.... 

. .

READINESS TO EXPAN D 


HEAD START EN ROLLM ENT


C;f,RVICf5' 

Richard P . Kusserow 

INSPECTOR GENERAL 

lq"dm AUGUST'1991
. . 

L . 1- , 

OFFICE- OFINSPRCfOR- GENERA 

The mission of the Officeoflnsp ctorGeneral (OIG), as mandated by Public Law95­ ,!1 . 

452, as amended, is to protect the intc:grity of the Department of Health ahdHuman 

Services' (HHS) programs as wellaslhehealthand .welfare of beneficiariessetvedby , 

those programs. This statutory mission iscarriedout through a naticinwidenetworkof 

audits, investigations, and inspections cQnducted by threeOIG operating .components: 

the Offce , of Audit Services, the Offce of Inve tigations, and the Office of Evaluation 

and Inspections. The OIG alsQ informs the Secretary of HHS of program and 

. management problems, and tecommenctscourses to correct them. 

OFFICE OF 
 AUDIT SERVICE

TheOIG' s 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 carrng out their respective responsibilties, and are intended to 

provide independent assessments :of HHSprograms and operations in order to reduce 

waste, abuse and mismanagernentand to promote economy and effciency throughout 

the Department. 

OFFICE OF INVETIGATIONS 

TheOIG' s Office of InvestigationsJOI) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing inHHSprograms or to HHS beneficiaries 

and of unjust enrichment by providers. The investigative efforts of 01 lead to criminal 

convictions, administrative sanctions, or civil ' money penalties. The 01 also oversees 

State i\1edicaid fraud control units which investigate and prosecute fraud and patient 

abuse in the Medicaid program. 

OFFICE OF 
 EVALUATION AN INSPECTONS

The OIG's Office of Evaluation and Inspections (OEI) conducts short-term 

management and program evaluations (called inspections) that focus on issues 

concern to the Department, the Congress, and the public. The findings and 

recommendations contained in the inspections reports generate rapid, accurate, and upto-date information on the efficiency, vulnerability, and effectiveness of departmental 

programs. This report was prepared in the New York Regional Offce under the 

direction of Regional Inspector General Thomas F. Tully. Project staff included: 

Joseph J. Corso Jr., Project Leader Jodi Nudelman 

Joseph Benkoski Alan S. Meyer 

Wiliam Counihan Alan S. Levine, Headquarters 

Luci1Je M. Cop 
Department of Health and Human Services


OFFICE 

INSPECTOR GENERAL


READINESS TO EXPAND


HEAD START ENROLLMENT


~ Sf,RVJCES. 

'0 

lt-l " "d.() 

Richard P. Kusserow 

INSPECTOR GENERAL 

OEI-02-91-00741 
EXECUTIVE SUMMARY


PURPOSE 

This inspection was conducted to assess the capacity of the Head Sta system to successfully 

manage the current and future enrollment expansion process. 

BACKGROUND 

This inspection was requested by the Assistant Secretar for Management and Budget (ASMB), 

Department of Health and Human Services (DHHS), based on concerns about the Head Star 

system s capacity to expand at a time of rapidly increasing appropriations. 

The national Head Star program is in its 26th year, and is now administered by the newly 

fOff1ed Administration for Children and Families (ACF). It serves primarly low-income 

children, ages 3 to 5, and their families. Currently about 1,300 grantees operate local Head Start 

programs. 

There were two rounds of Head Star enrollment expansion in FY 1990 totaling $266 million, a 

21 percent increase over FY 1989; another $159 milion, or a 10 percent increase, is scheduled 

for FY 1991. Total enrollment is projected to increase from 450,970 children to nearly 600,000 

children, during the same period. The Administration s budget for FY 1992 requests $100 

million in additional Head Start funding, for a total of about $2.06 billon. 

METHODOLOGY 

We conducted strctUred interviews with a stratified random sample of 75 grantees (2 large 

grantees were added), with 52 OHDS staff, including 5 or 6 from each of 10 regions, and 6 

OHDS headquarters' staff. We obtained data and perceptions regarding their experiences with 

enrollment expansion in 1990 and their plans and capacity to handle further expansion in 1991. 

FINDINGS 

Grantees Report Meeting Enrollment Expansion Goals 

Grantees have met their enrollment expansion goals for the first round of 1990 Head Start 

expansion and plan to full y meet them for the second round by September 1991. 

Most grantees report few problems with the FY 1990 grant process. 

Three-quarters plan to apply for the 1991 expansion funds. 
Acquiring Space Is Grantees' Primary Problem 

. In the FY 1990 expansion, most needed more space, cited frequently as a major problem 

and, typically, the biggest problem. 

Eighty-five percent of grantees wil need more space to implement the FY 1991 expansion. 

Half consider space a major problem. However, they expect to find suitable space by 

September. 

Grantees And Federal Staff Have Differing Views About The Impact Of Expansion On 

Qualiy 

Most grantees are generally positive about the expansion s impact on quality; 20 percent, 

however, think expansion wil either have no effect on or wil lower quality. 

In contrast, slightly more than half the Federal staff doubt whether grntees receiving expansion funds can maintain or improve quality over the next several years, while nearly 

40 percent say they have no reason to be concerned. 

Federal Capacity To Manage Expansion Appears Limited 

Regional staff feel they lacked sufficient time and staff to monitor and assist grantees in 

the FY 1990 funding rounds; also, most regional and headquaners staff claim a serious 

lack of resources to assess and assist grantees in FY 1991. 

Federal staff lack timely data on grantee enrollment. 

Most Head Start managers feel communication between headquaners and regions needs 

improvement. 

RECOMMENDATIONS 

The ACF should: 

address promptly the resource needs of ACF staff; 

provide maximum lead time for grantee expansion and offer technical assistance and 

guidance to grantees to resolve expansion problems; 

develop a system to collect timely data on grantee enrollment progress during expansions; 

and 

assure more direct and effective communication between headquaners and regional Head 

Start staff. 
AGENCY COMMENTS 

The Assistant Secretary for Children and Familes has reviewed the draft of this report and 

supports the study s findings and recommendations. The Assistant Secretar noted, however 

that the report s conclusions apply only to expansion efforts of the magnitude the Head Star 

program experienced during FY 1990. We agree with this assessment. The complete comments 

of the Assistant Secretary are included in the Appendix. 
.................................. .... ........ .......... ........... ...... ....

TABLE OF CONTENTS


EXECUTIVE SUMMARY 

INTR() D U CTI () N.. ...... .........,.............. ........................ .................. ...... ............ 


Purpose................................................................................................................ .


Background................................................................ .........................................


Methodology...................................................... ..................................................


FINDINGS ..,....................................... 


RECD MMENDA TI NS .... .............. ......


APPENDIX A 

Comments of the Assistant Secretar for Children and Familes................... A - 1 
INTRODUCTION


PURPOSE 

This inspection was conducted to assess the capacity of the Head Stat system to successfully 

manage the current and future enrollment expansion process. 

BACKGROUND 

This inspection was requested by the Assistant Secretar for Management and Budget (ASMB), 

Department of Health and Human Services (DHHS), based on concerns about the Head Stan 

system s capacity to expand at a time of rapidly increasing appropriations. 

The Head Start program, now in its 26th year, was established under Title V of the Economic 

Opportunity Act of 1964. A national program, it serves primarly low-income children, age three 

to the age of compulsory school attendance, and their families. It is now administered by the 

newly fonned Administration for Children and Families (ACF), DHHS, which absorbed the 

Office of Human Development Services (OHDS) where Head Stan was fonnerly managed. 

OHDS, the Administration for Children, Youth and Families (ACYF) and the Head Stan Bureau 

(HSB) administer the program. The program s services include education, health care (including 

medical, dental, nutritional and mental health services), parental involvement and social services. 

At least 10 percent of the enrollment in each State must be made available for handicapped 

children. 

Head Start grantee agencies car out the program s objectives. There are currently about 1 300 

grantees operating. A grantee agency may delegate all or pan of its responsibility for the 

operation of the program to a public or private nonprofit organization. There are about 600 such 

delegate agencies. The largest grantees, with enrollment in the thousands of children, are 

referred to as "supergrantees. 

Grants are awarded and monitored by OHDS regional staff in the Office of Community 

Programs and by the American Indians Programs Branch and Migrant Programs Branch in 

OHDS headquarters. The law requires that the Federal grant shall not (but with certain 

exceptions may) exceed 80 percent of the approved costs of the program. The grantee must 

contribute twenty percent of the costs in cash or in kind. 

Funding for Head Start grew substantially from $1.24 bilion in FY 1989 to $1.95 bilion in FY 

1991. Two rounds of enrollment expansion funding took place in FY 1990, the first for $100 

million, the second for $166 millon. Thus, the total increase for FY 1990 was $266 milion, a 

21 percent increase over the FY 1989 funding level. The second round resulted from an 

unexpected supplemental allocation by Congress late in the fiscal year. For the first round, 

grantees applied in April; they applied in either July or October 1990 for the second round. The 
Congress pemlitted the supplemental funds to be obligated by December 31 , 1990. In approving 

the awards, it was anticipated that full enrollment of children would take until September 1991. 

Further expansion of $159 milion, or a 10 percent increase, is scheduled for FY 1991. In 

addition , $1.95 million is available for quality enhancements to retain and recruit qualified staff 

and to increase staff salaries and fringe b nefits. Total enrollment is projected to increase to 

nearly 600,000 children. 

Head Start reauthorizing legislation projects expansion funding of $4.27 bilion for FY 1992; 

$5.92 billion for FY 1993; and $7.66 bilion for FY 1994. The Administration s budget for FY 

1992 requests $100 million in additional Head Sta funding, most of which is to be used for 

further enrollment expansion, bringing the total to about $2.06 billon, as outlined below: 

Fiscal Year 

Appropriation 

Expansion $ 

Expansion goals 

Guidance issued 

Funds obligated 

1990 

$1.38B* 

$99. 

37,500 

2/90 

9190 

1990 supp. 

$166M* 

$166M 

60, 

6/90 

12/90 

1991 

$1.95B 

$159M** 

000 

4/91 

1992 

$2.06B 

$90. 

* B = billion; M = million 

** An additional S241M is provided for quality enhancements ($ 195M) 

and other projccts, initiatives and assistance ($46M). 

METHODOLOGY 

We held strctured interviews with officials from a stratified random sample of 75 grantees (plus 

2 supergrantees), with 52 OHDS staff, including 5 or 6 from each of 10 regions, and 6 OHDS 

headquarters staff, to obtain data and perceptions based on their experiences with enrollment 

expansion in 1990 and backgrounds of regional staff from each region. We also asked them 

about their plans and capacity to handle further expansion in 1991. 

We held discussions in each OHDS region with the OHDS Regional Administrator, the Director 

of Fiscal Operations, the Director of Community Programs (and any supervisors on their staffs), 

and two program specialists. We conducted interviews in person with six OHDS, ACYF and 

HSB officials in five regions and in headquaners. 

We selected a stratified random sample of 75 grantees from the total of 1 , 140 (excluding 

American Indian and Migrant grantees) who received enrollment expansion awards in 1990. 

includes: 25 of the 100 (25 percent) who received more than $400,000 in FY 1990 expansion 

funding; 25 of the 513 (5 percent) who received between $51 000 and $399,000; and 25 of the 

527 (5 percent) who received no more than $50,000. None of the grantees from the latter 

stratum received funds for the first round of FY 1990 funding. 
We weighted grantee responses in each stratum to reflect the proportion which their stratum 

represented of the sample universe. In analyzing responses to questions which did not apply to 

all respondents, however, we reduced the universe based on the proponion of each stratum to 

whom the question did not apply. We also visited two supergrantees to lear about the 

experience of very large grantees with expansion; however, their responses are nOt included in 

grantee sample projections. 

We held telephone discussions with the Head Start Director and/or the Executive Director of the 

75 grantee agencies; and we conducted discussions with the two supergrantees at their offces. 

We obtained data and perceptions regarding their experience with enrollment expansion in 1990 

and their plans and capacity to handle further expansion in 1991. These discussions were held 

with these grantees in February and March 1991 , after two rounds of expansion funding in 1990 

and prior to the recent round of expansion funding begun in May 1991. 
FINDINGS


GRANTEES REPORT MEETING ENROLLMENT EXPANSION GOALS 

Goals for FY 1990 first round met; grantees confident about meeting second round goals 

Grantees report having met 97 percent of their enrollment expansion goals for the first round. 

They also expect to fully meet them for the second round of FY 1990 by September 1991. (See Graph) 

GRANTEES REPORT MEETING


ENROLLMENT EXPANSION GOALS


100 97% % of funded children enrolled now or by 9/91­


74% 

59% 

41% 

26% 

First Round Second Round Total 

404 children funded 56 469children funded 91 873 children funded 

00 Now enrolled Will enroll by 9/91 

*Numbers and percents of children funded and enrolled are 

projections to the national universe of 1 140 grantees. 

Few grantees report problems with the 1990 grant process 

Ninety percent of the grantees in the first round and 92 percent in the second round leared early about both rounds of expansion and used this lead time to begin planning. Somewhat more than 

half the grantees received help from regional offices. Over 90 percent of them rate the assistance 

as either very or somewhat helpful. Almost 75 percent repon having had no problems with the 

Federal instructions they received prior to applying in the fIrst round. Similarly, nearly 

percent report experiecing no problems with second-round instructions. 
Most grantees wil apply for FY /99/ expansion funds 

Seventy-five percent of the grantees plan to apply in 1991. Sixteen percent wil not because they 

feel they re not ready to expand. (Nearly a third of the latter grantees are reluctant to expand their programs before fully implementing current programs; a quarter said there was competition 

from public preschool programs for the same childrn; the remaining grantees cited varous 

reasons including lack of space, staffng problems and realistic assessments of limited capacity 

to expand further). The remaining nine percent of grantees will predicate their decision to apply 

on the availability of space, the timing of the grant and the amount of the award. Almost all say 

there are substantial numbers of unserved childrn in their service areas. 

ACQUIRING SPACE IS GRANTEES' PRIMARY PROBLEM 

At least eighty percent of the grantees needed more space in order to expand enrollment in each 

round; at least 4 of lOin each round rated obtaining space a major problem. Of those having a 

major problem of any kind, 30 percent in the fIrst round and 40 percent in the second round 

considered space their biggest problem. The space problem was most prevalent among grantees funded to increase enrollment by more than 200 children in each round. A typical grantee 

comment was "I may fInd a building, but I wil have to renovate it." Others cited strict licensing 

requirements and delays in license approval. 

The large majority of grantees in each round had to hire more teachers and support staf and 

obtain more transportation to expand enrollment. Most did not consider this a major problem. 

Eighty-five percent of the grantees anticipate needing more space to expand enrollment in FY 

1991; 47 percent of them expect this to be a major problem. Of those who believe space wil be 

a major problem, most say it wil be their biggest problem. Nevertheless, many grantees believe 

that suitable space can be obtained if enough lead time is provided. As indicated in the previous 

finding, grantees receiving four to six months advanced notifIcation of expansion funding in FY 

1990 were able to acquire space for expansion within twelve months of notifIcation. 

Eighty-three percent of the grantees will have to have additional staff and sixty-four percent wil 

need more transportation to expand enrollment in FY 1991. Again, few see these as major 

problems, with suitable lead time. 

GRANTEES AND FEDERAL STAFF HAVE DIFFERING VIEWS ABOUT THE 

IMPACT OF EXPANSION ON QUALITY 

Most grantees are generally positive about the expansion s impact on quality. About two-thirds 

expect expansion funds to raise the quality of services over the next few years. A majority 

express this without qualification, but others feel it is contingent upon monies being allocated for 

quality enhancements, such as increased staff salares and benefIts. (As noted on page 3, $195 

million wil be made available to grantees in FY 1991 for quality enhancements). In contrast 

about 20 percent believe expansion funds will either have no effect on or wil lower quality. 

These grantees typically feel quality depends upon meeting the rising cost of staff salares and 
benefits, rent and insurance. Grantees also noted the adverse effect on quality caused by the 

rising incidence of dysfunctional Head Sta families. The remaining 15 percent are uncertain 

about the impact of expansion on quality. 

In contrast to the relatively positive expectations of grantees, slightly more than half the regional 

and headquarers OHDS staff doubt that grantees who receive expansion funds wil be e to 

maintain or improve the quality of their services. They question whether allocations for salares 

and costs per child will be suffcient, whether grantees wil have the capacity to maintain quality, 

and whether Federal staff will be able to evaluate grantee quality. Nonetheless, nearly 40 percent 

say they have no reason to be concerned about the quality of grantee services. The remaining 12 

percent are uncertain about their position on the question. 

Regional respondents estimate that 107 grantees in their regions ar not ready for further 

expansion. That is about nine percent of all grantees nationally. Reasons most often cited 

include weaknesses in grantee infrastructure and management, "high risk" status, and lack of 

eligible children. 

FEDERAL CAPACITY TO MANAGE EXPANSION APPEARS LIMITED 

Regional stafffelt unable to adequately assist grantees in FY 1990 

Regional staff point to a number of barers to their having been able to help grantees. Fifty 

percent feel there was not enough time to adequately help grantees prepare applications in each 

round. Similarly, almost fifty percent report they were unable to do as good ajob as they d have 

liked in helping grantees prepare their expansion funding applications in the first round; 40 

percent were not able to do so for grantees who applied in the second round by July 16, and 20 

percent felt unable to do so for grantees who applied in the second round by October 15. 

Overall, half blamed lack of time and insufficient staff for keeping them from doing a better job. 

Most regional and headquarters staff are concemed about the lack of resources for FY 1991 

Eighty percent say they lack sufficient resources (both staff and travel funds) to monitor and 

assist grantees in the coming enrollment expansion effort. Having more staff but not enough 

travel money, or the reverse would not solve the problem. Providing technical assistance to 

grantees and performing comprehensive monitoring calls for more onsite visits than are currently 

possible. Only 3 of 10 OHDS Regional Administrators say they can provide technical assistance 

or assess grantee expansion progress and problems. 

Staff size and grantee workloads var widely among regions: there are 3 to 17 program staff in 

each region (the national total is 97) and average staf workloads range from 10 to 27 grantees. 

Regional offices currently have 31 staff vacancies, most of which are in Head Star slots. 

A positive note is that current regional Head Star professional program staff reflect depth in 

their educational background and program experience. Most have completed undergraduate 

and/or graduate studies related to Head Start. Many also have prior work experience with Head 
Start. Over half have from 10 to 20 or more years of Federal experience working with Head 

Start grantees. 

. Federal Head Start . taff lack timely information on enrollment 

The regional offices and headquarers staff lack ongoing infonnatjon on grantee expansion 

progress. They rely primarily on what grantees report to them annually (in June), as par of a 

Head Start Program Infonnation Report." They can only verify this infonnation during on site 

monitoring visits usually made to grantees no more frequently than once every three years. 

Most Head Start managers believe communication between headquarters and regional offices 

needs improvement 

Over half the Head Start managers do not consider communication between headquarers and 

regional offices to be as efficient and effective as they d like. They expressed concerns about the 

headquarters and regional structure under which the Head Star program has operated and other 

communications problems. 

The structure problem relates to the following: the regional Head Stat program staff has 

operated under the Offce of Human Development Services (OHDS), Offce of Community 

Programs (OCP), which existed only in the regions and had responsibility also for the Runaway 

Youth Program. (As noted above, the OHDS was recently absorbed by ACE) In headquarers 

HSB was within ACYF, a division non-existent in the regions. All official ACYF/HSB 

communications to the regions had to go through the Office of Regional Operations in OHDS 

headquarters to reach OHDS Regional Administrators. Similarly, all official Head Sta/OCP 

communications to ACYF/HSB had to follow the same procedure in reverse. Both regional and 

headquarters Head Start staff say this situation caused unnecessar delays in the processing of 

policy issuances and funding guidances, and has been problematic during the enrollment 

expansIon. 

Another concern cited by ACYF and HSB staff is that OCP Head Star staff were accountable to 

OHDS, not ACYF or HSB , for their perfonnance rating. One respondent said, "Head Star is a 

$2 bilion program and growing, and should be separated from other programs in OHDS. We 

need regional staff dedicated solely to the Head Star program. 

Regional OCP Head Start staff say that little opportunity exists for meaningful regional staff 

input into headquarters policy decisions, and there is limited regional decision-making authority. 

One respondent stated, "We have 100 pairs of eyes and ears in the communities," but noted that 

headquarters does not utilize this experience in developing funding guidances and enrollment 

expansion policy. 

Given the creation of ACF, there may be organizational changes planned which wil address 

some or all of the above-cited concerns. 
RECOMMENDATIONS


, The ACFshould: 

provide, as soon as possible, ACYF and regional staff with the resources to effectively 

manage and monitor their increasing responsibilities, including staff and discretionary 

travel funds for more frequent grtee site visits; 

provide maximum lead time for expansion implementation and offer technical assistance 

and guidance to resolve major expansion problems, including obtaining suitable space, 

qualified teachers and support staff, and trnsportation; 

develop a system to collect timely data on grantee enrollment progress during expansions; 

and 

assure more direct and effective communication between ACYF, HSB and regional Head 

Star staff. 

AGENCY COMMENTS 

The Assistant Secretar for Children and Familes has reviewed the draft of this report and 

supports the study s findings and recommendations. The Assistant Secretar noted, however 

that the report s conclusions apply only to expansion efforts of the magnitude the Head Star 

program experienced during FY 1990. We agree with this assessment. The complete comments 

of the Assistant Secretar are included in the Appendix. 
APPENDIX 

Comments of the A ssistant Secretary for Children and Families 
.,.\ .. 

III 

, / , .

DEPARTME!\T OF HEALTH & HUMA SERVICES

tLJ!r-r 

:, 

DIG- .I

ADMINISTRA TION FOR CHILDREN AND FAMILI 

DIG- Office of the Assistant Secretary. Suite 600
 DIG- 370 L'Enfant Promenade, S. W. -; 
 JJL 199\ AIGWashington, D.C. 20447


EX SEC 

OGC/IG - n;:;-11

DATE 7fl" , C'


c- : -:t ;.,,1 TO: Richard P. Kusserow 

Inspector General


Department of Health and Human Services


FROM: Assistant Secretary c.,
 for Children and Families


SUBJECT: Response to Office of Inspector General Draft Report: 

Readiness To Expand Head Start Enrollment

OEI-02-91-00741 

Thank you for the opportunity to review and comment on your draft


report entitled "Readiness To Expand Head Start Enrollment.


We are supportive of the findings and recommendations in this


report and think it presents a fair and accurate picture of the


FY 1990 expansion effort. We note, however, that your


conclusions only apply to expansion efforts of the magnitude we 

experienced during FY 1990. Significantly greater funding

increases , for example , might lead to different conclusions. 

We would like to comment on the four recommendations contained on 

page 7 of the report and provide some technical corrections for 

your consideration in preparing the final report. 

OIG Recommendation


The Administration for Children and Families (ACF) should


provide, as soon as possible, ACYF and regional staff with


the resources to effectively manage and monitor their


increasing responsibilities, including staff and


discretionary travel funds for more frequent grantee site
 visits 

ACF Comment


We concur with this recommendation. The shortage of staff and 

travel funds to assure the quality of' the program expansion 

efforts is critical. We are moving to increase the numer of 

staff in the Head Start program both in Headquarters and in


regional offices. In FY 1991, we will be adding an additional 


staff to Headquarters. Should Congress approve our FY 1992


request for additional employees, we anticipate a further staff


increase that would include more staff in the regions.


The need for additional increases for future years is also being


assessed. 
. Page 2 - Richard P. Kusserow 

Similarly, travel funds have been increased in FY 1991 and we 

hope to obtain additional increases in future years. Our 

intention is that these steps will correct the deficiencies that 

have existed in the past and bring us to a staffing level that


will assure our ability to " effectively manage and monitor our


increased responsibilities.


OIG Recommendation 

The ACF should provide maximum lead time for expansion


implementation and offer technical assistance and guidance


to resolve major expansion problems, including obtaining


suitable space , qualified teachers and support staff, and


transportation. 

ACF Comment


We concur with this recommendation and will make every effort in


future years to assure that both grantees and regional staff are


given guidance on implementing expansion as soon as possible in
 the fiscal year. We also agree that sufficient technical 

assistance and maximum lead time for expansion implementation 

should be provided to grantees who experience problems operating 

under compressed timeframes. Several regional off ices pointed 

out that lead time has not been a problem so far, because the 

required implementation dates for grantees were extended when 

necessary. We would like to emphasize , however, that no 

standard" has been developed. Nei ther this report nor our 

experiences with Head start expansion has allowed us to quantify

the term " adequate lead time. 

OIG Recommendation 

The ACF should develop a system to collect timely data on


grantee enrollment progress during expansions.


ACF Comment


We agree that grantees ' implementation of enrollment expansion


needs to be tracked to assess progress and resolve problems that 

are identified. Our regional offices have maintained close 

contact with grantees to follow their progress in implementing expansion. However, a more formal system of periodic reports 

from grantees could provide more reliable data and help assure 

that the expansion initiative is being implemented successfully. 

Wi thin the limits of available resources , especially staff in 

Headquarters and regional offices , we will explore the 

development of such a system. 
Page 3 - Richard P. Kusserow 

OIG Recommendation 

4 . The ACF should assure more direct and effective 

communication between ACYF, HSB and regional Head start

staff. 

ACF Comment


We agree that direct and effective communication between


Headquarters and regional staff is very important in assuring a


successful expansion effort and we will continue to explore ways


to improve this process. While some regional offices and


Headquarters staff may have experienced communication problems


which may have caused unnecessary delays in the expansion


process, several regions reported that their expansion efforts


were successful and their relationships with Headquarters staff


were posi ti ve. 

Technical Comments


Page 1	 The first sentence of paragraph five refers to "ACYF


regional staff" which do not exist; we suggest that


the acronym "ACYF" be deleted. It should also be noted


in this sentence that grants are awarded and monitored


by staff in the AIer ican Indians Programs Branch and


Migrant Programs Branch, as well as by regional staff


in the Office of Community Programs.


Page 2 On the first line, "$1. 95 billion " should be changed to


$195 million.


Page 	 It is stated in paragraph one that 16% of the grantees 

will not apply for expansion funds in FY 1991. As 

basis for designing appropriate technical assistance to 

such grantees, it would be useful if this section is 

expanded to include additional information collected by 

OIG on the reasons for this position. 

We suggest that the following statement be added to the


end of paragraph two: "However, since the report only 

covers early expansion efforts , we do not know how much 

lead time is " enough. 

Again, thank you for the opportunity to review and comment on


th i s report. 

h:f4