Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

MIGRANT HEAD START GRANTEES: 

PERSPECTIVES AND CHALLENGES 

DECEMBER 1993 
OFFICE OF INSPE~OR GENERAL 

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

amended, is to protect the integrity of the Department of Health and Human Services’ (HHS) 

programs as well as the health and welfare of beneficiaries served by those programs. This 

statutory mission is carried out through a nationwide network of audits, investigations, and 

inspections conducted by three OIG operating components: the Office of Audit Services, the 

Office of Investigations, and the Office of Evaluation and Inspections. The OIG also informs 

the Secretary of HHS of program and management problems and recommends courses to 

correct them. 

OFFICE OF AUDIT SERVICES 

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

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

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

carrying out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations in order to reduce waste, abuse, and 

mismanagement and to promote economy and efficiency throughout the Department. 

OFFICE OF INVESTIGATIONS 

The OIGS Office of Investigations (01) conducts criminal, civil, and administrative 

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

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

administrative sanctions, or civil money penalties. The 01 also oversees State Medicaid fraud 

control units which investigate and prosecute fraud and patient abuse in the Medicaid program. 

OFFICE OF EVALUATION AND INSPECI’IONS 

The OIG’S Office of Evaluation and Inspections (OEI) conducts short-term management and


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


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


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


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


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


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


Brad Rollin, Project Leader


Elizabeth Bell


Ellen Kotler


Donald Loeb


Jennifer Mallen


Brian Pattison


Alan Levine, Program Specialist, Headquarters


For additional copies of this report, please contact the San Francisco office at (415) 556-6830.

Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENEML 

MIGRANT HEAD START GRANTEES: 

PERSPECTIVES AND CHALLENGES 

DECEWER 1993 OEI-09-91-00761 
EXECUTIVE SUMMARY 

PURPOSE 

This inspection identified and assessed the expansion experiences and challenges of 

selected migrant Head Start grantees and delegates. 

BACKGROUND 

At the Federal level, the Department of Health and Human Services’ (HHS) 

Administration for Children and Families (ACF) is responsible for administering Head 

Start. The ACF awards grants to a public or private nonprofit agency (called a 

grantee) to operate a Head Start program. A grantee may contract with one or more 

other public or private nonprofit organizations in the community (called delegates) to 

run all or part of its Head Start program. The Migrant Programs Branch within 

ACF’S Head Start Bureau oversees all migrant grantees. Nationally, 28 grantees serve 

approximately 28,000 migrant children with a total annual budget of $88.8 million. 

Migrant Head Start provides valuable services to a population that otherwise might 

not receive them. Migrant families’ lives are complicated by their transitory nature, 

language and cultural barriers, and inexperience “navigating the system.” Migrant 

Head Start grantees provide children with a safe place to learn while their parents 

work. They ensure that each child’s health, nutrition, and other basic needs are met. 

Like non-migrant (hereafter referred to as “regular”) Head Start grantees, migrant 

grantees also are required to identify and address the needs of the entire family. 

Migrant grantees are very different from regular Head Start grantees. They serve a 

broader age range of children--including infants and toddlers--who require different 

facilities, equipment, and staff skills. Grantees must be able to provide setices for 

children whose parents work 10 to 14 hours per day and 6 to 7 days per week. In 

addition, grantees must provide services in a shorter timeframe, because families may 

not remain in the program for more than a few weeks before leaving the area. 

Both the Administration and Congress are committed to expanding Head Start. Since 

Fiscal Year 1990, Head Start total funding has increased more than $1 billion, adding 

almost 300,000 children. Based on concerns about grantees’ ability to handle 

expansion, ACF, the Assistant Secretary for Management and Budget, and the 

Assistant Secretary for Planning and Evaluation requested that the Office of Inspector 

General (OIG) review the implementation and status of Head Start expansion. These 

Department officials were concerned that rapid expansion might jeopardize the quality 

of services that grantees provide to children and families. The Head Start Migrant 

Programs Branch Chief expressed similar concerns about the impact of expansion on 

grantees that serve migrant children and families. 

i 
This report is one in a series prepared by the OIG on Head Start expansion. Two 

other reports in the series, “Head Start Expansion: Grantee Experiences” 

(OEI-09-91-O0760) and “Evaluating Head Start Expansion through Performance 

Indicators” (OEI-09-91-00762), describe regular Head Start grantees’ experiences with 

expansion. 

During September 1992, we conducted on-site visits and structured intemiews with six 

migrant Head Start grantees and delegates whose enrollment totals 28 percent of all 

children in migrant Head Start nationally. We selected the grantees and delegates 

based on the size of their expansions in 1990 and/or 1991. During the interviews, we 

asked grantees to describe their experiences and opinions about operating a Head 

Start program and their predictions about the future. Our goal was to obtain 

information that would provide a “snapshot” of selected migrant grantees’ ongoing 

operations as well as their experiences with expansion. In response to ACF’S 

comments on the draft report, we also conducted brief follow-up interviews with the 

grantees and delegates in August 1993 to obtain additional information about their 

facilities. We did not conduct a comprehensive management or file review to verify 

the accuracy of the grantees’ opinions and predictions. Nevertheless, we believe our 

findings will offer policymakers valuable information about major issues and problems 

facing migrant grantees. 

FINDINGS 

The following findings reflect the experiences and opinions of the six migrant grantees 

that we interviewed, 

Some Herd Startper$onnancereqtiementr muy not be approphte for migrantgrantees 

The sampled grantees expressed concerns about many of the major performance 

standards, including parent involvement, home visits, medical and dental screens, and 

enrollment and education. Although ACF recognizes that the standards should not be 

strictly interpreted for migrant grantees, specific guidelines have not been developed 

and disseminated. 

Some of theproposedinfantand todkilerprogmmstandard maybe u.nreai’htic 

Some migrant grantees may not be able to comply with several of the requirements 

contained in the proposed Head Start standards. Grantees are particularly concerned 

about the standards concerning child-to-staff ratios and medical examinations. The 

ACF is aware of this and will consider the grantees’ concerns and comments before 

the standards are finalized. 

ii 
LM@ed jimdingand unrehhbletif~tion about the migrantpopdahn @IU@@ 

hiiader grantees’ abilitytoplan 

All sampled grantees reported that delayed expansion funds inhibited planning, forced 

loans, and caused carry-over balances. In addition, the grantees experienced planning 

problems because of the lack of demographic information about migrants and the 

migrant stream. 

The six grantees described difficulties acquiring adequate and affordable facilities, 

providing transportation for children, hiring qualified staff, and meeting the Federal 

match requirement. The grantees overcame these problems but are concerned that 

the problems will be exacerbated with future expansions. 

Gmnteesare concernedthatongoingandfdure changesin the natureof m&rantwok 

may hindertheu abilityto servemigrantfamilies 

New job opportunities and conflicting agency definitions of the term “migrant” may 

present barriers to serving migrant families in the future. 

Sarnpkdgranteescitedprobkms withthe on-sitereviewprocm, the statisticalreprting 

req&men@ and the MigrantRograms Branch 

Some grantees have a strained relationship and difficulty communicating with the 

Migrant Programs Branch. 

RECOMMENDATION 

7%eACF shouldincludeprobkns specificto the migrantprogramin the reviewof Head 

start%management 

In the OIG report “Evaluating Head Start Expansion through Performance Indicators,” 

we recommended that the Secretary convene a task force to review ACF’S 

management of the Head Start program. On June 11, 1993, the Secretary appointed 

the Advisory Committee on Head Start Quality to conduct an in-depth study of the 

Head Start program with particular attention to issues identified in the OIG reports 

“Head Start Expansion: Grantee Experiences” and “Evaluating Head Start Expansion 

through Performance Indicators.” The Secretary asked the Advisory Committee, which 

is chaired by the Assistant Secretary for Children and Families, to develop 

recommendations to improve and strengthen the program in a time of expansion. 

As a result of this inspection, we recommend that the Advisory Committee include 

migrant Head Start in the examination. Because the migrant program is unique, the 

review also should: 

... 

111

determine whether separate performance standards for migrant programs 

would be appropriate, 

assess the cost and potential impact of the proposed infant and toddler 

program standards on both ACF and grantees, 

determine whether funding and expansion cycles should be tailored to migrant 

grantees, 

address the changing role of migrant work and whether changes in ACF’S 

definition of “migrant” are necessary, 

determine when it would be appropriate for migrant grantees to purchase 

property, 

evaluate the timing of the PIR process and the accuracy of PIR data, 

evaluate the role and effectiveness of the Migrant Programs Branch, and 

identify other areas where ACF should grant flexibility to grantees who are 

experiencing difficulties serving migrant ~amilies. 

AGENCY COMMENTS AND OIG RESPONSE 

We received written comments on the draft report from ACF. The ACF noted that 

the migrant program would be reviewed as part of the overall review of the Head 

Start program ordered by the Secretary. The full text of ACF’S comments appears in 

the appendix. In response to ACF’S comments, we conducted follow-up interviews 

with grantees to obtain additional information about their facilities. The final report 

incorporates information from the follow-up interviews, including more detail about 

the facility purchase issue. We also made technical corrections to the findings, 

clarified that the report is based on the grantees’ opinions and experiences, and 

modified the recommendation to ensure that it more accurately describes the issues 

that the Head Start task force should study. 

iv 
� 

� 

� 

� 

� 

� 

TABLE OF CONTENTS 

PAGE 

EXECUTIVE suMMf=Y 

1 

INTRODUmON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

Performance Requirements for Migrant Grantees . . . . . . . . . . . . . . . . . . . . . . . 

Infant and Toddler Progam Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

.8


Grantees’ Inability to Plan.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

..10


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

. 12


Changing Nature ofMigrantWork . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

On-Site Review Process, Statistical Reporting Requirements, . 12 

and the Migrant Programs Branch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

. 15 

RIZOMMENDAnON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

APPENDK. ACFComments 

7 

7 

8 
INTRODUCTION 

PURPOSE 

This inspection identified and assessed the expansion experiences and challenges of 

selected migrant Head Start grantees and delegates. 

BACKGROUND 

Head Start operates on the premise that children are best prepared for success in 

school when they and their parents participate in a comprehensive program that 

addresses their educational, economic, social, physical, and emotional needs. In 

addition to providing children with classes and health services, Head Start addresses 

the needs of the entire family. 

lhe Head StartI?ogram 

Head Start is a child development program funded primarily by the Federal 

government. The Administration for Children and Families (ACF) is responsible for 

administering Head Start. At the headquarters level, ACF’S Head Start Bureau 

provides leadership and develops legislative and budgetary proposals for Head Start 

management and operations. In each regional office, ACF’S Head Start and Youth 

Branch monitors all Head Start programs, except migrant and Native American 

programs, which are monitored by branches within headquarters. According to ACF, 

Head Start served approximately 622,000 children with Federal support of $2.2 billion 

in Fiscal Year (FY) 1992. 

Head Start programs are community-based, so agencies can respond to local needs 

and coordinate with other community organizations. As a result, program options, 

locations, and hours vary. The Federal government awards grants to a public or 

private nonprofit agency (called a grantee) to operate a Head Start program. A 

grantee may contract with one or more other public or private nonprofit organizations 

in the community (called delegates) to run all or part of its Head Start program. For 

the purposes of this report, we will refer to both grantees and delegates as “grantees” 

unless specific differences need to be noted. 

Head Start programs consist of four major components: health, education, social 

services, and parent irzvolvenzent. Specific performance standards, which have been 

published in the Code of Federal Regulations, require among other things that 

grantees: 

� develop children’s intellectual skills by encouraging them to solve problems, 

c provide children medical and dental examinations, 

1

� offer children nutritional meals and snacks, and 

�	 identi@ families’ social service needs and work with other community agencies 

to meet those needs. 

All grantees must comply with the performance standards. In addition, ACF has 

issued guidance material which elaborates on the intent of the performance standards 

and provides methods and procedures for their implementation. The guidance 

material, however, is not mandated. 

Mi~nt Head Start 

In 1969, Congress funded the Indian and Migrant Programs Division (IMPD) to 

separate Native American and migrant Head Start from regular Head Start 

administration. In 1984, IMPD split into two separate branches. Today, ACF’S 

Migrant Programs Branch oversees all migrant Head Start grantees. Nationally, 

28 grantees serve approximately 28,000 migrant children with a total annual budget 

of $88.8 million. 

The ACF limits eligibility for migrant Head Start to families 

...with children under the age of compulso~ school attendance who 

change their residence by moving from one geographic location to 

another, either intrastate or interstate, within the past 12 months, for the 

purpose of engaging in agricultural work that involves the production 

and hawesting of tree and field crops and whose family income comes 

primarily from this activity [45 CFR 1305.2(1)]. 

Migrant grantees may administer hornestate and/or upstream Head Start programs. 

Homestate grantees provide services from 6 to 9 months per year in what is 

considered a migrant family’s home State. Upstream grantees provide services for 

3 to 7 months to families as they travel in search of agricultural work. 

Migrant Head Start provides valuable services to a population that might not 

otherwise receive them. Migrant families face numerous barriers to obtaining services 

on their own. Their lives are complicated by their transitory nature, language and 

cultural barriers, and inexperience “navigating the system.” Often they are unable to 

obtain services such as housing assistance and Medicaid, because they are not 

residents of that State or locality. Migrant Head Start addresses these problems and 

more. Grantees provide children with a safe place to learn while their parents work. 

They ensure that each child’s health, nutrition, and other basic needs are met. Like 

regular Head Start, migrant grantees also are required to identify and address the 

needs of the entire family. 

2

Migrant Head Start programs face unique challenges. For example: 

Grantees serve children O to 6 years old, compared to regular Head Start 

grantees who serve primarily 3- to 5-year-olds. Serving infants and toddlers 

requires different facilities, equipment, staff skills, and more staff per child. 

Grantees sometimes must move their facilities if the migrant stream changes 

due to weather or crop conditions, 

Grantees often must provide services such as health screenings and social 

sefice referrals in a shorter timeframe because of the short program year and 

the fact that families may not remain in the program for more than a few 

weeks. 

Because of the nature of agricultural work, grantees often must provide services 

for 10 to 14 hours per day and 6 to 7 days per week. 

Grantees must have qualified, bilingual staff to serve migrant families 

effectively. 

Grantees must heir) families obtain services--such as Medicaid and State or 

local social service~--that are difficult to arrange because of migrant families’ 

transitory nature. 

To assist with planning, some grantees use the Department of Education’s Migrant 

Student Record Transfer System (MSRTS). The MSRTS is designed to track schoolage children through the migrant stream. Migrant Head Start grantees may find 

MSRTS data useful when attempting to determine how many families will enter their 

service areas during a particular year. 

l%posed Standard%for Infant$,T&ikKs, andl?egnant Women 

In June 1990, the Department issued a Notice of Proposed Rulemaking specifying 

requirements that govern the operation of Head Start programs serving infants, 

toddlers, and pregnant women. Essentially, the proposed regulations are intended to 

ensure quality sewices and require that: 

�	 grantees maintain low child-to-staff ratios for toddlers and infants. The ratios 

vary depending upon the age of the children and how many are in each class. 

The lowest ratio is 3-to-1, for children less than 2 years old in a classroom of 

6 children or less; 

�	 grantees obtain physical exams for infants and toddlers at ages 1 month, 

2 months, 4 months, 6 months, 12 months, 15 months, 18 months, 24 months, 

and 36 months; 

3

�	 each teacher obtain a Child Development Associate credential to serve infants 

and toddlers within 2 years; 

� each grantee provide 40 hours of pre-semice training to all teachers’ aides; and 

�	 grantees adapt other health, education, nutrition, social services, and parent 

involvement requirements, as appropriate, to meet the unique differences of 

serving infants, toddlers, and pregnant women. 

Head,Stat Expansion 

Both the Administration and Congress are committed to expanding Head Start. The 

Head Start Supplemental Authorization Act of 1989 and the Dire Emergency 

Supplemental Appropriation of 1990 marked the beginning of expansion for all 

grantees and provided funding for the first two expansions. Since FY 1990, Head 

Start total funding has increased more than $1 billion, to an FY 1993 total of 

$2.779 billion. In addition to the funds that were allocated for expanding enrollment, 

ACF set aside approximately $612 million for, among other things, quality 

improvement, salary enhancement, cost-of-living increases, and training and technical 

assistance improvement. 

The ACF allocated expansion funds differently for migrant grantees than for nonmigrant programs. Although ACF allocated funds differently for each expansion, in 

general, it allocated funds (1) to existing grantees in proportion to each grantee’s 

overall budget, (2) for grantees to compete to serve previously unsemed areas, and 

(3) to existing grantees based on a specific area’s need, The following chart illustrates 

the migrant Head Start program’s first 3 years of expansion: 

MIGRANT HEAD START EXPANSION, 1990-1992 

Fiscal


Year


1990


1991


1992


~TAL 

&


Expand


Enrollment


$7,515,523


$9,766,305


$2,422,430


$19,704S8


FundsAllocatedto: 

Improve
Program


Quality


None


$3,723,636


$1,720,897


$5,444933


1 

Provide
 Cost-of-Living


Adjustments


None


$117,522


$182,418


$299,940


MigrantI?ogramsBranchUvemigti 

The Migrant Programs Branch monitors compliance with Head Start performance 

standards primarily by conducting on-site reviews. During site visits, review teams 

assess compliance with the performance standards using the On-Site Performance 

Review Instrument (OSPRI). The Human Services Reauthorization Act of 

4 
1990 amended the Head Start Act and requires that ACF review each grantee or 

delegate at least once every 3 years to measure compliance with the performance 

standards. The Head Start Improvement Act of 1992 requires that ACF also review 

each new grantee or delegate after its first year and conduct follow-up reviews of all 

grantees when appropriate. 

In addition to conducting on-site reviews, ACF requires each grantee to report 

performance data annually using the Program Information Report (PIR). The PIR 

contains data that ACF can use to assess individual grantee and overall program 

performance. 

Concerns aboutExpansibn 

The ACF, the Assistant Secretary for Management and Budget, and the Assistant 

Secreta~ for Planning and Evaluation requested that the Office of Inspector General 

(OIG) review the implementation and status of Head Start expansion. Since migrant 

grantees were not included in the other OIG studies on expansion (see the following 

paragraph), the Chief of the Migrant Programs Branch requested that we conduct this 

inspection to assess their experiences. 

This report is one in a series prepared by the OIG on Head Start expansion. “Head 

Start Expansion: Grantee Experiences” (OEI-09-91-00760) used interviews to describe 

the experiences of regular Head Start grantees and ACF staff during the 1990 and 

1991 expansions. According to the grantees, expansion posed problems for them in 

such areas as child enrollment, facility acquisition, staffing, transportation, and social 

semices. In a companion report, “Evaluating Head Start Expansion through 

Performance Indicators” (OEI-09-91-00762), we assessed the impact of expansion on 

regular grantees using file reviews and selected indicators. While we did not find any 

statistically significant difference in grantee performance as a result of expansion, we 

found that the level of grantee performance as measured by our indicators was 

considerably lower than the level of performance reported by grantees and published 

by ACF. Because of inadequate grantee record keeping, the lack of specificity in the 

Head Start performance standards, and the fact that many grantees disregard ACF 

policy guidance, we were unable to determine if the program and performance data 

weaknesses that we found reflect serious deficiencies in the quality of services 

provided by Head Start. 

METHODOLOGY 

We selected three migrant grantees and three delegates based on the size of their 

expansion in 1990 and/or 1991. To establish the selection brackets, we divided the 

amount of each grantee’s expansion by its total budget. We divided the grantees and 

delegates into thirds based on the resulting percentage of expansion--small, medium, 

and large expansion--and selected one from each bracket. In order to achieve a fairly 

representative sample, additional selection criteria included geographic location and 

the overall size of the program. The total funded enrollment of the six grantees was 

5 
approximately 7,800. This represents 28 percent of all children enrolled in migrant 

Head Start nationally. 

During September 1992, we conducted on-site visits and interviews with each migrant 

Head Start program director and other appropriate staff. For the delegates in our 

sample, we also conducted interviews with their parent grantees. At each site, we 

visited the facility and several migrant campsites. In addition, we briefly examined the 

grantee’s records and file maintenance. During the interviews, we asked grantees to 

describe their experiences and opinions about operating a Head Start program and 

their predictions about the future. Our goal was to obtain information that would 

provide a “snapshot” of six migrant grantees’ ongoing operations as well as their 

experiences with expansion. In response to ACF’S comments on the draft report, we 

also conducted brief follow-up interviews with the grantees and delegates in August 

1993 to obtain additional information about their facilities. 

We did not conduct a comprehensive management or file review to veri~ the accuracy 

of the grantees’ opinions and predictions. Nevertheless, we believe our findings will 

give policymakers valuable information about major issues and problems facing 

migrant grantees. 

We conducted this inspection in accordance with the QwUy Stan&r&for Inspections 

issued by the President’s Council on Integrity and Efficiency. 

6

FINDINGS


7he folkwvingjindingsreflectthe experiencesand ophziimsof the six mipnt granteesthat 

we inkwiewed 

SOME HEAD START PERFORMANCE REQ UIREMENTS MAY NOT BE 

APPROPRIATE FOR MIGRANT GRANTEES 

The six migrant grantees that we visited have difficulty meeting some of the Head 

Start performance requirements because of the short program year, large client 

turnover, and varied ages of enrolled children. In general, grantees believe that the 

performance standards should be flexible and take into account the length of the 

school year and the short period of time that a family is involved with the program. 

The grantees expressed concerns about several of the major performance standards, 

including parent involvement, home visits, medical and dental screens, and enrollment 

and education: 

Parent Involvement All six grantees indicated that they have difficulty meeting the 

parent involvement requirements. Long work days and little time off prevent parents 

from becoming involved with centers. The grantees expressed frustration with their 

inability to get parents involved. One grantee stated, “We realize that there are limits 

to what we can reasonably expect when parents are working hard in the fields for 

12 hours a day and then have to go home and feed and bathe their kids. Only about 

3 to 4 percent of parents volunteer in the centers.” 

Home Visits: Grantees described particular problems meeting ACF’S home visit 

requirement. Several factors present difficult barriers for grantees attempting to 

complete the two required home visits: 

�	 families may be in the program only briefly, so it maybe difficult to complete 

home visits before a family withdraws; 

�	 migrant programs run full-day for fewer months, so there is less time in the day 

to do home visits; 

�	 high enrollment turnover increases the number of home visits that grantees 

need to complete overall; and 

�	 some parents don’t have time or are too tired to participate in home visits 

because of their long workdays. 

Medieal and Dental %reenx In general, grantees--particularly those who operate 

upstream programs--try to complete health and dental screens within 30 days rather 

than the 90 days recommended in ACF’S guidance on the performance standards. 

7

Two grantees questioned whether they should have the same health and dental 

screening requirements for infants and toddlers. “Toberequired toensure thata 

6-week-old child receive adental screen doesn’t make sense~’ said one grantee. 

Enrollment and Education Thenumber of families inagrantee’s sefice area 

fluctuates throughout the season. This causes problems maintaining consistent 

enrollment, class sizes, and average daily attendance. One grantee suggested that 

ACF allow grantees flexibility to overenroll by as much as 100 percent during certain 

parts of the program year to compensate for underenrollment during other parts of 

the program year. Another grantee recommended that ACF use a formula to prepare 

budgets and tabulate average daily attendance that is based on the sum of children 

who attended the program each day rather than the funded enrollment. 

The ACF Migrant Programs Branch recognizes that migrant grantees experience 

difficulty meeting some performance standards. Because of this, branch staff are 

flexible when determining if a grantee is in compliance with certain performance 

standards. 

SOME OF THE PROPOSED INFANT AND TODDLER PROGRAM 

STANDARDS MAY BE UNREALISTIC 

Grantees expressed concerns about the proposed standards for infants, toddlers, and 

pregnant women. Three grantees expressed concerns about the lower child-to-staff 

ratios. One grantee stated, “We need to get the children out of the camps during the 

day. It’s safer to be with us even if our facility doesn’t meet child care licensing 

standards than if they stayed in the camp, unsupemised.” 

In addition, the grantees believe that the Child Development Associate (CDA) 

credential requirement for teachers to serve infants would compound their ongoing 

problems hiring staff. “Requiring a CDA may make it impossible to hire people who 

will work in a summer program at minimum wage,” said one grantee. Two grantees 

argued that the strict physical exam schedule for infants and toddlers was prohibitive. 

One grantee stated, “There are so many physicals required. Medical exams for infants 

are important, but who’s going to pay for this?” 

The ACF is currently evaluating the proposed standards based on comments it 

received on the Federal Register publication. Some of the comments reflect the 

concerns of the migrant grantees. The ACF will take these concerns into 

consideration as it develops the final rule. 

DELAYED FUNDING AND UNRELIABLE INFORMATION ABOUT THE 

MIGRANT POPULATION FREQUENTLY HINDER GRANTEES’ ABILITY 

TO PLAN 

The six grantees described problems similar to regular Head Start in planning for 

expansions and administering services. Because of the unique nature of their 

8 
programs, however, delayed expansion funding and poor demographic information 

make even the simplest planning a challenge. 

All sixgranteesreportedthat&layed qansion funds ihhibitedpkmningforced kxm$ 

and causedcany-overbalances 

Congress determines the timing of expansion proposals and awards and bases it on the


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


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


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


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


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


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


time. Grantee comments included:


�	 We have to start planning more than a year in advance. This is too 

early for migrant programs. There can be major changes with the 

migrant population in a short time frame. 

.	 The timing of the funds is atrocious, as the money comes in August or 

September. This is too late--our program starts in June. 

.	 If we can’t get funded in a more timely manner, we may not accept 

future expansions after 1993. 

None of the grantees experienced any difficulty obtaining ACF’S approval for carryover balances. 

% lackof demographicinformationabout rnigrantiand the migrantstreamcauses 

pkmnihgproblemsfor allsixgrantetx 

Grantees are responsible for estimating the number of migrant children who will be in 

their area in order to plan their program years and apply for expansion. They 

sometimes rely on growers and migrant team leaders to give them any available 

information about the number of migrants who will be in the area. These sources are 

informal and are not always able to provide data on children. Grantees tend to 

estimate future needs based on prior years’ experiences. One grantee stated, “We 

open with a guess, and we close when we are no longer cost-effective. We try to keep 

track of the pregnant women, and we do some averaging.” 

Grantees find Migrant Student Record Transfer System data of limited use for 

planning, because (1) it is not up-to-date, (2) its definition of migrant is different from 

Head Start’s, and (3) it tracks only school-aged children. Grantees believe the Federal 

government should create a national database among all migrant agencies. This would 

allow grantees to plan 3 to 5 years in advance. 

9

SAMPLED MIGRANT GRANTEES EXPERIENCED SOME OF THE SAME 

PROBLEMS WITH EXPANSION AS REGULAR HEAD START GRANTEES 

The OIG report, “Head Start Expansion: Grantee Experiences; described the 

difficulties that non-migrant Head Start grantees encountered during expansion. The 

six migrant grantees described similar--and sometimes greater--problems acquiring 

adequate and affordable facilities, providing transportation for children, hiring 

qualified staff, and meeting the Federal match requirement. 

Facilities Migrant grantees face the following barriers to facility acquisition: 

availability, affordability, inability to purchase, timing of expansion awards, and 

licensing. In addition, community prejudice, the transitory nature of the migrant 

population, and different licensing requirements for facilities serving infants and 

toddlers have made these problems more difficult to overcome. “We need a break 

from the laws,” said one grantee. “Right now we can’t serve infants and toddlers in 

the same building as preschoolers.” 

Five of the six grantees expressed a desire to purchase property for their centers, 

which will be possible under the provisions of the Head Start Improvement Act of 

1992. “Head Start has renovated more churches than we can count,” said one grantee. 

Grantees recognize that weather and other factors can affect the migrant streams, but 

suggested purchasing facilities in areas with consistent migrant streams and using 

portables in outlying areas. Grantees further indicated that they would be cautious 

when using the purchase option. They would complete long-term demographic studies 

to be sure that the migrant stream would remain consistent and the facility would be 

cost-effective. 

Grantees cited examples of when purchasing facilities would be appropriate and costeffective: 

~	 One grantee indicated that it would share purchased facilities with regular 

Head Start, which would allow it to offer families integrated “one-stop 

shopping” for services. This grantee has never had to close a facility. 

�	 One grantee spent $115,000 to renovate a rented center. It has not had to 

close any of its centers in 10 years. 

*	 One grantee has had to close facilities early despite families needing the 

services because the landlord insists. 

*	 One grantee runs dozens of centers that have never had to move, even after 

15 years. 

Transportation: Providing adequate transportation is a problem for several grantees. 

Expansion has resulted in some one-way bus rides in excess of 1-1/2 hours. Grantees 

described problems with bus insurance and licensing when they cross State lines and 

10 
when bus rides are very long. In addition, grantees have difficulty hiring and retaining 

qualified bus drivers because of their long hours, short program year, and inability to 

compete with public school wages. One grantee summarized the transportation 

challenge: “Qualified bus drivers are hard to find. They are paid more in public 

school, and they don’t have to start work at 4:30 a.m.” 

Staffing Migrant grantees face greater problems hiring and retaining qualified staff 

than non-migrant programs. Long hours, short school years, low salaries, and 

inadequate benefits have resulted in severe staffing problems for several of the 

grantees. Grantees need educated staff who are bilingual, able to handle infants, 

toddlers, and youngsters, and able to perform multiple duties. Although their salaries 

are comparable to public schools, grantees believe supplemental compensation is 

necessary to recruit and retain staff who have these additional skills. 

Matching Funds: While grantees have been able to obtain some matching funds, they 

are not always able to achieve Head Start’s 20 percent match requirement. Most of 

the six grantees have obtained waivers from the Migrant Programs Branch that allow 

them to match at a lower rate. Two grantees are able to use State funds or donated 

property to meet the 20 percent Federal match requirement. The other grantees have 

limited success relying on donated services and volunteers. Migrant grantees have 

difficulty collecting contributions, because they often are viewed as outsiders by the 

local community, and parent participation is low. In addition, professional services are 

not readily available in rural areas. One grantee stated, “We are tapped out. Even 

with a waiver to 10 percent, we might not be able to expand in 1993.” 

Training and Technical Assistance: Like regular Head Start grantees, migrant 

grantees rely on in-house or private consultants for training needs, because they 

consider the training more appropriate than that offered by HHS agencies and their 

contractors. Although grantees have attended nationally-sponsored training, they 

believe that State and local training agencies, school districts, private consultants, and 

consortiums best seine their needs, because they better understand how to serve 

migrant families in their areas. Grantees believe that ACF training is most useful 

when it deals with ACF processes, rather than service delivery. Migrant grantees also 

mentioned that they frequently do not have enough time to train staff because of their 

long program hours and short program year. One grantee is considering closing a 

center briefly during the school year to conduct staff training. 

During the first 3 years of expansion, the grantees were able to overcome their 

problems with facilities, transportation, staffing, matching funds, and training and 

technical assistance. A couple of grantees, however, described lengthy delays meeting 

expansion goals and expressed concerns about expansion’s effect on staff morale. 

Also, some grantees anticipate that these problems will become more pronounced with 

future expansions. 

11

GRANTEES ARE CONCERNED THAT ONGOING AND FUTURE CHANGES


IN THE NATURE OF MIGRANT WORK MAY HINDER THEIR ABILITY


TO SERVE MIGRANT FAMILIES


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


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


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


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


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


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


Most of the migrant families we serve now have jobs working in the food 

processing plants. We’re concerned that these people may not qualify 

for migrant Head Start in the future. The manager of the processing 

plant told me that if it were not for the migrants, he would not be able 

to operate his plant. And these families are experiencing the same 

problems and issues as families working in the fields. 

Grantees expressed concerns about service agencies that use a different definition of 

“migrant.” Migrant health and education agencies use different eligibility rules than 

migrant Head Start. One grantee commented, “Various definitions of migrant by 

different agencies tend to break families apart into bureaucratic pieces. If we all 

worked together, the whole would be greater than the sum of the parts.” 

SAMPLED GRANTEES CIT’ED PROBLEMS WITH THE ON-SJT’E REVIEW 

PROCESS, THE STATISTICAL REPORTING REQUIREMENTS, AND THE 

MIGRANT PROGRAMS BRANCH 

All six grantees provided specific details about problems with the Migrant Programs 

Branch’s on-site review (OSPRI) process, difficulties completing ACF’S Program 

Information Report (PIR), and communication problems with the Migrant Programs 

Branch. 

Granteesdescribedcon.a k the OSPMprocess and complainedabout the kzckof 

timelyfeedback concemhg OSP~findings 

A majority of the six grantees expressed frustration with OSPRI teams who they 

believed were unfair, biased, or “out to find something.” According to the Migrant 

Programs Branch, some of the frustration may have resulted from the vague 

performance requirements and the Branch’s recent attempts to provide more direct 

oversight of migrant programs. 

The OSPRI review teams include staff from other Head Start grantees as well as staff 

from the Migrant Programs Branch. The grantees we intemiewed said that OSPRI 

team members often have preconceived notions about how a migrant Head Start 

program should be administered, based on the way they operate their own programs. 

12 
This occurred despite instructions from the Migrant Programs Branch to OSPRI team 

members emphasizing that they “must understand there are several ways and styles of 

meeting the Performance Standards,” One grantee explained, “The OSPRI team 

members say ‘We don’t do it this way at our center.’” In addition, two grantees 

claimed that the OSPRI teams either lacked knowledge about the performance 

standards or did not understand the challenges of seining migrants. 

Grantees also believe that delays receiving OSPRI reports and feedback cause 

uncertainty about whether they’re complying with ACF’S performance requirements. 

One grantee stated, “We still haven’t received a reply to our response to our 

1990 OSPRI. We don’t know whether or not we’re on the right track with our 

improvement plan.” 

% PIR rnuynot to be an ~ective informationgatheringtoolf~ rni~nt Head Start 

The OIG report entitled “Evaluating Head Start Expansion through Performance 

Indicators” (OEI-09-91-O0762) found that ACF’S directions for completing the PIR 

sometimes conflict with the performance standard requirements. Migrant grantees 

offered other criticisms about the substance and timing of the PIR. In their opinion, 

the report does not measure quality, and the timing is unrealistic. 

Grantees believe that if they are going to complete a PIR, it should be tailored to


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


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


enrollment fluctuation and the children’s ages. Grantees also believe that the PIR


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


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


quality of the service provided.”


Four grantees expressed frustration with the timing of the PIR. The ACF requires 

grantees to submit the PIR in May, which is the end of the program year for regular 

Head Start. This is unrealistic for many migrant grantees, since they often administer 

summer programs, and May is in the beginning or middle of their school year. 

Therefore, these grantees may submit PIR data that is incomplete or misleading, 

because it (1) represents only a small part of their program year, (2) is derived from 

parts of two different school years, or (3) represents services provided during the 

previous school year which may have ended several months before. 

Some granteesreprt comrnunicationproblemswiththe MigrantIYogramsBranch 

While most grantees complimented the enthusiasm of the Migrant Programs Branch 

staff, they complained about communication lapses, the inaccessibility of staff, and 

delays in funding approvals. Although grantees believe that the Migrant Programs 

Branch has improved under its current leadership, they have trouble communicating 

with staff on a day-to-day basis. Grantees frequently complained about the 

inaccessibility of Migrant Programs Branch staff when immediate technical assistance 

13

or approval for operating decisions is needed. At any given time, most or all of the 

staff may be unreachable, because they are conducting on-site reviews, “A big 

problem has been getting approval for renovations,” said one grantee director. “We’ve 

been delayed 2 to 3 months. We try to call, but their voicemail is often full, because 

they’re always in the field conducting on-site reviews.” 

14

RECOMMENDATION 

THE ACF SHOULD INCLUDE PROBLEMS SPECIFIC TO THE MIGRANT 

PROGRAM IN THE REVIEW OF HEAD START’S MANAGEMENT 

In the OIG report “Evaluating Head Start Expansion through Performance Indicators,” 

we recommended that the Secretary convene a task force to review ACF’S 

management of the Head Start program. On June 11, 1993, the Secretary appointed 

the Advisory Committee on Head Start Quality to conduct an in-depth study of the 

Head Start program with particular attention to issues identified in the OIG reports 

“Head Start Expansion: Grantee Experiences” and “Evaluating Head Start Expansion 

through Performance Indicators.” The Secretary asked the Advisory Committee, which 

is chaired by the Assistant Secretary for Children and Families, to develop 

recommendations to improve and strengthen the program in a time of expansion. 

As a result of this inspection, we recommend that the Advisory Committee include 

migrant Head Start in the examination. Because the migrant program is unique, the 

review also should: 

determine whether separate performance standards for migrant programs 

would be appropriate, 

assess the cost and potential impact of the proposed infant and toddler 

program standards on both ACF and grantees, 

determine whether funding and expansion cycles should be tailored to migrant 

grantees, 

address the changing role of migrant work and whether changes in ACF’S 

definition of “migrant” are necessary, 

determine when it would be appropriate for migrant grantees to purchase 

property, 

evaluate the timing of the PIR process and the accuracy of PIR data, 

evaluate the role and effectiveness of the Migrant Programs Branchj and

identify other areas where ACF should grant flexibility.- to grantees who are 

experiencing difficulties serving migrant families. 

AGENCY COMMENTS 

We received written comments on the draft report from ACF. The ACF noted that 

the migrant program would be reviewed as part of the overall review of the Head 

15 
Start program ordered by the Secretary. The full text of ACF’S comments appears in 

the appendix. 

OIG RESPONSE 

In response to ACF’S comments, we conducted follow-up interviews with grantees to 

obtain additional information about their facilities. The final report incorporates 

information from the follow-up interviews, including more detail about the facility 

purchase issue. We also made technical corrections to the findings, clarified that the 

report is based on the grantees’ opinions and experiences, and modified the 

recommendation to ensure that it more accurately describes the issues that the Head 

Start task force should study. Specifically, we now recommend that the task force (1) 

examine what the Federal government (rather than ACF alone) could do to tailor 

funding streams to migrant grantees and (2) assess how the Head Start facility 

purchase provisions should apply to migrant grantees. We still believe that ACF’S 

regulation and oversight of migrant grantees using performance standards and funding 

cycles that are not tailored to them causes problems. 

16

APPENDIX


ACF COMMENTS 

DEPARTMENT OF HEALTH& HUMAN SSRVICES


. .. ... ..- .,,,,,- -’.. . 

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mm AupEt2,1993 DIG.AB — 

To:


FROM: 

Actina !!!!!!:%i+~”:y’ tisistant ec etsrv 

Ii!?iiz. ,,­ for‘Childrenand Famili&3 

SUBJECT: Comments on Draft Office of Inspector General Report on Uigrant Head Start Grantees (OEI-09-91-00761) 

Thank you for the opportunity to review the draft Office of 

inspectorGeneral report entitled ‘WXi.grantHead Start Grantees:


Perspectives and Challenges.W


We believe that the report highlights some of the unique 

conditions facing Migrant Head Start grantees and sone of the 

problems they face because of these conditions. For example, we recognize that the changing nature of migrant work must be 

addressed as Head Start expands, and that migrant grantees, like 

nany Head Start programs, have experiencedproblems dealing with 

the rapid expansion of Head Start. 

he with your report *Head Start Bxpansion: Grantee Experiencesn


(OEI-09-91-00760),however, we have concerns about the way in 

which the information for the report was gathered end the 

presentation of some of the findings. The general aomments which 

we made on the methodology of that report apply to this reportas 

well. AS we did then,we now suggest‘thatthe reportprovide more descriptive information on the methodology used so that the 

reader will be aware that, in some instancee, opinions or 

‘predictions*were elicited from the interviewees* (March 15, 

1993 memorandum from Laurence J. Love to Bryan B. Mitchell, 

included as Appendix A to the above-cited report, page 2). “me 

result of the methodology used is a series of grantee opinions 

which are not balanced by information provided by program 

officials which would put those opinions in context. certain of 

the grantee opinions reported are not factually based, and some reflect self-interest on the part of the grantee or delegate 

agency.


In addition to the general comments noted above, we have several . specific comments, as follows: 

6E :2 ;:.j<- J:; Q.; 

A-1

Page 2 - Bryan B. Mitchell


�	 With respect to your findingthat some Head Start 

PerformanceStandardsmay not be appropriatefOr 

�igrant granteee,the Migrant Programs Branch and the 

Head Start Bureauwork plans for this year include a review of selectedPerformance Standards whioh will 

consider the comments of migrant grantees. While we 

recognizethat some grantees aay have difficulties 

meeting the PerformanceStandards,we do not envision 

dilution of the Performance Standards for migrant 

grantees. Rather, we will focus trainingind technical 

assistanceeffortson those granteeswhich have 

difficultymeeting the Performance Standards. 

�	 On page 8, with regard to concernsabout pending 

regulations,the infant and toddler standardsare in 

draft form and migrant programstviews are being 

actively consideredin developingthe final rule. 

�	 On pages 8 to 10, concerningthe fundingoycla and 

demographicdata, we have several comments. Funding 

for the Higrant Head Start programs comes from the 

appropriation for all Head Start programs under the 

Head Start Act in an annual cycle determined by the 

Bxecutive Branch and the Congress. The finding 

concerning fundingand planning is not clear, since 

migrant granteeshave considerablynore time to plan 

than other grantees because their services do not begin 

until the Spring months. (Ironically,on page 9 you 

include a comment from a grantee which complainsof


being given too much tine to plan.) With respect to


demographicdata, we are funding a study which will


improve our data on migrant children. However, it


should be noted that all Head Start grantees are
 responsiblefor obtainingdemographicdata for their


particularservice areas. National data are important


to provide a frameworkfor assessingthe unmet need for


Migrant Head Start services,but no outside, broad


survey will substitutefor local data collectedby


grantees.


�	 On pages 9 and 10, the discussionof facilitiesh 

lacking in context and misleading. The purchase of 

facilitiesby migrant granteeswould, in most 

instances,be inconsistentwith the nature and aim of 

the Migrant Head Start program. Migrant streams change 

due to changes in weather,growing areas, crops and 

urbanizationpatterns. Furthermore,the use of 

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Page 3 - Bryan B. Mitchell 

portable modulars has.been wall supported by the 

Nigrant Branoh. Since Ootober 1991, the purohase of 

approximately 20 portables has been approved. 

9� On page 12, the discussion of monitoring teams also 

lacks context andcontainsunsupportedstatements. For 

SXample, the repOrt states that ‘A BSjOdty of the SiX 

grantees expressedfrustration and anger with OSpRI 

teams who they believed were unfair, biased, or ‘out to 

find something.tw Monitoring is done to measure a 

granteets compliance with the performance Standards and 

other applicable policies and to find if the grantee is 

meeting the Performance Standards and properly 

administering the program. It is also not true that 

Membersof monitoring teams lack knowledge about the 

Performance Standards or do not understmd the 

challenges of serving migrants. Virtually all *rS 

of monitoring teams are qualified staff from other 

migrant programs, ohosen for their knowledge of and 

experience lnm@rantHeadS tart. Inaddit~on, me 

Branch has developed and distributed to programs a 

manual governing the compliance reviews, and has 

carefully trained selected peer reviewers. 

�	 The points made about the timing of thePIR (page 12) 

are valid, and the Head Start Bureau has stated in this 

yearle work plan its intentionto solve this problem by 

adjusting the reporting dates for migrant program data. 

�	 With regard to the recommendations, we note that the 

migrant program will be reviewed as part of the overall 

review of the Head Start program ordered by the 

Secretary. 

Thank you again for the opportunity to comment on this draft 

report. If you have any questions on this memorandum, please 

contact Joseph Mottola on 205-8347. 

A-3