Department of Health & Human Services 

OFFICE OF

INSPECTOR GENERAL

 

 

MOST EARLY HEAD START 

TEACHERS HAVE THE REQUIRED 

CREDENTIALS, BUT 

CHALLENGES EXIST 

Daniel R. Levinson 

Inspector General 

August 2011 

OEI-05-10-00240 
 

 

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 EXECUTIVE SUMMARY

OBJECTIVES

1. To determine the extent to which Early Head Start teachers had the 

required credentials.

2. To determine the extent to which Early Head Start programs 

employed only teachers with the required credentials.

3. To describe the activities and challenges of Early Head Start 

programs in employing credentialed and trained teachers. 

BACKGROUND

In 2007, Congress reauthorized the Head Start Act and created the first 

law governing the credentialing and training of center-based Early 

Head Start teachers. The Head Start Act requires that all center-based 

Early Head Start teachers have a minimum of a child development 

associate (CDA) credential and have been trained (or have completed 

equivalent coursework) in early childhood development by 

September 30, 2010. It also requires that all Early Head Start teachers 

have training (or have completed equivalent coursework) in early 

childhood development with a focus on infant and toddler development 

by September 30, 2012. 

Federal funding of Early Head Start dramatically increased in 2009. 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) 

gave the Administration for Children & Families (ACF) an additional 

$1.1 billion to expand Early Head Start services. ACF allocated the 

Recovery Act funds to both new and established grantees, resulting in 

an increase from 714 grantees in the 2008–2009 program year to 

992 grantees in the 2009–2010 program year. 

For this study, we reviewed credentials from a sample of 221 Early 

Head Start programs operating in the 2010–2011 program year. In 

addition, we surveyed the same sample of programs about the 

challenges to meeting the education and training requirements for 

teachers.

FINDINGS

Overall, 81 percent of Early Head Start teachers had the required 

credentials. Although 19 percent of teachers did not have the required 

credentials, more than half of these teachers were pursuing them. 

Teachers from preexisting programs were more likely to have the 
 

 

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EXECUTIVE SUMMARY

required credentials than teachers from new programs developed using 

Recovery Act funds. 

Approximately one-third of Early Head Start programs employed 

only teachers with the required credentials. Thirty-five percent of 

programs employed only teachers with the required credentials, 

whereas 65 percent of programs employed at least one teacher without

the required credentials. Overall, more than half of the teachers 

employed by 89 percent of programs had the required credentials. In

3 percent of programs, 25 percent of teachers or fewer had the required 

credentials.

Nearly all Early Head Start programs reported requiring teachers to 

complete training. Ninety-six percent of programs reported requiring 

teachers to complete ongoing training. Programs identified training 

topics in the areas of infant and toddler development, safety, and 

communication methods. 

Early Head Start programs reported challenges to employing only 

teachers with the required credentials and to training teachers. 

Most programs reported challenges to either employing only teachers 

with the required credentials or to training teachers. 

Eighty-three percent reported challenges to employing only teachers 

with the required credentials because they could not find teachers with 

credentials. In addition, programs most commonly reported finding 

substitutes and managing work schedules as challenges to training 

teachers. In rural areas, other challenges to training teachers appeared 

to be more prevalent. 

RECOMMENDATIONS

Work with Early Head Start programs to ensure that all teachers 

have the required credentials. ACF should ensure that all Early Head 

Start programs employ only teachers with the required credentials. 

ACF could:

• provide additional support to programs that were newly 

developed using Recovery Act funds, 

• identify and share strategies used by programs that employed

only teachers with the required credentials, or

• work with programs that employ teachers without the required 

credentials to develop and implement an action plan.
 

 

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EXECUTIVE SUMMARY

Provide guidance to programs about training teachers.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

ACF concurred with our recommendations. ACF stated that it plans to 

issue an information memorandum to provide additional guidance for 

programs on teacher credentials and qualifications. In addition, ACF 

stated that it could provide guidance about teacher training, but that it 

could not require a certain number of training hours without a 

regulatory change. We encourage ACF to issue both the planned 

information memorandum and guidance about teacher training. We did 

not make any changes to the report based on ACF’s comments. For the 

full text of ACF’s comments, see Appendix B.
 TABLE OF CONTENTS

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

INTRODUCTION ............................................ 1 

FINDINGS ................................................. 13 

Overall, 81 percent of Early Head Start teachers had the 

required credentials .................................... 13 

Approximately one-third of Early Head Start programs 

employed only teachers with the required credentials.......... 14 

Nearly all Early Head Start programs reported requiring

teachers to complete training ............................. 15 

Early Head Start programs reported challenges to employing only 

teachers with the required credentials and to training teachers . 16 

RECOMMENDATIONS ..................................... 20

Agency Comments and Office of Inspector General Response.... 21

APPENDIX ................................................ 22

A: Estimates and Confidence Intervals ..................... 22

 B: Agency Comments ................................... 26

ACKNOWLEDGMENTS ..................................... 31
 

 

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INTRODUCTION INTRODUCTION

OBJECTIVES 

1. To determine the extent to which Early Head Start teachers had the 

required credentials.

2. To determine the extent to which Early Head Start programs 

employed only teachers with the required credentials. 

3. To describe the activities and challenges of Early Head Start 

programs in employing credentialed and trained teachers. 

BACKGROUND

In 2007, Congress reauthorized the Head Start Act and created the first 

law governing the credentialing and training of center-based Early 

Head Start teachers.1 The Head Start Act requires that all teachers 

working for center-based Early Head Start grantees have a minimum of 

a child development associate (CDA) credential and have been trained 

(or have completed equivalent coursework) in early childhood 

development by September 30, 2010.2 It also requires that all Early 

Head Start teachers have training (or have completed equivalent 

coursework) in early childhood development with a focus on infant and 

toddler development by September 30, 2012.3

Overview of the Early Head Start Program

 Hereinafter, the part of 

the law referring to teacher credentials will be called the “education 

requirement” and the parts of the law referring to teacher training will 

be called the “training requirement.” 

Established in 1994, Early Head Start provides comprehensive services 

to low-income pregnant mothers and infants and toddlers from birth to 

age 3. Early Head Start’s mission is to promote healthy prenatal 

outcomes, enhance the development of infants and toddlers, and 

promote healthy family functioning. In the 2009–2010 program year, 

the Administration for Children & Families (ACF) served more than

1 Improving Head Start for School Readiness Act of 2007, P.L. 110-134 (Head Start Act) 

§ 645A(h), 42 U.S.C. § 9840a.

2 Ibid.

3 Ibid.
 

 

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INTRODUCTION

100,000 infants and toddlers through almost 1,000 Early Head Start

grantees.4, 5

Early Head Start grantees may include local public agencies, private 

nonprofit and for-profit organizations, Native American tribes, and 

school systems. Many Early Head Start grantees subcontract to 

delegate agencies. Grantees have a formal contractual relationship 

with delegate agencies and allow delegate agencies to independently 

manage Early Head Start centers. However, grantees are ultimately 

responsible for overseeing and managing the Early Head Start centers, 

including ensuring the credentialing and training of teachers. 

Early Head Start grantees and delegate agencies may deliver: 

(1) center-based services, (2) home-based services, (3) both center- and 

home-based services, or (4) alternative services. In center-based 

services, teachers work with children in a traditional classroom setting. 

In home-based services, staff members support children and families in 

their homes by meeting language development, health, and 

developmental needs. Alternative services may include a local option 

that tests new approaches to delivering Early Head Start services or a 

family childcare option.

In the 2009–2010 program year, approximately 54 percent of Early 

Head Start grantees delivered both center- and home-based services, 

approximately 23 percent delivered solely center-based services, and 

approximately 16 percent delivered solely home-based services.6 The 

remaining 7 percent of grantees delivered alternative services.7

Federal funding of Early Head Start dramatically increased in 2009. 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) 

gave ACF an additional $1.1 billion to expand Early Head Start 

services.8 This money was distributed through the end of fiscal year 

(FY) 2010. In comparison, Early Head Start’s original FY 2009 budget 

was $710 million.9

4 Office of Inspector General (OIG) analysis of 2010 ACF administrative data.

5 The program year is the 12-month period in which Early Head Start provides services. 

Program years can start at any time from August 1 through September 15.

6 OIG analysis of 2010 ACF administrative data.

7 Ibid.

8 Recovery Act, P.L. 111-5, (Feb. 17, 2009), Title VII.

9 Department of Health & Human Services (HHS), Fiscal Year 2010 Budget in Brief, 

May 7, 2009. Accessed at http://www.dhhs.gov on February 10, 2011.
 

 

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INTRODUCTION

ACF allocated the Recovery Act funds to both established and new 

Early Head Start grantees, resulting in an increase from 714 grantees 

and delegate agencies in the 2008–2009 program year to 992 grantees 

and delegate agencies in the 2009–2010 program year.10 Using these 

funds, Early Head Start grantees and delegate agencies served 

approximately 48,000 new children.11 Overall, the Recovery Act allowed 

Head Start and Early Head Start grantees and delegate agencies to hire 

an estimated 7,000 new teachers.12

Hereinafter, Early Head Start grantees and delegate agencies that 

existed prior to the Recovery Act are referred to as “preexisting.” Early 

Head Start grantees and delegate agencies created through Recovery 

Act funds are referred to as “new.”

Early Head Start Teacher Qualification Requirements 

Education requirement. ACF promulgated regulations exclusive to Early 

Head Start teachers in 1996. The regulations state that any teacher 

working with infants and toddlers must obtain a CDA specializing in 

infants and toddlers within 1 year of hire.13

These regulations were superseded by the Head Start reauthorization. 

The reauthorization had language that was specific to Early Head Start 

teachers and removed the 1-year grace period. While the 

reauthorization is clear that teachers must receive a CDA, it removed 

the specialization of an infant and toddler CDA.

 

14

Teachers pursuing a CDA must meet specific requirements. The 

Council for Professional Recognition (the Council) administers the CDA 

national credentialing program. Teachers are eligible for a CDA from 

the Council if they have a high school diploma or equivalent, 480 hours 

of childcare experience, and 120 hours of childcare education. 

 After the 

reauthorization, Early Head Start programs had to either ensure that 

teachers currently employed had or would receive credentials by the 

2010 deadline or hire new teachers who already had credentials. 

10 OIG analysis of 2009 and 2010 ACF administrative data.

11 HHS, FY 2012, ACF, Justification of Estimates for Appropriations Committees. 

Accessed at http://www.acf.hhs.gov on May 4, 2011.

12 Ibid.

13 45 CFR § 1304.52(f).

14 The Head Start reauthorization also addressed training requirements for Early Head 

Start home-based staff and education requirements for Head Start teachers, teaching 

assistants, and education coordinators.
 

 

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INTRODUCTION

Applicants must submit proof of their childcare experience and 

recommendations from students’ parents to the Council. After 

reviewing applications, Council staff interview applicants and 

administer a written test before awarding the CDA.15

ACF recognizes other credentials as having met the education 

requirement if they are equivalent to or more advanced than a CDA. 

For example, some States or universities may award diplomas or 

certificates in early childhood education. ACF refers to these diplomas 

and certificates as “alternative credentials” and recognizes them if they 

are approved by an expert panel within ACF.

 

16 In addition, ACF 

considers associate’s, bachelor’s, or advanced degrees in early childhood 

education (or a related field with equivalent coursework) as credentials 

that equal or exceed a CDA.17 Hereinafter, any credential that meets or 

exceeds a CDA will be referred to as a “required credential.”

Training requirements. ACF has not provided guidance on the requirement 

that all teachers have training in early childhood education by 

September 2010 or the requirement that all teachers have training in 

infant and toddler development by September 2012. In the 1996 

regulations, ACF offered general guidance on training for Early Head 

Start teachers.18 The regulations state that Early Head Start teachers 

must be trained in subject areas such as infant and toddler development, 

safety issues, and communication methods.19

ACF Support for Teacher Qualifications

 However, ACF has not 

provided guidance regarding the number of hours or frequency of training. 

ACF provides funds to help improve teacher qualifications. ACF 

provides a training budget and additional quality improvement funds to 

grantees when available. Grantees may use this money to fund the 

credentialing or training of Early Head Start teachers. The Recovery 

Act made nearly $354 million available in quality improvement 

15 Council for Professional Recognition, CDA Credential, CDA Assessment System. 

Accessed at http://www.cdacouncil.org on June 22, 2010.

16 ACF, Review and Approval of Child Development Associate (CDA) 

Equivalent/Alternative Training Programs by State, December 20, 2006. Accessed at 

http://www.acf.hhs.gov on February 25, 2011. 

17 ACF, Policy Clarifications-J-Staffing and Program Options-OHS-PC-J-033, 

April 29, 2008. Accessed at http://www.acf.hhs.gov on February 10, 2011. 

18 45 CFR § 1304.52(f).

19 Ibid.
 

 

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INTRODUCTION

funding.20 In addition, ACF funds Higher Education Partnership grants 

for colleges and universities. These grants help develop early education 

programs in colleges and universities and provide educational 

opportunities for Early Head Start teachers working toward credentials. 

Finally, Early Head Start teachers can apply for a student loan 

forgiveness program. 

ACF Oversight of Teacher Qualifications

ACF monitors Early Head Start teacher qualifications through the 

Program Information Report (PIR), onsite monitoring, and the risk 

management process. 

The PIR. Annually, grantees report to ACF the highest degree or 

credential of each teacher, as well as other program information.21 In 

addition, grantees report the number of staff enrolled in the degree or 

credential program above what they currently hold (e.g., of teachers 

that have a CDA, the number enrolled in an associate’s or bachelor’s 

degree program). However, ACF does not require grantees to report 

training that teachers received outside a credential or degree program. 

Onsite monitoring. The Head Start Act established monitoring 

requirements for all Head Start agencies, including Early Head Start.22

As part of the onsite monitoring visit, ACF reviews credential and 

training documents. If a grantee has teachers without credentials

during the 2010–2011 monitoring cycle, ACF will indicate a concern in 

the report and will review those grantees again at a later date.

 

The Head Start Act states that all grantees should receive a full review 

at least once every 3 years and that new grantees should be reviewed 

after their first year. 

23 

Risk management process. ACF conducts the risk management process

annually with each grantee.24

20 ACF, Head Start Funding Increase, ACF-PI-HS-09-06, May 12, 2009. Accessed at 

 ACF staff and grantees use this process 

http://www.acf.hhs.gov on May 4, 2011.

21 ACF, Early Childhood Learning and Knowledge Center, Program Information Report 

(PIR). Accessed at http://eclkc.ohs.acf.hhs.gov on March 31, 2010.

22 Head Start Act § 641A(c)(1)(A) and (B); 42 U.S.C. § 9836a(c)(1)(A) and (B).

23 ACF, Qualifications for Early Head Start Infant and Toddler Center-Based Staff, 

ACF-IM-HS-10-06, October 27, 2010. Accessed at http://www.acf.hhs.gov on 

February 10, 2011.

24 ACF, Head Start Risk Management Process, ACF-IM-HS-08-06, February 5, 2008. 

Accessed at http://www.acf.hhs.gov on February 15, 2011.
 

 

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INTRODUCTION

to identify grantees’ areas of strengths and needs for improvement. 

ACF staff also work with grantees to develop an action plan for 

identified areas of weakness, including the education requirement.

Related Reports

In a 2010 report responding to Recovery Act mandates, the Government 

Accountability Office (GAO) found that the percentage of Early Head 

Start teachers with credentials decreased between 2009 and 2010.25 In 

addition, GAO reported that grantees cited finding and developing staff 

as a significant challenge.26

Both OIG and GAO have completed work related to qualifications of 

Head Start teachers. A 2004 OIG report found that Head Start teacher 

qualifications had increased over the years, but that disparities among 

grantees existed in the percentage of degreed teachers.27 In a 

2003 report, GAO found that Head Start appeared to meet a 1998 

mandate that 50 percent of Head Start teachers nationwide have a 

minimum of an associate degree in early childhood education or a 

related field by September 30, 2003.28 However, GAO found that the 

PIR data did not capture whether a teacher with the required 

credentials was in each classroom.29

METHODOLOGY

 These reports did not focus on 

Early Head Start teachers. 

Through a review of teacher credentials from a sample of randomly 

selected Early Head Start grantees and their delegate agencies 

(hereinafter referred to as programs), this study determined the extent 

to which: (1) teachers had the required credentials and (2) programs

employed only teachers with the required credentials. In addition, we 

conducted a survey of the same programs to describe the activities and 

25 GAO, Recovery Act: Head Start Grantees Expand Services, but More Consistent 

Communication Could Improve Accountability and Decisions About Spending, GAO-11-166, 

December 2010.

26 Ibid.

27 OIG, Status of Efforts to Increase the Qualifications of Head Start Teachers, 

OEI-07-01-00560, January 2004.

28 GAO, Head Start: Increased Percentage of Teachers Nationwide Have Required 

Degrees, but Better Information on Classroom Teachers’ Qualifications Needed, GAO-04-05, 

October 2003.

29 Ibid.
 

 

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INTRODUCTION

challenges of Early Head Start programs trying to meet the education 

and training requirements. 

Scope

This study focused only on Early Head Start center-based programs 

within the 50 States and the District of Columbia operating in the 

2010–2011 program year. It excluded Early Head Start programs from 

U.S. territories. It also excluded Head Start programs, as Head Start 

teachers have separate education requirements. 

In addition, this study focused on whether Early Head Start 

center-based teachers had credentials. It did not focus on the 

credentials of other Early Head Start staff, including home-based staff, 

as the education requirements do not apply to them.

Finally, because of limited ACF guidance about the training 

requirement, this study did not determine whether grantees complied 

with the 2010 training requirement in early childhood development. 

However, we surveyed programs to identify activities and challenges in

meeting the training requirement. 

Sample Selection

Program sampling frame. We developed a sampling frame of programs 

that offered center-based Early Head Start services and were operating 

in the 2010–2011 program year. ACF provided a list of 763 programs 

that matched these criteria. We removed 20 programs from the 

sampling frame because of their location in territories, 1 program 

because it did not match the ZIP Code approximation file we used for 

stratifying samples, and 5 programs that pretested our instruments in 

the early stages of the study. Our final sampling frame consisted of 

737 programs offering Early Head Start center-based services. 

Sample selection. After creating the sampling frame of 737 programs, we 

selected a stratified random sample of 223 programs. We stratified by 

rural and urban status and by number of teachers per program. We 

stratified by rural and urban status because anecdotal evidence 

suggested that urban programs might be more likely to meet the 

education requirement than rural programs. We stratified by number 

of teachers to improve the precision of our estimates. 
 

 

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INTRODUCTION

To stratify by rural and urban status, we used the 2004 Rural Urban 

Commuting Area (RUCA) codes.30

To stratify by number of teachers, we obtained data about funded 

enrollment for the 2010–2011 program year from ACF. Then, to 

estimate the number of teachers, we assumed a 1:4 teacher-student 

ratio in classrooms, based on program requirements.

 We matched the ZIP Code of each 

Early Head Start program to 1 of 10 primary codes using RUCA’s ZIP

Code approximation file. We considered programs to be rural if they 

were located in an area with a population less than or equal to 49,999 

(RUCA primary codes 4–10). We considered programs to be urban if 

they were located in an area with a population greater than 49,999 

(RUCA primary codes 1–3). This is considered the standard split for 

rural and urban areas according to the RUCA definitions. Thirty-three 

percent of programs in the sampling frame were rural and 67 percent 

were urban.

31 Table 1 shows 

the population of programs within the sampling frame, the four strata, 

and the final number of programs selected in each stratum. 

30 RUCA codes classify U.S. Census tracts by population density, urbanization, and daily 

commuting. The ZIP Code approximation file was developed for use with health care data 

sets. The 2004 version is the most recent version available. Rural Health Research Center, 

About Us: RUCA Origins. Accessed at https://depts.washington.edu/uwruca/rucaabout.php on February 22, 2011.

31 45 CFR 1304.52(g)(4) describes the Early Head Start teacher-student ratio. In 

summary, it states that programs must ensure that each teacher has responsibility for no 

more than four infants and toddlers.
 

 

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INTRODUCTION

Table 1: Sample Stratification

Stratum 

Number Stratum Description Program Population

Number of 

Programs 

Selected

1 Urban programs with estimated number of teachers < 150 481 110

2 Urban programs with estimated number of teachers • 150 14 14

3 Rural programs with estimated number of teachers < 70 238 95

4 Rural programs with estimated number of teachers • 70 4 4 

Total 737 223

Source: OIG sample stratification, 2010.

Although we did not stratify based on whether a program received 

Recovery Act funds, we collected these data from ACF. 

Seventy-seven percent of the programs in the sampling frame were 

preexisting programs and the remaining 23 percent were new programs.

Data Collection

We emailed the request for teacher credentials and the survey 

regarding training to the 223 sampled programs in October 2010. We 

made at least two followup attempts by telephone and one by 

signature-required certified mail. Data collection lasted through 

November 2010. During data collection, we learned that one program 

no longer offered center-based services and another was not yet in 

operation. Our final sample consisted of 221 programs.

To ensure a timely and accurate analysis, we requested teacher 

credentials directly from programs rather than relying on PIR. PIR 

data for the 2010–2011 program year will not be available until late 

2011 or early 2012. In addition, previous OIG reports cited concerns 

about PIR data.32, 33 

Teacher credentials

32 OIG, Enrollment Levels in Head Start, OEI-05-06-00250, April 2007.

. From each program, we requested a master list of 

all Early Head Start teachers and one document supporting one of the 

following for each teacher: (1) highest level of completed education; or 

(2) proof of enrollment in a CDA, certificate, or degree program. 

33 OIG, Status of Efforts to Increase the Qualifications of Head Start Teachers.
 

 

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Documents to support the highest level of completed education could 

include: diploma, transcript indicating degree received, CDA, or 

alternative credential. Documents to support a teacher’s pursuit of a 

degree or certificate could include: transcript, CDA application, or 

receipt of paid tuition. Of the 221 programs, 209 responded to the 

request for teacher credentials, for a program response rate of 

95 percent. 

We estimate that the teacher response rate was 98 percent. The 

209 programs that responded indicated that they collectively employed 

3,799 teachers. Using 2010 PIR data, we estimated that, collectively,

75 teachers were employed at the 12 programs that did not respond to 

our request, for a total of 3,874 teachers. 

Survey

Data Analysis

. We also requested that each program complete a survey 

regarding the activities and challenges to ensuring the credentialing 

and training of teachers. Of the 221 programs, 215, or 97 percent, 

responded. 

Teacher credentials

We determined the types of credentials that teachers had. Our analysis 

included all 3,799 teachers working for the 209 programs that 

responded to the request. We considered a teacher to have a credential 

if the teacher had a CDA, a college degree, or any alternative credential. 

We considered a teacher as not having a credential if the program did 

not submit documentation for an individual teacher or if the teacher 

had only a high school equivalency. We calculated the overall 

percentage of teachers that had credentials. 

. To determine the extent to which Early Head Start 

teachers had the required credentials and programs employed only 

teachers with required credentials, we reviewed teacher credential 

documents. 

When teachers did not have credentials, we determined whether they 

were pursuing them. We considered teachers to be pursuing credentials 

if the documents provided indicated that they had applied for a CDA or 

were enrolled in a certificate or degree program in 2010. 

We considered a program to have met the requirement if all of its 

teachers had credentials. Our analysis of programs included the 

209 programs that responded to our documentation request. We 

calculated the percentage of programs that employed only teachers with 

required credentials and the percentage that did not. For programs 
 

 

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INTRODUCTION

that did not employ only teachers with required credentials, we 

determined the percentage of teachers within those programs that had 

required credentials. 

Survey. To analyze programs’ responses, we tallied responses to identify 

what programs were doing to meet the education and training 

requirements and any challenges that programs faced. We also 

reviewed programs’ open-ended responses to identify approaches to 

training. We used the results of this analysis to describe the activities 

and challenges of Early Head Start programs trying to meet the 

education and training requirements. 

Statistical tests and projections

In addition, we projected all results to all 737 Early Head Start 

center-based programs operating in the 2010–2011 program year and 

all teachers within those programs. See Appendix A for a list of 

95-percent confidence intervals for all statistical projections.

. For both teacher credentials and the 

training survey, we determined whether there were any differences by 

rural and urban status and by new and preexisting status. We used 

appropriate tests to determine whether any differences were 

statistically significant. We determined statistical significance based on 

a 95-percent confidence level. 

Data Limitations 

We did not determine whether alternative credentials met or exceeded 

the CDA requirement. Although ACF publishes a list of credentials 

that meet or exceed the CDA requirement, ACF staff acknowledge that 

this list is not up to date. Therefore, we accepted all alternative 

credentials.

In addition, we did not determine whether the subject area of a college 

degree was related to early childhood education. ACF has not defined 

what subject areas are related to early childhood education. To be as 

inclusive as possible, we accepted all degrees as meeting and exceeding 

a CDA, regardless of the subject areas. 

Finally, we based our analysis of teacher credentials on documents 

submitted by the program. Some teachers may not have provided 

their credentials to their program. During onsite monitoring visits, 

ACF reviews only credentials that programs keep on file. We 

assumed that programs sent us all the teachers’ credentials that were

on file. 
 

 

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Standards

This study was conducted in accordance with the Quality Standards for 

Inspection and Evaluation issued by the Council of the Inspectors 

General on Integrity and Efficiency.
 

 

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Eighty-one percent of Early Head 

Start teachers had credentials that 

were equivalent to or exceeded a 

CDA. The Head Start Act required all Early Head Start teachers to 

have credentials that were equivalent to or exceeded a CDA by 

September 30, 2010. 

Teachers from preexisting Early Head Start programs were more likely 

to have the required credentials than teachers from new programs, at 

82 percent and 73 percent, respectively.34

Teachers had a variety of credentials. Twenty-one percent had CDAs. 

Forty-five percent had college degrees that were more advanced than a 

CDA, such as associate’s, bachelor’s, or advanced degrees. 

Fifteen percent had alternative credentials aside from a college degree 

or a CDA. See Chart 1 for a breakdown of the education credentials.

 This difference may be due in 

part to the shorter time between new programs’ start dates and the 

deadline. When the Head Start reauthorization was enacted in 2007, 

preexisting programs had nearly 3 years either to hire teachers with the 

required credentials or to ensure that teachers without credentials 

obtained them by the deadline. However, new programs had less than a 

year to ensure that all teachers had the required credentials, as the first 

distribution of Recovery Act funds occurred in November 2009.

Chart 1: Education Credentials of Early Head Start Teachers

Source: OIG analysis of Early Head Start teacher credentials, 2011.

34 The difference was statistically significant at the 95-percent confidence level based on 

a Wald chi-square test, p = 0.04.

Overall, 81 percent of Early Head Start teachers 

had the required credentials 

 FINDINGS

19 21

15

24

19

2

0

5

10

15

20

25

30

No Credential CDA Alternative 

Credential

Associate's 

Degree

Bachelor's 

Degree

Advanced 

Degree

Percentage of Teachers

 FINDINGS
 

 

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FINDINGS

More than half of teachers without the required credentials were 

pursuing them

Although 19 percent of teachers did not have the required credentials, 

56 percent of these teachers were pursuing them (11 percent of 

teachers overall). Teachers were considered to be pursuing 

credentials if they were enrolled in a degree program or applying for a 

CDA. The remaining 44 percent of teachers without credentials were 

not pursuing them (8 percent of teachers overall). 

Teachers who were pursuing credentials may receive them in the near 

future. For example, 21 percent of teachers without credentials were 

applying for a CDA through the Council (4 percent of teachers 

overall). This means that they will most likely receive their CDA 

within a year’s time, assuming that they submitted all of the 

paperwork correctly and that the Council awards the CDA in a timely 

fashion. 

Thirty-five percent of programs 

employed only teachers with the 

required credentials, whereas 

65 percent employed at least 

one teacher without the required credentials. 

Overall, more than half of the teachers at 89 percent of programs had

the required credentials. While approximately one-third of programs 

employed only teachers with the required credentials, 76–99 percent 

of teachers employed by another third of programs had the required 

credentials. In 3 percent of programs, 25 percent or fewer teachers 

had the required credentials, including 1 percent that did not employ 

any teachers with the required credentials. See Chart 2 for a 

breakdown of programs by percentage of teachers with the required 

credentials. 

Approximately one-third of Early Head Start 

programs employed only teachers with the 

required credentials
 

 

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FINDINGS

Chart 2: Programs by Percentage of Teachers With Required Credentials

Source: OIG analysis of Early Head Start teacher credentials, 2011. 

Ninety-six percent of programs 

reported requiring teachers to 

complete ongoing training. This 

indicates that almost all programs were attempting to ensure that all 

teachers met the training requirements, which are: (1) that all teachers 

have training in early childhood development by September 30, 2010; 

and (2) that all teachers have training in infant and toddler 

development by September 30, 2012. 

In general, programs identified training topics that included early 

childhood development, infant and toddler development, safety, and 

communication methods. These topics correspond to the subject areas 

identified in the 1996 regulations. In addition, the topics appear to 

cover the broad areas outlined in the 2010 and 2012 training 

requirements. Some specific examples provided by programs included: 

developmentally appropriate curriculum, early literacy, sudden infant 

death syndrome, first aid, cardiopulmonary resuscitation, 

parent/teacher interaction, and responding to cultural diversity. 

In addition, some programs also identified a variety of training topics

focused on administering the Early Head Start program. These topics 

included State policies, procedures, and licensing requirements; 

performance standards; and records management. 

Nearly all Early Head Start programs reported 

requiring teachers to complete training

3

8

22

32

35

0

5

10

15

20

25

30

35

40

0–25% 26–50% 51–75% 76–99% 100%

Percentage of Programs

Percentage of Teachers With Credentials
 

 

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FINDINGS

Although most programs required training for teachers, the number of 

hours required varied widely. For example, programs’ survey responses

indicated a range of 0 to 140 hours per year, with a median of 15 hours 

per year. Only 3 of the 184 programs indicated that they did not expect 

teachers to receive any training hours in a year. This variation could 

occur, in part, because ACF has not provided guidance to programs 

regarding the amount of training that Early Head Start teachers must 

have. 

Early Head Start programs may look to Head Start requirements for 

guidance about training. The Head Start Act defines the number of 

hours of training that Head Start teachers must receive. Head Start 

teachers have a yearly 15-hour in-service requirement.35

Most programs reported 

challenges either to employing 

only teachers with the required 

credentials or to training 

teachers. In fact, 85 percent of programs identified at least one 

challenge to employing all teachers with the required credentials, and 

87 percent of programs identified at least one challenge to training 

teachers. In particular, programs reported challenges to credentialing 

and training teachers because of problems with the workforce.

 In fact, 

40 percent of Early Head Start programs required 15 hours of training 

per year. 

Eighty-three percent of Early Head Start programs reported challenges to 

employing only teachers with the required credentials

Many programs reported that they could not find teachers with 

credentials. In fact, there may not be a sufficient supply of teachers 

with credentials. In an October 2010 information memorandum, ACF 

recognized that Early Head Start programs may have difficulties 

finding qualified teachers. ACF recognized that the additional pressure 

to expand Early Head Start programs while finding teachers with 

credentials may create a demand-supply imbalance. In particular, new 

programs may have experienced challenges to finding teachers with 

credentials as a result of this imbalance.

Programs described some of their challenges to finding teachers with 

the required credentials. One program provided the following example: 

35 Head Start Act § 648A(a)(5), 42 U.S.C. § 9843a(a)(5).

Early Head Start programs reported challenges

to employing only teachers with the required 

credentials and to training teachers
 

 

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FINDINGS

We could not find qualified applicants that came to us with the 

required credentials. We hired staff that had experience in Early 

Childhood infants and toddlers who already had some documented 

hours of training and some of the required hours for the CDA 

process. 

Early Head Start programs most commonly identified finding substitutes

and managing work schedules as challenges to training teachers

Programs identified several challenges to training teachers. Most 

commonly, programs reported difficulties finding substitutes and 

managing work schedules as challenges to providing training, at 

80 percent and 66 percent, respectively.36

Programs indicated that if teachers attend training during the workday, 

they must either close the program for the day or find substitute 

teachers. Closing for the day can cause problems for parents who 

depend on full-day services. On the other hand, hiring substitutes 

raises concerns about continuity of care for the children. However, if 

training is offered during evening or weekend hours to lessen the need 

for substitutes, this creates a work-life imbalance for teachers. In many 

cases, programs indicated that they must pay overtime for training 

outside the scheduled workdays. In fact, 52 percent of programs stated 

that they did not have the funds to pay teachers overtime to attend 

training.

 

Programs described some of their challenges related to scheduling and 

finding substitutes. One clearly described its difficulties in finding 

substitutes and concerns about overtime pay: “Our pool of substitutes is 

not adequate for staffing EHS [Early Head Start] classrooms when 

[training] classes are offered during center hours of operation. 

Therefore, we would have to pay overtime that would adversely impact 

our budget.” 

Another program discussed its concern that scheduling training causes 

work schedule problems:

Basically, classroom coverage is always a challenge. We want to 

have consistency and continuity of care for our children, so 

substitutes are not appropriate, unless they are regular and 

familiar with the children. Also, teachers are tired and have 

families. They want to go home in the evenings. Too many 

evening classes causes stress for them and their families.

36 Programs reported these challenges more frequently than others. This difference is 

statistically significant at the 95-percent confidence level.
 

 

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FINDIN G S

FINDINGS

Other challenges to training teachers appeared to be more prevalent in rural 

areas

Although most programs identified at least one training challenge, some 

appeared to be more prevalent in rural areas. For example, overall, 

18 percent of programs reported challenges to identifying trainers for 

infant and toddler development in their areas. However, this challenge 

was heightened for programs in rural areas. Thirty-four percent of 

rural programs identified this as a challenge compared to 11 percent of 

urban programs. Table 2 compares challenges faced by rural and urban 

programs.

Table 2: Programs That Identified Challenges, Overall and by Rural and Urban Status

Challenge Overall Rural Urban

Difficulty finding substitute teachers 80% 80% 80%

Difficulty managing training around work schedules 66% 71% 64%

Inadequate funds to pay teachers overtime to attend training 52% 59% 49%

Difficulty finding appropriate programs 30% 44%* 23%

Lack of funds to pay outside trainers 23% 34%* 17%

Lack of trainers for infant and toddler development 18% 34%* 11%

Lack of trainers for early childhood development 12% 24%* 6%

Trainers’ refusal to travel to area 10% 17%* 6%

* Indicates a statistically significant difference between rural and urban programs at the 95-percent confidence level. 

Source: OIG analysis of program survey responses, 2011.

Rural programs discussed unique challenges to providing training, such 

as distance between programs, travel time, and additional expenses 

related to travel. One program in particular provided a good overview 

of its difficulties trying to ensure that teachers receive training: 

Our program has EHS [Early Head Start] in 5 rural counties and 

getting staff together for any training event is difficult due to 

distances that staff have to travel. We often get hotel rooms for 

these staff members to come to trainings. This is an extra expense 

to the program. The travel takes time and therefore time away 

from work with children and families. Our in house component 

trainers are also limited in making individualized visits to EHS 

sites again due to travel, distance and time. One of our sites is 

2 hours away from the central office and to get to this site it 
 

 

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FINDINGS

requires traveling over a mountain which is not always safe in 

winter weather.
 

 

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RECOMMENDATIONS

Overall, 81 percent of Early Head Start teachers had credentials that 

were equivalent to or exceeded a CDA. Approximately one-third of 

programs employed only teachers who met the education requirement 

that all teachers have a minimum of a CDA. Nearly all programs 

reported requiring teachers to complete training. However, most 

reported challenges either to employing only teachers with the required 

credentials or to training teachers. In particular, challenges related to

the lack of a workforce and, in rural areas, finding appropriate training.

To increase the percentage of programs that employed only teachers 

with the required credentials and to help programs meet the 

requirements, we make the following recommendations to ACF:

Work with Early Head Start programs to ensure that all teachers have the 

required credentials

ACF should work to ensure that all Early Head Start programs employ

only teachers with the required credentials. ACF could pursue a variety 

of options. For example, ACF could:

Provide additional support to Early Head Start programs that were newly 

developed with Recovery Act funds. Teachers from new programs were 

less likely to have credentials than teachers from preexisting programs. 

Identify and share strategies used by programs that employed only teachers 

with the required credentials. Approximately one-third of programs 

employed only teachers with the required credentials. Their 

experiences and strategies may be useful to programs that do not 

employ only teachers with the required credentials. 

Work with programs that employ teachers without the required credentials to 

develop and implement an action plan

Provide guidance to programs about training teachers

. Approximately two-thirds of 

programs did not employ only teachers with the required credentials. 

ACF could work with programs to develop an action plan to ensure that 

all teachers obtain the required credentials. This action plan may

include ensuring that all teachers without credentials are pursuing 

them and that there is at least one credentialed teacher in each 

classroom. 

ACF should develop guidance regarding training, which may include an 

expected number of training hours or a list of suggested online 

coursework. It may also include guidance on what needs to be done to 

meet the training requirements for future teachers hired. Programs’ 

survey responses varied widely in the amount of training they provided 

 RECOMMENDATIONS
 

 

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REC OMMENDATIONS

to teachers, with a range from 0 to 140 hours per year and a median of 

15 hours per year. Further, ACF has not provided guidance to 

programs regarding the amount of training that Early Head Start 

teachers must have. 

In addition, because 87 percent of programs identified at least one 

challenge to training teachers, ACF’s guidance should include 

suggestions for overcoming such challenges. This could include 

compiling a list of teachers, training, or courses available online. ACF 

could also work with programs to determine any lessons learned or 

successful strategies that could be shared with other programs. 

Particular attention should be paid to rural programs because

challenges to training teachers appeared to be more prevalent in rural 

areas. 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

ACF concurred with our recommendations. ACF described ongoing 

initiatives to increase the number of Early Head Start teachers with 

credentials, such as partnerships with educational institutions. It also 

stated that it plans to issue an information memorandum in the

summer of 2011 to provide additional guidance for programs on teacher 

credentials and qualifications. In addition, ACF stated that it could 

provide guidance about teacher training, but that it could not require a 

certain number of training hours without a regulatory change. 

We encourage ACF to issue both the planned information memorandum 

about teacher credentials and qualifications and guidance about teacher 

training. We did not make any changes to the report based on ACF’s 

comments. For the full text of ACF’s comments, see Appendix B. 
 

 

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Estimates and Confidence Intervals

Table A-1: Estimates of Teachers With the Required Credentials

Estimate Description Sample Size Percentage 95-Percent 

Confidence Interval

Teachers with the required credentials 3,799 81.1% 77.6%–84.6% 

Teachers from preexisting programs with the required credentials 3,257 82.5%* 78.7%–86.3% 

Teachers from new programs with the required credentials 542 73.1% 65.6%–80.6% 

* Actual result is 82.489 percent, which we rounded to 82.5 percent in this table and 82 percent in the findings.

Source: Office of Inspector General (OIG) analysis of Early Head Start teacher credentials, 2011.

Table A-2: Estimates of Teachers by Type of Credential

Estimate Description Sample 

Size Percentage 95-Percent Confidence Interval

Teachers with a child development associate (CDA) credential 3,799 21.4% 18.2%–24.6% 

Teachers with any degree (i.e., associate’s, bachelor’s, or advanced 

degree) 3,799 44.6% 40.8%–48.5%

Teachers with alternative credentials 3,799 15.2% 11.4%–18.9% 

Teachers with no credentials 3,799 18.9% 15.4%–22.4% 

Teachers with associate’s degrees 3,799 23.9% 20.8%–26.9% 

Teachers with bachelor’s degrees 3,799 18.8% 16.3%–21.3% 

Teachers with advanced degrees 3,799 2.0% 1.5%–2.4% 

Source: OIG analysis of Early Head Start teacher credentials, 2011.

 APPENDIX ~ A
 

 

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APPENDIX ~ A

Table A-3: Estimates of Teachers Pursuing Credentials

Estimate Description

Percentage 

of Teachers 

Without 

Credentials

Sample Size

Percentage 

of All 

Teachers

Sample Size

95-Percent 

Confidence Interval

95-Percent 

Confidence Interval

Teachers who were pursuing credentials 56.4%

706

10.7%

3,799

46.8%– 66.0% 8.1%–13.2%

Teachers who were not pursuing credentials 43.6%

706

8.3%

3,799

34.0%–53.2% 5.8%–10.7%

Teachers in the process of applying for CDAs 20.8%

706

3.9%

3,799

14.1%–27.4% 2.6%–5.3%

Source: OIG analysis of Early Head Start teacher credentials, 2011.

Table A-4: Estimates of Programs Hiring Only Teachers With Required Credentials

Estimate Description Sample 

Size Percentage 95-Percent Confidence Interval

Programs that had only teachers with the required credentials 209 35.1% 29.2%–41.1% 

Programs that did not have only teachers with the required credentials 209 64.9% 58.9% –70.8% 

Source: OIG analysis of Early Head Start teacher credentials, 2011.

Table A-5: Estimates of Programs With Teachers Who Had the Required Credentials

Estimate Description Sample 

Size Percentage 95-Percent Confidence Interval

Programs in which the majority of teachers had the required credentials 209 88.8% 84.9%–92.7%

Programs in which 76–99% of teachers had the required credentials 209 32.2% 26.3%–38.0%

Programs in which 0–25% of teachers had the required credentials 209 3.2% 0.9%–5.5%

Programs in which 0% of teachers had the required credentials 209 1.0% 0.3%–3.4%

Programs in which 26–50% of teachers had the required credentials 209 8.0% 4.7%–11.3% 

Programs in which 51–75% of teachers had the required credentials 209 21.5% 16.5%–26.6%

Source: OIG analysis of Early Head Start teacher credentials, 2011.
 

 

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APPENDIX ~ A

Table A-6: Estimates of Survey Responses Regarding Teacher Credentials and 

Training

Estimate Description Sample 

Size Percentage 95-Percent Confidence Interval

Programs that require teachers to complete ongoing training 212 95.5% 92.9%–98.1%

Programs that require 15 hours of training per year 184 40.0% 33.7%–46.4%

Programs that identified at least one challenge to having only teachers 

with the required credentials 

98 84.7% 77.9%–91.5%

Programs that identified at least one challenge to training teachers 215 87.4% 83.3%–91.6%

Programs that could not find teachers with the required credentials 98 83.1% 76.1%–90.0%

Programs that reported finding substitutes as a challenge 213 80.3% 75.3%–85.2%

Programs that reported managing work schedules as a challenge 213 66.0% 60.2%–71.9%

Programs that reported not having funds to pay teachers overtime to 

attend training as a challenge

213 52.4% 46.2%–58.5%

Programs that reported challenges to identifying trainers for infant and 

toddler development in their areas 213 18.4% 14.2%–22.7%

Rural programs that reported challenges to identifying trainers for infant 

and toddler development in their areas 95 34.3% 26.8%–41.9%

Urban programs that reported challenges to identifying trainers for 

infant and toddler development in their areas 118 10.6% 5.5%–15.7%

Rural programs that reported finding substitutes as a challenge 95 80.1% 73.8%–86.5%

Urban programs that reported finding substitutes as a challenge 118 80.3% 73.7%–87.0%

Rural programs that reported managing work schedules as a challenge 95 71.1% 63.8%–78.3%

Urban programs that reported managing work schedules as a challenge 118 63.5% 55.6%–71.5%

Rural programs that reported not having funds to pay teachers overtime 

to attend training as a challenge

95 58.5% 50.6%–66.4%

Urban programs that reported not having funds to pay teachers 

overtime to attend training as a challenge

118 49.4% 41.1%–57.7%

Programs that reported finding appropriate training programs as a 

challenge

210 30.2% 24.8%–35.6%

Rural programs that reported finding appropriate training programs as a 

challenge

93 44.4% 36.3%–52.4%

Urban programs that reported finding appropriate training programs as 

a challenge

117 23.3% 16.3%–30.3%

Programs that reported not having funds to pay outside trainers as a 

challenge

211 22.5% 17.6%–27.4%

Rural programs that reported not having funds to pay outside trainers 

as a challenge

93 34.2% 26.5%–41.9%

continued on next page
 

 

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APPENDIX ~ A

Table A-6: Estimates of Survey Responses Regarding Teacher Credentials and 

Training (Continued) 

Estimate Description Sample 

Size Percentage 95-Percent Confidence Interval

Urban programs that reported not having funds to pay outside trainers 

as a challenge

118 16.9% 10.6%–23.1%

Programs that reported challenges to identifying trainers for early 

childhood development

213 11.7% 8.3%–15.1%

Rural programs that reported challenges to identifying trainers for early 

childhood development 

95 24.2% 17.3%–31.0%

Urban programs that reported challenges to identifying trainers for 

infant and toddler development in their areas 118 5.6% 1.7%–9.4%

Programs that reported trainers’ refusal to travel to their areas as a 

challenge

207 9.6% 6.3%–13.0%

Rural programs that reported trainers’ refusal to travel to their areas as 

a challenge

92 17.2% 11.1%–23.3%

Urban programs that reported trainers’ refusal to travel to their areas as 

a challenge

115 5.9% 2.0%–9.9%

Note: The number of respondents varies because survey respondents did not answer every question.

Source: OIG analysis of program survey responses, 2011.
A P PEN 0 x - B 

Agency Comments 

DEPARTMENT OF HEALTH &. HUMAN SERVICES 

ADMINISTRATION FOR CHILDREN AND FAMILIES 

Office of the Assistant Secretary, Suite 600 

370 L'Enfant Promenade, S.W. 

Washington, D.C..20447 

JUN 1 52011 

TO: Daniel R. Levinson 

Inspector General 

FROM: David A. Hansell 

Acting Assistant Secretary 

for Children and Families 

SUBJECT: Office of Inspector General (OIG) Draft Report titled, "Most Early Head 

Start Teachers Have the Required Credentials, But Challenges Exist" 

(OEI-05-10-00240) 

Attached is the Administration for Children and Families comments on the above-referenced 

OIG draft report. 

Should you have questions or need additional infonnation, please contact Yvette Sanchez 

Fuentes, Director, Office ofHead Start, at 202-205-8573. 

Attachment 

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APPENDIX ~ B

 

 
 

 

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APPENDIX ~ B

 
 

 

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APPENDIX ~ B
 

 

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APPENDIX ~ B
 

 

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

Inspector General for Evaluation and Inspections in the Chicago 

regional office, and Thomas F. Komaniecki, Deputy Regional Inspector 

General. 

Nicole Hrycyk served as the team leader for this study. Beth McDowell 

served as the lead analyst. Other principal Office of Evaluation and 

Inspections staff from the Chicago regional office who contributed to the 

report include Ericka Kilburn and Margarita Rodriguez; other central 

office staff who contributed include Talisha Searcy and Kevin Farber.

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

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

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

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

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

inspections conducted by the following operating components:

Office of Audit Services 

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

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

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

out their respective responsibilities and are intended to provide independent assessments of 

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

mismanagement and promote economy and efficiency throughout HHS.

Office of Evaluation and Inspections 

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

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

issues. These evaluations focus on preventing fraud, waste, or abuse and promoting 

economy, efficiency, and effectiveness of departmental programs. To promote impact, OEI 

reports also present practical recommendations for improving program operations. 

Office of Investigations 

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

of fraud and misconduct related to HHS programs, operations, and beneficiaries. With 

investigators working in all 50 States and the District of Columbia, OI utilizes its resources 

by actively coordinating with the Department of Justice and other Federal, State, and local 

law enforcement authorities. The investigative efforts of OI often lead to criminal 

convictions, administrative sanctions, and/or civil monetary penalties.

Office of Counsel to the Inspector General 

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

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

legal support for OIG’s internal operations. OCIG represents OIG in all civil and 

administrative fraud and abuse cases involving HHS programs, including False Claims Act, 

program exclusion, and civil monetary penalty cases. In connection with these cases, OCIG 

also negotiates and monitors corporate integrity agreements. OCIG renders advisory 

opinions, issues compliance program guidance, publishes fraud alerts, and provides other 

guidance to the health care industry concerning the anti-kickback statute and other OIG 

enforcement authorities.