Department of Health and Human Services


OFFICE OF 

INSPECTOR GENERAL 

ENROLLMENT LEVELS 


IN HEAD START


Daniel R. Levinson


Inspector General 


April 2007


OEI-05-06-00250

Office of Inspector General 
 http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, 

as amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The Office of Audit Services (OAS) provides all auditing services for HHS, either by 

conducting audits with its own audit resources or by overseeing audit work done by others. 

Audits examine the performance of HHS programs and/or its grantees and contractors 

in carrying out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations. These assessments help reduce waste, 

abuse, and mismanagement and promote economy and efficiency throughout HHS. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 

HHS, Congress, and the public with timely, useful, and reliable information on 

significant issues. Specifically, these evaluations focus on preventing fraud, waste, or 

abuse and promoting economy, efficiency, and effectiveness in departmental programs. 

To promote impact, the reports also present practical recommendations for improving 

program operations. 

Office of Investigations 

The Office of Investigations (OI) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries 

and of unjust enrichment by providers. The investigative efforts of OI lead to criminal 

convictions, administrative sanctions, or civil monetary penalties. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support in OIG's internal operations. OCIG imposes program exclusions and civil 

monetary penalties on health care providers and litigates those actions within HHS. 

OCIG also represents OIG in the global settlement of cases arising under the Civil False 

Claims Act, develops and monitors corporate integrity agreements, develops compliance 

program guidances, renders advisory opinions on OIG sanctions to the health care 

community, and issues fraud alerts and other industry guidance. 
ΔINTROD UCT ION

 EXECUTIVE SUMMAR Y 

OBJECTIVES 

1. To determine the enrollment levels of Head Start grantees. 

2. To describe grantees’ challenges to maintaining full enrollment. 

3. To assess the Administration for Children and Families’ (ACF) 

monitoring of enrollment. 

4. To assess ACF’s enforcement of full enrollment. 

BACKGROUND 

Established in 1964, Head Start is a nationwide program designed to 

increase school readiness in children from low-income families. Within 

ACF, the Office of Head Start administers Head Start. In fiscal year 

(FY) 2005, ACF provided $6.8 billion in funding to grantees for 

approximately 900,000 Head Start children. Grantees are local public 

agencies, private organizations, Native American tribes, and school 

systems. 

To determine the enrollment levels of Head Start grantees, we analyzed 

attendance data from 200 randomly sampled grantees. We also 

surveyed sampled grantees and ACF staff regarding challenges to 

maintaining full enrollment. To assess ACF’s monitoring of enrollment 

levels, we reviewed the accuracy of the enrollment data reported by 

grantees. To assess ACF’s enforcement of full enrollment, we 

interviewed grantees and ACF staff. 

FINDINGS 

Almost all Head Start grantees had high enrollment levels. In the 

2006 program year, 40 percent of grantees were fully enrolled. 

Eighty-one percent of Head Start grantees had enrollment levels of 

95 percent or higher. Enrollment levels by grantee ranged from full 

enrollment to a low of 68 percent. 

Overall, this translated into 5 percent of Head Start slots that were 

funded but not filled. Head Start slots that are funded but not filled 

equal Federal dollars that are inefficiently used. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART i 
EXE CUTIVE S CUTIVE S U MMAR Y

Grantees cited challenges to maintaining full enrollment. Grantees 

cited the requirement to fill 90 percent of Head Start slots with very 

low-income children, competition with State and locally funded 

prekindergarten programs, and transportation issues as the biggest 

challenges to maintaining full enrollment. 

ACF’s monitoring of enrollment levels may rely on inaccurate data. 

For the 2006 program year, only 11 percent of grantees reported to ACF 

actual enrollment levels that matched the actual enrollment levels we 

determined based on attendance records. We also question the ability of 

26 percent of grantees to maintain accurate attendance records and 

thus their ability to determine enrollment accurately. 

ACF’s enforcement of full enrollment has increased overall but 

varies by region. ACF has increased its practice of reducing or 

withholding funds to grantees not at full enrollment. However, 

reductions varied greatly by region. In particular, there were variations 

among regions in the levels of underenrollment that prompted funding 

reductions and the amounts of the reduction. ACF has also increased 

its supplemental monitoring and is providing additional technical 

assistance to grantees. 

RECOMMENDATIONS 

Based on the results of our review, ACF should: 

Address grantee challenges to maintaining full enrollment. ACF 

should focus particular attention on the challenges identified in this 

report: the requirement that grantees fill 90 percent of slots with 

children from very low-income families, competition with State and 

locally funded prekindergarten programs, and transportation issues. 

Ensure that enrollment data are accurate. To help ensure the 

accuracy of reported enrollment data, ACF should work with grantees to 

facilitate the maintenance of accurate attendance records and provide 

Program Information Report training to grantees. 

Issue guidance concerning the use of funding reductions for 

grantees not at full enrollment. To ensure consistent enforcement of 

the full enrollment requirement, ACF should clarify guidelines to 

regional offices concerning the level of enrollment that warrants a 

funding reduction. ACF should also issue guidance concerning the 

calculation of funding reductions and the process of negotiating funding 

reductions with grantees. 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S I N HEAD S TART ii 
EXE CUTIVE S U MMAR Y

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

ACF indicated general support for our recommendations. However, 

ACF pointed out problems with two suggestions we offered on how our 

recommendation to address grantee enrollment challenges regarding 

the requirement that grantees fill 90 percent of slots with children from 

very low-income families might be implemented. We continue to 

recommend that ACF address grantees’ reported challenges to 

maintaining full enrollment, including challenges related to the 

income-eligibility guidelines. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART iii 
Δ T ABLE OF CONTENTS 

EXECUTIVE SUMMARY ..................................... i

INTR O D U C T I ON ........................................... 1

FINDI NGS ................................................ 10

Almost all grantees had high enrollment.................... 10

Grantees cited challenges to maintaining full enrollment ...... 11

ACF’s monitoring may rely on inaccurate data . .............. 13

ACF’s enforcement increased but varied . ................... 15

RECOM M E NDATI O NS ..................................... 18

Agency Comments and Office of Inspector General Response . . . 19 

APPENDIXES ............................................. 20

A: Detailed methodology ................................ 20

B: Estimates and confidence intervals ..................... 23

C: Agency Comments ................................... 26

ACKN O W LEDGMENTS .................................... 29
ΔINTROD UCT ION

 INTRODU C TION 

OBJECTIVES 

1. To determine the enrollment levels of Head Start grantees. 

2. To describe grantees’ challenges to maintaining full enrollment. 

3. To assess the Administration for Children and Families’ (ACF) 

monitoring of enrollment. 

4. To assess ACF’s enforcement of full enrollment. 

BACKGROUND 

Head Start 

Established in 1964, Head Start is a nationwide grant program 

designed to promote school readiness in children from low-income 

families. Head Start services include early childhood education; 

medical, dental, and mental health care; nutritional services; and efforts 

to encourage parental involvement. 

Within ACF, the Office of Head Start (OHS) administers Head Start. 

OHS administers four Head Start programs: the Head Start program, 

the Early Head Start program, the American Indian–Alaska Native 

Head Start program, and the Migrant and Seasonal Head Start 

program. In fiscal year (FY) 2005, ACF funded approximately 

900,000 slots for children, with the majority (800,750) of slots awarded 

to the Head Start program and the American Indian–Alaska Native 

Head Start program. We limited our study to these two Head Start 

programs, hereafter referred to as Head Start. 

ACF awards Head Start funds directly to grantees. Grantees are local 

public agencies, private organizations, Native American tribes, and 

school systems. In FY 2006, ACF awarded funds to 1,405 grantees. 

Many Head Start grantees contract out the operation of services to 

delegate agencies that operate programs at the community level. 

Head Start Eligibility 

Head Start serves children from age 3 through the State mandatory school 

age (generally age 5). Head Start services are available to families who 

meet any of the following four criteria: 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 1 
INTROD UCT ION

o The family income is at or below the poverty line (in FY 2006, 

$20,000 for a family of four)1; 

o The family receives Social Security Income (SSI) benefits; 

o The family receives benefits or services on a regular basis2 through 

Temporary Assistance for Needy Families (TANF); or 

o The family cares for a foster child. 

At least 90 percent of children enrolled by each Head Start grantee 

must be from low-income families. Head Start grantees may enroll 

children from families with incomes above the poverty line so long as 

they do not exceed 10 percent of total enrollment.3 Grantees must also 

offer 10 percent of their slots to children with disabilities, regardless of 

income.4 

Head Start Funding 

Grantees’ base funding is their historical funding amount from 1998. 

Additional funds are determined using a formula based on the number 

of children under age 5 living in poverty in each State.5 Funding for all 

four programs of Head Start was $6.8 billion in FY 2005.6 

Head Start funding covers not only the costs of program services 

(e.g., health services, teacher salaries, parent involvement services) but 

also administrative costs, including organizationwide management 

functions of accounting, budgeting, coordination, direction, and 

planning; as well as the management of payroll, personnel, property, 

and purchasing.7 Because grantee funding covers both direct and 

indirect costs, ACF does not compute funding using a predetermined 

per-child formula. 

Once ACF awards funds to a Head Start grantee, the funding continues 

until the grantee relinquishes the grant or ACF terminates it for cause. 

1 Annual update of the Department of Health and Human Services Poverty Guidelines, 

71 Federal Register 3848 (January 24, 2006). 

2 ACF Program Instruction, “Receipt of Public Assistance and Determining Eligibility for 

Head Start” (ACYF-PI-HS-99-06), July 29, 1999. 

3 45 CFR § 1305.4(b)(2). A Head Start grantee operated by an Indian tribe may enroll up 

to 49 percent of its children from families whose income exceeds the low-income guidelines 

under certain conditions specified in 45 CFR § 1305.4(b)(3). 

4 Section 640(d) of the Head Start Act, 42 U.S.C. § 9835(d), and 45 CFR § 1305.6(c). 

5 Section 640(a)(4) of the Head Start Act, 42 U.S.C. § 9835(a)(4). 

6 Consolidated Appropriations Act, 2005, Pub. L. No. 108-447. 

7 45 CFR § 1301.32(b) and (c).

OE I-05-06-00 250 E N R O L L M E N T L E V E L S I N HEAD S TART 2 
INTROD UCT ION 

After ACF grants the initial award, the grantee submits a 

noncompetitive continuation application for subsequent budget periods.8 

Grantees are generally required to match 20 percent of their Head Start 

grant award with non-Federal funds.9 According to ACF, most grantees 

fulfill this requirement through in-kind donations (e.g., subsidized 

space, volunteer staff); however, some grantees fulfill this requirement 

using State funds. 

Enrollment Requirements 

ACF assigns each grantee a specific number of children it is required to 

serve, known as the funded enrollment. In negotiating how many Head 

Start children a grantee will serve, ACF considers variation in grantee 

services and locality costs. By accepting their annual Head Start grant 

award, grantees agree to serve the number of children assigned.

10 

Head Start regulations require grantees to maintain enrollment at 

100 percent of the funded enrollment level.11 If a child stops attending 

Head Start, the grantee must establish that a vacancy exists. No more 

than 30 calendar days may elapse before the grantee fills the vacancy; 

otherwise, ACF considers the grantee underenrolled. ACF refers to a 

vacancy left open more than 30 days as an “enrollment vacancy.” If 

fewer than 60 days remain in the grantee’s program year at the time an 

enrollment vacancy occurs, the grantee can choose not to fill the vacancy 

without ACF considering it underenrolled. 

To facilitate prompt filling of vacancies, Head Start regulations require 

each grantee to maintain a waiting list that ranks children according to 

its selection criteria and to select those with the greatest need for Head 

Start services.12 

Monitoring Enrollment 

Nationally, ACF monitors Head Start enrollment through the Program 

Information Report (PIR) and the Program Review Instrument for 

8 ACF, “Application and Grant Award Process.” Available online at 

http://eclkc.ohs.acf.hhs.gov/hslc/Program%20Design%20and%20Management/Fiscal/Gran 

t%20Award%20Process/Grant%20Award%20Process/fiscal_pub_00154a_080905.htm. 

Accessed on January 9, 2007. 

9 Section 640(b) of the Head Start Act, 42 U.S.C. § 9835(b), and 45 CFR § 1301.20. 

10 45 CFR § 1305.2(f). 

11 45 CFR § 1305.7(b). 

12 45 CFR § 1305.6. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 3 
INTROD UCT ION

Systems Monitoring (PRISM). Regional and branch offices monitor 

enrollment through ongoing contact with grantees in their regions. 

Federal regulations require grantees to “establish and implement 

procedures for ongoing monitoring.”13 Grantees use PIR software to 

self-report enrollment, demographic, and performance data to ACF. 

Grantees report a variety of information, including their funded 

enrollment and actual enrollment levels. Two studies from the Office of 

Inspector General (OIG), “Status of Efforts To Increase Qualifications of 

Head Start Teachers” and “Head Start Services for Children With 

Asthma,” cited concerns related to PIR data.14 These reports noted that 

grantees receive little training or guidance about completing the PIR 

and questioned the usefulness of PIR data. 

In 2003, the Government Accountability Office (GAO) found that ACF 

could not determine the level of enrollment in Head Start from PIR data 

because of inaccuracies in the database and reporting delays.15 GAO 

also noted that data often arrived after the beginning of the subsequent 

program year and that ACF allowed grantees to select the 2 months for 

which they provided enrollment figures. 16 

In 2006, ACF addressed some of these issues. Specifically, ACF now 

requires grantees to report enrollment levels for 3 specified months. 

Additionally, grantees must submit their enrollment data for these 

3 months as soon as each month has ended.17 

PRISM is a standardized instrument used by ACF staff to conduct 

comprehensive reviews of Head Start grantees. Each Head Start 

grantee receives a PRISM review every 3 years. This intensive, 

weeklong review covers all aspects of grantees’ performance, including 

enrollment. Using PRISM, reviewers calculate a grantee’s enrollment 

by counting the number of children enrolled during the week of their 

onsite review. 

13 45 CFR § 1304.51(i)(2). 

14 “Status of Efforts To Increase the Qualifications of Head Start Teachers” 

(OEI-07-01-00560), 2004; and “Head Start Services for Children With Asthma” 

(OEI-09-01-00330), 2002. 

15 “Head Start: Better Data and Processes Needed To Monitor Underenrollment,” 

(GAO-04-17), p. 2. 

16 Ibid, p. 14. 

17 ACF Information Memorandum, “On-line Reporting Beginning in November, 2006” 

(ACF-IM-HS-06-04), September 12, 2006. 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 4 
INTROD UCT ION

Enforcing Full Enrollment 

Maintaining full enrollment was a major focus of the 2004 Head Start 

Management Initiative.18 The initiative reiterated the regulatory 

definition of underenrollment as anything less than 100 percent 

enrollment. The initiative stated that ACF would hold systematic, 

periodic discussions with grantees related to enrollment. 

Head Start regulations and guidance specify that grantees that do not 

maintain full enrollment may be referred for technical assistance or 

may face a reduction in funding, denial of refunding, or termination of 

financial assistance. 19 Regulations and guidance do not specify the 

amount of the reduction.

20 ACF reports that most reductions are 

subject to negotiations between the regional offices and grantees. 

Head Start regulations state that ACF can terminate a grant or deny 

refunding if a grantee received a deficiency because of underenrollment 

and failed to correct the deficiency.21 In addition, ACF guidance states 

that ACF can decrease funding in situations in which enrollment issues 

are caused by changing demographics that have resulted in insufficient 

numbers of eligible children in a grantee’s service area.22 

An amendment to the Head Start Act was proposed, but not enacted, 

during the 109th Congress that would have required grantees to report 

their enrollment to the Secretary of Health and Human Services, who 

then would have been required to develop plans to reduce or eliminate 

underenrollment for any grantee less than 95-percent enrolled. The bill 

also provided for the recapture, reduction, or withholding of a portion of 

a grantee’s basic grant in the case of chronic underenrollment.23 

18 Head Start Management Initiative, 2004. Available online at: 

http://eclkc.ohs.acf.hhs.gov/hslc/Program%20Design%20and%20Management/Fiscal/Manag 

ement%20Initiatives/Accountability/fiscal_rep_00058_061605.html. Accessed on 

January 9, 2007. 

19 45 CFR §§ 1304.60, 1304.61, and 1305.10; ACF Program Instruction, “Achieving and 

Maintaining Full Enrollment” (ACYF-PI-HS-04-03), November 30, 2004. 

20 Ibid. 

21 45 CFR §§ 1304.60, 1304.61, and 1305.10. 

22 “Achieving and Maintaining Full Enrollment” (ACYF-PI-HS-04-03). 

23 School Readiness Act of 2005, H.R. 2123, 109th Cong., § 8(f) (as passed by the 

U.S. House of Representatives, October 25, 2005). 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 5 
INTROD UCT ION

Hispanic Families 

Although Hispanic families compose 14 percent of the population 

nationwide, Hispanic children represent 22 percent of the population 

under 5 years of age.24 Twenty-two percent of the Hispanic population 

lives in poverty, and almost one-third of Hispanic children under age 

5 lives in poverty.25 Concerns have been raised that grantees in areas 

with recent growth in Hispanic population may have difficulty 

recruiting these families because of cultural and linguistic issues. 

METHODOLOGY 

To determine the enrollment levels of Head Start grantees, we analyzed 

attendance data from 200 grantees randomly selected from a stratified 

sample. For grantees’ 2005–2006 operating period,26 hereafter referred 

to as the 2006 program year, we compared grantees’ actual enrollment 

to their funded enrollment. We also surveyed sampled grantees and 

ACF staff regarding challenges to maintaining full enrollment. See 

Table 1 for the definitions of key terminology used when discussing 

grantee enrollment levels. 

Table 1: Key Terminology 

Attendance 

data 

A grantee’s daily record of children who are present. If a child does not 

attend for 30 consecutive days, the child is no longer considered enrolled. 

Actual 

enrollment 

The number of children enrolled with the grantee as of the end of a 

month. 

Funded 

enrollment 

The number of children the grantee is funded to enroll, as 

determined by ACF and as stated in the grantee’s application. 

Source: OIG summary of key terminology, 2006. 

To assess ACF’s monitoring of enrollment levels, we reviewed the 

accuracy of PIR enrollment data and attendance records submitted by 

grantees. To assess ACF’s enforcement of full enrollment, we 

interviewed ACF staff and grantees. Lastly, we reviewed all Head Start 

laws, regulations, and policies pertinent to enrollment. 

24 U.S. Census Bureau, Current Population Survey, Annual Social and Economic 

Supplement, 2005. These figures were generated using the Microdata Access, Current 

Population Survey Table Creator. Available online at 

http://www.census.gov/hhes/www/cpstc/cps_table_creator.html. Accessed on 

January 9, 2007. 

25 Ibid. 

26 Operating period is defined by the grantee’s contract, and the months covered can 

differ by grantee. 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 6 
INTROD UCT ION 

Below we provide a basic description of our methodological approach. 

See Appendix A for a more detailed description of our methodology. 

Sample 

This study determines the enrollment levels for Head Start grantees in 

the 50 States and Washington, DC, hereafter referred to as the 

51 States. As previously stated, we excluded grantees from the Early 

Head Start and Migrant and Seasonal programs. We excluded Early 

Head Start grantees because this is a much smaller program that, 

according to ACF staff, does not face the same enrollment challenges. 

We excluded the Migrant and Seasonal program grantees because they 

face a unique set of logistical, recruitment, and enrollment challenges 

not typical of other grantees. 

We also excluded 28 grantees in American Samoa, Guam, the Northern 

Mariana Islands, Puerto Rico, and the Virgin Islands because the 

U.S. Census Current Population Survey does not capture Hispanic data 

for these locations and we therefore could not stratify grantees in these 

areas appropriately. The exclusion of these 28 grantees brought our 

study population to 1,377 grantees. We randomly selected 200 grantees 

out of the 1,377 grantees in the 51 States. 

To assess enrollment issues related to the shifting Hispanic population, 

we stratified our sample according to recent growth in the Hispanic 

preschool-age population using U.S. Census data. Grantees in counties 

where the total Hispanic population age 4 and under27 increased by 

more than 40 percent between 2000 and 2004 fell into the “Hispanicgrowth” stratum; the remaining grantees were placed in the 

“nongrowth” stratum. 28 To improve our estimates, we also stratified by 

grantee size. See Table 2 on the next page for our stratified sampling 

structure. 

27 This was the most appropriate census category available. 

28 U.S. Census Bureau, Current Population Survey, Annual Social and Economic 

Supplement, 2000–2004, Ethnicity and Ancestry Statistics Branch, Population Division. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 7 
INTROD UCT ION

Table 2: Sample Structure 

Stratum 

Number Stratum Description 

Grantee 

population 

Number of 

grantees 

selected 

Number of 

grantees whose 

attendance data 

were reviewed 

1 Small grantees (funded enrollment <=1,600) 211 65 58 

2 Large grantees (funded enrollment >1,600) 10 10 10 

3 Small grantees (funded enrollment <=600) 908 55 49 

4 Medium grantees (funded enrollment 601–6,000) 241 63 56 

5 Large grantees (funded enrollment >6,000) 7 7 6 

Hispanic-growth grantees 221 75 68 

Nongrowth grantees 1,156 125 111 

Total 1,377 200 179 

Data Collection 

We obtained data for this study from grantee attendance records, 

grantee surveys, and interviews with ACF staff. We also obtained 

2006 program year PIR data. 

We requested 3 months (November 2005 and January and April 2006) of 

attendance records from sampled grantees. We selected these 3 months 

after consulting with grantees in pretest interviews to ensure that these 

months were representative of enrollment during the rest of those 

years.29 

Although our request for attendance data yielded a response rate of 

93 percent, we reviewed attendance data for 90 percent (179 of 200) of 

sampled grantees. We did not review all attendance records we received 

because some grantees did not include attendance data for all of their 

delegate agencies, or they submitted such a large volume of paper 

attendance records that we could not analyze them within the 

timeframe of the study. 

In June 2006, we surveyed grantees to ascertain their difficulty in 

maintaining full enrollment and to identify challenges affecting 

enrollment. Overall, our survey achieved a response rate of 95 percent 

29 We did not select the last 2 months of the program year because of the exemption that 

allows grantees to leave a vacancy open if it occurs within 60 days of the end of the program 

year. See 45 CFR § 1305.7(b). 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 8 
INTROD UCT ION

(189 of 200). We also asked ACF staff to identify challenges grantees 

face in maintaining full enrollment. 

To assess ACF’s oversight of enrollment levels, we conducted structured 

interviews with ACF headquarters staff and key staff in all 10 regional 

offices and the American Indian–Alaska Native program office 

(hereafter referred to as 11 regional offices). 

Data Analysis 

To determine grantees’ enrollment, we counted all children who 

attended at least once within each month (i.e., 30 calendar days). We 

determined the level of actual enrollment by averaging grantees’ 

attendance data over the 3 sampled months. We then compared 

grantees’ actual enrollment as determined based on attendance records 

to their funded enrollment as reported by ACF. 

To assess ACF’s monitoring of enrollment, we reviewed the accuracy of 

grantee data self-reported to the PIR and attendance records submitted 

to OIG. We compared the actual enrollment levels reported by grantees 

in the PIR to our determination of actual enrollment based on 

attendance records. We also compared grantees’ reported funded 

enrollment to the funded enrollment figures provided by ACF. Finally, 

we assessed the ability of grantees to provide us with complete, 

unduplicated attendance records based on our data request. 

Unless otherwise noted, we projected all statistics to the population of 

Head Start grantees in our study. See Appendix B for a list of 

95-percent confidence intervals for all statistical projections. 

Limitations 

Although we requested that grantees provide data for ACF-funded 

children only and pretested our instruments to ensure their validity, 

some grantees may have incorrectly submitted attendance records for 

State-funded children. However, we believe that the risk of this 

occurring is minimal because ACF regularly asks grantees to 

distinguish between ACF-funded and State-funded enrollment for the 

PIR. Further, when grantees use State funds as the 20-percent fiscal 

match, children served through these matching funds are considered 

ACF-funded children. 

Standards 

This study was conducted in accordance with the “Quality Standards for 

Inspections” issued by the President’s Council on Integrity and 

Efficiency and the Executive Council on Integrity and Efficiency. 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 9 
Δ FINDINGS

Overall, enrollment rates by 

grantees were high. Forty percent 

Almost all Head Start grantees had high 

enrollment levels 

of grantees were fully enrolled in 

the 2006 program year. Eighty-one percent of grantees had enrollment 

levels of 95 percent or higher. Ninety-one percent of grantees had 

enrollment levels in excess of 90 percent, leaving only 9 percent of 

grantees with enrollment levels less than 90 percent. See Table 3 for a 

breakdown of the enrollment levels by stratum. 

Table 3: Percentage of Grantees by Enrollment Levels 

Enrollment Levels Percentage of Grantees 

 All Grantees 

Grantees in 

HispanicGrowth Areas 

Grantees Not 

in HispanicGrowth Areas 

100% 40% 41% 40% 

≥ 95% and < 100% 41% 50% 40% 

≥ 90% and < 95% 10% 3% 11% 

Less than 90% 9% 6% 9% 

Source: OIG analysis of grantee enrollment, 2006. 

Despite grantees’ overall high enrollment levels, the Head Start 

program did experience underenrollment. Enrollment levels by 

grantees in our sample ranged from full enrollment to a low of 

68 percent.30

Nationally, an estimated 5 percent of slots were funded but unfilled 

The 5 percent of funded but unfilled slots represents approximately 

33,726 enrollment vacancies. Given the $6.8 billion cost of the Head 

Start program, less-than-full enrollment could represent ineffective use 

of considerable Federal dollars. Additionally, less-than-full enrollment 

may mean that vulnerable children are not receiving early childhood 

services for which they are eligible. 

Grantees in areas with recent growth in the Hispanic population had levels 

of enrollment similar to those of grantees in all other areas 

Concerns have been raised that grantees serving areas with a recent 

growth in the Hispanic population may have difficulty maintaining full 

enrollment because they may have difficulty modifying their 

recruitment strategies to adapt to the cultural and linguistic differences 

30 Eighteen grantees in our sample had enrollment levels lower than 90 percent, and 

three grantees were less than 70-percent enrolled. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 10 
F I NDING S 

in the shifting population. However, more grantees in the 

Hispanic-growth areas were at least 95-percent enrolled than grantees 

in all other areas. Specifically, 91 percent of grantees in 

Hispanic-growth areas were at least 95-percent enrolled, while 

80 percent of grantees in the non-Hispanic-growth areas were at least 

95-percent enrolled. This difference is statistically significant at the 

95-percent confidence level. This statistical difference implies that 

grantees serving areas with high growth rates of Hispanic children have 

higher enrollment levels. We did not evaluate grantees’ recruitment 

and enrollment of Hispanic children. 

Nine regional offices reported a growth of Hispanic families in their 

regions. None of the staff from these offices believe that the increase 

poses a challenge for enrollment. In fact, staff from two regional offices 

reported that the increase in this population helps grantees to maintain 

full enrollment; one office stated that this is because grantees in 

Hispanic-growth areas have a larger income-eligible population from 

which to enroll. Moreover, 80 percent of grantees that reported recent 

increases in Hispanic families in their service areas reported changing 

their recruitment strategies to reflect this population change. The most 

common changes to recruitment strategies were translating program 

material into Spanish and hiring Spanish-speaking staff. 

Grantees cited challenges to maintaining full Fifty-five percent of grantees

reported difficulty maintaining 

full enrollment during the 

2006 program year.31 Even among grantees with enrollment levels of 

95 percent or higher, 49 percent reported difficulty. Grantees who 

reported difficulties were asked to identify the specific challenges that 

they faced in maintaining full enrollment. Grantees cited the 

requirement to fill 90 percent of Head Start slots with very low-income 

children, competition with State and locally funded prekindergarten 

programs, and transportation issues. Many ACF regional offices also 

cited that these challenges face grantees in maintaining full enrollment. 

enrollment 

31 In our sample, 106 of 189 grantees reported difficulty maintaining full enrollment. 

The projected percentage is 55 percent of grantees. Because data are self-reported, the 

noted challenges are the grantees’ perceptions and not demonstrated reasons that grantees 

are not at full enrollment. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 11 
F I NDING S 

See Table 4 for the percentage of grantees and the number of ACF 

regional offices that cited each challenge. 

Table 4: Challenges to Maintaining Full Enrollment 

Percentage of grantees that 

reported challenge 

ACF regional offices that 

reported challenge 

Income requirements too low 71% 6 of 11 

Competition with other childcare programs 49% 9 of 11 

Transportation issues 46% 6 of 11 

Source: OIG analysis of grantee surveys and ACF interviews, 2006. 

Grantees report that the income requirement is too low for their service 

areas 

Among the 55 percent of grantees that reported difficulty maintaining 

full enrollment, 71 percent stated that the dollar amounts of the income 

requirements are too low for their service areas. As a result, grantees 

reported difficulty recruiting enough eligible families. Similarly, 

41 percent of grantees noted a decline in the number of eligible families 

in their service areas. 

Grantees reported that the working poor in their service areas earn 

incomes slightly above the poverty guidelines, often at 120 to 

150 percent of the poverty level,32 and therefore do not qualify for Head 

Start. For example, a family of four with two parents earning the 

Federal minimum wage, $5.15/hour,33 would earn enough to be slightly 

over the Head Start income guidelines. This problem is of even greater 

concern to grantees in States with higher minimum wages. 

Twenty-six percent of grantees stated that they could better maintain 

full enrollment if ACF increased the income threshold or if ACF 

permitted grantees to serve a greater number of families that are above 

the stated income guidelines. 

Grantees report that competition with other childcare programs is a 

challenge 

Another reported challenge to maintaining full enrollment relates to the 

recent growth in the number of subsidized State and locally funded 

32 This amounts to $24,000–$30,000/year for a family of four, respectively. 

33 Section 6(a) of the Fair Labor Standards Act of 1938, as amended 

(29 U.S.C. § 206(a)(1)). 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 12 
F I NDING S 

prekindergarten programs. Of the 55 percent of grantees that reported 

difficulty maintaining full enrollment, 49 percent stated that they 

compete with these programs for eligible children. According to 

grantees, these programs are often more convenient to a parent’s job, 

the family’s home, or places siblings are enrolled, or are more 

compatible with full-time work schedules. Further, grantees noted that 

State and locally funded programs can often recruit Head Start-eligible 

families in addition to families above the poverty guidelines because 

these programs do not have to comply with Federal income 

requirements. 

Grantees report that they are unable to provide, or face obstacles in 

providing, transportation services 

Of the 55 percent of grantees that reported difficulty maintaining full 

enrollment, 46 percent reported transportation issues as a challenge to 

maintaining full enrollment: either they are unable to provide 

transportation at all or they face obstacles to providing it. Some 

grantees in rural areas find that eligible families live outside their 

transportation service areas. Budget constraints have forced grantees 

in both urban and rural areas to reduce or eliminate bus routes. In 

addition, grantees stated that State programs are able to offer 

transportation while many Head Start grantees are not, further 

contributing to a competitive disadvantage. 

ACF primarily relies on PIR ACF’s monitoring of enrollment levels may rely data to monitor enrollment. 

on inaccurate data We found inaccuracies in the 

grantee-reported actual enrollment and funded enrollment data in the 

PIR. We also have concerns about the accuracy of the attendance 

records some grantees use as the basis for reporting their actual 

enrollment to the PIR. 

Most grantees reported inaccurate enrollment data in the PIR 

For the 2006 program year, only 11 percent of grantees reported actual 

enrollment levels that matched those we determined based on our 

review of grantee-provided attendance records. Of the 89 percent of 

grantees that misreported their actual enrollment levels, 69 percent 

overreported their enrollment and 19 percent underreported their 

enrollment. The net effect of this misreporting is an overreporting by 

38,587 children. Of the grantees that misreported, 20 percent 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 13 
F I NDING S 

misreported by more than 50 children, which accounts for 88 percent of 

the misreporting. 

Grantees’ overreporting affects ACF’s ability to monitor enrollment 

using PIR data. According to the 2006 PIR data, total actual enrollment 

was 4 percent higher than the total funded enrollment. By contrast, in 

reviewing attendance records, we determined that the total actual 

enrollment was an estimated 5 percent lower than total funded 

enrollment. 

Similarly, our review indicated that 40 percent of grantees were fully 

enrolled, while PIR data indicated that 59 percent of grantees were fully 

enrolled. We found that

9 percent of grantees had

enrollment rates of less

than 90 percent. 

According to PIR data, 

only 1 percent of grantees 

were less than 90-percent 

enrolled. See Table 5 for a 

full comparison of the OIG 

review of enrollment levels 

Table 5: Percentage of Grantees by

Enrollment Levels (OIG vs. PIR) 

Enrollment Levels Percentage of 

Grantees 

OIG review PIR 

100% 40% 59%

≥95% and <100% 41% 36%

≥90% and <95% 10% 5%

Less than 90% 9% 1%

Source: OIG analysis of grantee enrollment and PIR data, 

by grantee to the reported 2006. 

PIR data.34

In addition to reporting actual enrollment, grantees report their 

understanding of their funded enrollment in the PIR. In the 2006 

program year, 7.5 percent of grantees reported in the PIR funded

enrollment levels different from levels in official ACF records. 

Fifty-seven percent of these inaccuracies involved differences of more

than 20 slots from official ACF records. ACF headquarters staff could 

not identify reasons for these discrepancies. These differences limit the

validity of the PIR and raise concerns that some grantees are unaware

of the number of children whom they are responsible for serving. 

Two previous OIG reports highlight the need for PIR training to ensure

accurate reporting.35 The inaccuracies in PIR data suggest that

34 There are no statistically significant differences between OIG and PIR enrollment 

levels for grantees 95- to less than 100-percent enrolled and 90 to less than 95-percent 

enrolled. 

35 “Status of Efforts To Increase the Qualifications of Head Start Teachers,” and “Head 

Start Services for Children With Asthma.” 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 14 
F I NDING S 

grantees are still not receiving PIR training. Only 3 of 11 regional 

offices reported providing PIR training to grantees and only 6 percent of 

grantees reported receiving any (PIR or other) enrollment-related 

training from their regional offices. 

The ability of 26 percent of grantees to produce accurate attendance counts 

is questionable 

PIR data may be inaccurate if Head Start grantees are unable to 

accurately monitor attendance and thus determine enrollment. In 

conducting this review, we had significant concerns about the ability of 

26 percent of grantees to produce accurate attendance counts. We 

determined accurate enrollment counts for these grantees only after a 

labor-intensive cross-check among multiple files. 

In response to our data request, 74 percent of sampled grantees 

provided records for all children they served in a given month compiled 

into a single file or list, or used a system capable of producing such a 

report.36 Twenty-two percent of grantees submitted attendance data 

separated by classroom or delegate agency and did not appear to have 

systems capable of compiling accurate attendance lists. Another 

4 percent of grantees could not provide us with completed attendance 

data because they could not collect attendance records from all of their 

delegate agencies or the burden of gathering their attendance data 

would have taken longer than the study allowed.37 

Regional offices reported ACF’s enforcement of full enrollment has taking a variety of increased overall but varies by region enforcement actions with 

grantees that were not 

fully enrolled. The most commonly cited enforcement action was 

withholding or reducing funds. Other commonly cited actions include 

supplemental monitoring and providing technical assistance. 

36 Several electronic software packages are capable of producing an unduplicated, 

complete list of children. Therefore, grantees that submitted data from one of these 

systems could produce accurate counts of their enrollment. 

37 We accepted grantee data up to 2.5 months after our initial data request. 

OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 15 
F I NDING S 

ACF’s action of reducing or withholding funds has increased, but its use 

varies by region 

Reducing or withholding funds as an enforcement action has increased 

since 2003. At that time, three regional offices reduced funds for six 

grantees, and two regional offices withheld funds.38 In the 2006 

program year, 8 regional offices reported that they reduced funds for 

30 grantees. In addition, three regional offices temporarily withheld 

funding until the grantees achieved full enrollment.39 

The levels of enrollment that prompted regions to reduce funds varied 

widely in 2006: five regions reported reducing funds when a grantee 

was chronically underenrolled,40 one region reduced funds when 

enrollment levels fell below 90 percent, and one region reported 

reducing funds to grantees less than 100-percent enrolled. Among the 

eight regional offices reporting funding reductions, four reduced funds 

when the number of eligible families in grantees’ service areas declined. 

The amount of funding reductions imposed by regions also varied. To 

determine funding reductions, 6 of 11 regional offices reported that they 

negotiate a cost-per-child reduction less overhead and administrative 

costs. Among the 30 grantees that experienced funding reductions in 

2006, there was over a $9,000 range between the cost-per-child 

reduction.

41 

The observed range of reductions per enrollment vacancy may be 

attributed to a number of factors. First, there is no standard Head 

Start cost per child. Therefore, grantees funded to serve the same 

number of children may receive different grant awards. Second, 

regional offices, in consultation with ACF, negotiate funding reductions 

with grantees. Lastly, the only guidance ACF headquarters provides to 

regional offices describes situations in which a funding reduction may 

38 “Head Start: Better Data and Processes Needed To Monitor Underenrollment” 

(GAO-04-17), p. 25. 

39 These grantees had between 10 and 200 enrollment vacancies. 

40 Three regional offices did not define “chronic,” one regional office defined a grantee as 

chronically underenrolled when the grantee was underenrolled for at least 6 months, and 

one regional office defined a grantee as chronically underenrolled when a grantee was 

underenrolled for at least 1 year. 

41 The 30 grantees that lost funding in the 2006 program year lost between $906 and 

$10,000 per enrollment vacancy. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 16 
F I NDING S 

be appropriate. 42 The guidance does not specify how to determine the 

amount of the reduction or the process of negotiation. 

Supplemental monitoring and technical assistance also increased 

Since 2003, ACF has also increased its use of supplemental monitoring 

and technical assistance as enforcement actions. In 2003, only five 

regional offices increased monitoring and three provided technical 

assistance in response to underenrolled grantees.43 In the 2006 

program year, 8 of 11 regional offices increased monitoring and 6 of 11 

provided technical assistance to grantees not at full enrollment. 

 OE I-05-06-00 250 

42 Once a regional office becomes aware of an underenrolled grantee, the grantee 

generally has 90 days to correct the problem. If the grantee remains underenrolled, it may 

be cited as deficient and given another period, not to exceed 90 days, before the regional 

office begins the process of a funding reduction or termination. “Achieving and Maintaining 

Full Enrollment” (ACYF-PI-HS-04-03). 

43 “Head Start: Better Data and Processes Needed To Monitor Underenrollment” 

(GAO-04-17), p. 25. 

E N R O L L M E N T L E V E L S IN HEAD S TART 17 
ΔFR IE NDING C O MMENDA S T I O N S 

 RECOMME NDA TIONS 

We found relatively high levels of enrollment among Head Start 

grantees. In fact, 81 percent of grantees were at least 95-percent 

enrolled in the 2006 program year. Despite high enrollment, more than 

half of grantees reported challenges to maintaining full enrollment. In 

addition, we found continued inaccuracies in the data used to monitor 

enrollment. Finally, we found that although ACF enforcement of full 

enrollment had increased, enforcement varied by region. 

Based on the results of our review, ACF should: 

Address Grantee Challenges to Maintaining Full Enrollment 

ACF should focus particular attention on the challenges identified in 

this report: specifically, the requirement that grantees fill 90 percent of 

slots with children from very low-income families, competition with 

State and locally funded prekindergarten programs, and transportation 

issues. 

o To address concerns regarding the requirement that grantees fill 

90 percent of slots with children from very low-income families, 

ACF could amend its regulations to increase the allowable 

percentage of eligible families that exceed the income guidelines or 

assist grantees in identifying and recruiting categorically eligible 

families, i.e., those receiving TANF or SSI or those with foster 

children. 

o To address concerns about competition with State and locally 

funded prekindergarten programs, ACF could work with grantees 

to increase coordination with these programs. Increased 

coordination could help ensure that States make information 

available to parents about Head Start programs. 

o To address concerns regarding transportation, ACF could provide 

technical assistance to grantees regarding transportation resources. 

Ensure That Enrollment Data Are Accurate 

To help ensure the accuracy of reported enrollment data, ACF should: 

o Work with grantees to maintain accurate attendance records. To 

facilitate this, ACF could encourage the use of electronic attendance 

records. 

o Provide PIR training to grantees. 

o Fill in the grantee’s funded enrollment field in the PIR. Because 

ACF establishes the funded enrollment level, there is no need to ask 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 18 
R E C O MMENDA T I O N S 

grantees to report this. This allows for an unnecessary source of 

reporting error. 

Issue Guidance Concerning the Use of Funding Reductions for Grantees 

Not at Full Enrollment 

To ensure consistent enforcement of the full enrollment requirement, 

ACF should: 

o clarify guidelines to regional offices concerning the level of 

enrollment that warrants a funding reduction, and 

o issue guidance to regional offices concerning the calculation of 

funding reductions and the process of negotiating funding 

reductions with grantees. 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

ACF indicated general support for our recommendations. However, 

ACF pointed out problems with two suggestions we offered on how our 

recommendation to address grantee enrollment challenges regarding 

the requirement that grantees fill 90 percent of slots with children from 

very low-income families might be implemented. First, ACF stated that 

it is not within its purview to change the income guidelines. Second, 

ACF did not support our suggestion to amend its regulation to increase 

the allowable percentage of eligible Head Start families that exceed the 

low-income guidelines. ACF felt that this change would allow grantees 

to enroll higher-income children without ensuring participation by the 

neediest children. The complete text of ACF’s comments is located in 

Appendix C. 

We understand ACF’s concern that Head Start continue to serve the 

neediest children. However, grantees cited the current Head Start 

income-eligibility requirements as a challenge to maintaining full 

enrollment. Thus, we continue to recommend that ACF address 

grantees’ reported challenges to maintaining full enrollment, including 

challenges related to the income-eligibility guidelines. 

ACF’s technical comments are not included in Appendix C, but we made 

changes in the report where appropriate. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 19 
Δ APPENDIX~A 

DETAILED METHODOLOGY 

Sample 

To improve the precision of our enrollment estimates, we stratified our 

sample by grantee size. Within the Hispanic-growth stratum, we 

created two substrata based on size; within the nongrowth stratum, we 

created three substrata based on size. The size-of-grantee strata are 

defined differently for the Hispanic-growth stratum and the nongrowth 

stratum because the relative sizes of grantees are different for these 

groups (i.e., there are more large grantees in the nongrowth stratum). 

We do not make comparisons of grantees based on their size. 

Data Collection 

Data for this study came from grantee attendance records, grantee 

surveys, interviews with the Administration for Children and Families 

(ACF) staff, and 2006 program year Program Information Report (PIR) 

data. 

To ensure the construct validity of our grantee survey instrument and 

data request for attendance records, we pretested both on a subset of 

22 grantees. After the grantees responded, we contacted them by phone 

to conduct a short cognitive interview to determine whether the survey 

and data request were clear and understandable. The vast majority of 

grantees interpreted the questions as we intended. We altered the few 

unclear questions to make them more understandable. We included 

these pretested grantees in the final sampling frame. 

We also conducted in-depth reviews of attendance records for 9 of the 

22 Head Start grantees selected for pretesting. In these reviews, we 

compared grantees’ original attendance records with attendance 

information grantees provided us. We found that our instrument was 

successful in eliciting accurate attendance records. 

Our request for attendance data yielded a response rate of 93 percent 

(185 of 200). We designed our sample to produce an estimate of the 

total number of enrolled and underenrolled Head Start slots with an 

expected relative precision of 15 percent at the 95-percent confidence 

level, assuming a grantee response rate of 80 percent. Beyond the nine 

grantees that did not respond to our request, an additional six grantees 

did not comply with the data request because they either could not 

collect attendance records from all their delegate agencies or the effort 

of gathering all of their attendance data would have taken the grantees 

more time than the study allowed. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 20 
APP E N D I X ~ A 

Another six grantees submitted a large volume of hard-copy attendance 

records. We determined that the task of reviewing these hard-copy 

records was significant and would have taken longer than the time 

allotted for the study. Because we designed our sample to obtain 

precise estimates with a grantee response rate as low as 80 percent and 

our response rate would be 90 percent (179 of 200) without including 

these six, we did not analyze attendance records for these six grantees. 

Thus, we reviewed attendance data for 90 percent (179 of 200) of 

sampled grantees. 

To understand ACF regional offices’ enforcement of full enrollment, we 

interviewed staff from all 11 regions. We asked regional offices about 

their definitions of underenrollment, the actions they took in response 

to grantees’ failure to maintain full enrollment, and the number of 

grantees whose funding they reduced and/or froze during the 

2006 program year because of the inability to maintain full enrollment. 

Data Analysis 

Estimating enrollment levels. For each grantee, we counted children as 

enrolled if they attended at least once within a given month. We could 

not determine whether a child whose first day of attendance was after 

the beginning of the month was filling a vacancy that had been open for 

more than 30 days. Also, because we counted each child who attended 

at least 1 day in the month as a separate enrolled slot, it is possible that 

we double-counted children who were filling the same slot. For 

example, if a child attended at the beginning of the month and then 

dropped out and another child filled that slot within 30 days, we would 

count them as filling two enrolled slots. This method produced a 

conservative count of enrolled children. 

We used grantees’ average attendance data over 3 sampled months to 

determine their actual levels of enrollment. We then compared the 

number of children actually enrolled to grantees’ funded enrollment 

according to ACF. We projected from our sample to the population of 

Head Start grantees to estimate the proportion of fully enrolled 

grantees and the degree to which other grantees were enrolled. We also 

estimated enrollment levels nationwide and the total number of 

enrollment vacancies. 

Comparing our estimates of enrollment levels with the PIR. The PIR 

requires that grantees report their enrollment for 3 specified months 

per year. To facilitate comparison between our enrollment data and the 

PIR, we chose two sampled months (November 2005 and April 2006) to 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 21 
APP E N D I X ~ A 

overlap with PIR reporting months. To assess accurate reporting of 

actual enrollment levels, we compared the 179 grantees’ actual 

enrollment levels from our review to the actual enrollment levels they 

reported in the PIR for these 2 months. 

Limitations 

Although we requested that grantees provide data for ACF-funded 

children only and we pretested our instruments to ensure validity, some 

grantees may have incorrectly submitted attendance records for 

State-funded children. 

State funding for Head Start services is still relatively uncommon. ACF 

headquarters staff reported that State-funded Head Start slots are 

proportionally few compared to ACF-funded Head Start slots. 

According to ACF, only 7 percent (14 of 200) of sampled grantees served 

State-funded children during the 2006 program year. In the event that 

some grantees included State-funded children in their attendance 

records, our enrollment level estimates would be conservative. 

To reduce the possible effect of grantees reporting State-funded children 

along with ACF-funded children in their attendance records, we 

considered grantees whose actual enrollment was greater than 

ACF-funded enrollment to be fully enrolled and did not report the 

amount of overenrollment. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 22 
ΔR E C O MMENDA T I O N S 

 APPENDIX~B 

ESTIMATES AND CONFIDENCE INTERVALS 

Table 6A: Estimates Discussed in Finding One: Almost All Head Start Grantees Had High 

Enrollment Levels 

95-Percent 

Sample Point Confidence 

Estimate Description Size Estimate Interval 

Percentage of grantees at least 95-percent enrolled 179 81.5% 74.2%–88.9% 

Overall percentage of Head Start slots unfilled 179 4.6% 2.9%–6.2% 

Number of total unfilled Head Start slots 179 33,726 20,551–46,901 

Percentage of grantees in the Hispanic strata at least 95-percent 

enrolled 68 91.0% 85.7%–96.3% 

Percentage of grantees in the non-Hispanic strata at least 

95-percent enrolled 111 79.7% 71.0%–88.4% 

Percentage of grantees who reported changing their recruitment 

strategies because of an increase in the Hispanic population in their 

service area 111 79.7% 70.2%–89.2% 

Source: Office of Inspector General analysis of grantee attendance records, 2006. 

Table 6B: Estimates in Table 3 of Finding One: Almost All Head Start Grantees Had High 

Enrollment Levels 

Percentage of Grantees 

Enrollment Levels 95-Percent Confidence Interval 

Grantees in Hispanic- Grantees Not in HispanicAll Grantees Growth Areas Growth Areas 

(n = 179) (n = 68) (n = 111) 

40.2% 41.0% 40.1% 

100% (30.8%–49.6%) (30.6%–51.4%) (29.1%–51.1%) 

41.3% 50.1% 39.6% 

≥ 95% and < 100% (32.1%–50.6%) (39.6%–60.6%) (28.8%–50.5%) 

9.8% 2.6% 11.2% 

≥ 90% and < 95% (4.1%–15.5%) (0.9%–7.2%) (4.4%–18.0%) 

8.7% 6.4% 9.1% 

< 90% (3.4%–13.9%) (1.7%–11.0%) (2.9%–15.3%) 

Source: Office of Inspector General analysis of grantee attendance records, 2006. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 23 
APP E N D I X ~ B 

Table 7: Estimates Discussed in Finding Two: Grantees Cited Common Challenges To Maintaining 

Full Enrollment 

Estimate Description 

Percentage of grantees that reported difficulty maintaining full 

enrollment 

Percentage of grantees at least 95-percent enrolled that expressed 

difficulty maintaining full enrollment 

Of the 55 percent of grantees that reported difficulty maintaining full 

enrollment, the percentage that cited low-income requirements as a 

challenge 

Of the 55 percent of grantees that reported difficulty maintaining full 

enrollment, the percentage that cited population shifts/declines as a 

challenge 

Of the 55 percent of grantees that reported difficulty maintaining full 

enrollment, the percentage that stated that they could better 

maintain full enrollment if ACF increased the income thresholds or 

permitted grantees to serve a greater number of families above the 

stated income guidelines

Of the 55 percent of grantees that reported difficulty maintaining full 

enrollment, the percentage that cited competition with State 

programs as a challenge 

Of the 55 percent of grantees that reported difficulty maintaining full 

enrollment, the percentage that cited transportation issues as a 

challenge 

Source: Office of Inspector General analysis of grantee surveys, 2006. 

95-Percent 

Sample Point Confidence 

Size Estimate Interval 

189 54.7% 45.6%–63.9% 

144 48.9% 38.4%–59.4% 

106 71.2% 60.2%–82.1% 

106 41.3% 29.0%–53.7% 

106 26.0% 15.2%–36.8% 

106 49.5% 37.0%–62.0% 

106 45.8% 33.3%–58.2% 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 24 
APP E N D I X ~ B 

Table 8: Estimates Discussed in Finding Three: ACF’s Monitoring of Enrollment Levels May Rely 

on Inaccurate Data 

Estimate Description 

Sample 

Size 

Point 

Estimate 

95-Percent 

Confidence 

Interval 

Percentage of grantees that reported actual enrollment levels that 

matched those we determined based on our review of attendance 

records 175 11.2% 4.8%–17.6% 

Percentage of grantees that misreported actual enrollment levels 175 88.8% 82.4%–95.2% 

Percentage of grantees that overreported actual enrollment levels 175 69.4% 60.7%–78.1% 

Percentage of grantees that underreported actual enrollment levels 175 19.4% 12.3%–26.5% 

Net number of children misreported 159 38,587 22,802–54,373 

Percentage of grantees that misreported actual enrollment levels by 

more than 50 children 175 19.6% 12.3%–27.0% 

Percentage of misreporting accounted for by the 20 percent of 

grantees that misreported by more than 50 children 159 87.8% 80.8%–94.7% 

Percentage of grantees that reported receiving any enrollmentrelated training from their regional offices 189 5.7% 0.9%–10.5% 

Percentage of grantees for which we had significant concerns about 

their ability to produce accurate attendance counts 191 26.2% 17.9%–34.4% 

Percentage of grantees that provided records for all children they 

served in a given month compiled into a single file or list or used 

systems capable of producing such reports 191 73.8% 65.6%–82.1% 

Percentage of grantees that submitted attendance data separately 

by classroom or delegate agency and did not appear to have 

systems capable of compiling accurate attendance lists 191 21.7% 14.0%–29.4% 

Percentage of grantees that could not provide us with completed 

attendance data because they could not collect attendance records 

from all their delegate agencies or the task of gathering attendance 

data would have taken longer than the study allowed 191 4.5% 0.3%–8.6% 

Source: Office of Inspector General analysis of grantee surveys and attendance records, 2006. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 25 
 

 O E I - 0 5 - 0 6 - 0 0 2 5 0 E NROLLMENT L EVELS IN HEAD S TART 26 

AGENCY COMMENTS 

Δ APPENDIX~C 
APP E N D I X ~ C 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 27 
APP E N D I X ~ C 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 28 
Δ ACKNOWLEDGMENTS 

This report was prepared under the direction of Ann Maxwell, Regional 

Inspector General for Evaluation and Inspections in the Chicago 

regional office, and Thomas Komaniecki, Deputy Regional Inspector 

General. 

This report was led by Emily Melnick and Anne Bracken. Other 

principal Office of Evaluation and Inspections staff who contributed 

include Kevin Farber, Alan Levine, Tamara Perry, Louise Schoggen, 

Elise Stein, Rosaella Washington, and Mara Werner. 

 OE I-05-06-00 250 E N R O L L M E N T L E V E L S IN HEAD S TART 29