1. System for Designation Renewal of Head Start and Early Head Start Grantees Colleen Rathgeb Office of Head Start Administration for Children and Families September 12, 2012

2. Designation Renewal System
The Improving Head Start Act changed Head Start grants from indefinite to 5 year grants.
The Act required HHS to develop a system for “designation renewal.”
Grantees determined to be delivering high quality and comprehensive services receive a five year grant automatically.
Service areas where HHS can not determine that grantees are delivering high quality and comprehensive services shall be subject to an open competition.
All Head Start grants have been awarded for an indefinite period since the program’s inception.
ACF has been able to de-fund grantees for poor performance but it is a lengthy legal process.
Conference Report:
Makes clear that the intention is for programs not providing quality services to be subject to competition.
But it is not intended for the majority of Head Start programs to be subject to competition and that competing quality programs could undermine overall program quality

3. Development of Rule Secretary’s Advisory Committee 2008
Advisory Committee Report issued December 2008
Notice of Proposed Rulemaking (NPRM)issued September days for comment
16,000 public comments received
Final Rule published November 9, 2011, and became effective on December 9, 2011
Act required an Advisory Committee to make recommendations for the system.
Seven members on the Committee chaired by the Acting Director of OHS.
Final Report Issued in December 2008.

4. Final Rule for Designation Renewal System
One Deficiency in meeting program performance standards identified through monitoring
CLASS Scores below a minimum threshold or in the lowest 10% in Emotional Support, Classroom Organization, or Instructional Support
Failure to establish, utilize and analyze children’s progress on agency established School Readiness Goals
Revocation of License to operate
Suspension by OHS
Debarment by another Federal or State agency or disqualification from CACFP
7. Determination from Audit of being at risk for failing to continue as “Going Concern”

5. Deficiency
One or more deficiencies identified through triennial, follow-up, or other reviews under section 641A(c)(1)(A),(C), or (D), starting with reviews conducted since June 12, 2009
All deficiencies except those identified on first year reviews
Includes deficiencies issued from off-site reviews
The issuance of a deficiency causes competition, but the correction of the deficiency does not prevent competition. Correction of a deficiency is required in order to avoid termination but is not considered in determinations made under the Designation Renewal System.
Deficiency is defined in the Head Start Act.

6. License Revocation
An agency that has had a license revoked by a state or local licensing agency and the revocation has not been overturned or withdrawn would be required to compete.
Grantees must report the revocation of a license to Office of Head Start within 10 days

7. License Revocation Many comments were received on license revocation
Final rule clarifies that condition is only a revocation (or removal of a license to operate) which is the final step in licensing corrective action processes.

8. Deficiency
Systemic or substantial material failure of an agency in an area of performance that the Secretary determines involves:
A failure to comply with standards related to early childhood development and health services, family and community partnerships, or program design and management, including income verification
A threat to the health, safety, or civil rights of children or staff
A denial to parents of the exercise of their full roles and responsibilities
The misuse of funds
Loss of legal status or financial viability;
Systemic or material failure of the governing body of any agency to fully exercise its legal and fiduciary responsibilities; or
Area of noncompliance that the agency has shown an unwillingness or inability to correct after notice from the Secretary.
Deficiency is defined in the Head Start Act.

9. CLASS: Background
The Head Start Act requires that as part of monitoring OHS use “a valid and reliable observational instrument that assesses classroom quality through dimensions of teacher-child interaction that are linked to positive child development and later achievement.”
The Act also requires that classroom quality as measured by that tool be considered in DRS.
The Conference Report suggested OHS consider using the Classroom Assessment Scoring System (CLASS) developed at the University of Virginia.
OHS is using the CLASS to fulfill these requirements.
There is no requirement for any grantee to adopt the CLASS.
Head Start, and early childhood classrooms in all settings, have tremendous need to improve, especially in the Instruction Support Domain.
Based on data collected in our CLASS monitoring being piloted, 39% of the grantees are in the low range in Instructional Support which is better than national studies
Improved scores into the mid- range are associated with significantly better child outcomes
OHS is focusing training &technical assistance and expects significant improvement before this criteria would be used.
Play

10. CLASS: Background
The CLASS is a valid and reliable observational instrument that assesses classroom quality through multiple dimensions of teacher-child interaction.
Measures Three Domains of Classroom Quality:
Emotional Support: Teachers’ skills in supporting social and emotional functioning in the classroom.
Classroom Organization: Classroom processes related to the organization & management of children’s behavior, time & attention.
Instructional Support: Implementation of curricula to effectively support children’s cognitive & language development.
Trained reliable CLASS observers use a seven point scale to rate quality with Low (1-2) Mid (3-5) and High (6-7).
Play video from Understanding CLASS
Head Start, and early childhood classrooms in all settings, have tremendous need to improve, especially in the Instruction Support Domain.
Based on data collected in our CLASS monitoring being piloted, 39% of the grantees are in the low range in Instructional Support which is better than national studies
Improved scores into the mid- range are associated with significantly better child outcomes
OHS is focusing training &technical assistance and expects significant improvement before this criteria would be used.
Play

11. CLASS Implementation CLASS Professional Development since 2008
CLASS Monitoring Pilot in 2009
CLASS in 2010 and 2011 Triennial Monitoring
2012 CLASS Monitoring
Assessor Pool
Random Sampling of Classrooms
Observation Cycles and Timing

12. CLASS Condition for DRS
Of those grantees assessed in CLASS in any year the 10% of grantees with the lowest average scores in each domain will be required to compete.
Additionally, a grantee with an average score below established thresholds on any of the three CLASS domains will be required to compete (even if that means more than 10% compete based on that domain).
If the lowest 10% in any of the three CLASS domains includes grantees with a score of 6 or 7, those grantees would not be required to compete (even if this means that fewer than 10% would be required to compete based on that domain).
So if 90% of programs assessed in that year have average class scores that are better than your program on any one of these domains – all of which we know matter for kids– then your program will have to compete.
Minimum Thresholds:
Instructional Support – 2
Classroom Organization – 3
Emotional Support - 4

13. School Readiness Goals Condition
Responsible HHS official has determined that an agency has not established program goals for improving the school readiness of children in accordance with requirement sand taken steps to achieve those goals.
Director of Office of Head Start is currently the responsible HHS official
Regulation further delineates requirements on establishing goals and demonstrating the steps to achieving those goals.
Based on comments received on the NPRM, definitions were added to the Final Rule to provide additional clarity on the expectations of school readiness goals.

14. Establish School Readiness Goals
Agencies must establish program goals for improving the school readiness of children participating in its program that:
Align with the Head Start Framework, State early learning standards, and expectations of the schools;
Are appropriate for the ages of children;
Address, at a minimum, the domains of language and literacy, cognition and general knowledge, physical well-being and motor development, social and emotional development, and approaches toward learning; and
Are established in consultation with parents.

15. Demonstrate Use of School Readiness Goals for Individual Children
Analyzing individual ongoing, child-level assessment data for all children and
Using that data, in combination with input from parents and families, to:
determine each child’s status and progress with regard to, at a minimum, language and literacy development, cognition and general knowledge, approaches toward learning, physical well-being and motor development, and social and emotional development and
individualize the experiences, instructional strategies, and services to best support each child.

16. Demonstrate Use of School Readiness Goals for Continuous Improvement
Aggregating and analyzing child-level assessment data at least three times per year and using that data, in combination with other program data, to:
Determine progress toward meeting goals,
Inform parents and the community of results, and
Direct continuous improvement related to curriculum, instruction, professional development, program design and other program decisions

17. Suspension by OHS
An agency that has been suspended from the Head Start or Early Head Start program by ACF and the suspension has not been overturned or withdrawn would be required to compete.
Grantee can be suspended if
Health or safety of children or staff are at risk, or
There is serious risk of substantial injury to property or loss of funds or violation of criminal statute
Note that the Committee received comments that state and local variation in licensing standards would result in differential impacts on grantees but felt strongly that local licensing standards reflect that community’s standards for the care of young children and that suspending or revoking a license is so serious in nature that it should be included.
This may have a differential impact on very large grantees and we are asking for comments on this in the proposed reg
There is an exception if the suspended grantee did not have a chance to show cause as to why the suspension should not happen, in which case the full appeal process will be undertaken before a competition is required. This will be a very rare occurrence.

18. Debarment or Disqualification
An agency has been debarred from receiving State or federal funds from another State or federal agency will be required to compete
An agency that has been disqualified from CACFP will be required to compete

19. Audit Findings
An agency is at risk for failing to continue functioning as a “Going Concern”
A finding of Going Concern means that an organization fails to operate without the threat of liquidation for the foreseeable future, a period of at least 12 months

20. Special Provisions for American Indian/Alaska Native Grantees
The Act includes special provisions for Tribal Government Consultation and Re-evaluation in Designation Renewal.
HHS shall engage in government-to-government consultation to establish a quality improvement plan with an AIAN grantee that met one of the re-designation conditions.
That plan must be established and implemented within 6 months of that review.
HHS will re-evaluate the grantees performance 6 months after the quality improvement plan has been implemented.
The Act also includes a prohibition against a non-Indian Head Start Agency receiving a grant for an Indian Head Start program unless there is no Indian agency available.

21. HHS Grants Forecast Each Forecast includes:
Service area
Available Federal funds
Expected number of awards
200+ Forecasts made public in January
Will continue to forecast and announce Funding Opportunities
hhsgrantsforecast/
grants.gov

22. Grant Forecast Example

23. Competition & Transition
Open Competitions
Began in April of 2012
Paneling Completed in 2012
All Eligible Applicants
Objective Evaluative Process
Transitions
Minimal Disruption of Services to Children and Families