in them; and (2) adding

the bus monitor responsibilities to duties of existing staff or having had monitors already 

in place. 

Some transit agencies and other transportation providers who work with Head 

Start are facing difficulties in using the alternative vehicle. This is due to a lack of 

guidance for adapting it to transport other populations in addition to Head Start children. 

While it was developed so that grantees’ transportation partners could meet the 

requirements of both Head Start and other groups, such as older adults or people with

disabilities, NHTSA did not define how the vehicle could differ with respect to school bus 

features such as narrow aisle width, high-back seats, narrow, high steps, and 

compartmentalized seating. These features make using the vehicle difficult for older 

adults and people with disabilities. 

Page 5 GAO-06-767R Head Start Transportation
Fewer grantees requested more time to implement the restraint and monitor

provisions in 2006 compared to 2004, but the number of waiver requests is 

unknown. In 2006, 19 percent of grantees submitted extension requests, dropping from 

30 percent in 2004.11 As for waivers requested under the general waiver authority provided 

for in the regulations, the Office of Head Start officials stated that they were unaware that 

any were submitted. However, we obtained copies of some waiver requests or the Office 

of Head Start’s denials of them from a few regional offices and grantees. Additionally, 

bureau officials confirmed that they have not specifically defined criteria for submitting a 

waiver to guide grantees in applying for a waiver or the bureau in approving or denying 

waiver requests. 

With respect to the costs and effects on grantees associated with implementing the regulations, 

we found that: 

Many grantees reported some cost effects from implementing the regulations, 

but noted that they were facing other budgetary pressures. Fifty-six percent of

grantees reported no more than moderate cost effects on their transportation budgets 

from implementing the vehicle, restraint, or monitor requirements while 44 percent 

reported experiencing large or very large increases associated with one or more of these 

requirements. However, grantees that we visited stated that other costs, such as health 

insurance, affected their budgets as much as or more than the regulations. 

Historically, Head Start helped grantees with the cost of purchasing vehicles and 

restraints through supplemental money called Program Improvement (PI) funds, 

providing grantees a total of approximately $76 million in fiscal years 2001 through 2005.12

However, grantees are now expected to pay for replacing vehicles and restraints out of 

annual operating monies or nonfederal sources. 

Grantees are experiencing effects to transportation services or program 

operations as a result of implementing the regulations. Fifty-eight percent of 

grantees reported at least one effect on transportation services as a result of the 

regulations, most often noting that they changed transportation routes (83 percent) or 

reduced transportation services (50 percent). Sixty-seven percent of grantees also 

reported that implementing the regulations had at least one effect on their program 

operations, most often reporting that they increased the number of staff (58 percent); 

increased staff hours (54 percent); changed, reduced, or eliminated other program 

services (49 percent); or reduced staff hours in the classroom (49 percent). 

Some grantees are facing difficulties sustaining transportation partnerships. 

Thirty-six percent of grantees contracted with or used another organization—mostly 

school systems—for transportation services to at least some or all of their program sites. 

 11We do not have data to determine the reasons for the decline in extension requests between 2004 and 2006. However, 

our survey data shows that grantees have taken actions to comply with the regulations either by making the required

changes or, in some cases, reducing or eliminating transportation services.

12This figure only represents the amount of PI funding that was provided to help grantees in implementing some 

provisions of the transportation regulations; it does not represent the total amount of PI funding awarded by Head

Start for these years. 

Page 6 GAO-06-767R Head Start Transportation
About a quarter of them reported that their transportation partners discontinued service 

for this program year while approximately 39 percent of these grantees reported that the 

contractor would discontinue services for the 2006/2007 program year. For example, 14 of 

Iowa’s 15 DOT regions provided transportation via transit buses to Head Start grantees 

prior to the regulations; since the regulations’ issuance, 9 have discontinued or plan to

discontinue some or all services to Head Start grantees, primarily because transit buses 

do not meet the definition of an allowable vehicle under the regulations. Although Iowa’s 

transit buses were built to meet several of NHTSA’s school bus crashworthiness 

standards and can accommodate child restraints, they do not meet all of them, such as

compartmentalization. According to Iowa DOT officials, the loss of Head Start funding 

has resulted in some Iowa transit agencies reducing services, raising costs, or both for 

others they serve, such as older adults or people with disabilities. FTA and transit 

officials indicated that other transit agencies that have had a history of coordinating 

human services transportation have encountered similar difficulties. 

CONCLUSIONS 

Many grantees have implemented the transportation regulations, with some experiencing adverse 

program and budgetary effects to do so, including reducing transportation services. But the 

Office of Head Start does not track transportation services that grantees provide and thus will 

not know if grantees will be able to continue to comply, or, if over time, other budget pressures 

will lead more grantees to cut transportation. These cuts could ultimately affect grantees’ ability 

to meet enrollment and other program goals, or reduce transportation safety by children using 

less safe forms of transportation. 

The waiver process will be the key mechanism for grantees to bring compliance issues to the 

Office of Head Start’s attention. However, the Office of Head Start lacks a management process 

for tracking and considering waivers. Developing such a process would also allow the bureau to 

define the circumstances or issues on which it needs NHTSA’s and FTA’s expertise. Further, the 

bureau has not specifically defined its criteria for “good cause” so that grantees would know the 

conditions under which adhering to the regulations would create a safety hazard appropriate for 

requesting a waiver. The absence of a clear process and criteria may pose a barrier for grantees 

in using this mechanism and reduce grantees’ assurance that their issues will be weighed 

appropriately. 

Transit agencies are facing difficulties addressing dual goals: meeting the mobility needs of 

multiple populations including Head Start children, people with disabilities, and older adults 

while addressing federal safety requirements. While the federal government has encouraged 

human service and transit agencies to use one type of vehicle to more efficiently transport 

multiple populations, there has been limited federal guidance on simultaneously achieving both 

efficient mobility and safety goals. Specifically, few transit agencies use the alternative vehicle 

because, while it meets Head Start safety requirements, it does not comply with ADA 

requirements and consequently is not practical for transporting older adults and people with 

disabilities. Information on how the alternative vehicle can be adapted for transit would be useful 

to both transit agencies and Head Start grantees given the program’s mandate to provide services 

to children with disabilities. 

Furthermore, some transit agencies—in an effort to maintain long-standing coordination 

efforts—have adapted transit buses to incorporate standards that they believe sufficiently 

Page 7 GAO-06-767R Head Start Transportation
protect preschool age children. However, NHTSA, FTA, and Head Start have not determined the 

safety features needed for transit buses to sufficiently protect these children. Thus, transit 

agencies are faced with reducing or eliminating service to Head Start, resulting in some children 

being transported in vehicles that are less safe or not being able to attend Head Start at all. 

RECOMMENDATIONS FOR EXECUTIVE ACTION 

In order to determine the ability of grantees to provide transportation services and to define the 

waiver process, we make the following three recommendations to the Office of Head Start: 

• Systematically track transportation services provided by grantees so that the Bureau can 

determine changes in the availability of these services, especially any reduction in them. 

• Establish a waiver process that specifies criteria for submitting waivers, including more 

specific guidance on what constitutes “good cause,” lists the responsible entities for review 

and approval, and documents the receipt, review, and final disposition of each waiver. Should 

any waiver requests submitted require Head Start to address issues concerning vehicles, the 

waiver process should include consultation with NHTSA and FTA as appropriate. 

• Once a process has been established, take steps to ensure that grantees and regional staff 

know about it and understand how it works. 

In order to enable grantees and transit agencies to better coordinate transportation services, we 

make the following two recommendations to DOT, in consultation with Head Start: 

• Develop guidance on adapting the alternative vehicle to incorporate ADA requirements and 

communicate this guidance to Head Start grantees and transit agencies. 

• Determine if certain safety features could be incorporated into transit buses used by Head 

Start grantees to provide a level of safety comparable to school buses or alternative vehicles 

in transporting preschoolers. 

• If this determination cannot be made before the remaining deadlines expire, we 

recommend that Head Start, in consultation with DOT, should determine on a case-by-case 

basis whether grantees using transit vehicles with child safety restraints can continue to 

do so until such a determination can be made. 

• If DOT determines that transit vehicles with appropriate safety features would afford 

suitable protections, we recommend that Head Start adopt these features into the final

Head Start transportation regulations. 

AGENCY COMMENTS 

We provided a draft of our report for comment to the Administration for Children and Families 

(ACF); and the Department of Transportation (DOT), specifically NHTSA and FTA. DOT 

provided technical comments which we incorporated where appropriate. Regarding the lack of 

guidance on achieving mobility and safety goals, FTA noted that it has a research project under 

way aimed at developing a new small bus that would meet both of these goals. We encourage 

FTA to continue these efforts. 

ACF agreed with the two recommendations regarding the waiver process and indicated that it 

would consider our recommendation that it track the availability of transportation services. ACF 

also provided technical comments that we included in the report where appropriate. (See encl. 

III for a copy of ACF’s comments.) 

Page 8 GAO-06-767R Head Start Transportation
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 relevant congressional committees and other interested parties and will make copies 

available to others upon request. The report will also be available on GAO’s Web site at 

http://www.gao.gov. If you or your staff have any questions about this report, please contact 

either one of us at (202) 512-7215 (Marnie Shaul) or (202) 512-6570 (Katherine Siggerud). Betty 

Ward-Zukerman and Cathy Colwell, Glen Trochelman–Assistant Directors—Lynn Filla-Clark and 

Janet Mascia—Analysts-in-Charge—and Sandra Tasic, Jeffrey Weinstein, Stuart Kaufman, and 

Nancy Hess also made key contributions to this report. 

Marnie Shaul Katherine Siggerud 

Director, Education, Workforce, and Director, Physical Infrastructure 

Income Security Issues Issues 

Enclosures 

Page 9 GAO-06-767R Head Start Transportation
List of Congressional Requesters 

The Honorable Howard P. “Buck” McKeon 

Chairman 

The Honorable George Miller 

Ranking Minority Member 

Committee on Education and the Workforce 

House of Representatives 

The Honorable Don Young 

Chairman 

The Honorable James L. Oberstar 

Ranking Minority Member 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Michael N. Castle 

Chairman 

The Honorable Lynn C. Woolsey 

Ranking Minority Member 

Subcommittee on Education Reform 

Committee on Education and the Workforce 

House of Representatives 

The Honorable John A. Boehner 

House of Representatives 

The Honorable Betty McCollum 

House of Representatives 

The Honorable Anne Meagher Northup 

House of Representatives 

Page 10 GAO-06-767R Head Start Transportation
ENCLOSURE I ENCLOSURE I 

OBJECTIVES, SCOPE, AND METHODOLOGY 

We designed our study to determine the following: (1) the research and cost information Head 

Start considered in establishing the transportation regulations; (2) the actions Head Start 

grantees have taken to implement the vehicle, restraint, and bus monitor requirements of the 

regulations and the number of grantees that have sought waivers and extensions; and (3) the 

associated expenses and effects of implementing the regulations on grantees and their 

transportation partners. 

We obtained information to determine these objectives by interviewing cognizant federal and 

state officials as well as representatives from associations, advocacy groups, bus manufacturers 

and dealers, and independent transportation contractors; collecting and analyzing extension 

requests from Head Start grantees submitted to the Office of Head Start for 2004 and 2006; 

conducting site visits with Head Start program officials and their transportation partners; and 

surveying a nationally representative sample of Head Start grantees and delegates. 

Interviews

Office of Head Start and HHS Regional Offices: We interviewed officials from the Office of Head 

Start to discuss, among other things, the background and development of the Head Start 

transportation regulations, information on grantees’ transportation services, and the extension 

and waiver process. We also interviewed Head Start program staff in the 10 HHS Regional offices 

as well as officials from the American Indian-Alaska Native and Migrant and Seasonal Program 

Branches responsible for Head Start grantees and delegates serving migrant, American Indian, 

and Native Alaskan families and children. From the regional offices, we collected data on the 

amount of Program Improvement funds awarded to grantees for purchasing buses and child 

restraints, and discussed their perspective on the impact of the regulations on Head Start 

grantees and delegates in their regions. 

Transportation Agencies: We interviewed officials from the U.S. Department of Transportation, 

including the National Highway Traffic Safety Administration (NHTSA) and the Federal Transit 

Administration (FTA). We also interviewed officials from the National Transportation Safety 

Board (NTSB), an independent federal agency charged by Congress to investigate transportation 

accidents. Our interviews inquired about the current safety research regarding transporting 

preschool children on school buses or alternate vehicles, the agencies’ involvement in helping 

Head Start to develop the transportation regulations, issues related to the development of the 

alternative vehicle, and the impact of the regulations on transit agencies working with Head Start

grantees and other human service organizations. 13

Associations and Advocacy and Trade Organizations: In addition to federal officials, we also met 

with representatives of transportation associations including the American Public Transportation 

Association, Community Transportation Association of America, National Association of State 

Directors of Pupil Transportation Services, the National School Transportation Association, and 

 13The regulations describe this vehicle as an Allowable Alternate Vehicle; NHTSA defines it as a Multi Function School 

Activity Bus. For purposes of this report, we will refer to it as the alternative vehicle.

Page 11 GAO-06-767R Head Start Transportation
ENCLOSURE I ENCLOSURE I 

the National Association for Pupil Transportation to discuss the impact of the regulations on 

their members. We also met with representatives of the American Academy of Pediatrics to 

discuss safety issues concerning the transportation of preschool age children. We spoke with 

representatives from the National Head Start Association as well as several of their members at 

their annual state directors’ meeting to learn more about the perspective of Head Start grantees 

on implementing the regulations. Finally, we interviewed representatives from bus 

manufacturers and dealers, as well as independent transportation contractors primarily to gather 

cost information about school buses, alternative vehicles, and contracting for transportation 

services. 

Site Visits 

We visited seven Head Start grantees located in five different states and ACF regions in order to 

learn more about the effects on grantees’ budgets and program services from implementing the 

regulations, and to meet with their transportation partners, where appropriate, to discuss the 

impact of the regulations on providing transportation to Head Start. The states and HHS Regions 

in which the selected grantees operated were Indiana (Region 5), Iowa (Region 7), Kentucky 

(Region 4), Massachusetts (Region 1), and Washington (Region 10). Overall, the grantees were 

selected based on geographical diversity; size (e.g., funded enrollment); organization type; and to

achieve a mix of grantees that filed requests in 2004 for more time to implement the restraint and 

monitor requirements and those that did not. (See table 1.) In addition to these criteria, we 

specifically selected Iowa and Washington because of unique partnerships between some Head 

Start grantees in those states and organizations that helped them transport Head Start children to

and from their centers. 

Table 1: Site Selection Characteristics 

Grantee location

ACF 

region Organization type

Funded enrollment 

(children) 

Filed extension 

request in 2004 

Greencastle, Ind. 5 Non-profit 415 No

Louisville, Ky. 4 School system 1,850 Yes 

Fort Dodge, Iowa 7 Non-profit 194 Yes 

Renton, Wash. 10 Government agency 1,703 Yes 

Pullman, Wash. 10 Non-profit 72 No

Boston, Mass. 1 Community action agency 2,000 Yes 

Westfield, Mass. 1 School system 205 No 

Documentation 

In conducting our work, we reviewed relevant background information on the programs, 

regulations, legislation, and transportation research studies and viewed videotapes of NHTSA’s 

crash testing of small school buses with preschool-age dummies. We also collected and analyzed

all extension requests for more time to implement the restraint and monitor provisions from 

Head Start grantees to the Office of Head Start, as well as some waiver request letters that either 

regional offices or grantees provided us. Finally, we collected data on the amount of Program 

Improvement funds awarded to Head Start grantees used to purchase buses or child restraints 

Page 12 GAO-06-767R Head Start Transportation
ENCLOSURE I ENCLOSURE I 

from all HHS regional offices. While we asked for this data for fiscal years 2001 through 2005, 

some Regional offices were not able to provide this information for all years. Specifically, we did 

not receive data from four regions for fiscal years 2001 and 2002, and from two regions for fiscal 

year 2003. Also some regions could not report the number of buses that had been financed, in 

whole or in part, with Head Start funding, or the number sold or taken out of service because 

such requests were not retained. 

Survey Development and Sample Selection 

We developed the survey questionnaire and conducted five pretests of its content and format 

with Head Start grantee directors and others knowledgeable about the transportation of children 

to and from Head Start centers. The pretests were conducted either in-person or by telephone. 

During these pretests, we asked Head Start grantees whether the questions were clear and 

unbiased, whether the terms contained in the questionnaire were accurate and precise, and 

whether they would be able to provide us with accurate data on various attributes of the vehicles 

used to transport children. We made changes to the questionnaire based on the pretest results. 

The surveys were conducted using self-administered electronic questionnaires posted on the 

World Wide Web. We sent e-mail notifications to all sampled Head Start grantees on January 5,

2006, to inform them that our Web-based survey would soon be activated. On January 10, 2006, 

we sent each potential respondent another e-mail containing a unique username and password to 

ensure that only Head Start grantees included in our sample could participate in the survey. To 

encourage respondents to complete the questionnaire, we sent follow-up e-mails to those who 

had not yet responded on January 19, 2006; January 27, 2006; and on February 6, 2006. During the 

week of February 13, 2006, GAO support staff made telephone calls to grantees that still had not 

responded in order to encourage them to respond. We closed the survey on February 28, 2006. 

We were interested in obtaining information on transportation services provided by Head Start 

grantees and their progress and challenges in implementing the Head Start transportation 

regulations. To do this, we drew a stratified random probability sample of 449 Head Start 

grantees or delegates from a population of 1,928 agencies that operate local Head Start programs. 

Grantees and delegates that operated only Early Head Start programs were excluded from the 

population from which we selected our sample. We selected our sample to represent eight strata 

defined by the organization type (community action agencies, government or tribal entities, 

private, non-profit, or school systems) and whether the program had filed an extension request in

2004. Ultimately, we received 339 responses for an adjusted response rate of 77 percent. The 

division of the population, the sample, and the respondents across the eight strata can be found 

in table 2. Each sampled grantee or delegate was subsequently weighted in the analysis to 

represent all the members of the population. 

Page 13 GAO-06-767R Head Start Transportation
ENCLOSURE I ENCLOSURE I 

Table 2: Sample Disposition

Stratum

number Stratum description 

Total 

population size

Total

sample size

Number of 

respondents

1 CAA that filed an extension request 233 44 33

2 CAA that did not file an extension request 405 76 64

3 School system that filed an extension request 132 40 36

4 School system that did not file an extension request 235 70 53

5 Private organization that filed an extension request 122 21 18

6 Private organization that did not file an extension 

request 

560 99 72

7 Government entity that filed an extension request 57 24 13

8 Government entity that did not file an extension request 184 75 50

Total 1,928 449 339

All percentage estimates from our sample have margins of error (that is, confidence interval 

widths) of plus or minus 10 percentage points or less, at the 95-percent confidence level unless 

otherwise noted. 

In addition to sampling errors, the practical difficulties of conducting any survey may introduce 

errors, commonly referred to as non-sampling errors. For example, difficulties in how a 

particular question is interpreted, in the sources of information that are available to respondents, 

or in how the data are entered into a database or were analyzed, can introduce unwanted 

variability into the survey results. We took steps in the development of the questionnaire, the 

data collection, and the data analysis to minimize these non-sampling errors. For example, a 

survey specialist designed the questionnaire in collaboration with GAO staff with subject matter 

expertise. Then, the draft questionnaire was pretested with a number of Head Start officials to 

ensure that the questions were relevant, clearly stated, and easy to comprehend. In addition, the 

questionnaire was reviewed by a second survey specialist. When the data were analyzed, a 

second, independent analyst checked all computer programs. Since this was a Web-based survey, 

respondents entered their answers directly into the electronic questionnaire. This eliminated the 

need to have the data keyed into a database thus removing an additional source of potential 

error. 

Sample Selection for Analyzing Extension Requests 

To characterize reasons for Head Start agencies filing an extension request, we drew a stratified 

random probability sample from the population of 581 agencies that filed an extension request in 

2004. We selected our sample for two strata defined by the Head Start region (Region 3, all other 

regions). Ultimately, we examined 188 extension requests. The division of the population and the 

division of the sample across the two strata can be found in table 3. Each sampled agency that 

filed an extension request was subsequently weighted in the analysis so that final results 

represent all the members of the population of agencies that filed extension requests. 

Page 14 GAO-06-767R Head Start Transportation
ENCLOSURE I ENCLOSURE I 

Table 3: Sample Disposition

Stratum

number Stratum description 

Total agencies that filed

an extension request

Total sample 

size 

1 Region 3 agency requests 68 68 

2 All other regions’ agency requests 513 117 

Total 581 185

All percentage estimates from our sample of the extension requests have margins of error (that 

is, confidence interval widths) of plus or minus 7 percentage points or less, at the 95-percent 

confidence level unless otherwise noted. 

Page 15 GAO-06-767R Head Start Transportation
ENCLOSURE II ENCLOSURE II 

ENCLOSURE II ENCLOSURE II 

1

Head Start: Progress and 

Challenges in Implementing

Transportation Regulations

Briefing to Staff of the House

Committees on Education and the Workforce, 

Transportation and Infrastructure,

Subcommittee on Education Reform and 

Representatives McCollum and Northup

May 16, 2006

Page 16 GAO-06-767R Head Start Transportation
ENCLOSURE II ENCLOSURE II 

Page 17 GAO-06-767R Head Start Transportation

2

Introduction

• Young children are some of our most vulnerable citizens, especially when

being transported in vehicles. The Head Start program serves over 900,000 

children, ages birth to 5, and provides most of them with transportation

services, sometimes in partnership with other agencies, to and from Head

Start programs each day.

• As required by provisions in the 1992 Head Start Improvement Act, the Head

Start Bureau developed transportation regulations to assure that safe and 

effective transportation services were available.

• Issued regulations in January 2001

• Pursuant to statutory changes, the compliance date for meeting the 

vehicle type requirement is June 30, 2006, by which time programs are 

to use school buses or specific alternate vehicles that incorporate 

school bus safety features

• Compliance dates for equipping vehicles with restraints and assuring the presence of bus monitor was June 2004 for those who did not 

request more time, or the end of grantees’ 2006 program year for those

who received time extensions
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Introduction

• To increase transportation safety in Head Start, the regulations required grantees to meet vehicle, equipment, training, and personnel provisions.

• Additionally, Head Start regulations required that grantees coordinate transportation services

with other human services programs to ensure that transportation is as widely available as

possible. Many of these programs provide transportation services—a 2003 GAO report found that 

62 federal programs funded transportation services and that many of them did not coordinate 

with each other.1

• The regulations were developed in consultation with two Department of Transportation (DOT) agencies—the National Highway Traffic Safety Administration (NHTSA) and the Federal Transit

Administration (FTA).

• In commenting on the proposed regulations, some Head Start programs expressed concern about 

implementing the regulations without adversely affecting their budget, transportation services, and other program services provided.

• In response, Head Start allowed grantees to request extensions for more time to implement the 

child restraint and bus monitor provisions.

1GAO, Transportation-Disadvantaged Populations: Some Coordination Efforts Among Programs Providing Transportation Services, but Obstacles Persist, GAO-03-697 (Washington, D.C.: June 30, 2003).
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4

Objectives

To provide information on the regulations and their implementation, 

GAO determined:

1. The research and cost information Head Start considered in

establishing the transportation regulations

2. The actions Head Start grantees have taken to implement the 

vehicle, restraint, and bus monitor requirements of the 

regulations, and the number of grantees that have sought 

waivers and extensions

3. The associated expenses and effects of implementing the 

regulations on grantees and their transportation partners

See glossary on slides 50-55 for definitions of terms used throughout these slides and pictures of vehicles

used by Head Start grantees and child safety restraints
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5

Scope and Methodology

• Surveyed a nationally representative sample of 449 Head Start grantees out

of a total of 1,928 that deliver Head Start services1

• Overall response rate was 77 percent

• Responses from this survey were used to project to approximately 1,370 grantees and delegates that provide transportation services,

2 with

a 95-percent confidence interval of +/- 10 percent

• Interviewed federal and state officials; representatives from transportation

association and advocacy groups; Head Start program providers; bus

manufacturers; and transportation providers

(continued)

1For the purposes of these slides, we refer to all Head Start grantees and their delegate agencies—entities that help grantees deliver services--as grantees. Our survey excluded grantees that provided only Early Head Start services. 2This number is an estimate with a range from 1,290 to 1,460.
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6

Scope and Methodology

• Conducted site visits with 7 grantees in 5 states, selected 

for geographic diversity, size, and organization 

sponsorship to learn about the steps and choices

grantees made to meet the regulations

• Reviewed transportation research, agency regulations and guidance and other documentation 

• Analyzed the Head Start Bureau’s extension and waiver 

request documentation

• This work was conducted in accordance with generally accepted government auditing standards.
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7

Results in Brief – Objective 1

• Head Start used NHTSA and the National Transportation Safety Board 

(NTSB) research in formulating its vehicle and restraint requirements. 

• NHTSA and NTSB research shows that preschoolers are safer on 

school buses than passenger vehicles. 

• NHTSA research shows preschoolers on small school buses are even

safer when in child safety restraints. Similarly, data from a 2002 

NHTSA report indicates that lap/shoulder belts offer some benefit to

older children riding school buses. Because lap/shoulder belts are not 

appropriate for preschool age children, they would need child safety

restraints when riding on large school buses to achieve the same

benefit.

• The requirement for a bus monitor was based on the Head Start Bureau’s

conclusion that young children should be supervised by an adult while

riding on the bus, in the event that the driver became disabled.
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Results in Brief – Objective 1

• The Head Start Bureau no longer has the documentation 

supporting its $18.9 million estimate for the cost of

implementing the regulations nor does it systematically 

track grantees’ transportation services. Thus, it lacks

basic information to develop a reliable estimate.
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9

Results in Brief—Objective 2

• Based on our survey, about two-thirds of the approximately 1,370 

Head Start grantees that offer transportation reported having

completely finished implementing the regulations as of February 28, 

2006. An additional 18 percent reported having almost finished. 

• Others are still having problems in meeting the requirements. GAO’s 

analysis of Head Start’s 2006 extension request documentation

shows that 19 percent of grantees asked for more time to implement 

the restraint and monitor requirements. The number of waivers– requests for exemptions from the regulations submitted by grantees

with their annual refunding application--is unknown.
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10

Results in Brief—Objective 2

• Of the approximately 1,370 grantees providing transportation, 97

percent report using vehicles that meet the Head Start requirements

for vehicle type, mostly school buses. 

• The small percentage of grantees that work with transit and other

transportation partners using an alternative vehicle allowed by the

regulations are challenged by the lack of guidance on how to adapt these vehicles to meet the transportation and safety needs of Head

Start as well as other populations that they serve.

• The waiver process exists as a mechanism for grantees to raise 

issues with the Bureau regarding compliance, but the Bureau does

not have a clearly defined process for tracking and considering

waiver requests. This may pose a barrier for grantee use.
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11

Results in Brief—Objective 3

• Approximately 56 percent of grantees who provided transportation reported 

having, at most, moderate cost effects associated with implementing the 

vehicle, restraint, and/or the monitor requirements while 44 percent

reported large to very large cost effects for at least one or more of these

provisions.

• Grantees reported effects on their transportation services and operations as

a result of implementing the regulations:

• An estimated 58 percent of the 1,370 grantees providing transportation

reported at least one effect on their transportation services such as 

changing routes or reducing transportation services. 

• An estimated 67 percent of grantees reported at least one effect on

program operations, including increasing the number of staff needed or

increasing staff hours.

• A third of grantees reported increased parental satisfaction with

transportation services.
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12

Background: 

Head Start

• Head Start was created in 1965 to provide comprehensive child development services

primarily to poor children.

• In FY 2005, Congress appropriated $6.84 billion to almost 2,000 Head Start grantees

that provide services to over 900,000 children nationwide.

• Grantees are not required to provide transportation services, but many do so to assist

children’s access to the program, especially those from very poor families.
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13

Background: Head Start Transportation Regulations

Modified after Issuance

• In January 2001, Head Start issued transportation regulations requiring,

among other things, that

• By January 20, 2004, vehicles transporting Head Start children have a 

bus monitor on board and all children be transported in age-height 

appropriate child safety restraints.

• By January 18, 2006, vehicles transporting Head Start children be

school buses or allowable alternate vehicles1 that meet safety standards required of school buses.

• Section 1310.2(c) of the regulations also allowed grantees to apply for

waivers to any transportation requirement for “good cause” (i.e.,where

implementation may cause a safety hazard to children); cost cannot be cited

as a reason for a waiver.

1NHTSA has also defined this vehicle as a Multi Function School Activity Bus. However, for 

purposes of these slides, we will refer to it as the alternative vehicle.
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14

Background: Head Start Transportation Regulations 

Modified After Issuance

• In January 2004, the Head Start Bureau issued interim final regulations allowing

grantees to apply for a time extension to meet the monitor or restraint requirements.

• For grantees with approved extension requests, time to comply was extended to

January 2006

• In December 2005, the Labor-HHS-Education appropriations act extended the time

allowed to meet

• the vehicle requirement to June 30, 20061

• the monitor and restraint requirements until September 30, 2006,(by authorizing HHS to grant a waiver of these requirements) or the date of the enactment of a 

statute that authorizes appropriations for FY 2006 to carry out the Head Start

Act, whichever date is earlier2,3

1In June 2006, P.L.109-234 extended the compliance date for the vehicle provisions to December 2006. 2The Head Start Bureau’s guidance to grantees in 2006 states that the agency will consider waiver requests that would cover the remainder of a grantee’s program year, thus making that date the effective compliance date for the grantee. 3On May 30, 2006, Head Start issued a Notice of Proposed Rulemaking (NPRM) that, if finalized, would expand the definition of “good cause” under the regulations to allow for a waiver of the restraints and monitors requirements if the grantee demonstrates that compliance with these requirements would result in a significant disruption to the grantee’s program and that waiving these requirements would be in the best interest of the children involved. This provision differs from the earlier waiver process in that the cost of complying could be considered when determining whether good cause exists for a waiver.
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15

Background: U.S. DOT and NTSB

• Two DOT agencies whose missions are to ensure safe transportation services and provide human 

service transportation have worked with Head Start to help develop the Head Start transportation 

regulations.

• NHTSA helps ensure highway and motor vehicle safety and establishes standards intended 

to protect occupants during accidents, as well as to prevent accidents

• FTA provides financial assistance to develop new transportation services and improve,

maintain, and operate existing systems that serve the general population as well as older

adults and people with disabilities

• Transit agencies receiving FTA funding must have vehicles that comply with Americans 

with Disabilities Act (ADA) requirements, including being wheel chair accessible

• FTA participates in the United We Ride program established pursuant to an executive 

order in 2004 that required coordinating transportation for human services programs, including Head Start

• NTSB is an independent federal agency charged by Congress to investigate a variety of transportation accidents and make recommendations about preventing future ones, and provided 

input to HHS regarding the safety of vehicles used for Head Start
ENCLOSURE II ENCLOSURE II 

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16

Background: Vehicles Used to Transport 

Children to Head Start

• Head Start grantees or their transportation partners use a variety of vehicles 

to transport children, including:

• Large and small school buses, which are built to safety standards 

issued by NHTSA, and include various safety features to protect 

children in the event of an accident, such as compartmentalization, a 

system of closely spaced and padded seats 

• An alternate vehicle that is similar to a school bus, with the exception 

that it does not have stop arms or flashing lights

• Public transit buses, which are used by public transit agencies that also

transport members of the general population as well as older adults 

and people with disabilities

Definitions and more detailed explanations of these vehicles, as well as pictures, are included in the 

glossary on slides 51-53
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17

Background: Child Safety Restraints

• Child safety restraints include:

• Restraints that are added to the vehicle after it is 

purchased

• Restraints that are built into the seat, also known as 

integrated child safety restraints.

Additional information describing the various types of child safety restraints, as well as pictures, can be

found in the glossary on slides 54 and 55
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18

Objective 1: Head Start Considered Safety

Of School Buses and NTSB Recommendations

• The Head Start Bureau considered school 

bus safety data in deciding to require their

use or the use of alternative vehicles.

• In the 1990’s, some Head Start grantees 

used 15-passenger vans (see picture at

right) that do not meet NHTSA school 

bus standards such as joint strength

and rollover protection, high backed 

padded seats, and minimum seat

spacing

• In 1998 and 1999, 4 accidents occurred 

involving children in vehicles not 

meeting these standards, including 15-

passenger vans, resulting in fatalities

and serious injuries, including a fatally injured Head Start child

• As a result, in 1999 NTSB recommended to

Head Start that children should be 

transported in vehicles meeting NHTSA

school bus standards.
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19

Objective 1: School Buses Have Lower Fatality Rates

Than Other Modes of Transportation

• NHTSA data indicates school buses

have much lower student fatality rates 

than passenger vehicles. 

• School buses: 0.2 fatalities per 100 

million vehicle miles traveled

• Cars: 1.5 fatalities per 100 million 

vehicle miles traveled

• 2002 Transportation Research Board 

report, The Relative Risks of School

Travel, indicates school buses and 

other buses account for far fewer 

fatalities among school age children

during normal school hours than other 

modes of school transportation. (See

figure to the right.)
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20

Objective 1: NHTSA Testing Shows Need for 

Restraints on School Buses, but Gaps in Testing 

Exist for Transit Buses • Head Start relied on NHTSA research and recommendations to require child safety

restraints:

• NHTSA crash testing in 1997 and 1999 demonstrated that compartmentalization

did not provide preschool age children on small school buses sufficient

protection and that they are safer using child safety restraints

• In 1999, NHTSA recommended that preschool age children transported in school 

buses use child safety restraints

• Although NHTSA’s research did not address preschool age children on large school

buses, data in NHTSA’s 2002 report to Congress on school bus safety indicates that lap/shoulder belts offer some benefits to older children riding large school buses. However, NHTSA also found that lap/shoulder belts are not appropriate for preschool 

age children. Consequently, these younger children require child safety restraints on

large buses to achieve the same level of protection

• NHTSA has not conducted crash testing to assess the risk for preschool age children 

using child safety restraints on transit buses
ENCLOSURE II ENCLOSURE II 

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21

Objective 1: Head Start Based Monitor Requirement 

on Safety Considerations

• The Head Start Bureau based the decision to require monitors on 

the belief that preschool children riding a bus, and infants and

toddlers also transported by some grantees, should be supervised by

an adult monitor in case the driver became disabled.

• More recently, the American Academy of Pediatrics standards for

child care also identifies bus monitors as necessary for child care 

facilities, which also transport preschool age children.

.
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22

Objective 1: Head Start Lacks Cost Documentation 

and Data on Transportation Services to Develop Cost

Estimates

• In the final regulations issued in 2001, Head Start estimated the cost of 

implementing the regulations to be $18.9 million, most of which reflects the

cost of restraints, but the Bureau no longer has the supporting

documentation for its estimate.

• Without documentation, we cannot determine the reliability of the data

Head Start used to develop its estimates. However, Head Start does not

systematically track transportation services and thus lacks basic 

information on which to develop a reliable estimate. 
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23

Objective 2: Most Grantees Report Having

Completed Implementation

• An estimated 1,370 grantees-- approximately 70 percent of Head Start

grantees--provide transportation

services

• Of these, 64 percent of grantees

reported having completely finished

implementing the regulations

• Of the 36 percent reporting that they 

were not finished, about half were

almost done while the remaining were

either half-way done, less than half-way 

done, or not sure.
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24

Objective 2: Reasons Why Some Grantees Are Not 

Finished With Implementation Are Unknown

• Of the 36 percent that reported they were not finished with

implementing the regulations, approximately 30 percent reported 

operating under a waiver or extension for the restraint or monitor 

requirement, or both.

• We cannot fully determine from our survey data the circumstances

under which the remaining grantees—those reporting that they were

not finished implementing the regulations but did not report

obtaining an extension or waiver-- are operating. 
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25

Objective 2: Most Grantees Primarily Use Vehicles

That Meet Head Start Regulations

• About 97 percent of grantees

reported primarily using vehicles

that meet the Head Start

regulations—93 percent reported

using school buses and 4 percent 

reported using the alternative

vehicles

• Others primarily used transit buses

(less than 1 percent), vans (1

percent), or other (2 percent)
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26

Objective 2: Challenges in Using Alternative Vehicles

• While only 4 percent of grantees reported using an alternative vehicle, this option was 

offered so that grantees and their transportation partners—especially transit 

agencies--could meet both the Head Start requirements and other requirements

governing the transport of other populations such as older adults or people with 

disabilities.

• The alternative vehicle presents challenges for transit agencies and other providers 

because the focus of NHTSA’s standards is safety in general and they do not 

specifically address other features, such as ADA requirements, that would facilitate 

transporting other populations

• Transit industry officials indicated that the alternative vehicle would be difficult

for other populations, such as older adults or people with disabilities, to use 

because they were very similar to a school bus in terms of aisle width, high-back

seats, and high steps 

• DOT officials in a state that has made extensive efforts in the past to coordinate

human services transportation indicated that the requirement that the

alternative vehicle have compartmentalized seating made it difficult for older

adults and people with disabilities to comfortably use the seats

• Transit officials have also indicated that other features of the bus, such as the 

narrow, high steps in the alternative vehicle made it difficult for older adults and

people with disabilities to use
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27

Objective 2: Challenges in Using Alternative 

Vehicles

• No guidance exists to identify allowable changes to the alternative vehicle 

to accommodate populations such as older adults and people with 

disabilities

• Officials at one school bus manufacturer that makes the alternative 

vehicle saw the Head Start population and the transit population as two

very distinct populations and did not see how the alternative vehicle 

could be used for transit 

• A transit provider and school bus manufacturer indicated that

manufacturers are reluctant to modify the alternative vehicle for transit

use without guidelines from DOT because of concerns about liability if 

they alter a bus considered to be a category of school bus

• FTA identified one transit provider that was using the alternative vehicle for

transit

• This provider independently researched how to incorporate ADA

requirements such as overhead handrails and supports

• Although the manufacturer was initially reluctant to modify the vehicle 

to incorporate these features, the transit provider’s research ultimately

convinced the manufacturer that they were acceptable
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28

Objective 2: Steps Reported by Grantees to

Implement the Restraint Requirement

• Grantees took a variety of actions to implement the restraint 

requirements, most often through buying restraints and retrofitting

vehicles with them.
ENCLOSURE II ENCLOSURE II 

29

Objective 2: Steps Reported by Grantees to 

Implement the Monitor Requirement

• While grantees reported taking various steps to implement the 

monitor requirement, over half reported already having monitors in 

place.

Page 44 GAO-06-767R Head Start Transportation
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30

Objective 2: Fewer Grantees in 2006 Than

2004 Are Requesting Extensions

• Based on GAO’s analysis of extension request documentation submitted to the Head

Start Bureau (shown on slide 31),

• the percent of grantees requesting more time to implement the restraint and 

monitor requirements dropped from 30 percent in 2004 to 19 percent in 2006.

• Numbers may be understated because extension requests had to be calculated

against the total number of Head Start grantees, not just those offering transportation.

• In 2004 and 2006, requests for time extensions to implement the restraint

requirement have outnumbered the monitor requirement; however, about one- third of those seeking extensions sought more time to implement both in 2004, while around half did so in 2006.

• The 2004 interim final rule and 2005 appropriations act provision authorized Head

Start to waive the requirements for restraints and monitors for those grantees who

requested more time to implement these provisions, but did not specifically authorize

similar actions for the vehicle requirement.

1

1See page 29 for information on recently enacted changes to compliance dates for vehicles, restraints,

and monitors.
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31

Objective 2: Fewer Grantees Are Requesting 

Extensions
ENCLOSURE II ENCLOSURE II 

32

Objective 2: Cost of Implementing the Requirements

Was Major Reason for Extension Requests

In both 2004 and 2006, the cost of implementing the restraint or monitor

requirements was the reason most often given by grantees for requesting

extensions, but non-cost reasons have become almost as common in 

requests for extensions to implement the restraint requirement.

Page 47 GAO-06-767R Head Start Transportation
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33

Objective 2: Head Start Approved Extension 

Requests with Few Exceptions

• In 2004, the Bureau approved all extension requests, including those 

that were submitted up to a month or two after the March 2004

deadline; denied only those requests that came in a few months or a 

year after the deadline, and could no longer be processed 

• In 2006, the Bureau approved all extension requests made by school 

systems and all others except extension requests in meeting the

• child safety restraint requirement for children who were not 

being transported on school buses

• child safety restraint requirement for Early Head Start 

children

• bus monitor requirement for children being transported on 

public vehicles where they are sharing rides with non-Head

Start populations 
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34

Objective 2: Head Start Lacks System for 

Considering Waiver Requests

• The waiver process provided in 45 C.F.R. § 1310.2(c) is intended to be

available for grantees to present special circumstances for the Bureau’s

consideration, but the Bureau does not have a clearly defined process for

tracking or reviewing them. Specifically, 

• Bureau officials stated that they have not outlined a process or specific

criteria defining “good cause” for when adherence to a requirement

would create a safety hazard and thus demonstrate cause to grant a

waiver

• We found 12 waivers submitted to the Bureau for review—some of

which were denied--but Bureau officials stated that they were unaware 

of any waivers that were submitted; one grantee reported submitting a 

waiver but never receiving a response

• Three grantees and staff in 4 regional offices whom we interviewed were

not sure about what the waiver process was, how it differed from the 

extension process, and when and by whom requests were approved or

denied
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35

Objective 3: Grantees Must Plan for Vehicle 

and Restraint Costs in the Future

• Bureau and Regional officials stated that grantees are now expected to pay for

replacing vehicles out of annual operating monies or nonfederal sources.

• Head Start historically funded such costs, in addition to other priorities, with

supplemental money called Program Improvement (PI) funds1

• Grantees received approximately $76 million in PI funding for vehicles and

restraints between FY01-05,2 with about 85 percent awarded for vehicles3

• Staff from some Regional offices stated that they only partially funded the cost

of buses prior to 2005 and required grantees to finance the remainder

• Grantees are allowed to receive PI funding for restraints, but Head Start guidance

states that fiscal year 2006 will be the last year this funding will be awarded in the

foreseeable future

• 1PI funds are monies reallocated from grantees who have not used all of their funding to other grantees who are requesting additional funds that meet the Bureau’s priorities established for these monies. 2The Head Start Bureau did not award fiscal year 2005 PI funds. 3This figure only represents the amount of PI funding that was provided to help grantees to implement some provisions of the transportation regulations; it does not represent the total amount of PI funding awarded by Head Start for these years.
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36

Objective 3: Vehicle Costs Driven by Size,

Options, and Purchase Method

• Costs of vehicles vary depending on factors such as passenger capacity,

weight, types of seats, wheel chair lifts, air-conditioning and other items

specified by the buyer, as well as how they are purchased

• Price discounts---which could amount to $3,000-$6,000 per vehicle-- are 

offered by some manufacturers when a certain number of buses is

purchased

• Some grantees were able to purchase vehicles at reduced cost through 

collaboration with school systems or other transportation partners
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37

Objective 3: Types and Costs of Restraints 

Vary

• Grantees have a variety of restraints from which to choose

• Cost of restraints vary by type1

• Integrated restraints (e.g.,those built into the seat) tend to be

more expensive than those added to the bus later

• Information gathered by GAO shows price ranges for 

• Integrated restraints cost approximately $350-$773 (per

seat)

• Add-ons cost approximately $55-$200 (per restraint)

1

Our data only reflects the costs of the restraints and not the additional costs of retrofitting the bus in cases where 

that would be necessary.
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Objective 3: Some Grantees Found Ways to 

Pay Less for Vehicles

• Pullman, WA: Head Start grantee paid less for a bus by partnering with

local Area Office on Aging (AoA)

• AOA secured 80 percent of the cost through FTA funding 

• Grantee’s share was only $11,000 

• Vehicle was built to meet Head Start requirements and ADA

requirements for other populations, such as older adults and people 

with disabilities

• Westfield, MA: Head Start grantee used nonfederal funds to buy buses

• Received funding from the Community Partnership for Children grants

awarded by the Massachusetts Department of Education

• Community Partnership grants can be used for a variety of purposes

including transportation
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Objective 3: Some Grantees Found Ways to

Pay Less for Vehicles

• Renton, WA: The Head Start grantee partners with school 

systems that own and operate school buses to transport 1,200

Head Start children

• Grantee “piggy-backs” on the school systems’ specifications 

for school bus orders, modifying them to reflect the grantee’s 

needs

• School systems receive state funding to buy school buses 

• Cost to grantee for buses is any amount that exceeds basic

state funding for a school bus
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Objective 3: Regulations Have Some Cost Effects on Grantees, But

They Also Report Other Budgetary Pressures

• A majority of grantees who provided transportation reported having, at most, moderate cost 

effects associated with implementing the vehicle, restraint, and/or monitor requirements.

1

• However, a significant portion of grantees—approximately 44 percent—reported large to very large cost effects for at least one or more of these provisions

• Grantees we visited and some regional officials stated that other costs, such as health insurance,

are affecting their budgets as much or more than costs incurred from the transportation 

regulations

1We note that it is difficult to separate the effect of the transportation regulations on grantees’ overall costs from changes in other factors that affect grantee costs, such as changes in capital funds provided, labor or health costs.
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Objective 3: Regulations Have Some Cost Effects on

Grantees

• In looking at the cost effects reported by grantees on their

transportation budgets for the vehicle, restraint, and monitor

provisions separately, we found that

• Monitors were cited more often as having the smallest or no 

cost effect

• Restraints and vehicles were cited more often as having a large 

or very large cost effect
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Objective 3: Examples of Effects on Grantee Costs

Jefferson County, Kentucky: The grantee stated that the public school system 

transports around 5,000 preschool children a day—approximately 1,900 are Head 

Start children—on large buses. They estimated that retrofitting integrated restraints

into 402 buses that transport the preschoolers will cost the school system

approximately $6 million (parts and labor), and indicated that this cost would force

them to stop providing transportation services to Head Start.

Renton, Washington: The grantee noted that adding bus monitors to transport approximately 1,800 Head Start children cost the grantee around $420,000 in program year 2005. The grantee absorbed these costs by closing classrooms and cutting staff 

classroom hours, among other things, but also noted benefits in having monitors on 

buses in the event of problems

Greencastle, Indiana: The grantee reported using volunteers to meet the bus 

monitor requirement and “paid” them with $10 gift cards from Wal-Mart. According to the grantee, the cards cost approximately $34,000 in program year 2003; these costs

were absorbed by cutting an administrative staff position from the budget. The gift

cards helped maintain an adequate number of volunteers.
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Objective 3: Regulations Led Many Grantees 

To Change Transportation Services

• Overall, 58 percent of the estimated 1,370 grantees providing 

transportation reported at least one of the following effects 

on their transportation services as a result of implementing

the regulations:

• changing routes 

• reducing transportation previously provided

• changing how transportation is provided, such as using a 

new contractor

• discontinuing services altogether 
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Objective 3: Regulations Led Many Grantees

to Change Transportation Services

• The top two effects on transportation services that grantees

reported as a result of implementing the regulations were changes to

transportation routes and reduction in transportation services.
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Objective 3: Regulations Led Many Grantees

to Change Program Operations

• An estimated 67 percent of the 1,370 Head Start grantees who provide transportation noted at

least one effect on program operations as a result of implementing the regulations 

• Looking at each specific effect, over one-half of grantees cited having to increase the number of

staff and staff hours while approximately half also reported changing or eliminating other services 

and reducing staff hours in the classroom

• About one-third also reported that the regulations increased parents’ satisfaction with

transportation
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Objective 3: Some Grantees Contracting for

Transportation Services Reported Problems

with Continuing Transportation

• 36 percent of the grantees providing transportation reported that at least

some of their program sites contract or use another organization to

transport their children. 

• For the 36 percent who contract

• About a quarter reported the contractor could not currently continue

the partnership (8 percent of all grantees providing transportation); 

• 39 percent reported the contractor will not continue providing

transportation in program year 2006/2007 (14 percent of all grantees

providing transportation)
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Objective 3: Some Transit Agencies Report 

Difficulties Sustaining Head Start Partnerships

• Iowa: State law requires coordination among human services programs

• Iowa requires that transit buses used to transport children must meet some but not all of NHTSA crashworthiness standards that apply to school buses; thus these buses don’t comply with the Head Start transportation regulations 

• Before the regulations, 14 of 15 state DOT regions provided transportation to grantees; 9 of these have since

discontinued or plan to discontinue some or all services to grantees

• The regulations led Head Start grantees in Iowa to either

• Purchase school buses or alternative vehicles; some transit agencies operate these buses for grantees 

• Reduce or eliminate transportation services, or

• Rely on school districts

• Iowa DOT officials stated that the loss of funding from Head Start grantees had resulted in some regional transit agencies reducing services, raising costs, or both for other groups they serve, such as older adults or people with

disabilities

• FTA officials confirmed that this loss of funding has similarly affected the cost and level of services other transit agencies provide
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Objective 3: Some Transit Agencies Report 

Difficulties Sustaining Partnerships

Michigan and Pennsylvania: 

• Transit agencies were using transit buses that met FTA’s standards and had 

restraints. However, officials were not certain whether the buses met NHTSA’s

school bus standards

• The restraint requirement has affected the number of children transit agencies can

transport 

• Transit officials also said that seats with restraints are uncomfortable and impractical

for the adults and people with disabilities that they serve, requiring different buses to

transport them

• Officials in charge of these agencies told us that older adults have difficulty

exiting seats because of additional padding

• One of these officials also told us that the buses used for Head Start have

impacted the cost and quality of service provided to other customers, and that

the seats have been difficult to maintain and keep clean

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Objective 3: Examples of Grantees Having

Difficulties Sustaining or Developing Transportation 

Partnerships

Michigan: One grantee that serves 21 counties (13,000 sq. miles) 

and transports about 700 children had partnered with the public 

schools to transport around a quarter of the children. The grantee

stated that the schools can no longer do it because of the restraint 

requirement. As a result, the grantee plans to discontinue some

transportation services if it cannot find another partner. 

Independent Transportation Contractors: For some Head Start 

grantees, contracting with an independent transportation provider

may not be an option. Contractors reported that they need a critical

mass of children to make a contract economically feasible for both 

parties. Typically contractors work best with very large grantees or

those connected with school systems. 
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Glossary

• Head Start requirements: requirements outlined in the Head Start 

transportation regulations

• NHTSA school bus standards – safety standards NHTSA issues to

protect children on and around a school bus. 

• “Crash-worthiness” standards offer protection in the event of an 

accident and include rollover and fuel tank protection, joint 

strengthening, and a system of closely spaced and padded seats,

commonly referred to as compartmentalization. 

• Traffic control standards are intended to help prevent accidents, 

and include requirements that the bus have stop arms and 

flashing lights.
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Glossary

• Large School Buses: exceed 10,000 pounds, seat between 24 – 84 children

• Often used for school age children, but also transport preschool

children. 

• Bus size and design absorbs the force of a crash, thus NHTSA does not 

require restraints in these buses for older children

• Compartmentalized design is intended to offer protection in the event 

of a crash.

• Small School Buses: less than 10,000 pounds; seat no more than 24 children 

• Often used for preschool children. 

• NHTSA requires lap belts because the smaller size does not absorb the

force of a crash as well as a large bus and lap belts reduce the chance 

of a child being ejected.
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Glossary

• Allowable Alternate Vehicle: sub-category of school bus that meets all crash

worthiness standards but not traffic control standards. 

• Created for use by public transit agencies that transport children to

Head Start so they could still serve the needs of others who use public

transit. 

• Sizes vary, but similar to school buses. 

• Lap belts required on small vehicles but not on large vehicles.

• Public Transit Buses: used by public transit agencies in cities, small 

communities, and rural areas. Size and design varies, depending on needs

of the population served, which can include the general public, older adults, and people with disabilities.

• Buses must meet NHTSA standards for buses, pass FTA’s performance 

testing at Altoona, PA testing facility, and comply with Americans with

Disabilities Act. 

• Buses are not required to meet NHTSA school bus standards or

undergo crash testing and most cannot accommodate child safety 

restraints.
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Glossary: Pictures of Buses
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Glossary

• Child safety restraints – Designed to keep children in their seats and protect 

from injury in the event of a crash. They can take various forms and offer a 

range of protection:

• Harnesses and vests – Worn over child’s shoulder and torso. Restraint 

is attached to bus seat and seat back to keep child in place in the event

of a crash

• Convertible seat – Placed on bus seat and attached using seat belt. Child is restrained in seat

• Booster seat – Placed on bus seat and secured with a lap/shoulder belt. Built-in harnesses are used to secure child

• Integrated child safety seat – Restraint is built into bus seat and folds

out for use. It is folded back up when older child or adult uses the seat.
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Glossary: Pictures of Restraints
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