Unemployment Insurance: Various Factors Affect Head Start and Other Early Childhood Teachers' Eligibility for Benefits
Published: 2016-10-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2015, the Head Start child development program provided federal funds to local grantees that employed over 90,000 teachers. Some of these grantees run programs that do not run during the summer, and some teachers may, in turn, seek UI benefits to help meet expenses during that time. All states have laws generally prohibiting certain employees of educational institutions from collecting UI benefits between terms, though they have flexibility in setting specific eligibility restrictions. GAO was asked to review Head Start and other ECE teachers' eligibility for UI benefits during the summer months.
This report examines (1) the extent to which states have laws or policies that affect whether Head Start and other ECE teachers are eligible for UI benefits during summer breaks; (2) how many Head Start teachers may have been eligible for these benefits during their summer breaks in 2015; and (3) what is known about how states communicate information about eligibility for UI benefit payments to Head Start and ECE employees and the effectiveness of these efforts. GAO surveyed UI directors in all 50 states, the District of Columbia, Puerto Rico, and the Virgin Islands (with 100 percent responding); analyzed Head Start data from program year 2015; reviewed relevant federal laws; and interviewed federal officials and stakeholders, including employer associations and teacher associations, in five states selected using criteria such as their benefit restrictions.
section_title: What GAO Found
paragraphs: In response to GAO's survey, officials from all 50 states, the District of Columbia, and two territories reported that they have various laws or policies that may affect whether Head Start and other early childhood education (ECE) teachers are allowed to collect unemployment insurance (UI) benefits during summer breaks. Officials in three states—Indiana, Pennsylvania, and Wyoming—reported that Head Start teachers are generally not eligible for UI benefits over summer breaks. In other states, officials outlined various factors that can affect eligibility. Specifically, officials from 30 states said the type of employer—for-profit, non-profit, or municipality—can influence eligibility for Head Start teachers (officials in 28 states reported this for ECE teachers). In addition, officials in 17 states reported that eligibility for Head Start teachers can be affected by the program's relationship to a school or board of education (officials in 11 states reported this for ECE teachers). For example, West Virginia officials reported that Head Start teachers considered under the authority of the board of education are generally not eligible for UI benefits.
In 2015, about half of the 90,000 Head Start teachers (about 44,800) across the country may have been eligible for UI benefits during their summer break, according to GAO's analysis of available data and the information states reported about their laws, regulations, and policies in response to GAO's survey. The remaining teachers and assistant teachers were likely not eligible because they worked for school districts or charter schools (about 14,150); worked in programs with breaks that were too short to allow them to collect benefits (about 28,940); or were generally not eligible under state laws, regulations, or policies (about 2,510).
To communicate UI eligibility rules to both employers and employees, state UI agencies reported using a variety of methods; however, selected stakeholders identified several concerns with these efforts. According to GAO's survey, state directors reported that they use various communication channels to provide general information to both employers and employees on matters, such as how to file a claim in their states. The three most commonly cited methods used by the states included websites, hotlines, and handbooks. Even though most states reported that they are using multiple methods of communication with employers and employees, some Head Start and ECE stakeholders in five selected states told GAO that the complexity of federal and state laws and policies governing state programs continue to make UI eligibility rules difficult to understand, even with information that their states are providing. While some of this confusion can be attributed to the variability and complexities of states' eligibility policies, GAO also found that states are generally not evaluating the effectiveness of their communication approaches. Specifically, over half of the states reported that they have not evaluated the effectiveness of their communication approaches with employees, and about two-thirds reported they have not evaluated the effectiveness of their communication approaches with employers. The states that were conducting evaluations reported that the feedback allowed them to make improvements in their communication materials for both employers and employees. For example, some states reported making their claims processing applications more user friendly and understandable as a result of this feedback.
section_title: What GAO Recommends
paragraphs: GAO is not making recommendations.

section_title: Letter
paragraphs: The Head Start program is one of the largest early childhood education  (ECE) programs overseen by the federal government. For fiscal year  2016, Congress appropriated nearly $9.2 billion for the program, and it  served approximately 1.1 million children in program year 2015. Head  Start services—including early learning for children and parenting  guidance and nutrition education for adults—were provided through  approximately 1,600 local organizations and funded by grants  administered by the Department of Health and Human Services (HHS).  Similar to other entities providing educational services, organizations  administering ECE might not run during the summer months, potentially  leaving their teachers and teaching assistants without work during that  time. To help meet expenses, some of these employees may seek  unemployment benefits until they return in the fall.
The federal-state unemployment insurance (UI) program, nationally  overseen by the Department of Labor (DOL), temporarily replaces part of  the lost earnings of those who become unemployed through no fault of  their own. Federal law provides a broad rule on eligibility for instructional  employees of certain educational institutions, though the specifics of  eligibility  are determined by each state. Given this state flexibility,  state  laws may vary in whether Head Start and other ECE employees are  eligible for UI benefits.
In 1985, HHS’s Office of Inspector General audited the Head Start  program and found widespread problems related to the receipt of UI  payments by its grantees’ personnel. The Inspector General  recommended, in turn, that routine UI payments should be discontinued  for those employees.
You asked us to provide information on the eligibility  of Head Start and  other ECE teachers  for UI benefits during the summer months.  Specifically, this report examines:  1.  the extent to which states have laws or policies that affect whether  Head Start and other ECE teachers can claim UI benefits during  summer breaks;  2.  how many Head Start teachers may have been eligible for UI benefits  during their summer breaks in 2015; and  3.  what is known about how states communicate information about  eligibility  for UI benefit payments to Head Start and ECE employees  and the effectiveness of these efforts.
To address these questions, we surveyed state UI directors (including all  50 states, the District of Columbia, Puerto Rico, and the Virgin Islands);  analyzed data from the Head Start program in conjunction with survey  results; and interviewed stakeholders in four states and one territory.  Specifically, for the first question we surveyed state UI directors about  state laws, regulations, and policies that might affect whether Head Start  and other ECE teachers are eligible to claim UI benefits during summer  breaks. We obtained responses from 100 percent of the states surveyed.  For the second question, we used data from the Office of Head Start’s  Program Information Report, which each Head Start grantee is required  to submit on an annual basis. In conjunction with data from the 2014- 2015 program year (the most recent available), we used information from  our survey on state laws, regulations, and policies to estimate the number  of Head Start teachers and teaching assistants who may be eligible for UI  benefits during summer breaks. After reviewing the Head Start program  data and interviewing knowledgeable officials about them, we found the  data to be sufficiently reliable for our purposes. For the third question, we  used our survey of state directors to ask about their respective states’  efforts to communicate with stakeholders regarding UI eligibility, and how  they evaluate these efforts. We also selected four states (Alabama,  Indiana, New Jersey, and Wyoming) and one territory (Puerto Rico)  where we interviewed state UI directors, Head Start grantees, and other  stakeholders to gather more in-depth information. We selected these  states to obtain a mixture of stakeholder experiences based on factors  such as the number of Head Start centers and survey responses  regarding eligibility  and improper payments. The results of these  interviews are not generalizable to all states. In addition, we interviewed  DOL, HHS, and state officials and stakeholders (including the National  Head Start Association and the National Association of State Workforce  Agencies) to obtain information on how they have assisted states and  grantees in communicating UI eligibility  restrictions. Lastly, we reviewed  relevant federal laws, regulations, and policies on agency roles and  responsibilities. For more information on our methodology, see   appendix I.
We conducted this performance audit from August 2015 to October 2016  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The Head Start program, which is overseen by HHS’s Office of Head  Start, performs its mission to promote school readiness and development  among children from low-income families through its nearly 1,600  grantees. More specifically, Head Start grants are awarded directly to  state and local public agencies, private nonprofit and for-profit  organizations, tribal governments, and school systems for the purpose of  operating programs in local communities. According to Head Start  program reports, more than 90,000 employees taught in grantee  programs during program year 2014-2015. Of these employees, about  half were preschool classroom teachers (44,677), and the other half were  preschool assistant teachers (45,725). Head Start officials told us that  many grantees do not run programs during the summer months, which  could leave these teachers and teaching assistants without wages from  these employers during that time. According to HHS, Head Start teachers  were paid about $29,000 annually (compared to annual median earnings  of nearly $52,000 for kindergarten teachers). Head Start teachers and  teaching assistants are among the approximately 960,000 ECE  employees across the nation, according to the Bureau of Labor  Statistics.
The nation’s UI system is a joint federal-state partnership originally  authorized by the Social Security Act and funded primarily through federal  and state taxes on employers. Under this arrangement, states administer  their own programs according to certain federal requirements and under  the oversight of DOL’s Office of Unemployment Insurance, but they have  flexibility  in setting benefit amounts, duration, and the specifics of  eligibility.  In order for employers in the states to receive certain UI tax  benefits, states must follow certain requirements, including that the states  have laws generally prohibiting instructional employees of certain  educational institutions from collecting UI benefits between academic  terms if they have a contract for, or “reasonable assurance” of,  employment in the second term. However, the Act does not define  educational institution, leaving states discretion with this classification.  Federal policies regarding the eligibility  of Head Start teachers for UI  benefits have remained the same for decades, according to DOL officials,  and are stated in a 1997 policy letter in which DOL’s position is clarified  on applying the federal provision regarding employees of educational  institutions.
section_title: State Officials Reported That State Laws and Policies Can Affect Teacher Eligibility for Unemployment Insurance Benefits All Head Start Teachers are Generally Not Eligible in Some States
paragraphs: In responding to our survey, state UI directors reported having to follow  various state laws and policies that may affect whether Head Start and  other ECE teachers are allowed to collect benefits during the summer.
In 3 of the 53 states and territories in which we conducted a survey about  laws and policies that may affect teacher eligibility,  officials reported that  Head Start teachers are generally not eligible for UI benefits over summer  breaks. Specifically, in 2 of the states we surveyed, officials reported that  Head Start teachers are generally not eligible for UI benefits over summer  breaks but other ECE teachers may be. In the first state, Pennsylvania,  officials told us that because of a 2007 state court decision, Head Start  teachers are generally not eligible for UI benefits because the state  generally considers Head Start teachers to be employees of educational  institutions, and such employees are generally not eligible. For other ECE  teachers, however, Pennsylvania officials said that eligibility  may vary by  employer. More specifically, the officials told us that employees of for- profit institutions would not be subject to the educational institution  restriction, and therefore may be eligible for UI benefits over summer  breaks. In the second state, Wyoming, officials reported that their state  excludes from UI eligibility  those engaged in instructional work of an  educational institution. The officials also reported that Head Start  teachers “fall under this provision by consistent interpretation and  precedent decisions” in Wyoming and therefore are not eligible for UI  benefits over summer breaks, though other ECE teachers not employed  by educational institutions are potentially  eligible for benefits during that  time.
Officials in a third state, Indiana, told us that state law restricts eligibility  for employees who are on a vacation period due to a contract or the  employer’s regular policy and practice, which affects both Head Start and  other ECE teachers who are on summer break. The officials explained  that these workers are not considered unemployed during regularly  scheduled vacation periods and are therefore not eligible to receive UI  benefits. This law was not targeted at Head Start or other teachers but  instead was meant to address those individuals with predictable vacation  periods, according to officials. Indiana’s Department of Workforce  Development determines whether the employee is on a regularly  scheduled vacation period by analyzing historical data, rather than relying  on the employer to notify the department. Officials told us they have an  internal unit that works to detect claims patterns over time to identify  these vacation periods for specific employers.
In contrast, based on what officials in the remaining 50 states and  territories we surveyed reported to us, Head Start and other ECE  teachers in the remaining states may be eligible for benefits over summer  breaks in those states, usually depending on a number of factors, such as  the type of employer or the program’s connection to a school or board of  education, as discussed below.
subsections: section_title: Type of Employer Can Affect Eligibility
paragraphs: Officials told us that eligibility  for UI benefits can be affected by the type of  employer in 30 states for Head Start and 28 for ECE. State officials  reported having to abide by a wide ranging set of laws and policies in this  area, including those that sometimes include or exclude certain types of  organizations from the state’s definition of educational institution. For  example:
Employers included as educational institutions. Officials in some  states told us that their laws include certain types of employers in the  definition of an educational institution. Consequently, Head Start and  ECE teachers at these institutions are generally not eligible for UI  benefits over summer breaks. For example, New York officials told us  that nursery schools and kindergartens would be considered  educational institutions but day care providers generally would not.  Alaska officials reported that the state generally defines an  educational institution as a “public or not-for-profit” institution that  provides an organized course of study or training. Head Start  employees of private for-profit institutions, however, may be eligible.
In a separate example, New Jersey officials told us that teachers who  work in private preschools mandated by the state to operate in  districts known as “Abbott districts” are generally not eligible for UI  benefits during summer breaks, because they are considered  employees of educational institutions. In Abbott districts, they said,  the state must provide preschool for all students living in that district,  either directly through a public agency or by contracting with a private  provider, which could also potentially be a Head Start grantee  organization. They further explained that Abbott teachers are paid  significantly higher salaries than Head Start teachers outside of  Abbott districts are paid. As a result, they said, Abbott teachers may  be less in need of UI benefits during summer breaks. Furthermore,  ECE teachers who work for non-Abbott providers are potentially  eligible, according to New Jersey officials.
Employers not considered educational institutions. In other  cases, state officials reported that their laws specified that certain  types of employers are not included in the definition of an educational  institution and that teachers working for these specific types of  employers are potentially eligible for UI benefits over summer breaks.  For instance, officials in 10 states for Head Start and 4 states for ECE  reported that community action groups operating Head Start or other  ECE programs are not included in the definition of an educational  institution. Therefore, the general restriction against employees of  educational institutions getting UI benefits during summer breaks  does not apply to these teachers. For example, Kansas officials  reported that private for-profit institutions are not considered  educational institutions, and California officials reported that non- profits are not considered educational institutions. Head Start and  ECE teachers in these types of programs may be eligible for benefits.
section_title: The Program’s Relationship with a School or Board of Education Can Affect Eligibility
paragraphs: Officials in 17 states reported that UI eligibility  for Head Start teachers  can be affected by the program’s relationship to a school or board of  education, and officials in 11 states reported similar restrictions for ECE  teachers. For example:
Program is an “integral part” of a school or school system.
Officials in some states reported that teachers who worked for Head  Start and ECE programs that operated as integral parts of a school or  school system could be affected by eligibility  restrictions. For  example, Illinois officials specified in their response to our survey that  “integral part” means the Head Start program is conducted on the  premises of an academic institution and that the staff is governed by  the same employment policies as the other employees of the  academic institution.
Program’s relationship with a school board. In other states,  officials reported potentially allowing or restricting eligibility for Head  Start and other ECE programs based on the program’s relationship  with a board of education. West Virginia officials reported that if a  teacher works for a Head Start program that is “under the influence or  authority” of a county board of education, and his or her wages are  reportedly paid by the board of education, the teacher is generally  considered a school employee and is therefore not eligible for UI  benefits over the summer break. Colorado officials told us that  “educational institution” does not include Head Start programs that are  not part of a school administered by a board of education.
section_title: About Half of All Head Start Teachers May Have Been Eligible for Unemployment Insurance Benefits during Summer Breaks in 2015
paragraphs: We estimated that approximately 44,800 of the nearly 90,400 Head Start  teachers across the country may have been eligible for UI benefits during  their summer breaks in 2015. Among the teachers who were likely  ineligible for UI benefits, we estimated that about 14,150 were likely not  eligible because they work in school systems or charter schools, which  we assumed would be included in the states’ definitions of educational  institutions. We also estimated that about 28,940 Head Start teachers did  not have summer breaks long enough to allow them to collect UI benefits.  Because states pay UI benefits on a weekly basis, and in most states  individuals must first serve a waiting period of a week, employees must  have a summer break of at least 2 weeks in most states before they can  collect benefits. This break must be at least 1 week in states without a  waiting period. We counted those teachers at employers with shorter  summer breaks than these as likely ineligible. Lastly, we estimated that  about 2,490 were likely not eligible to receive UI benefits during summer  breaks because of state restrictions, as shown in figure 1.
Based on our analysis of available data, about 2,100 of these teachers  work in Indiana, Pennsylvania, and Wyoming, where, as mentioned  earlier, Head Start teachers are generally not eligible for UI benefits over  summer breaks. The other Head Start teachers we estimated were likely  not eligible for UI benefits were potentially affected by restrictions on  teachers who work for certain types of employers, such as government  agencies or non-profits.
section_title: States Identified Various Communication Efforts with Employees and Employers of Head Start and Early Childhood Education Programs, and Stakeholders Identified a Number of Limitations with These Efforts
paragraphs: States reported using a variety of methods to communicate general UI  eligibility  information to both Head Start and ECE employers and  employees. Specifically, state officials most frequently reported using  websites to communicate laws, regulations, and policies regarding UI  benefit eligibility  to employers and employees (52 out of 53 states, or 98  percent), followed by the use of handbooks with 39 out of 53 states (74  percent) reporting using this method for employers and 47 out of 53  states (89 percent) reporting using this method for employees. Beyond  these approaches, state officials often reported being in contact with  employers through call centers, with 26 out of 53 states (49 percent)  reporting this method. The other most frequently used communication  approach for employees was through hotlines, with 44 out of 53 states  (83 percent) reporting using this method. See figure 2 for more  information on communication methods states reported using to  employers and figure 3 for communication methods states reported using  to employees.
Even with the information states reported providing, the Head Start and  ECE employer and employee representatives we interviewed said that  state UI programs can remain difficult to understand because of the  complexity of the various federal and state laws, regulations, and policies  governing the programs. For example, one employer in Wyoming told us  that she did not feel she could effectively advise her employees on  eligibility  policies because there was no clear, readily available  information or guidance from the state. More specifically, the employer  told us that a general overview of what the benefits are, how long they  last, and what requirements claimants have to meet to keep receiving  benefits would be helpful. However, through our survey, officials in 51 of  53 states (96 percent) reported that they did not provide any additional  communication specific to Head Start or other ECE regarding eligibility  policies. As mentioned earlier, the impact of these eligibility rules can vary  greatly across states and even within a state, and an employee’s eligibility  can be affected by certain circumstances, such as the type of employer  and the employer’s relationship with a school.
State officials also told us that misunderstandings about program  eligibility  can be perpetuated when state officials inconsistently administer  the policies or delay implementation of new state policies. For example,  Indiana officials told us the legislature passed a law that eliminated UI  benefits during regularly scheduled vacation periods in July 2011, but  officials were not able to fully implement this new law until October 2012  because it was difficult to identify all of the industries or employees that  would be affected. As mentioned earlier, instead of relying on employers’  reports, the Indiana  office analyzes historical data by employer to help  identify claim patterns that may indicate a regularly scheduled break.  Officials said they did not enforce the changes to employees claiming  benefits during the summer of 2011 and started attempting to enforce it  during the summer of 2012 to the extent that they were able to detect  regularly scheduled vacation periods. These officials told us that in  hindsight they should have reached out to Head Start and ECE  employees after they began to implement the regularly scheduled  vacation period provision, but they did not realize the full impact of the  policy change until after the provision was fully implemented.
Similarly, New Jersey officials told us that they recently had to hold a  meeting among key internal state officials responsible for initial case  determinations and appeals because they realized not all staff understood  state eligibility policies. According to a New Jersey official, in some cases,  when the initial claims adjudicator denied the case, the employees had  wrongly obtained benefits through appeals. They also mentioned that  they planned to distribute a letter to the ECE community to clarify the  state’s eligibility  policy.
Due to the complexity of eligibility  issues and the potential for inconsistent  adjudications that may affect the integrity of the program, officials in New  Jersey and Indiana told us they developed dedicated offices to handle  claims and monitor improper payments for groups that include Head Start  and ECE employees. New Jersey officials told us they have a centralized  office that handles all school employee claims to ensure that the  adjudication process is uniform and all claims are handled appropriately.  According to a New Jersey official, 10 of the best examiners were  selected from various field offices to receive specialized training to handle  school employee claims from all over the state. Similarly, Indiana officials  told us they have an office dedicated to resolving claims that may be  affected by a regularly scheduled vacation period.
To some extent, the concerns raised by stakeholders can be associated  with the fact that states do not generally assess the effectiveness of their  communication approaches. Thirty-four of 53 states (64 percent) reported  that they do not conduct evaluations to assess the effectiveness of their  communications with employers. Of the remaining 19 states that reported  conducting evaluations, 12 states said they conducted those evaluations  on an ongoing basis, such as providing employers the opportunity to  regularly provide feedback through an evaluation form posted on their  website. Of the states that reported conducting evaluations of their  communication efforts with employers, 16 of 19 states reported using the  results to make program changes. For example, one state reported that it  has made changes to its online employer handbook by providing a search  tool that allows employers to find information more quickly. Other states  reported that they have created employer training materials or mandated  customer service training for all employees after assessing their  communication efforts.
Similarly, 29 of 53 states (54 percent) also reported that they do not  conduct evaluations of their communication with employees. Of the  remaining 23 states that reported conducting evaluations, 18 states said  they conduct them on an ongoing basis by providing an evaluation form  posted on their website. When feedback is collected, these states  reported using the information to make program changes. For example,  one state official told us they have an ongoing satisfaction survey on their  website that employees can fill out after they apply for benefits and that  feedback from that survey is used to improve the eligibility determination  process. Other states reported making significant changes to their claims  processing systems and making the language on the applications more  reader friendly and understandable.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Department of Health and Human  Services and the Department of Labor for review and comment. Officials  from both agencies provided technical comments which we incorporated  in the draft as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  Secretary of Health and Human Services, the Secretary of Labor,  appropriate congressional committees, and other interested parties. In  addition, the report will be available at no charge on the GAO website at  http://www.gao.gov. Please contact me on (202) 512-7215 or at  brownbarnesc@gao.gov if you or your staff have questions about this  report. Contact points for our Offices of Congressional Relations and  Public Affairs may be found of the last page of this report. Key  contributors to this report are listed in   appendix II.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We examined (1) the extent to which states have laws or policies that  affect whether Head Start and other ECE teachers can claim UI benefits  during summer breaks; (2) how many Head Start teachers may have  been eligible for UI benefits during their summer breaks in 2015; and (3)  what is known about how states communicate information about eligibility  for UI benefit payments to Head Start and ECE employees and the  effectiveness of these efforts.
subsections: section_title: Survey of State UI Programs
paragraphs: To address all three objectives, we conducted a web-based survey of  state UI directors (including all 50 states, the District of Columbia, Puerto  Rico, and the Virgin Islands) from February to April 2016. The survey  included questions about state laws, regulations, and policies that might  affect whether Head Start employees and other ECE teachers are able to  receive UI benefits during summer breaks. For example, we asked  whether the type of employer would affect eligibility for benefits. The  survey also included questions about key internal controls, especially  those related to communication and monitoring, such as whether states  targeted communication to Head Start or other ECE employers or  employees and whether states were aware of improper payments to  Head Start or other ECE employees. We received responses from all 53  states. We followed up with states when necessary to clarify their  responses, but we did not independently  verify the information they  provided. For example, while we asked states to provide a description of  relevant state laws, regulations, and policies, we did not confirm their  descriptions with an independent review. Thus, in this report all  descriptions and analysis of state laws, regulations, and policies are  based solely on what states reported to us.
section_title: Analysis of Survey Responses and Data Quality
paragraphs: We used standard descriptive statistics to analyze responses to the  questionnaire. Because we surveyed all states, the survey did not involve  sampling errors. To minimize non-sampling errors, and to enhance data  quality, we employed recognized survey design practices in the  development of the questionnaire and in the collection, processing, and  analysis of the survey data. For example, we pretested the questionnaire  with three state UI directors to minimize errors arising from differences in  how questions might be interpreted and to reduce variability  in responses  that should be qualitatively  the same. We further reviewed the survey to  ensure the ordering of survey sections was appropriate and that the  questions within each section were clearly stated and easy to  comprehend. An independent survey specialist within GAO also reviewed  a draft of the questionnaire prior to its administration. To reduce  nonresponse, another source of non-sampling error, we followed up by e- mail with states that had not responded to the survey to encourage them  to complete it. We reviewed the data for missing or ambiguous responses  and followed up with states when necessary to clarify their responses. On  the basis of our application of recognized survey design practices and  follow-up procedures, we determined that the data were of sufficient  quality for our purposes.
section_title: Analysis of Head Start Data
paragraphs: To address our second objective, we used data from the Office of Head  Start’s Program Information report, which each Head Start grantee is  required to submit on an annual basis through HHS’s Head Start  Enterprise System. We interviewed knowledgeable HHS officials to  determine the reliability of the data, and we concluded that they were  sufficiently reliable for the purposes of our audit. We analyzed data from  the 2014-2015 program year, the most recent available. In conjunction  with this data, we used information from our survey on state laws,  regulations, and policies to estimate the number of Head Start teachers  and teaching assistants who may have been eligible for UI benefits during  summer breaks in 2015. We assessed the potential eligibility of teachers  and assistant teachers based solely on their wages while employed by  Head Start programs. We were not able to identify whether these  teachers had wages from other employment that would affect their  eligibility  for benefits based on those wages. In addition, we were not able  to determine whether a Head Start grantee may be offering work to its  employees during the summer that is outside of the Head Start program,  which may affect eligibility  for benefits.
In conducting this analysis, we made various assumptions that could  impact the results. For example, we assumed that two grantee types— charter schools and school systems—are classified as educational  institutions by all states and are therefore ineligible for UI benefits. This  assumption may not always be correct, however, as there may be  instances in which charter schools or school systems are not defined as  educational institutions in their state. In addition, according to HHS  officials, grantees self-report their category, and HHS does not verify this  information. Therefore, there may be grantees that would be classified as  educational institutions by states because they are charter schools or  school systems that we were unable to identify in the data. We also  assumed that all employees have reasonable assurance of continued  employment after the summer break. However, not all employees may  have such assurance, which may lead to an underestimation of the  employees who are potentially eligible for UI benefits between terms. We  also identified programs that did not have a long enough break to allow  employees to collect UI benefits by examining the start and end of the  program year. In doing so, we assumed that all teachers at such  employers were employed for the full school year and were thus not  eligible for UI benefits. However, we were not able to identify whether all  teachers and teacher assistants in those programs were employed for the  entire length of the program year. Therefore, this may be an overestimate  of the population with breaks too short to collect UI benefits. In the course  of following up with certain states, we asked various questions that were  not asked on the survey, and as a result, these states answered  additional questions and gave additional details about their state laws  which affected the results of our analysis for those states. In conducting  this analysis, when faced with uncertainty about the status of a Head  Start grantee, we classified employees of such grantees as potentially  eligible for UI benefits since we did not have enough information to  conclude that they are ineligible. We assessed the potential eligibility of  teachers and assistant teachers based solely on their wages while  employed by Head Start programs. We were not able to identify whether  these teachers had wages from other employment that would affect their  eligibility  for benefits based on those wages.
section_title: Site Visits
paragraphs: Concurrent with our survey, we conducted site visits to two states,  Indiana and New Jersey, and phone interviews with officials and  stakeholders in Alabama, Puerto Rico, and Wyoming. We selected these  states and that territory based on factors such as the number of Head  Start centers and survey responses regarding eligibility  and experiences  with improper payments and because they are located in geographically  diverse regions. In each state, we interviewed state UI program officials  as well as stakeholders, such as ECE association officials and Head Start  grantees. The results from our interviews with state UI programs and  stakeholders are not generalizable. In our interviews with state officials,  we asked about eligibility policies and changes to such policies, improper  payments, communication with employers and employees, and other  internal controls. In our interviews with stakeholders, we asked about their  awareness of eligibility  policies, the extent to which their employees  collect UI benefits, and their experiences with the state UI department.
We conducted this study from August 2015 to October 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: GAO Contact and Staff Acknowledgements
subsections: section_title: GAO Contact
paragraphs: Cindy S. Brown Barnes, (202) 512-7215, brownbarnesc@gao.gov.
section_title: Staff Acknowledgements
paragraphs: In addition to the contact named above, Danielle Giese, Assistant  Director; Amy Sweet, Analyst-in-Charge; Meredith  Lilley, and Vernette  Shaw made significant contributions to this report. Also contributing to this  report were Amy Buck, David Chrisinger, Alex Galuten, Jill Lacey, Mimi  Nguyen, Jerome Sandau, and Almeta Spencer.
section_title: Related GAO Products
paragraphs: Unemployment Insurance: States’ Customer Service Challenges and  DOL’s Related Assistance. GAO-16-430. Washington, D.C.: May 12,  2016.
Unemployment Insurance: States’ Reductions in Maximum Benefit  Durations Have Implications for Federal Costs. GAO-15-281.  Washington, D.C.: April 22, 2015.
Managing for Results: Selected Agencies Need to Take Additional Efforts  to Improve Customer Service. GAO-15-84. Washington, D.C.: October  24, 2014.
Improper Payments: Government-Wide Estimates and Reduction  Strategies. GAO-14-737T. Washington, D.C.: July 9, 2014.
Unemployment Insurance: Economic Circumstances of Individuals Who  Exhausted Benefits. GAO-12-408. Washington, D.C.: February 17, 2012.