..J . -1 

Deparment of Health and Human Services 

OFFICE 

INSPECTOR GENERAL


HEAD START SELF-ASSESSMENT


f,RVICE$. 

.f Richard P. Kusserow 

INSPECTR GENERA

'0 l. FEBRUARY 1991

;fq"d3U 
Department of Health and Human Services


OFFICE 

INSPECTOR GENERAL


HEAD START SELF-ASSESSMENT


f,RVICE$. 

.f Richard P. Kusserow 

INSPECTOR GENERAL 

'0 OEI-04-89-00790

;fq"d:W 
EXECUTIVE SUMMARY


PURPOSE 

This inspection was conducted to examne self-assessment in the Head Star Progr. It 

describes the process and analyzes the utility of self-assessment to grtees and to the staff of the 

Admnistration for Childrn Youth and Famlies (ACYF). 

BACKGROUND 

Head Start Program 

Head Star is a comprehensive, pre-school child development progr designed to serve 

low-income childrn, handicapped children and their famlies. The progr is based on the 

premises that all childrn shar cenain social and cognitive development needs and that 

low-income children can especially benefit from a developmenta progr addressing those 

needs. 

Head Star is admnistered by the ACYF within the Offce of Human Development Services 

(OHDS). In Fiscal Year 1988, the program served 446,523 childrn in 1 910 local projects 

throughout the countr, with a Federal expenditue of $1.2 bilion. 

Self-As!essment 

Title 45, Par 1304 of the Code of Federal Regulations requirs every Head Sta grantee to 

conduct an annual self-assessment of its progr. These regulations give the Policy Council 

responsibilty for conductig the self-assessment. However, the regulations do not provide 

guidance on how self-assessment should be done. Grtees ar allowed to self-assess in any 

manner they choose. 

The ACYF has not developed criteria for judging the quality of a self-assessment. Many 

grantees, though, have made judgments about the effectiveness and wonh of self-assessment practices. 
FINDINGS 

This inspection found: 

Virually all grntees are conducting self-assessment annually, as required. 

Nearly all grantees (90%) use the Self Assessment Validation Instrment (SA VI) for 

conducting self assessment. However, many have concerns about its length, 

complexity and comprehensiveness. 

Policy Councils are involved in the self-assessment process in a varety of ways, 

including design, data collection, analysis and oversight. 

Every self-assessment requires a significant commtment of staff and volunteer 

resources. 

Grantees use self-assessment for a varety of puroses, including determning 

compliance with program performance standads, improving programs, garering 

additional resources, enhancing public relations and training team members. 

The ACYF uses self-assessment findigs in its review of grantees ' major refunding 

applications every third year, and as a basis for on-site monitorig of grantees. 

The self-assessment process would benefit from: 

being scheduled later in-the program year to allow for more traiing; 

improved trning by ACYF and the local grantee; and, 

improved communication/feedback between ACYF and the grantee, and within the 

grantee self-assessment team. 

RECOMMENDATIONS 

The ACYF should: 

Improve the Self-Assessment/alidation Instrment (SAVI) which grantees use for


conducting self-assessment.


Eliminate the redundancy in the instrment to make it simpler and less time-consuming. 

Simplify the terms used in the instrment in order to make it more appropriate for 

parents and other team members not famliar with Head Star termnology. 
Update the instrment to keep it current with changes in the program, for example 

by adding transponation and handicapped sections. 

Provide feedback and technical assistace which grantees fmd useful when they voluntarly 

submit their self-assessment findings. 

Develop and provide training and technical assistace to grantees on how to improve 

self-assessment. 

Grantees should:


Provide feedback to self-assessment team members and all sta on the findings and actions 

resultig from self-assessment so that they can better understand the process. 

Trai team members thoroughly so that each fully understads his/her component and 

responsibilty in the self-assessment process. 

COMMENTS ON THE DRAFT REPORT 

The comments from the Assistat Secreta for Human Development Services on the draft report 

were supponive of the fmdings and the recommendations. However, OHDS did not agree with 

an OIG recommendation in the draft repon that grtees be required to conduct self-assessments 

no earlier than March. We have deleted that recommendation from the fmal repone 
.... .................... ...... ........ ...... ........ ...... .... ...... ...... ...... ..... ................ .... .......... .............. .... ........ ......... .... ........ ........ .......... .... .. ................ ................. . ...... .... .... .... .... 

TABLE OF CONTENTS


EXECUTIVE SUMMARY 

INTR 0 D U CTI 0 N .. 

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

Ba ck groun d.......... ...... ...... .................... .... ................ .......... 

Methods........................................ ...... 

FIND IN G S .... 

Virtually All Grantees Are Conducting 

S elf - Assessments .. ............ ............ ................ ...... .... .......... 


Self-Assessment Is Useful To G ran tees .............................................................


A CYF Can Improve Self-Assessment ...............................................................


CON CL U SI 0 N S .......... .... .......... .... .... 


RECD MMEND A TI 0 NS .........................................................................................


COMMENTS ON THE DRAFT REPORT ...............................................12 .


APPENDIX 

Detailed Description of Methods.................................................................. A-


Comments on the Draft Report ....................................................................

INTRODUCTION


PURPOSE 

This inspection was conducted to examne self-assessment in the Head Star Program. It 

describes the process and analyzes the utilty of self-assessment to grtees and to the staff of the 

Administration for Childrn Youth and Famlies (ACYF). 

BACKGROUND 

Head Start Program 

Head Star is a comprehensive, pre-school child development program designed to serve 

low-income children, handicapped children and their famlies. The progr is based on the 

premises that all children shar cenain social and cognitive development needs and that 

low-income children can especially benefit from a developmental progr addressing those 

needs. 

Head Star is admnistered by the ACYF within the Offce of Human Development Services 

(OHDS). Most projects are funded and monitored by the regional ACYF offces. Head Stan is 

the only child development program that is largely Federally funded. In Fiscal Year 1988, the 

program served 446,523 children in 1 910 local projects throughout the countr, with a Federal 

expenditure of $1.2 bilion. 

Head Star is also unusual in that it is one of the few large programs of the Deparent of Health 

and Huma Services funded diectly to local grantes. Grantes include local general purose 

governments, school boards, community action agencies and single purose non-profit 

organizations. Grtees ar required to contrbute a non-federal share to their local projects, of 

at least 20 percent of the total operating amount. 

A grantee may operate the entie local project or delegate the operation of al or par of it to other 

suitable entities called delegate agencies. 

There are four component areas for all Head Star programs: education, health, social services 

and parent involvement. Head Star provides a wide varety of services across these component 

areas. 

Par of the local grant is designated for trning. Each local project has access to a Regional 

Resource Center (RRC), a contractor which is responsible for providing training on all Head 

Star components except health. 
Expectations for grantee perfonnance ar detaled in the Head Sta perfonnance stadards for


each component area. This careful blueprint is said by respondents at all levels to have


contrbuted to the program s success since its inception in 1965.


Policy Council 

Each grantee has a Policy Council (called the Policy Commttee in delegate agencies). The 

Policy Council is a group comprised of parnts of curently enrolled Head Sta children and 

representatives of the community. No more than 50 percent of the Council's members may 

community representatives. 

The Policy Council exercises approval and disapproval functions over the grantee s operations. 

The Policy Council reviews and votes on such personnel actions as promotions, hig and 

firng. It also approves grant applications, major purchases and proposed changes in program 

operations. The Policy Council is one of the priar vehicles for promotig parnt involvement 

in the local program. 

Self-Assessment 

Title 45, Part 1304 of the Code of Federal Regulations requirs every Head Sta grantee to 

conduct an annual self-assessment of its program. Head Star is one of the few Federal grant 

. programs that requires such a sophisticated self-examnation. 

The regulations give the Policy Council responsibilty for conductig the self-assessment. 

However, the regulations do not provide guidace on how the self-assessment should be done. 

Grantees are allowed to self-assess in any manner they choose as long as all component areas are 

covered. 

The ACYF has not developed criteria for judging the quality of a self-assessment. Many


grantees, though, have made judgments about the effectiveness and wonh of self-assessment


practices. Grantee staf shar these judgments with inspection team members. The


characteristics which distinguish outstanding self-assessments ar said to include:


a high degree of commitment by local Head Sta project management to the process 

of self-assessment;


the total involvement of the Policy Council in conducting the activity; 

intensive training for self-assessment team members; 

open communication providing all team members the opponunity to express their 

opinions and ideas; 
feedback to all team members on findigs and corrtive actions; and 

a formal, wrtten corrective action plan outlining the steps needed to bring the Head 

Star project into compliance with performnce standards. 

Program Monitoring 

Current ACYF policy calls for an on-site monitoring visit by ACYF staf every three years prior 

to submission of the major refundig application. 

The ACYF has developed a Self-Assessment/alidation Instrment (SA VI). The grantees may 

use the instrment to conduct self-assessment. The ACYF staf use this document to validate 

grantees ' self-assessment fmdings. The SAVI details the performance standards and is 

acknowledged by respondents at all levels to be rigorous and comprehensive. There is also a 

SA VI for Admnistration. 

METHODS 

Information for this inspection was gathered though discussions with Head Sta grantee staff 

parents and community representatives. Discussions were also held with sta of ACYF and the 

Regional Resource Centers. Additional information came from review of Head Star regulations 

and other program documents penient to self-assessment. Appendix A provides more detaled 

information regardig the methods used for this inspection. 
FINDINGS


VIRTUALLY ALL HEAD START GRANTEES ARE CONDUCTING 

SELF -ASSESSMENTS 

Policy Council Involvement 

Although Policy Councils are involved in the self-assessment process, the nature of their 

involvement vares from program to progr. Policy Council activities include planning and 

diecting the self-assessment, collecting and analyzing data, reviewing findigs and corrective 

action plans and implementing cOITective action plans. Respondents repon that the greater the 

involvement of Policy Council members in the self-assessment process, the better the process 

works. 

Use of SA VI 

Nearly all grantees (90%) use the SAVI for conductig the self-assessment. Use of the SAVI 

helps to organize data collection in all program aras and anticipates the ACYF staf validation. 

Despite its widespread use, the SA VI does cause problems for many team members. 

Respondents in 35 of the progrs which use it question the suitabilty of the SA VI for 

conducting the self-assessment. They are most concerned that the instrment is too complex and 

that parents fmd it hard to use. The Program Performance Stadards SA VI is 81 pages. It 

requires that evaluation be done on such multi-facete crteria as: 

Does the parent involvement program adequately provide methods and 

opportunities for enhancing parents parenting' skils such as: 

Experiences and activities which lead to enhancing the development 

of their skils, self-confidence, and sense of independence in fostering 

an environment in which their children can develop to their full 

potential... " 

Most grantees (86%) have suggestions for modifying the SA VI to improve its utility in 

self-assessment. Many propose simplifying the abstract and technical terms in the document so 

that it is more understandable to parents who serve as self-assessment team members. 

Others suggest elimnatig redundancies thoughout the instrment. Many of the redundancies 

result from the inteITelated nature of the components of the Head Sta Program. For example, 

parent education, an impottt facet of Head Star, is addressed in the education, health and 

social services components of the SA VI. There is, funher, a parnt involvement component 

which covers these same parent education issues. Many grantes suggested that for 

self-assessment, once would be enough. 
Some respondents suggest that sections on trsponation and services to handicapped children 

be added to make the instrment more complete. While a SA VI instrment for the handicapped 

does exist in some regions, this inspection found that may grtees were either unaware of it or 

not using it. 

Several grtees have adapted SA VI to their own programs, for example, by simplifying it into a 

short checklist. Some grantes use a shon checklist for two years and then use the more 

comprehensive SAVI in the third year to prepare for the major refunding application. 

Commitment of Resources 

Self-assessment represents a major commtment of resources among Head Star grantees. These 

resources include:


staff time developing and delivering training to self-assessment team members. 

time spent by grntee personnel, Policy Council members and community volunteers 

receiving training and actually performg the self-assessment. 

time devoted by team members and Head Sta managers and staff developing and 

implementing solutions to problems uncovered by self-assessment. 

At Head Sta grantee and delegate agencies, the size of the resource commtment depends on the 

number of persons involved in the self-assessment. These numbers correlate roughly with the 

size of the Head Star project. Since self-assessments typically exame at least one component 

in each Head Star center, large grantees (with many centers) require much larger teams. One 

grantee included in this inspection described a self-assessment team of 64 members. 

Teams ar made up of Policy Council members, grtee sta, parnts and persons from outside 

the program. Respondents repon that a diversity of well-qualifed people improves the quality 

of self-assessment. 

Training for Self-Assessments 

Training is such an imponant par of the resources being commtted to Head Star that it deserves 

specific attention. One-half of Head Star Directors repon never having received formal training 

in conduct of self-assessment. Most of those who have received instrction were traied six 

more years ago. Directors report that this lack of training in self-assessment is a major detrment 

to the activity. 

Although many respondents report that they are unaware of available trning, al of the RRCs 

contacted can provide self-assessment traiing. The RRCs repon that this training is not often 

requested by grantees. Since RRCs usually organize training for clusters of grantees rather than 
individual grtees, it is unlikely that the RRC wil provide self-assessment traiing unless 

interest is widespread. 

Grantees train their assessment teams prior to each annual self-assessment. Traiing is usually 

organized around progr components and conducted by component coordinators or the Head 

Star Director. Typically, self-assessment training rages from two hours to one-hal day. 

Given the comprehensiveness of the widely-used SA VI, ACYF respondents question whether 

such short periods of training are adequate. Parents, to, repon that they have difficulty with 

aspects of the SA VI that reuir specialized educational background. In fact, there ar elements 

in each component of Head Star which require special knowledge. Judgments on "foods which 

broaden the child' s food experience" or the existence of an "organize health education 

program" would be diffcult without such knowledge. 

Some Head Star grtees with pancularly successful self-assessments trai team members at 

each Policy Council meeting stag in September, the beginning of the Head Sta school year. 

By the time of the self-assessment in March or Apri, the parnts on the team have received up to 

thiny-six hour of tring. In order to allow suffcient time to prepar, at least one regional 

offce now requires that grantees schedule self-assessments no sooner than March. 

GRANTEES REPORT THAT SELF -ASSESSMENT IS USEFUL 

All grantees contacted in this inspection report some positive outcomes from self-assessment. 

Head Star Directors, component coordinators and parents are pancularly positive in their 

repons. Community professionals are also enthusiastic about their parcipation. On the other 

hand, first line program staf, for example teachers and aides, tend to question the value of the 

self-assessment process which they say consumes to much time for the benefits gained. Often 

these staf are involved only in the trning and data collection phases of the activity and are not 

famliar with outcomes. 

Head Star grtees use the self-assessment process and the fmdings in five ways: 

identifying and correcting areas out of compliance with Head Star performance 

standards, 

improving program areas which ar in compliance, 

garering additional resources for the project, 

educating self-assessment team members about the Head Star program, and 

enhancing the project's public relations. 
Identifying and Correcting Areas Out Of Compliance 

Nearly all grtees (91 %) consider any negative self-assessment findig to be non-compliance 

with performce standads. If the self-assessment contas no negative findings, grantees 

consider themselves to be in compliance. Once non-compliance is determned, the Head Sta 

Director or her/his designee develops a corrctive action plan to addrss the aras out of 

compliance. 

Usually the corrective action plan is wrtten and specifies actions to be taen within specific tie 

frames. In some cases, the plan is not wrtten, but an infonnal agreement is made by the Head 

Star Director and staf to tae cenan corrective actions. A formal, wrtten corrctive action plan 

is reponed by many respondents to be superior in that it provides a common basis of 

understandig for all those involved. In many projects, the Policy Council may also vote to 

approve the corrective action plan. 


Most grantees (70%) trat self-assessment findigs of non-compliance as an internal matter. 

These fmdings ar not regularly reponed to the regional ACYF offce. 

In two instances, however, self-assessment findings are routinely reportd to ACYF: 

The findings of the most recent self-assessment ar included in the major refunding 

application. 

Where corrective actions require substantial new resources, grtees may use 

self-assessment findings to justiy requests for supplemental funding. 

Head Stan Directors repon that non-compliance uncovere though the self-assessment is 

seldom a serious problem; the shoncomings identified are usualy smal and easily corrected. 

Nor are grantees concerned that ACYF wil become aware of their non-compliance findings, as 

there is little lielihoo of a monitoring visit. 

Improving the Program 

Self-assessment results in two types of modification to Head Star projects. Most of the 

modifications mentioned in the corrctive actions plans brig the project into compliance with a 

Head Stan requirement. For example, if the self-assessment discovers a staiay accessible to 

the children, the center diector may instal a gate to bar access. 

However, every improvement does not addrss non-compliance. Other self-assessment 

follow-up actions improve operations which were alady in compliance. For example, the 

assessment team may discover and repon on an effective teaching technique or an unusually 

good set of materials in one center which could be adopted by other centers in the project. 

Respondents cite innovative ideas from parents as the most rewarding of these modifications 

because they demonstrate parent involvement in improving their children s Head Sta program. 
Garnering Additional Resources 

Grantees use the self-assessment process in two ways to increase their resources. First they use 

self-assessment findings to justify requests to ACYF for additional funding. Often these requests 

represent one-time capita expenditures to improve facilties or to purchase major equipment that 

the self-assessment shows is needed. 

The second type of increased resources comes from the expanded "Head Star famy." Many 

grantees repon that they have received additional cash, in-kind contrbutions and pro bono


services as a result of the involvement of community leaders in self-assessment and their


buy-in" to the Head Sta philosophy. Such benefits as expanded health screenings, newly


donated facilities and improved access to local social services were mentioned.


Educating Self-Assessment Team Members 

All grantees use the self-assessment activity as a vehicle for educating team members about the 

Head Star Program. Much of the staff trning is cross-component traiing. A staf member 

. who works in one area wil become familar with and assess another. Normally staf members 

assess centers other than those in which they work. Assessing other component areas and other 

centers tends to broaden staf understanding of Head Sta. 

Parents are usually trained to perform self-assessment in one component area. Such traiing 

increases their understading of how their children benefit from that component Many grtees 

cite this traiing as one of their most effective activities with parents. Yet 58% of the projects 

train parents for less than four hour. This miimal trng greatly dinishes the potential 

benefit parnts can brig to self-assessment, as well as the value that they can receive from it. 

Enhancing Public Relations 

Grantes use self-assessment findings to promote the Head Sta program in their communities. 

Some Head Star grantees use a number of community professionals on their assessment teams. 

In this way they famliarze outsiders with the Head Star program. Respondents who have 

successfully used this approach say that Head Star sells itself. 

By involving qualfied professionals from outside the Head Sta progr, grtees ar able to 

extend the "Head Star famy" in the community. The local project can be enhanced as these 

professionals share new skills and ideas. However, most grantees fail to utilze these generally 

available community resources. 
ACYF CAN IMPROVE SELF-ASSESSMENT 

Better Using Self-Assessment Results 

The ACYF staf use self-assessment repons as the basis for monitoring grantee performance. 

The ACYF policy calls for one in-depth monitoring visit every th years. The monitorig 

procedur uses the SAVI to valdate grantee self-assessments. In past year, the monitorig visit 

involved several people reviewing the progr for several days. Presently, due to limited travel 

funds in ACYF, a typical monitoring visit is more likely to be conducted by one Child 

Development Program Specialist (CDPS) for one day or less. 

ACYF staf also use self-assessment results by requirng that the most recent findigs be 

included in the major refunding package which grantes submit every three years. The findigs 

are evaluated along with other information contaned in the application; however, grtees raely 

get any feedback specifically on self-assessment findings. Most respondents repon that specific 

feedback would be helpful in many cases to assist them in resolving problems. 

Improving the Self-Ass.essmentProcess 

When ACYF staf receive self-assessment findigs independent of the refunding application 

they mayor may not respond with useful feedback to the grtee. Some of the grtees do send 

at least summar information to their CDPSs in the ACYF regional offces. Other grantees 

repon having done so in the past. 

In a few cases, the CDPSs make a signifcant effon to respond to self-assessment inormation 

from the grtees. They suggest ways to remedy shortcomings that mayhave been discovered 

by other grantees. Grantees who receive this constrctive tye of feeback report that it adds 

substatially to the value of self-assessment.


In most cases, however, grantees get no feedback from regional program staf on the findings 

which they voluntary submit. ACYF has an opportnity to improve Head Stan projects by 

increasing the quantity and quality of the feedback to grtees on self-assessment fmdings. 

A well-done self-assessment provides a very imponant framework for an abbreviated monitoring 

visit. However, respondents from both ACYF and the grantees question the effectiveness of the 

current monitoring practices. They agree that these visits ar too brief and infrquent to be 

helpful, either to the grantee or to ACYF. ACYF has an opponunity to improve its process for 

monitoring grantees, including the attention given to valdating the self-assessment. 

There is a limit to the resources that a grantee can devote to self-assessment. ACYF can help by 

improving training packages, updating the SA VI and providing a mechanism for grantees to 

share successful experiences. 
CONCLUSIONS 

Head Start grantees are peIfonning self-assessments as required. Each year, the process of 

self-assessment consumes considerable grantee time and effort. All grantees repon that 

self-assessment is valuable. The grantees use the activity and the findings in a variety of ways which strengthen their programs. 

The ACYF uses the self-assessment findings for monitoring grantee perfonnance and evaluating 

the major refunding package. These uses make self-assessment valuable to ACYF. 

Increased infonnation and feedback on self-assessment are needed to improve the activity. With 

ACYF assistance, the benefits of self-assessment to grantees could be substantially increased. 
RECOMMENDATIONS


The ACYF should: 

Improve the SAVI instrment which grantees use for conducting self-assessment. 

Eliminate the redundancy in the instrment to make it simpler and less time-consuming. 

Simplify the terms used in the instrment in order to make it more appropriate for 

parents and other team members not famliar with Head Star termnology. 

Update the instrment to keep it current with changes in the progr, for example, 

by adding sections on transporttion and services to the handicapped. 

Provide feedback and technical assistace which grantees fmd useful when they voluntarly 

submit their self-assessment findings. 

Develop and provide training and technical assistance to grantees on how to improve 

self-assessment. 

Grantees should:


Provide feedback to self-assessment team members and all staf on the. findigs and actions 

ultig from the self-assessment so that they can bettr understand the process. 

Trai self-assessment team members thoroughly so that each fully understads his/her 

component and responsibility in the self-assessment process. 
OIG RESPONSE TO OHDS COMMENTS


The comments from OHDS were in genera agrement with most of the recommendations. 

However, OHDS did not concur with a recommendation in the draft repon that grantees be 

required to conduct self-assessments no earlier than March, due to the wide range of differences 

in the individual schedules of grtees. While we believe that in general it would be more 

beneficial to conduct the self-assessment late in the program year, we acknowledge the OHDS 

concern that such a requirment would be overly prescriptive and might not allow grantees to 

follow a schedule more suitable to their own individual needs. We have deleted that 

recommendation from the final repone 

Although OHDS concured with the recommendation that the SA VI be modfied to make it more 

user friendly" and to include sections on the handicapped and trsponation, OHDS indicated 

that the SAVI would be diicult to change because it is so closely tied to the Head Star 

regulations. OHDS fuher indicated that the Head Star On-Site Progr Review Instrment 

(OSPRI), which is now being used for monitoring by OHDS regional offces, is designed to be 

more "user friendly" and has a section on children with disabilties. However, it does not 

address the transponation issue. 

As a follow-up to their fonnal response to the draft repon, OHDS sta met with the OIG and 

provided an overview of an action plan that would more fully address the repon 

recommendations. According to this action plan, which wil be submitted in grater detai to the 

DIG within 60 days, OHDS wil provide the results of this OIG inspection to all grantees and 

regional offces. In addition, sinc the OSPRI is now being utilized for regional offce 

monitoring, grntees wil be encouraged, but not required, to replace the SA VI with the OSPRI. 

Grantees wil also be encouraged to include transponation in the self-assessment; the scope and 

focus of the transporation review wil be determed by each grtee. Within the next year 

OHDS plans to establish a task force to address transporttion. One of the agenda items wil be 

how best to formally incorporate this issue into the self-assessment process. Finally, the OHDS 

action plan wil identify a policy or procedure that wil enable regional offce sta to provide 

feedback to grantees on self-assessment results that ar voluntaly submitted. 

We have included the comments from the Assistant Secreta as well as the technical comments 

and clarcations from OHDS at Appendi B. 
............ ............ .....................

APPENDIX A


DETAILED DESCRIPTION OF METHODS 

. Very little information exists on self-assessment despite the fact that self-assessments 

performed annually by all grantees. The Head Sta regulations mention self-assessment one 

time. No guidace has been developed by ACYF to clarfy either how self-assessment should be 

done or what constitutes goo quality self-assessment. 

This inspection provided an opportunity, though a large number of discussions with people 

involved in self-assessment, to determne what grtees believe to be the most imponant aspects 

of self-assessment. 

The inspection team conducted interviews with: 

A CYF staf.. ................ ...... 

Head Star grantee staf .............................................. 117 

Head Star parnts........ 

Community professionals.... ............ .............................. 33 

Regional Resource Center staf...................................... 13


TOTAL 250 

The inspection team interviewed respondents from all ten ACYF regions. Furer, the grtee 

staff represented 58 grtees, including large and smal grtees located in urban and rual settings. 

Documents reviewed included: 

pertnent sections of the Code of Federal Regulations, 

Head Star Grant Application Package, 

Head Sta Self-Assessment Validation Instrments (SA VI), 

regional and grantee-specific instrctions on self-assessment, and 

training materials provided by Regional Resource Centers. 
APPENDIX 


COMMENTS ON THE DRAFT REPORT 

Immediately following are comments on the draft repon from the Assistant Secretar for Human 

Development Services and technical comments from the Office of Human Development 

Services. 
. . . . OffiC: ot
 DEPARTMENT OF HEALTH &. HUMAN SE \\'ED Human Development Services 

ff\C OF tNSPEC TOR 

"""flO GENERAL Assistant Secretary 

25 PM q: 3 \ Washington DC 20201 

\990 Jil 


2 5 1990
 JIll 

TO:	 Richard P. Kussero 

Inspector General


FROM: Assistant Secretary for


Human Development Services


SUBJECT :	 Office of Inspector General Draft Report on "Head 

Start Self-Assessment" (OEI-04-S9-00790) 

Attached are comments on the draft report by the Office of
 Inspector General (OIG) entitled "Head Start Self-Assessment. 

In general, we support the findings of this report and believe 

that it fairly characterizes the state of' self-assessment in 

Head Start programs. It contains good information to share with 

grantees regarding "best practice" self-assessment activities. 

Moreover, it shows that self-assessment can contribute to grantees. improving the quality of services .provided by Head Start 

We appreciate the opportunity to comment on this draft report. 

Mary kfdia G 

Attachment 

I" " DIG-AS 


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DIG-OI 

AIG-MP 

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JUL 7 , I ; Db 	 EXSEC :b J.ld l1fr 0661 DATE SENT -


""V".'­ O.:.1j 

Ol 3dSNI ::O 3 

031\'3 /::::'J 
COMMNTS OF THE OFFICE OF HU DEVLOPMENT SERVICES ON THE OFFICE OF INSPECTOR GENERL' S REPORT, "HEAD START 

SELF-ASSESSMENT, " OEI-04-89-00790 

General Comment


Pages i and 2 contain references to Title 45, Part 1304 of the
 Code of Federal Regulations (CFR) which state that every Head
 Start grantee is required to conduct an annual self-assessment. 

As a point of clarification, the only regulatory reference in 

Part 1304 is Appendix B, Chart B. It states that Head Start 

grantees and delegate agencies must "Conduct self-evaluation of 

(the) agency' s Head Start program. The "operating responsibility" is assigned to the Head Start Policy Council 

Commi ttee. The reference to conducting an annual 

self-assessment is implied, since at least 50% of the membership

of Policy Councils and Committees are parents of children 

currently enrolled in Head Start, and these groups change . annually. The implication is that each Policy Council 

Committee will then be involved in a self-assessment each year. 

ACYF Recommendation #1


Improve the SAVI instruent which grantees use for conducting
 sel f-assessment. 

a. Eliminate the redundancy in the instruent to make it 

simpler and less time-consuming. 

b. Simplify the terms used in the instruent in order to 

make it more appropriate for parents and other team 

members not familiar with Head Start terminology. 

c. Update the instruent to keep it current with changes in 

the program, for example by adding transportation and


handicapped sections.


OHDS Comment 

We concur with the recommendation.


The Self-Assessment Validation Instrument (SAVI) is designed to


assist Head Start programs in determining their compliance


status with Head Start regulations, specifically 45 CFR Parts


1301, Head start Grants Administration, and 1304, the Head Start


Program Performance Standards. The organization of the SAVI


reflects that of the regulations and redundancy is attributable

to the language and organization of the regulations. Part 1304
 for example, is organized into four component areas. Al though there is a separate component for Parent Involvement, the


requirement to involve parents in all aspects of Head Start


program operations is woven throughout all component areas and


contributes to much of the redundancy. 

The Head Start Bureau has taken some steps to simplify the
 instruent that is used by Federal staff to conduct on-site moni toring reviews. During fiscal year 1990, Federal staff began using a revised instruent entitled the On-Site Program Review Instruent (OSPRI). The OSPRI is organized to minimize
 the redundancy of some Head Start regulations. In addition, we have replaced the SAVI guidance with indicators for each


regulation item to better assist the reviewer in determining


that the grantee is meeting the intent of the regulation.


After one year of use, HDS Regional staff are generally pleased


with the OSPRI, finding that the indicators make it an easier
 instruent to use. Some Regions have trained all grantees in the use of the OSPRI. Because the SAVI is not a required 

sel f-assessment instruent, many grantees have begun to use the
 OSPRI as it is the instruent Federal staff use for monitoring. Grantees are reporting that the OSPRI is easier than the SAVI


for parents and staff to use.


We have not eliminated the SAVI as an option for self-assessment for grantees. In addition to instruents grantees develop on their own, the SA VI and the OSPRI will be available for grantees
 to use for sel f-assessment. 

By fiscal year 1991, the Office of Human Development Services


plans to review the OSPRI to assure that the content and format


assist the reviewer in obtaining the information necessary to


make a compliance determination. When we do this , we will
 consider adding areas that are not currently included. The 

OSPRI now has a brief section on services to children with


disabilities. We are considering adding to this and will also 

consider adding other areas, such as transportation, to the

OSPRI. There is not a SAVI related to services to children with disabili ties or related to transportation because there are no 

regulations that address such services. Regulations covering

services to children with disabilities are, however, in the 

process of being published. 

ACYF Recommendation 


Provide feedback and technical assistance which grantees find 

useful when they submit their self-assessment findings. 

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OHDS Comment 

We concur with this recommendation.


Because of limited travel resources over the past several years,


Federal monitoring of Head start grantees declined, with
 moni toring frequently limited to problem grantees. Prior to 

this, Federal staff monitored all grantees through an in-depth


team review at least once every three years. Self-assessment 

was part of a "monitoring system" generally occurring prior to
 the on-site review. The Federal team then validated the grantee' s self-assessment findings during the review process. 

When the agency' s capacity to conduct on-site reviews declined,


the link between self-assessment and monitoring also declined.


During fiscal year 1990, Regional Offices monitored at least 25%


of the grantees they fund, a much higher percentage than was


achieved in the recent past. This trend is expected to continue


with on-site monitoring increasingly receiving emphasis. We believe that increased monitoring 'wi11 also increase the 

attention paid by Federal staff to grantee self-assessment 

resu1 ts. While we currently have not defined a national system 

for monitoring or self-assessment, we expect to do so when the 

revised Head Start Grant Application Instructions become 

effective sometime during fiscal year 1991. These Instructions 

implement a three-year grant application cycle that will require 

grantees to submit a comprehensive grant application package 

once every three years. Monitoring and self-assessment are 

expected to be linked to this cycle but we have not defined that


process at this time. The revised Instructions request that 

grantees submit information regarding the progress they have 

made in addressing self-assessment findings. This information 

will be submitted annually and will create an opportunity for


more reqular feedback to all grantees.


ACYF Recommendation 


Develop and provide training and technical assistance to


grantees on how to improve self-assessment.


OHDS Comment 

We concur with this recommendation. 

Head start Resource Centers are designed to provide large, mUlti-grantee training activities in response to needs identified by grantees. We will advise the Resource Centers 

that self-assessment training should be an option for grantees 

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when conducting training needs assessments and that they should 

be prepared to provide training in this area. In addition, the Head start Bureau is planning a Management Institute for key 

grantee staff during fiscal year 1991. Self-assessment is a 

topic that will be addressed during the Management Institute. 

Grantee Recommendations


Grantees should: 

Provide feedback to self-assessment team members and all


staff on the findings and actions resulting from


self-assessment so that they can better understand the


process. 

Train team members thoroughly so that each fully


understands his/her component and responsibility in the


self-assessment process.


Schedule the self-assessment for no earlier than March to


allow for adequate training.


OHDS Comment 

We concur that the first two recommendations are "best practice"
 activities that all grantees should address in their own 

self-assessment process. The third recommendation is affected


by plans and schedules of the individual grantees. The
 self-assessment is a key activity in the early stages of a

grantee' s planning process. All grantees have different

schedules to address. While the March to May time-frame is a 

logical and good one for many grantees , we are reluctant to 

require it for all grantees.


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