Report to Congressional Requesters

United States General Accounting Office 

GAO 

December 2003 HEAD START 

Better Data and 

Processes Needed to 

Monitor 

Underenrollment 

GAO-04-17 
The extent to which Head Start programs have enrolled fewer children than 

they are funded to serve is unknown because the Administration for 

Children and Families (ACF) does not collect accurate national data and 

does not monitor underenrollment in a uniform or timely manner. While 

some modest fluctuations in enrollment are to be expected, regional offices 

had differing definitions of unacceptable underenrollment, and the 

approaches they used to identify it were either not timely or not systematic. 

The regional offices identified a total of about 7 percent of grantees as 

unacceptably underenrolled in 2001-02, significantly less than the percentage 

of grantees reporting enrollment ratios below 100 and 95 percent on ACF’s 

survey of grantees (see chart below). As a result of differences in regional 

definitions of what constitutes an unacceptable level of underenrollment, 

grantees with similar levels of underenrollment may be treated differently 

across regions. 

ACF regional officials and officials of underenrolled Head Start grantees 

often cited a mixture of factors that made it difficult to achieve full 

enrollment, including increased parental demand for full-day child care, a 

decrease in the number of eligible children, facilities-related problems, and 

more parents seeking openings with other sponsors of early education and 

care. 

ACF national and regional offices and grantees all report taking action to 

address underenrollment through the issuance of guidance, increased 

monitoring by regional offices, and more aggressive outreach attempts by 

grantees. The ACF national office issued a memo in April 2003 that 

instructed regional offices to address underenrollment with a variety of 

measures depending on its causes. While this guidance was clear on the 

actions to be taken, it lacked clear criteria for prioritizing grantees for 

corrective actions. Also, while many grantees we spoke with had taken steps 

to address underenrollment, some told us of their concern to maintain total 

funded enrollment levels, even as they were converting unfilled part-day 

openings to full-day. While 18 of the 25 grantees we contacted had made 

progress toward full enrollment, others cited continuing problems. 

Percentage of Underenrolled Grantees Using Three Different Definitions 

Percentage

Less than 100% enrolled 

Less than 95% enrolled

Regionally identified as

"unacceptable"

0 10 20 30 40 50 60

Source: GAO analysis of ACF regional office survey responses and Program Information Report data.

7

33

57

Head Start, created in 1965, is 

designed to prepare low-income 

preschool children for school by 

providing a comprehensive set of 

early child development services 

primarily through communitybased organizations. Over the last 

decade there have been a number 

of changes in Head Start’s 

operating environment, including a 

decrease in the number of poor 

children; an increase in the 

number, size, and scope of other 

federal and state early childhood 

programs; and an expansion in 

Head Start spending and 

enrollment. Given this 

environment, GAO was asked to 

determine (1) what is known about 

the extent to which Head Start 

programs are underenrolled, 

(2) ACF regional officials’ and 

Head Start grantees’ views on what 

factors contribute to 

underenrollment, and (3) what 

actions ACF and grantees have 

taken to address underenrollment.

GAO recommends that the 

Secretary of HHS direct ACF to 

(1) ensure the accuracy of national 

enrollment data, (2) develop a 

standard criterion for regional 

offices to use in identifying 

grantees whose underenrollment 

merits action, (3) develop an 

additional enrollment measure that 

takes into consideration the 

different levels of service provided 

by full-day and part-day programs, 

and (4) develop a more systematic 

process for regional offices to 

collect reliable enrollment data 

during the program year. 

www.gao.gov/cgi-bin/getrpt?GAO-04-17.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Marnie S. 

Shaul at (202) 512-7215 or shaulm@gao.gov. 

Highlights of GAO-04-17, a report to 

Congressional Requesters 

December 2003

HEAD START

Better Data and Processes Needed to 

Monitor Underenrollment 
Page i GAO-04-17 Head Start Enrollment 

Letter 1

Results in Brief 2

Background 4

The Extent to Which Head Start Programs Are Underenrolled is 

Not Known 11

Regional and Grantee Officials Often Cited Combinations of 

Factors as Responsible for Underenrollment 18

ACF and Grantees Use a Variety of Approaches to Address 

Underenrollment 22

Conclusions 28

Recommendations for Executive Action 29

Agency Comments 30

Appendix I Scope And Methodology 31 

Appendix II Factors That the ACF Regions and the American 

Indian-Alaska Native Program Branch Believed 

Contributed to Underenrollment to a Major or 

Moderate Extent 33 

Appendix III Factors that Grantees Believed Contributed to 

Their Head Start Programs’ Underenrollment 34 

Appendix IV Comments from the U.S. Department of Health 

and Human Services 35 

Appendix V GAO Contacts and Staff Acknowledgments 37 

GAO Contacts 37

Acknowledgments 37

Related GAO Products 38 

Contents 
Page ii GAO-04-17 Head Start Enrollment 

Tables 

Table 1: ACF Regional Thresholds for Unacceptable Levels of 

Underenrollment 13

Table 2: Number of ACF Regions Relying on Various Methods to 

Oversee Head Start Grantee and Delegate Agency 

Enrollment Levels 14

Table 3: Percentage of Head Start Grantees, by Region, Reported as 

Unacceptably Underenrolled by ACF Regions with 

Unacceptable Underenrollment Thresholds, Compared 

with PIR Data at the Same Thresholds 17

Table 4: Comparison of Region II and III Grantees Identified as 

Underenrolled 18

Table 5: April 2003 National Head Start Guidance to ACF Regions 24

Table 6: Actions by ACF Regions toward Underenrolled Grantees 25

Table 7: Actions Taken by Interviewed Grantees to Address 

Underenrollment 27

Table 8: Factors Cited By ACF Regions as Contributing to 

Underenrollment to a Major or Moderate Extent, during 

Program Years 2001-02 and 2002-03 33

Table 9: Factors Cited by 25 Grantees as Contributing to Head Start 

Program Underenrollment, during Program Years 2001-02 

and 2002-03 34

Figures 

Figure 1: ACF Regions 5

Figure 2: Distribution of Head Start Services between Full-day and 

Part-day 6

Figure 3: Head Start Enrollment Compared with Children Under 

Age 6 Living in Poverty (1992-2002) 8

Figure 4: Growth in Federal Investment in Child Care, Fiscal Years 

1997 through 2002 in Nominal Dollars 10

Figure 5: Comparison of Enrollment Ratios as reported in 2001-02 

PIR Survey with Unacceptably Underenrolled Grantees as 

Reported by ACF Regions 15
Page iii GAO-04-17 Head Start Enrollment 

Abbreviations 

ACF Administration for Children and Families 

CCDF Child Care Development Fund 

HHS Department of Health and Human Services 

PIR Program Information Report 

SSI Supplemental Security Income 

TANF Temporary Assistance for Needy Families 

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Page 1 GAO-04-17 Head Start Enrollment 

December 4, 2003 

The Honorable George Miller 

Ranking Minority Member 

Committee on Education and the Workforce 

House of Representatives 

The Honorable Dale E. Kildee 

House of Representatives 

The Honorable Adam Schiff 

House of Representatives 

Head Start is the largest federal early childhood program, funded at about 

$6.7 billion in fiscal year 2003. Created in 1965, Head Start is designed to 

prepare poor children for school by providing a comprehensive set of 

developmental services. The Administration for Children and Families 

(ACF) of the Department of Health and Human Services (HHS) 

administers the program. Over the last decade, the Head Start program has 

expanded substantially. Between fiscal years 1990 and 2002, 

appropriations for Head Start quadrupled from $1.6 billion to over 

$6.5 billion, and the number of children served increased by 69 percent 

from about 540,000 to over 910,000. 

Over the past decade, significant changes to Head Start’s environment may 

have created challenges for some Head Start grantees when they tried to 

find children to fill funded slots. For example, in the 1990s there was a 

decline in welfare caseloads following welfare reform and a decline in the 

number of children living in poverty, which may have decreased the 

number of children eligible for Head Start. At the same time, the 

expansion of other federal and state early childhood programs may have 

increased child care options available to Head Start-eligible families. 

Consequently, it is possible that federally funded Head Start slots in some 

areas remain unfilled even while eligible children elsewhere remain on 

waiting lists. Given these potential challenges, and in anticipation of Head 

Start’s reauthorization, you asked that we determine the extent to which 

Head Start grantees were underenrolled and that we identify potential 

causes of underenrollment. As agreed with your offices, our review 

addresses: (1) what is known about the extent to which Head Start 

programs are underenrolled, (2) what factors may have contributed to 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-04-17 Head Start Enrollment 

underenrollment, and (3) what actions ACF and grantees have taken to 

address underenrollment. 

To determine what is known about the extent to which Head Start 

programs are underenrolled, we attempted to verify the accuracy of 

national enrollment data, interviewed ACF headquarters officials, and 

reviewed federal guidance and regulations on enrollment. Because we 

determined that national enrollment data were not reliable and because 

the regional offices have primary responsibility for identifying and 

addressing underenrollment, we surveyed all 10 ACF regional offices and 

the American Indian-Alaska Native Program Branch.1

 We asked them to 

identify the threshold below which they consider underenrollment to be 

unacceptable and to identify grantees with enrollment levels beneath this 

threshold. To gather further details on the process by which regions 

identify and address underenrollment, we interviewed regional officials in 

3 regions—region III (covering Delaware, the District of Columbia, 

Maryland, Pennsylvania, Virginia, and West Virginia), region V (Illinois, 

Indiana, Michigan, Minnesota, Ohio, and Wisconsin), and region IX 

(Arizona, California, Hawaii, Nevada, and the Pacific Insular Areas)—

selected on the basis of geographical representation and the number of 

underenrolled grantees they reported to us. To determine what factors 

ACF officials and Head Start grantees believed contributed to 

underenrollment and to identify actions they took to address it, we 

surveyed all 10 ACF regional offices and the American Indian-Alaska 

Native Program Branch office, selected and interviewed 25 grantees 

identified by regional offices as unacceptably underenrolled, and 

conducted site visits to 3 regional offices listed above. We performed our 

work between May and October 2003 in accordance with generally 

accepted government accounting standards. Appendix I further describes 

our scope and methodology. 

The extent to which Head Start programs are underenrolled is unknown 

because ACF does not collect accurate national data and its regional 

offices do not monitor grantee enrollment in a uniform or timely manner. 

The agency surveys grantees annually to determine national enrollment 

levels, but we found these data contained many inaccuracies and were 

 1

We did not survey the Migrant and Seasonal Program Branch due to the program’s distinct 

seasonal operating schedule. We generally will refer to the 10 regions and 1 program 

branch we surveyed as “regional offices” or “regions” throughout the report. 

Results in Brief 
Page 3 GAO-04-17 Head Start Enrollment 

unavailable during the current program year for regional use in monitoring 

grantees. Consequently, we could not determine the extent to which Head 

Start grantees had enrollments below 100 percent of funded enrollment, 

which is how HHS’ regulations define underenrollment. We found that 

three regional offices did not set a threshold below which they view 

underenrollment as unacceptable, while the other regions use thresholds 

ranging from anything below 100 percent to enrollment below 74 percent. 

We also found that the approaches regions used to identify unacceptable 

levels of underenrollment, such as visits to grantees and reviews of grant 

re-funding applications and grantee audits, were either not timely or did 

not systematically address underenrollment. Using varying thresholds, the 

regional offices identified a total of 170 grantees as unacceptably 

underenrolled in program year 2001-02, or about 7 percent of all grantees. 

By contrast, using the regulatory definition of underenrollment, survey 

data indicated that as many as half or more of the grantees could be 

underenrolled. As a result of differences in regional thresholds for what 

constitutes an unacceptable level of underenrollment, grantees with 

similar levels of underenrollment may be treated differently across 

regions. 

ACF regional officials and officials of underenrolled Head Start grantees 

often cited combinations of factors that made it difficult to achieve 

acceptable levels of enrollment, including increasing parental demand for 

full-day child care and decreasing numbers of eligible children. Providing 

full-day care was said to be more expensive than providing part-day care 

because it would require more facility space and staff per child. To make 

full-time slots available, many grantees we spoke with were attempting to 

expand their facilities or partner with other programs. However, 14 of the 

25 grantees we interviewed reported having difficulty acquiring and 

developing adequate facilities. Underenrolled grantees and regional 

officials also said that underenrollment occurred because parents were 

increasingly seeking services from other early education and child care 

programs, some of which subsidized care provided by relatives. Other 

contributing factors were less frequently cited, such as eligible families 

moving from the service area, language and cultural differences between 

children’s families and program staff, and weak or inadequate outreach 

efforts by grantees to locate eligible families. 

ACF national and regional offices and grantees all report taking actions to 

address underenrollment, such as issuing guidance, increasing monitoring, 

and more aggressively trying to recruit participants. The ACF national 

office issued a memorandum in April 2003 that instructed regional offices 

to address underenrollment in particular ways depending on its underlying 
Page 4 GAO-04-17 Head Start Enrollment 

cause. However, the guidance lacked clear criteria for prioritizing which 

grantees should be subject to corrective action based upon their level of 

underenrollment. According to regional officials, the actions they most 

frequently took to address underenrollment were to monitor enrollment 

levels, track improvement efforts, and provide training and technical 

assistance. Many grantees we spoke with have also taken steps to address 

underenrollment, such as increasing their outreach efforts, seeking 

partners to help them provide more full-day service, or increasing the 

availability of full-day slots. Furthermore, some grantees told us of their 

concern to maintain total funded enrollment levels, even as they were 

converting unfilled part-day openings to full day. Consequently, in some 

instances, grantees attempting to convert part-day slots to full-day slots 

said they had to expand facilities or find other child care partners in order 

to serve the same number of children. While 18 of the 25 grantees we 

contacted had made progress toward achieving full enrollment, others 

cited continuing problems. 

To improve ACF’s ability to identify and address underenrollment in a 

more systematic and timely manner, we are making recommendations that 

the agency improve the quality of enrollment data and establish more 

uniform criteria and procedures for identifying and addressing 

underenrollment. 

Head Start was designed to help break the cycle of poverty by providing 

comprehensive educational, social, health, nutritional, and psychological 

services to low-income children. Head Start is authorized to serve children 

at any age prior to compulsory school attendance. Originally, the program 

was aimed at 3- to 5-year-olds. A companion program begun in 1994, Early 

Head Start, made these services available to children from birth to 3 years 

of age as well as to pregnant women. Head Start and Early Head Start 

programs are administered by ACF, which funds and monitors more than 

1,500 grantees through its 10 regional and 2 branch offices. (See fig. 1) 

ACF’s national office has responsibility for overseeing and providing 

guidance to the regional offices, as well as for administering and collecting 

annual survey data from grantees. 

Background 
Page 5 GAO-04-17 Head Start Enrollment 

Figure 1: ACF Regions 

Head Start grantees include community action agencies, school systems, 

for-profit and nonprofit organizations, other government agencies, and 

tribal governments or associations. Also, many Head Start grantees 

provide services by subcontracting with other organizations, known as 

delegate agencies. In fiscal year 2002, Head Start grantees served more 

than 912,000 children, a 69 percent increase over the number of children 

served in 1990. Head Start has traditionally been a part-day, part-year 

program, but currently serves more children on a full-day basis, which is 

defined as 6 hours or more a day, than on a part-day basis. Approximately 

47 percent of children served by Head Start were enrolled in a centerbased full-day program for 6 hours or more a day.2

 Less than 20 percent of 

children enrolled in Head Start receive 8 hours or more of center-based 

services a day. As of 2001-02, about 44 percent of Head Start children were 

 2

Center-based programs are those where services are provided to children primarily in 

classroom settings. 

Source: ACF.

VI

IX

X

VIII

VII

IV

V

III

II

I
Page 6 GAO-04-17 Head Start Enrollment 

enrolled in a part-day center-based program. Figure 2 shows the 

percentages of Head Start services provided on a full-day or part-day basis. 

Figure 2: Distribution of Head Start Services between Full-day and Part-day 

Head Start funds are allotted among the states based on their 1998 

allocation and, for funds exceeding that amount, by formula based on the 

number of children in each state under the age of 5 from families whose 

income is below the federal poverty level.3

 Head Start grantees are 

required to provide at least 20 percent of annual program funding, which 

can include in-kind contributions, such as facilities for holding classes. 

During the award process, Head Start grantees receive from ACF regional 

officials their level of funded enrollment—the number of children the 

grantee is to serve. 

Head Start regulations require that at least 90 percent of the children 

enrolled in Head Start come from families with incomes at or below the 

federal poverty guidelines, from families receiving public assistance, or 

from families caring for a foster child. While the poverty guidelines are 

 3

For 2003, the federal poverty line for a family of four was $18,400 within the 48 contiguous 

states and the District of Columbia. In Alaska and Hawaii, the guidelines were $23,000 and 

$21,160, respectively. The poverty guidelines are updated periodically in the Federal 

Register, by the U.S. Department of Health and Human Services under the authority of 

42 U.S.C. 9902(2). 

9%

20%

44%

27%

Other

Center-based full-day greater 

than or equal to 8 hours per day

Center-based full-day between 

6 and 8 hours per day

Center-based part-day less 

than 6 hours per day

Source: GAO analysis of 2001-02 Program Information Report Data.
Page 7 GAO-04-17 Head Start Enrollment 

firm, grantees have some flexibility in determining income eligibility. For 

example, grantees can use the 12 months prior to the month the family 

applied to Head Start or the previous calendar year as a basis for 

determining income eligibility. Also, once a family is determined to be 

eligible in 1 program year, it is considered eligible for the subsequent 

program year, for a total of 2 years. Additionally, families that participate 

in the Temporary Assistance for Needy Families program (TANF) or the 

Supplemental Security Income program (SSI)4

 or that care for a foster 

child are eligible for Head Start services even when family income exceeds 

the poverty guidelines. Grantees may fill up to 10 percent of their slots 

with children from families that exceed the low-income guidelines. 

An enrollment occurs when a Head Start program officially accepts a child 

and completes all necessary steps to begin providing services. If a child is 

chronically absent and the grantee cannot serve the child in another way, 

the child’s slot is considered vacant. Once a slot is vacant, the grantee 

generally must fill it within 30 days to be considered fully enrolled. 

Consequently, actual enrollments can fluctuate somewhat throughout 

funding periods. Head Start regulations require grantees to track program 

attendance on a daily basis. However, grantees are asked to annually 

report enrollment levels for any 2 months they choose as part of ACF’s 

annual Program Information Report (PIR) survey. ACF regions may 

require grantees to report enrollment data more frequently. 

Head Start regulations require grantees to maintain enrollment at 100 

percent of the funded level and regional offices have primary 

responsibility for identifying and addressing underenrollment.5

 However, 

as a practical matter, not all grantees are able to continually sustain 

enrollment at the fully funded level. Underenrollment can occur for a 

variety of reasons and can vary from month to month in a given program. 

Therefore, before deciding that underenrollment is unacceptable and 

taking action, the regions take into consideration a variety of factors about 

underenrollment, including its level and duration, its causes, and the 

actions taken by grantees to address it. 

 4

Under TANF, the federal government provides grant funds to states, territories, and tribes 

for their programs to assist needy families with children. SSI pays monthly benefits to 

people who are age 65 or older or blind or have a disability and who do not own much or 

have much income. 

5

Enrollment ratio is the ratio of actual enrollment to funded enrollment; therefore, a 

grantee with 100 funded enrollment slots and an actual enrollment of 95 has an enrollment 

ratio of 0.95, or 95 percent. 
Page 8 GAO-04-17 Head Start Enrollment 

The number of children eligible for Head Start services on the basis of 

being below the poverty line has decreased over the last decade, falling 

from over 6 million children in 1992 to just over 4 million in 2000. By 2002, 

the number of children under age 6 living in poverty had increased to 

nearly 4.3 million. Over the same period, Head Start enrollment has 

increased to over 910,000 children—a level that is significantly below the 

number of children living in poverty. (See fig. 3.) However, it should be 

noted that Head Start predominately serves children ages 3 and 4, who 

make up only a portion of all children under 6 living in poverty. 

Figure 3: Head Start Enrollment Compared with Children Under Age 6 Living in 

Poverty (1992-2002) 

Note: Data on number of children under age 6 living in poverty includes only those residing with a 

relative. 

In addition, during the 1990s, the number of other federal and state 

programs offering services to low-income children increased substantially. 

For example, welfare reform in 1996 greatly expanded the Child Care 

Development Fund (CCDF) and also allowed TANF funds to be used for 

Number of children

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

7,000,000

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002

Years

Head Start enrollment

Children under age 6 and in poverty

Source: Poverty data are taken from the Census Bureau's Current Population Survey, Annual Social and Economic Supplements. 

Enrollment figures are from ACF's PIR data.
Page 9 GAO-04-17 Head Start Enrollment 

child care.6 For fiscal years 1997 through 2002, these programs increased 

their investment in children; CCDF spending increased from $2.5 billion to 

$6.4 billion and TANF spending on child care increased from $13 million to 

$1.6 billion.7 (See fig. 4.) On the state level, one study cited by the 

Congressional Research Service (CRS) found that state spending on 

prekindergarten programs increased from about $700 million in 1991-92 to 

about $1.7 billion in 1998-99.8

 Over the same period, the number of 

children served by these programs has increased from 290,000 to 725,000. 

 6

Other federal programs that support early childhood education for children under 5 years 

include Special Education Preschool grants under the Individuals with Disabilities 

Education Act, preschool programs under Title I, and Even Start. See Education and Care: 

Head Start Key Among Array of Early Childhood Programs, but National Research on 

Effectiveness Not Completed, GAO-03-840T (Washington D.C.: July 22, 2003). 

7

CCDF child care funds can be used for families with children up to age 13. In 2000, we 

reported that an estimated 70 percent of CCDF funds and 7.5 percent of TANF funds were 

used for child care for children under age 5 in fiscal year 1999. See Early Education and 

Care: Overlap Indicates Need to Assess Crosscutting Programs. GAO/HEHS-00-78. 

Washington D.C.: April 28, 2000. 

8

See Blank, Helen, with Karen Schulman and Danielle Ewin. Seeds of Success, State 

Prekindergarten Initiatives, 1998-99. Children’s Defense Fund, September 1999 as cited in 

Early Childhood Education: Federal Policy Issues, CRS, (Washington, D.C.: January 27, 

2003). 
Page 10 GAO-04-17 Head Start Enrollment 

Figure 4: Growth in Federal Investment in Child Care, Fiscal Years 1997 through 

2002 in Nominal Dollars 

Note: CCDF amounts include dollars states transferred from their TANF programs to CCDF as 

allowed under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. The 

amounts shown for TANF include only those TANF funds expended for child care. 

Expanding federal and state early childhood programs has increased the 

need for coordination to better ensure that services are provided in a 

complementary fashion. One way that Head Start encourages coordination 

is by requiring all grantees to periodically prepare community assessments 

that analyze trends in the number of eligible children in their jurisdictions 

and assess the other early childhood services provided in the area. While 

grantees are not required to coordinate with other service providers, ACF 

has issued guidance encouraging grantees to coordinate with other 

providers in order to provide more full-day services. Also, in recent years, 

ACF has used some Head Start expansion money to build partnerships 

with child care providers to deliver full-day, full-year services. As another 

way to increase coordination, HHS has been authorized since 1998 to 

provide additional funds to states to encourage such collaboration. 

Dollars in millions

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

1997 1998 1999 2000 2001 2003

Years

TANF

CCDF

Sources: CRS Report, Child Care: Funding and Spending under Federal Block Grants, March 19, 2002 and ACF budget figures.
Page 11 GAO-04-17 Head Start Enrollment 

The extent to which Head Start programs are underenrolled is unknown 

because ACF does not collect accurate national data and it does not 

monitor grantee enrollment in a uniform or timely way. Specifically, 

national enrollment data contain many inaccuracies and regional offices 

use a variety of thresholds to define “unacceptable” levels of 

underenrollment.9

 Additional approaches used by the regions to identify 

underenrollment do not systematically address underenrollment or 

provide timely information. Using varying thresholds, the regional offices 

identified 170 grantees as unacceptably underenrolled in program year 

2001-02, or about 7 percent of all grantees. By contrast, the agency’s 

annual survey data indicated that as many as half or more of the grantees 

were enrolled at less than 100 percent—the enrollment level grantees are 

required to maintain under Head Start regulations. Overall, regions’ use of 

different thresholds for unacceptable underenrollment suggests that 

regions may treat grantees with similar enrollment ratios differently. 

ACF’s annual survey of grantees—the only source of nationwide 

information on grantee enrollment rates—contained many inaccuracies. 

The PIR survey, as it is known, requests actual enrollment figures for any 

2 months that grantees choose to report. When we attempted to verify 

2001-02 PIR enrollment data for 19 of the grantees, we found that 8 had 

reported erroneously. For 6 underenrolled grantees, we found they 

underreported their enrollment ratio by an average of 25 percent. We also 

found that 2 overenrolled grantees had erroneously reported enrollment 

ratios that were over 200 percent. A similar review by ACF of 75 grantees 

and delegate agencies10 that had reported particularly high or low 

enrollment levels found that approximately half had erroneously reported 

their actual numbers. GAO and ACF found a variety of causes that 

grantees cited for misreported enrollments, including typographical errors, 

failure to report children who were enrolled in the home-based or after-

 9

While 100 percent of funded enrollment is required by Head Start regulations, as a 

practical matter underenrollment can occur as a result of programmatic fluctuations. 

Consequently, we asked the regional offices to identify the threshold, if any, they used for 

determining when a grantee’s level of enrollment compared with its total funded 

enrollment was “unacceptable.” We then asked regional officials to report back to us the 

grantees they were aware of that fell beneath this threshold. 

10A delegate agency means a public or private nonprofit organization or agency to which a 

Head Start grantee has delegated all or part of its responsibility for operating a Head Start 

program. For the remainder of the report, we will refer to grantees and delegate agencies 

as grantees only. 

The Extent to Which 

Head Start Programs 

Are Underenrolled is 

Not Known 

ACF Annual Grantee 

Surveys Contain 

Inaccurate Enrollment 

Data 
Page 12 GAO-04-17 Head Start Enrollment 

school programs, and reporting on 2 months in which enrollment was not 

their highest. 

We found that ACF regional offices employed different criteria and used a 

variety of data sources and approaches to determine if a grantee is 

underenrolled. Given that regional offices are responsible for identifying 

and monitoring underenrollment, we asked regional offices to identify 

their operational criterion for an unacceptable level of underenrollment. 

Of 11 regional offices we surveyed, we found that 3 did not utilize a 

specific threshold to distinguish between acceptable and unacceptable 

underenrollment, while the other 8 offices used different thresholds. Each 

of the 3 regions that did not have a set threshold for “unacceptable” 

underenrollment indicated that underenrollment was treated on a case-bycase basis that would take into consideration the degree of 

underenrollment and other factors, including the grantee’s efforts to 

increase enrollment. For the regions that specified thresholds of 

“unacceptable” underenrollment, these thresholds ranged from any 

enrollment ratio below 100 percent in 3 regions to below 74 percent in one 

region (See table 1.) 

Regional Monitoring 

Efforts Employed Varied 

Criteria and Lacked Timely 

Data 
Page 13 GAO-04-17 Head Start Enrollment 

Table 1: ACF Regional Thresholds for Unacceptable Levels of Underenrollment 

ACF region or branch and coverage area 

 Thresholds for unacceptable 

underenrollment 

Region I 

Connecticut, Maine, Massachusetts, New 

Hampshire, Rhode Island, and Vermont 

 No threshold 

Region II 

New Jersey, New York, Puerto Rico, and U.S. 

Virgin Islands 

 No threshold 

Region III 

Delaware, District of Columbia, Maryland, 

Pennsylvania, Virginia, and West Virginia 

 Less than 97 percent 

Region IV 

Alabama, Florida, Georgia, Kentucky, Mississippi, 

North Carolina, South Carolina, and Tennessee 

 Less than state averagea

Region V 

Illinois, Indiana, Michigan, Minnesota, Ohio, and 

Wisconsin 

 Less than 100 percent 

Region VI 

Arkansas, Louisiana, New Mexico, Oklahoma, 

and Texas 

 No threshold 

Region VII 

Iowa, Kansas, Missouri, and Nebraska 

 Less than 74 percent 

Region VIII 

Colorado, Montana, North Dakota, South Dakota, 

Utah, and Wyoming 

 Less than 95 percent 

Region IX 

Arizona, California, Hawaii, Nevada, and Pacific 

Insular Areas 

 Less than 95 percent 

Region X 

Alaska, Idaho, Oregon, and Washington 

 Less than 100 percent 

American Indian-Alaska Native Program Branch—

23 of 50 states 

 Less than 100 percent 

Source: GAO survey of ACF regional offices and ACF. 

a

State average in region IV refers to the average enrollment level of all Head Start grantees for each 

state within the region. 

ACF regional offices reported that they identify unacceptable 

underenrollment primarily by visiting grantees every 3 years and also by 

engaging grantees in periodic dialogue. More than half of the regions also 

said that they relied heavily on PIR data and on their review of grantrefunding applications. Finally, 5 regions indicated that they rely to a great 
Page 14 GAO-04-17 Head Start Enrollment 

extent on their reviews of annual audits of grantees. Table 2 presents the 

extent to which regional offices rely on various approaches to identify 

underenrollment. 

Table 2: Number of ACF Regions Relying on Various Methods to Oversee Head 

Start Grantee and Delegate Agency Enrollment Levels 

 Extent relied upon 

Great or 

very great Moderate 

Some, little, 

or no 

On-site monitoring 11 0 0 

Periodic dialogue with grantees 10 1 0 

Review of grant re-funding 

application 8 2 1 

Analyze PIR data 7 3 1 

Review of annual audits 5 3 3 

Source: GAO survey of ACF regional offices. 

Each of the approaches used by regional offices to monitor enrollment is 

lacking in timeliness or accuracy, or is not used systematically to monitor 

underenrollment. For example, in 3 regions we visited, ACF officials 

commented that while the on-site visits are designed to systematically 

assess underenrollment, the visits do not provide timely information 

because they are only conducted every 3 years. Conversely, while most 

regional officials we surveyed said that they rely on periodic discussions 

with grantees to identify underenrolled grantees, regional officials we 

visited said that they do not systematically discuss enrollment levels with 

grantees during this process. Officials from one region we interviewed also 

said that enrollment data included in grant re-funding applications are not 

informative because the data are based on forecasts. Also, while surveyed 

officials listed the PIR data as a key resource, those we spoke with said it 

was not necessarily accurate or timely due to the fact that data arrive after 

the subsequent program year has begun. Finally, regarding the use of 

annual audits, regional officials we spoke with said they did not always 

receive them for all grantees and that the audits they did receive do not 

necessarily comment on grantee enrollments.11

 11Currently, under the Single Audit Act any state or local government or nonprofit 

organization that spends $300,000 or more per year ($500,000 for fiscal years ending after 

December 31, 2003) in federal funds must have its financial statements, internal controls, 

and compliance with federal laws and regulations audited. 
Page 15 GAO-04-17 Head Start Enrollment 

Applying a range of underenrollment thresholds to national data indicates 

that a higher percentage of grantees may be underenrolled than what was 

reported to us by regional offices. Regional offices, using a range of 

enrollment thresholds, reported to us that about 7 percent of grantees 

were unacceptably underenrolled. Comparatively, PIR survey data 

indicated that more than 50 percent of Head Start grantees had enrollment 

ratios below 100 percent—the regulatory definition of fully enrolled. PIR 

data also showed a significantly higher proportion of grantees—33 

percent—reported enrollment ratios below 95 percent than the 7 percent 

of grantees reported as unacceptably underenrolled by the regional 

offices. Finally, PIR data showed that a similar proportion of grantees—

about 9 percent—reported an enrollment ratio below 80 percent as the 

7 percent of unacceptably underenrolled grantees reported to us by the 

regions. (See fig. 5.) 

Figure 5: Comparison of Enrollment Ratios as reported in 2001-02 PIR Survey with 

Unacceptably Underenrolled Grantees as Reported by ACF Regions 

The portion of grantees that regions reported as unacceptably 

underenrolled differed from what would have been identified by applying 

the regional threshold to national PIR data. When compared with the 

percentage of unacceptably underenrolled grantees reported by regions, 

National Data on the 

Extent of Underenrollment 

Differs from Regionally 

Reported Data on Number 

of Unacceptably 

Underenrolled Grantees 

Percentage of all grantees

0

10

20

30

40

50

60

PIR < 100%

PIR < 95%

PIR < 80%

Regionally

identified

Source: GAO analysis of ACF regional office survey responses and PIR data.

57

33

9

7
Page 16 GAO-04-17 Head Start Enrollment 

PIR data show larger percentages of grantees below these thresholds for 

each region that specified a threshold. This was true even in regions that 

indicated they relied on PIR data to a great or very great extent. (See table 

3). For example, region V, using a threshold of 100 percent for 

unacceptable underenrollment, reported to us that slightly less than 2 

percent of its grantees were unacceptably underenrolled in 2001-02. PIR 

data from that same year indicate that about 62 percent of region V 

grantees had enrollment ratios less than 100 percent—a difference of 60 

percentage points from what was reported to us. In fact, only regions III 

and VII, of the 7 regions in table 3 with clearly defined thresholds for 

unacceptable underenrollment, reported to us a percentage of 

unacceptably underenrolled grantees that was within 10 percentage points 

of what PIR data show using the same threshold. While we do not think 

that PIR data are reliable for reporting national enrollment figures, the 

regional offices based what they reported to us in part on their review of 

PIR data. 
Page 17 GAO-04-17 Head Start Enrollment 

Table 3: Percentage of Head Start Grantees, by Region, Reported as Unacceptably Underenrolled by ACF Regions with 

Unacceptable Underenrollment Thresholds, Compared with PIR Data at the Same Thresholds 

Region/program branch 

Regionally defined 

unacceptable 

underenrollment 

threshold 

Percentage of 

grantees reported 

by ACF regions as 

being unacceptably 

underenrolled in 

2001-02 

Extent to which 

regional office 

reported relying on 

PIR data 

Percentage of grantees 

reporting enrollment 

ratios at less than 

regionally defined 

unacceptable 

underenrollment 

threshold using 2001-02 

PIR survey 

Region V 

Illinois, Indiana, Michigan, 

Minnesota, Ohio, and 

Wisconsin 

Less than 100 percent 1.7 Moderate 62 

Region X 

Alaska, Idaho, Oregon, and 

Washington 

Less than 100 percent 13.6 Great 64.8 

American Indian-Alaska 

Native Branch – 23 of 50 

states 

Less than 100 percent 44.5 Great 59.8 

Region III 

Delaware, District of 

Columbia, Maryland, 

Pennsylvania, Virginia, and 

West Virginia 

Less than 97 percent 14.3 Very great 21.4 

Region VIII 

Colorado, Montana, North 

Dakota, South Dakota, 

Utah, and Wyoming 

Less than 95 percent 4.3 Some 26.1 

Region IX 

Arizona, California, Hawaii, 

Nevada, and Pacific Insular 

Areas 

Less than 95 percent 0.9 Moderate 33.8 

Region VII 

Iowa, Kansas, Missouri, 

and Nebraska 

Less than 74 percent 2.2 Great 8.2 

Source: GAO analysis of survey responses from ACF regional offices and PIR data. 

As a result of differences in regional definitions of what constitutes an 

unacceptable level of underenrollment, grantees with similar levels of 

underenrollment may be treated differently across regions, particularly in 

areas without a defined threshold. Regional offices reported to us that 

they take a variety of actions to address unacceptable underenrollment, 

including increased monitoring, technical assistance, and, occasionally, 

enforcement actions, including recouping funds and reducing future grant 

Differing Definitions of 

Underenrollment Create 

Potential for Uneven 

Treatment of Grantees 

across Regions 
Page 18 GAO-04-17 Head Start Enrollment 

awards. To the extent that differing thresholds affect the identification of 

deficiencies that would lead to these actions, regions may subject grantees 

to different treatment. For example, as shown in table 4, although a higher 

percentage of grantees in region II have enrollment levels below 95 

percent than in region III, according to PIR data (44 percent versus 18 

percent), region II considers only 3 percent of its grantees unacceptably 

underenrolled, while region III considers 14 percent of its grantees 

unacceptably underenrolled. This discrepancy may be attributable to the 

fact that region II lacks a threshold for defining unacceptable enrollment, 

while region III has set a threshold of 97 percent. As a result, more 

grantees in region III have been subject to monitoring and enforcement 

actions. 

Table 4: Comparison of Region II and III Grantees Identified as Underenrolled 

Region II—New Jersey, New York, 

Puerto Rico, and U.S. Virgin Islands 

Region III—Delaware, District of 

Columbia, Maryland, Pennsylvania, 

Virginia, and West Virginia 

Percentage of grantees with enrollment ratio 

below 95% according to PIR 44.4 % 17.6 % 

Threshold for unacceptable enrollment No threshold Less than 97% 

Percentage of grantees reported to us by 

region as unacceptably underenrolled 2.7 14.3 

Source: GAO analysis of survey responses from ACF regional offices and PIR data. 

ACF regional officials and officials of underenrolled Head Start grantees 

often cited a mixture of factors that made it difficult to achieve full 

enrollment, including increased parental demand for full-day child care 

and a decrease in the number of eligible children. Many said welfare 

reform has increased the number of working parents, increasing demand 

for full-day child care and reducing the number of eligible children. Also, 

more than one-half of the grantees we interviewed reported they were 

having difficulty acquiring and developing adequate facilities. Meanwhile, 

underenrolled grantees and ACF regional officials also said that 

underenrollment was occurring because more parents were seeking 

services with other early education and child care programs, some of 

which subsidized care with relatives. Other contributing factors, such as 

eligible families moving from the service area, language, and cultural 

differences between children’s families and program staff, and weak or 

inadequate recruiting efforts by the grantees, were less frequently cited. 

Regional and Grantee 

Officials Often Cited 

Combinations of 

Factors as 

Responsible for 

Underenrollment 
Page 19 GAO-04-17 Head Start Enrollment 

Many grantees indicated that the combination of multiple factors had 

fostered underenrollment for their program. Nearly two-thirds of the 

underenrolled grantees we spoke with cited two or more contributing 

factors. For example, one northern California grantee believed that 

underenrollment was caused by a decrease in income-eligible children in 

its area, because the high cost of living and a shortage of affordable 

housing in the area, and also by the number of families moving from 

welfare to work. In addition to citing the decrease in eligible children, this 

grantee expressed a need for more full-day slots, and reported facing 

increasing competition from day care programs that reimbursed relatives 

or friends to provide full-time child care. Similarly, one New Jersey 

grantee experiencing problems acquiring a new facility was also affected 

by a state supreme court decision requiring free preschool for poor 

children. Additionally, this grantee felt that it was losing eligible children 

as a result of families on welfare finding jobs and needing more full-day 

slots. A commonly cited combination of factors—cited by 8 of the 25 

grantees we interviewed—was the simultaneous shortage of full-day slots 

and the movement of families out of welfare and into the workforce. 

Regional and grantee officials most frequently cited the increased demand 

for full-day child care, construction delays and inadequate facilities, and 

the increased availability of early education and child care programs as the 

factors causing underenrollment. Other factors, such as high turnover 

rates and income eligibility criteria were also cited, but less frequently. 

Each of the factors affecting underenrollment that grantees and regions 

cited is described in more detail in the following sections. Appendix II lists 

the factors identified by regions as contributing to grantee 

underenrollment, and appendix III lists factors identified by grantees. 

Both regional and grantee officials said that the movement of low-income 

families from welfare to work had contributed to underenrollment. Seven 

of 11 regions cited the movement of low-income families from welfare to 

work as either a major or a moderate reason for grantees’ 

underenrollments. Similarly, of the 25 grantees we contacted, 11 cited this 

factor. Regional officials and grantees suggested the movement from 

welfare to work affected enrollments in two ways. First, as many parents 

began to work full-time, they increasingly needed full-day care. When 

Head Start grantees could not meet this need, some eligible families 

secured child care elsewhere. Second, some families entered work and 

earned income that disqualified their children from Head Start programs. 

A number of grantees related specific examples of how the movement 

from welfare to work affected enrollments. For example, 

Multiple Factors Often 

Linked to Underenrollment 

Increased Demand for 

Full-day Care, Facilities 

Problems, and Increased 

Availability of Other 

Programs Most Frequently 

Cited as Affecting 

Underenrollment 

Grantees and Regions Said 

Movement of Families from 

Welfare to Work Affected 

Enrollment and Increased 

Demand for Full-day Care 
Page 20 GAO-04-17 Head Start Enrollment 

• A large grantee in Illinois said that many former welfare recipients who 

need full-day child care services no longer qualify for Head Start because 

they earn wages just above the Head Start income guidelines or work 

rotating schedules to avoid using formal child care services. 

• A grantee in California said that the cost associated with switching to fullday care sometimes is a barrier to meeting families’ needs. 

Of the 25 underenrolled grantees we surveyed, 14 reported that difficulty 

acquiring and developing adequate facilities contributed to 

underenrollment. Similarly, over half of the 11 regions reported that 

underenrollment was linked to a major or moderate extent to facilities 

being completed more slowly than expected. For example, an Eastern 

grantee was unable to serve children in need of full-day care because it 

lacked classrooms and found it difficult to acquire more space. In the 

Midwest, 2 grantees reported that their inadequate facilities kept them 

from filling about 1,800 funded slots—43 percent of their funded slots—

even though many eligible families desired Head Start services for their 

children. The grantees said that they had difficulty acquiring alternate 

facilities: some potential sites were environmentally unsuitable, while 

others faced neighborhood opposition. In another case, an American 

Indian grantee that had 25 unfilled Early Head Start slots expects to 

achieve 100 percent enrollment in the fall of 2003 when a new facility is 

scheduled to open. 

Regional and grantee officials often indicated that competition from other 

early education or child care centers serving low-income preschool 

children contributed to Head Start underenrollment. Seven of 11 regions 

cited this factor as a major or moderate contributor to underenrollment, 

and 8 of 25 grantees we interviewed identified this factor. In addition, 5 

grantees said that a closely related factor also reduced families’ use of 

Head Start—the availability of state subsidies to pay relatives or friends 

for child care. 

Officials in 2 regions provided specific examples of increased availability 

of other programs having a negative impact on Head Start enrollment. 

According to region V officials, the availability of other programs had a 

major impact on a large grantee in Michigan when the public school 

system increased its preschool programming and as a result increased the 

options available to Head Start-eligible children. As a result, the grantee 

sustained a shortfall of almost 2,000 children. 

Grantees also reported specific examples of increased availability of other 

programs having a negative impact on Head Start enrollment: 

Construction Delays and 

Inadequate Facilities Affected 

Enrollments 

Other Early Education and 

Child Care Programs Can 

Affect Enrollments 
Page 21 GAO-04-17 Head Start Enrollment 

• A large underenrolled grantee on the East Coast said that availability of 

prekindergarten programs at public and charter schools is the most 

important reason its delegate agencies are underenrolled. 

• A medium-sized grantee in Oklahoma with 454 funded slots indicated that 

in the 2001-02 school year, the local public school started a preschool 

program for 4-year-old children that resulted in a slight decline in Head 

Start enrollments at some of its service centers. 

• Officials representing a smaller grantee in Georgia with 161 funded slots 

said that their program was affected in 2001-02 when the state funded a 

prekindergarten program in public schools. Specifically, the grantee said 

that some children who had been pre-enrolled for Head Start switched to 

the state-funded program. 

Regional and grantee officials also indicated that state subsidies for 

unlicensed child care caused some grantees to be underenrolled. Officials 

of region IX (Arizona, California, Hawaii, Nevada, and Pacific Insular 

Areas) said that increasingly, low-income parents make use of state child 

care subsidies to pay for child-care exempt from licensing standards, such 

as care provided by friends or nonresident relatives. Region IX officials 

believed this had a significant impact on reducing Head Start program 

enrollments. In another example, a grantee in Pennsylvania saw its 

enrollments drop after the state allowed parents to use state child care 

subsidies to pay nonlicensed child care providers such as relatives and 

friends. In another instance, a grantee in California said that since its 

program primarily offers part-day/part-year services, many families chose 

to use subsidized, license-exempt care by relatives or friends who can 

provide full-day or part-day care. 

Less frequently, regions and grantees also cited other factors as negatively 

influencing Head Start enrollment. Eight grantees indicated that eligible 

families had moved from their service areas, often because of the high cost 

of living, increasing underenrollment. Three regions also reported that 

high turnover rates among enrolled children contributed moderately to 

underenrollment. 

Five grantees indicated that the income-eligibility criterion for Head Start 

was too low in their high-cost areas. For example, 4 underenrolled 

California grantees said that even relatively poor families were disqualified 

from Head Start participation because their incomes, though inadequate to 

meet the basic costs in the local area, were above the federal poverty 

guidelines. Officials of an underenrolled grantee in Oakland indicated that 

during the 2002-03 program year they had denied Head Start services to 

over 100 families because their incomes exceeded the current poverty 

Other Factors Affected 

Enrollments, but Were Cited 

Less Frequently 
Page 22 GAO-04-17 Head Start Enrollment 

guidelines. The other three California grantees said that they were also 

turning families away because they were slightly over the income 

guidelines. Grantees said that families just over the federal poverty 

guideline cannot afford to send their children to education and child care 

programs equivalent in quality to Head Start programs. 

Four regions cited inadequate program management factors, such as weak 

recruitment efforts, as a major or moderate contributor to 

underenrollment. Five grantees also cited such factors as inhibiting Head 

Start enrollments. Inadequate program management was characterized by 

weak recruitment efforts, not developing or using waiting lists of Head 

Start-eligible children, and planning enrollment expansions poorly. For 

example, a grantee in Pennsylvania agreed to expand enrollment by 144 

slots, and although the grantee received increased funding in the 2000-2001 

program year, grantee officials said they had difficulty filling the additional 

slots because of inadequate planning by the previous management team. 

Three grantees in California noted that language and cultural differences 

between eligible Head Start families and program staff complicated 

outreach and consequently reduced enrollments from some minority 

groups. One grantee indicated that families in its service area spoke over 

25 languages at home. Another grantee said it was difficult to find staff 

that spoke the same languages as the families needing service. 

ACF national and regional offices and grantees all report taking action to 

address underenrollment, such as issuing guidance, increasing monitoring, 

and attempting to conduct broader outreach efforts. The ACF national 

office issued a memorandum instructing regional offices to address 

underenrollment, and all ACF regions we surveyed said that they have 

increased their monitoring efforts. Some ACF regions have also taken 

action to reduce grantees’ funding and recoup federal funds. Many 

grantees we spoke with have increased outreach efforts, sought partners 

to help provide more full-day services, and increased the capacity of 

physical facilities. While 18 of the 25 grantees we contacted had made 

progress toward achieving full enrollment, others cited continuing 

challenges. 

ACF and Grantees 

Use a Variety of 

Approaches to 

Address 

Underenrollment 
Page 23 GAO-04-17 Head Start Enrollment 

In April 2003, ACF headquarters issued policy guidance to its regional 

offices instructing them to take specific actions with underenrolled 

grantees, although it provided no particular instructions for the review 

process or any criteria for prioritizing grantees for corrective action. The 

guidance instructs regional officials to address underenrollment 

depending on four possible causes. For example, if the grantee can 

demonstrate that an inappropriate program option is causing 

underenrollment, the guidance instructs regions to carefully consider 

grantee requests to make changes to their services, such as converting 

current part-day slots to full-day slots. The four causes identified in the 

guidance and the recommended actions are summarized in table 5. 

ACF-Issued Guidance for 

Managing 

Underenrollment Lacks 

Specific Criteria for 

Priority Review and 

Corrective Action 
Page 24 GAO-04-17 Head Start Enrollment 

Table 5: April 2003 National Head Start Guidance to ACF Regions 

 Category of underenrollment Expected regional action 

1 Temporary in nature (e.g., awaiting completion 

of a new facility). 

Ask grantee to document in writing when it will return to full enrollment. Periodic 

follow-up by assigned regional program specialist. Reevaluate grantee status if it 

remains in this category for more than several months. 

2 Attributable to a nonimplemented expansion 

(i.e., where a grantee that was given 

expansion funding to serve an increased 

number of children failed to enroll these 

children within a reasonable time period). 

Generally, all grantees must have the additional children enrolled in their 

programs within 1 year of receiving their grant expansion. Regions should 

• track grantee expansion, 

• contact grantee and discuss reasons for delays, 

• judge whether grantee is making sufficient progress to warrant extension, 

• require an implementation plan for any extension, which must not exceed 

6 months, and 

• inform the grantee in writing that expansion funds will no longer be available if 

at any time the region determines that the grantee will not be able to 

implement its approved expansion in a reasonable time period. 

3 Attributable to demographic changes that have 

reduced the number of eligible children in the 

grantee’s service area. 

Determine an appropriate reduction in the grantee’s enrollment and funding 

levels. ACF’s general policy will be to 

• give the grantee appropriate notice that a funding reduction will be initiated, 

• implement funding reductions at the time a grant is being refunded, based on 

a grantee’s historical underenrollment problems, and 

• reduce funding proportionate to the degree of underenrollment (i.e., on a cost 

per child basis adjusting for those grantee costs that are not directly related to 

enrollment such as the salaries and fringe benefits of management staff. 

4 Not attributable to any of the above causes, 

but occurring because of grantee management 

issues. This would include poor community 

outreach, inadequate needs assessments, 

inappropriate program options, inadequate 

transportation services, poor facility planning, 

lack of coordination with other community 

providers, such as prekindergarten programs, 

or any other management problems causing 

underenrollment. 

Make an on-site monitoring visit to the grantee to fully assess the reasons for 

underenrollment. The assessment could result in the region designating the 

grantee as deficient. (The region may designate a grantee as being in noncompliance rather than deficient if it determines underenrollment is an isolated 

issue that does not seem to be part of a more systemic problem with the 

grantee’s ability to provide an appropriate level of Head Start services.) 

A deficient grantee is required to submit a Quality Improvement Plan (QIP) 

indicating how, within 1 year or less, it will achieve full enrollment. This could be 

accomplished by fixing the problem causing the underenrollment or by agreeing 

to an enrollment reduction that would bring the grantee to its full enrollment level, 

or some combination thereof. The region should monitor the grantee’s progress 

in implementing its QIP and provide any appropriate technical assistance. If the 

underenrollment has not been corrected at the end of the QIP period, the region 

needs to initiate an adverse action against the grantee, which would be 

termination or denial of re-funding. 

If an inappropriate program option is a major factor causing underenrollment, 

regions must consider a grantee’s request to reconfigure its program options. 

Changes such as conversion of part-day slots to full-day or reduction of double 

sessions may include some proposed reduction for enrollment levels. Each such 

proposal should be judged on its own merits, including the extent to which the 

grantee proposes to collaborate with other community providers and the extent 

to which the proposed reconfiguration is supported by data from the grantee’s 

current community assessment. 

Source: GAO analysis of ACF memorandum. 
Page 25 GAO-04-17 Head Start Enrollment 

The April guidance does not suggest any systematic process for identifying 

underenrolled grantees, nor does it specify criteria for prioritizing when 

grantees should be subject to corrective action based on their level of 

underenrollment. One regional official said that the lack of a threshold 

offered no gauge for establishing priorities and intensifying monitoring 

efforts. 

The ACF regions we surveyed reported taking a variety of actions to 

address underenrollment ranging from providing assistance to recouping 

federal funds in some cases. Officials in all 11 regions responded that they 

had taken at least one action to ensure that grantees address 

underenrollment. The interventions taken most often were to monitor 

enrollment levels (55 grantees), track improvement efforts (43), and 

provide training and technical assistance (30). Notably, 4 regions provided 

additional funds to a total of 18 underenrolled grantees to purchase or 

renovate facilities. Somewhat less often, regions took action to reduce 

funded enrollment levels or recoup funds. Specifically, only 2 regions 

reported that they recouped funds from a total of 6 underenrolled 

grantees. (See table 6.) 

Table 6: Actions by ACF Regions toward Underenrolled Grantees 

Regional actions 

Count of regions 

taking the action 

Number of grantees to 

which action applied 

Identified deficiency and pursued QIP 6 19 

Met with grantees and developed plan to address underenrollment 5 29 

Required frequent (such as monthly) reporting of enrollment 5 55 

Provided funds for purchase or renovation of facilities or for more comprehensive 

community assessments 4 18 

Tracked correction efforts for compliance 3 43 

Provided training and technical assistance 3 30 

Negotiated reductions in funding levels and funded slots 3 9 

Withheld or recaptured funds for the year of underenrollment 2 6 

Held meetings with grantee’s board and management 2 3 

Proposed Head Start grant be relinquished or terminated 2 2 

Requested audit by the HHS Office of Inspector General 1 1 

Changed program options 1 1 

Source: GAO analysis of ACF regional office survey responses. 

Regional Officials 

Reported Intervening with 

Underenrolled Grantees to 

Correct Underenrollment 
Page 26 GAO-04-17 Head Start Enrollment 

As noted earlier, many regions and grantees said the need for full-day 

services was a major factor fostering underenrollment. As part of their 

efforts to assist grantees in providing more full-day services, some ACF 

regional officials told us they had encouraged grantees to collaborate with 

other programs or had provided additional funds to purchase or renovate 

facilities. However, such efforts can be costly. For example, region V 

officials told us that it costs more to provide full-day care than part-day 

care because full-day care requires more facility space and staff per child. 

Grantees we interviewed took a variety of actions to address 

underenrollment, including more aggressive recruiting efforts, 

collaborating with other preschool and child care programs, and 

increasing slots in selected program options such as home-based services. 

Most grantees we contacted said that they had taken one or more actions. 

The most frequently mentioned was more aggressive recruiting followed 

by collaboration with other programs. For example, a large grantee in New 

York State that faced increased demand for full-day care since welfare 

reform collaborated increasingly with other child care providers to piece 

together a package of full-day services. Nine grantees also reported trying 

to increase physical facilities capacity. (See table 7.) Other actions taken 

to address underenrollment, which were cited by 3 or fewer grantees, 

included improving the tracking or monitoring of enrollment 

opportunities, hiring multilingual staff, reducing the number of funded 

slots, and providing contractual incentives for delegate agencies to 

maintain full enrollment. 

Underenrolled Grantees 

Report Taking Some 

Remedial Actions 
Page 27 GAO-04-17 Head Start Enrollment 

Table 7: Actions Taken by Interviewed Grantees to Address Underenrollment 

Action taken 

Number of grantees 

taking the action 

(n = 25) 

Took more aggressive and proactive recruiting approach 14 

Collaborated with other preschool and child care programs 12 

Increased capacity of physical facilities 9 

Increased slots in selected program options 6 

Worked on updating community assessment 6 

Increased marketing of Head Start to the community 5 

Relocated and developed new program centers 5 

Identified a new unserved low-income population 4 

Trained staff in recruitment and program promotion 2 

Increased home-based program enrollments 1 

Source: GAO analysis of interviews with underenrolled grantees. 

Several grantees told us that converting part-day services to full-day was 

often challenging to implement in addition to being more costly. 

Additionally, 2 grantees said that ACF did not fully understand all that was 

involved in transitioning from part-day to full-day services, and that there 

was no clear national guidance on how to do so. According to these 

California grantees, 

The costs of transitioning part-day, double sessions, to full-day services have never been 

fully understood and no national process has emerged to assist grantees and regional 

offices to address this problem. The major costs often include facilities and additional 

staffing (where only two and one-half staff are needed for a double session, four to six are 

needed to staff a full-day session, depending on the number of hours the option operates). 

Such fixed costs would require a reduction in the number of slots (children enrolled) or an 

increase in funding in order to transition from part-day double sessions to two full-day 

sessions. 

While these two grantees expressed concern over a lack of guidance, it 

should be noted that there is national guidance on budgeting for 

partnerships between child care and Head Start and on financial 

Grantees Cite Obstacles to 

Providing Additional FullDay Care 
Page 28 GAO-04-17 Head Start Enrollment 

management issues in Head Start programs utilizing other funding 

sources.12

Furthermore, grantees told us of their concern to maintain total funded 

enrollment levels, even as they were converting unfilled part-day openings 

to full-day. According to region V officials, this concern to maintain 

enrollment levels may be in keeping with national efforts to serve a greater 

number of needy children.13 For example, one underenrolled grantee said 

that ACF suggested several alternatives to address underenrollment, 

including converting part-day to full-day slots, but would not permit the 

grantee to reduce funded slots as a way to address underenrollment. 

Consequently, while converting part-day slots to full-day slots, the grantee 

would have had to expand its facilities or find other child care partners in 

order to serve the same number of children. 

Some grantees reported success addressing underlying factors 

contributing to underenrollment, while others did not. Of the 25 

underenrolled grantees that we contacted, 18 (72 percent) indicated that 

their underenrollment had either been corrected (10 grantees) or would be 

corrected shortly (8 grantees). These 18 grantees overcame a variety of 

factors that they said affected underenrollment. For example, 6 of these 18 

grantees overcame a shortage of available full-day slots and 8 managed to 

fill slots lost due to a decline in eligible children attributed to declining 

TANF rolls. The 7 grantees that had not made progress addressing 

underenrollment often cited similar issues. For example, 3 of these 

7 grantees said they had faced challenges resulting from decreasing TANF 

caseloads and were unable to respond to the increased demand for fullday services. On the basis of our limited number of interviews, we could 

not determine why some grantees reported they were able to successfully 

address problems that other grantees could not. 

Because ACF has no reliable nationwide data on enrollment, it is not 

possible for the agency to identify and track underenrollment trends and 

to develop strategies to ensure that federally funded Head Start slots are 

filled. While we could not determine with any precision the extent to 

 12ACF Information Memorandums: IM-HS-01-13, 11/16/2001 and IM-HS-01-06, 3/8/2001. 

13ACF’s primary performance indicator for the number of children served gives equal 

weight to part-day and full-day slots. 

Grantees Reported Mixed 

Results Resolving 

Underenrollments 

Conclusions 
Page 29 GAO-04-17 Head Start Enrollment 

which there is underenrollment, our survey work and analysis indicate it is 

possible that underenrollment is more widespread than ACF has 

acknowledged. The complexity of factors buffeting Head Start grantees 

underscores the need for ACF to accurately identify underenrollment and 

its causes on a timely basis. Even if ACF corrects national survey data 

issues, there is no guarantee that its regions will know of underenrollment 

in a timely manner because the main national data source is not available 

until the following program year. 

Furthermore, because ACF regions vary in how they define unacceptable 

levels of underenrollment and because they rely on approaches to identify 

grantees that are not timely or consistent, there is some indication that 

Head Start grantees with similar levels of underenrollment are treated 

differently across regions. ACF guidance to the regions on how to address 

different types of underenrollment is a good first step toward a more 

systematic approach to underenrollment. However, until ACF issues 

guidance that more clearly explains how to prioritize grantees with 

varying levels of underenrollment for purposes of corrective action, 

regions are likely to continue using varied criteria or none at all. Also, until 

more timely and systematic approaches are developed for regions to 

identify underenrolled grantees, it is possible that low enrollment will go 

undetected and federal dollars will not be fully utilized for low-income 

children who could benefit from Head Start’s program goals. 

Finally, it appears that there may be a perceived incentive for 

underenrolled grantees to maintain or increase enrollments due, in part, to 

ACF’s emphasis on counting the total number of children served 

irrespective of whether they are enrolled part-day or full-day. Measuring 

Head Start enrollments without capturing the difference in level of service 

provided by full-day or part-day programs adds to the difficulty of meeting 

local needs and adjusting to changes in those needs. Until ACF can get a 

better grasp of the nature and size of underenrollment and align program 

incentives with family needs, it may be a challenge for Head Start to best 

meet the needs of some families it could serve. 

We recommend that the Secretary of HHS direct ACF to (1) take steps to 

ensure the accuracy of enrollment data reported in its annual nationwide 

survey of grantees, (2) develop a standard criterion for regional offices to 

use in identifying grantees whose underenrollment merits monitoring or 

corrective actions, (3) develop an additional measure of aggregate services 

other than total enrollment that takes into consideration the different 

levels of service provided by full-day and part-day programs, and (4) work 

Recommendations for 

Executive Action 
Page 30 GAO-04-17 Head Start Enrollment 

with regional offices to develop a more systematic process for them to 

collect reliable enrollment data during the program year so that they can 

address underenrollment more quickly. 

We provided a draft of this report to the Department of Health and Human 

Services for review and comment. In its written response, included as 

appendix IV of this report, HHS agreed with our recommendations and 

indicated that it will take action to address each recommendation. 

We are sending copies of this report to the Secretary of Health and Human 

Services and other interested parties. In addition, the report will be 

available at no charge on GAO’s Web site at http://www.gao.gov. 

If you or your staffs have any further questions about this report, please 

call me on (202) 512-7215. Other GAO contacts and staff acknowledgments 

are listed in appendix V. 

Sincerely yours, 

Marnie S. Shaul 

Director, Education, Workforce, 

 and Income Security Issues 

Agency Comments 
Appendix I: Scope And Methodology 

Page 31 GAO-04-17 Head Start Enrollment 

To determine what is known about the extent to which Head Start 

programs are underenrolled, we assessed the reliability of PIR enrollment 

data, conducted interviews, reviewed program documentation, and 

surveyed ACF regional offices. Specifically, we assessed the reliability of 

the PIR data on grantee enrollment by (1) performing electronic testing of 

key data elements for obvious errors in completeness and accuracy, 

(2) reviewing existing information about the data and the system that 

produces it, and (3) contacting 19 underenrolled and overenrolled 

grantees selected across a range of reported enrollment ratios. We did not 

assess the reliability of other PIR data used in the report. We also 

interviewed ACF headquarters officials, reviewed federal guidance and 

regulations on enrollment, surveyed the regions and a branch office, and 

interviewed regional officials in regions III, V, and IX. The 3 regions were 

selected for site visits on the basis of geographical representation and the 

number of underenrolled grantees they reported to us. Since ACF 

oversight of Head Start grantees is primarily accomplished through its 

regions and program branches, we designed a survey instrument in which 

these entities could provide written responses to our specific requests for 

such information as: 

• the methods the regions used to oversee grantee and delegate agency 

enrollment levels; 

• the threshold, if any, they had established for determining the point at 

which a grantee or delegate agency’s level of underenrollment is 

considered to be unacceptable; 

• a list of all grantees and delegate agencies that they believed had 

unacceptable levels of underenrollment for both the 2001-02 and 2002-03 

program years; 

• the reasons that they believed unacceptable levels of underenrollment had 

occurred and the extent (major, moderate, minor, or none) that they 

believed each identified reason had contributed to underenrollment; 

• the actions they had taken to address the unacceptable level of 

underenrollment for their grantees and delegate agencies. 

We surveyed all 10 ACF regional offices and the American Indian-Alaska 

Native Program Branch. The Migrant and Seasonal Program Branch was 

excluded from our review because of its lack of comparability with the 

other branch and regions caused by anticipated enrollment fluctuations 

resulting from the seasonal movement of migrant families. 

Appendix I: Scope And Methodology 
Appendix I: Scope And Methodology 

Page 32 GAO-04-17 Head Start Enrollment 

To determine ACF officials’ and Head Start grantees’ views on the factors 

that contribute to underenrollment and to identify actions they took to 

address underenrollment, we relied on our survey of the ACF regional 

offices and the American Indian-Alaska Native Program Branch office as 

well as a interviews with 27 grantees (1 of which was actually a delegate 

agency) that had been identified by the regions as underenrolled. Twenty 

grantees were contacted by telephone and 7 were interviewed face-to-face. 

Two of the 27 grantees said that they had not experienced any 

underenrollment; therefore, our grantee survey results were based on the 

responses of 25 grantees that agreed with the regions’ designation of their 

underenrolled status. 

Using a standard set of questions, we interviewed at least 1 identified 

grantee from each region or branch. In selecting grantees to be 

interviewed, we chose 7 from the metropolitan areas of the 3 regions that 

we visited so that we could conduct some of the interviews in person. The 

other 20 grantees we interviewed were primarily selected from each region 

based on having been identified as being underenrolled for 2 program 

years (2001-02 and 2002-03). We also attempted to interview both grantees 

that were funded for more than 500 slots and grantees that were funded 

for fewer. 

The grantee interview requested that grantee officials 

• describe the factors they believed contributed to the grantee’s 

underenrollment, 

• identify the actions the grantee had taken to address underenrollment, and 

• indicate whether they believed that the grantee’s underenrollment had 

been corrected. 

Because of the lack of reliable enrollment data, the information we 

collected regarding underenrollment was primarily testimonial. Apart from 

assessing the basic consistency of interviewees’ responses with known 

program characteristics, we did not independently test the information 

they provided, such as reasons for underenrollment. 
Appendix II: Factors That the ACF Regions 

Believed Contributed to Underenrollment to a 

Major or Moderate Extent 

Page 33 GAO-04-17 Head Start Enrollment 

Table 8: Factors Cited By ACF Regions as Contributing to Underenrollment to a Major or Moderate Extent, during Program 

Years 2001-02 and 2002-03 

Factor cited as contributing to underenrollment 

Number of times 

cited 

Percentage of 

regions citing 

factor 

1 Fewer eligible families (moving into jobs and off TANF) 7 63.6 

2 Not enough full-day slots 7 63.6 

3 Other day care or education centers are available in the area 7 63.6 

4 Completion of facilities was slower than planned 6 54.5 

5 Demographic change: decrease in the number of eligible children in service area 6 54.5 

6 Shortage of eligible children below the poverty rate cutoff 5 45.5 

7 Too many part-day slots 5 45.5 

8 Waiting lists of eligible children not developed or used 4 36.4 

9 Weak recruitment efforts 4 36.4 

10 High turnover rate (e.g., families move often) 3 27.3 

11 Actual enrollments not yet caught up with recent funded program expansion 2 18.2 

12 Not enough part-day slots 1 9.1 

13 Too many full-day slots 1 9.1 

Source: GAO analysis of ACF regional office survey responses. 

Appendix II: Factors That the ACF Regions 

Believed Contributed to Underenrollment to 

a Major or Moderate Extent 
Appendix III: Factors that Grantees Believed 

Contributed to Their Head Start Programs’ 

Underenrollment 

Page 34 GAO-04-17 Head Start Enrollment 

Table 9: Factors Cited by 25 Grantees as Contributing to Head Start Program Underenrollment, during Program Years 2001-02 

and 2002-03 

 Factors contributing to underenrollment 

Number of times 

cited 

Percentage of 

grantees citing 

factor 

(n = 25) 

1 Difficulties in acquiring and developing adequate facilities 14 56.0 

2 Families moving into jobs and off TANF 11 44.0 

3 Not enough full-day slots 9 36.0 

4 Other day care or education centers are in the area 8 32.0 

5 Lack of housing for low-income families 7 28.0 

6 Income eligibility criterion too low for high-cost area 5 20.0 

7 Programs paying relatives or friends for child care 5 20.0 

8 Lack of income-eligible children in service area 4 16.0 

9 High turnover rate (e.g., families move often) 4 16.0 

10 High cost of living causes low-income families to move 4 16.0 

11 Language and cultural barriers among eligible families make selling program difficult 3 12.0 

12 Actual enrollments not yet caught up with expansion 2 8.0 

13 Centers in wrong service area location 2 8.0 

14 Centers with wrong mix of program service options 2 8.0 

15 High cost of transitioning from part-day to full-day care 2 8.0 

16 Inadequate program management 2 8.0 

17 Poorly planned enrollment expansion 2 8.0 

18 Weak or inadequate recruiting efforts 2 8.0 

19 Completion of facilities was slower than planned 1 4.0 

20 Difficulties in finding qualified collaborative care partners 1 4.0 

21 Head Start income levels too low for collaborating with other low-income programs 1 4.0 

22 Parents do not recognize the benefit of Head Start for their child 1 4.0 

23 Waiting lists of eligible children not developed or used 1 4.0 

Source: GAO analysis of interviews with underenrolled grantees. 

Appendix III: Factors that Grantees Believed 

Contributed to Their Head Start Programs’ 

Underenrollment 
Appendix IV: Comments from the U.S. 

Department of Health and Human Services 

Page 35 GAO-04-17 Head Start Enrollment 

Appendix IV: Comments from the U.S. 

Department of Health and Human Services 
Appendix IV: Comments from the U.S. 

Department of Health and Human Services 

Page 36 GAO-04-17 Head Start Enrollment 
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 37 GAO-04-17 Head Start Enrollment 

Betty Ward-Zukerman, (202) 512-2732, wardzukermanb@gao.gov

Bryon Gordon, (202) 512-9207, gordonb@gao.gov 

In addition to those named above, Daniel Jacobsen, Lesley Woodburn, 

Luann Moy, Barbara Johnson, James Rebbe, Susan Bernstein, and 

Amy Buck made key contributions to the report. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Acknowledgments 
Related GAO Products 

Page 38 GAO-04-17 Head Start Enrollment 

Education and Care: Head Start Key Among Array of Early Childhood 

Programs, but National Research on Effectiveness Not Completed. GAO03-840T. Washington, D.C.: July 22, 2003. 

Head Start and Even Start: Greater Collaboration Needed on Measures of 

Adult Education and Literacy. GAO-02-348. Washington, D.C.: March 29, 

2002. 

Early Childhood Programs: The Use of Impact Evaluations to Assess 

Program Effects. GAO-01-542. Washington, D.C.: April 16, 2001. 

Title I Preschool Education: More Children Served, but Gauging Effect 

on School Readiness Difficult. GAO/HEHS-00-171. Washington, D.C.: 

September 20, 2000. 

Early Education and Care: Overlap Indicates Need to Assess 

Crosscutting Programs. GAO/HEHS-00-78. Washington, D.C.: April 28, 

2000. 

Early Childhood Programs: Characteristics Affect the Availability of 

School Readiness Information. GAO/HEHS-00-38. Washington, D.C.: 

February 28, 2000. 

Education and Care: Early Childhood Programs and Services for LowIncome Families. GAO/HEHS-00-11. Washington, D.C.: November 15, 

1999. 

Head Start: Challenges in Monitoring Program Quality and 

Demonstrating Results. GAO/HEHS-98-186. Washington, D.C.: June 30, 

1998. 

Head Start Programs: Participant Characteristics, Services, and 

Funding. GAO/HEHS-98-65. Washington, D.C.: March 31, 1998. 

Related GAO Products 

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