Head Start:

Progress and Challenges in Implementing Transportation Regulations

GAO-06-767R: Published: Jul 27, 2006. Publicly Released: Aug 28, 2006.

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The leading cause of death for children ages 3 to 7 is motor vehicle traffic crashes. Head Start, a federal early care and education program run by local grantees and targeted at low-income children, currently serves approximately 900,000 children, and transports many of them to and from Head Start centers across the country. While not required to do so, many Head Start grantees offer transportation as a way to make Head Start more widely available to the eligible population, especially very poor children. To address concerns about transporting children safely, the 1992 Head Start Improvement Act directed the Office of Head Start, housed within the U. S. Department of Health and Human Services (HHS), to develop transportation regulations to ensure the safety and effectiveness of transportation services made available to children by Head Start grantees. Head Start issued these regulations in 2001. To provide Congress with information that it requested on the regulations and their implementation, we determined: (1) the research and cost information Head Start considered in establishing the transportation regulations; (2) the actions Head Start grantees have taken to implement the vehicle, restraint, and bus monitor requirements of the regulations and the number of grantees that have sought waivers and extensions; and (3) the associated expenses and effects of implementing the regulations on grantees and their transportation partners.

Concerning the research and cost information that Head Start considered, we found that the Office of Head Start considered safety research and data in developing the regulations. Research and safety data from the National Highway Traffic Safety Administration (NHTSA), the National Transportation Safety Board (NTSB)--an independent federal agency charged with investigating transportation accidents and identifying safety improvements--and the National Academy of Science's Transportation Research Board shows that buses--both school buses and other types, such as transit buses--have lower fatality rates than other modes of transportation. The requirement for a bus monitor was based on Head Start's conclusion that young children on a bus should be supervised. Although the Office of Head Start did not research the need for monitors, it based this requirement on the belief that preschool- age children and younger who ride a bus should be supervised by an adult monitor in case the driver becomes disabled. The Office of Head Start no longer has supporting documentation for its cost estimate of $18.9 million for implementing the regulations. Without this documentation, we cannot determine the reliability of the data Head Start used to develop its estimates. Regarding grantees' actions to implement the regulations and the extent to which they sought extensions and waivers, we found that grantees have made progress in implementing the regulations. Approximately 64 percent report that they have finished implementing the regulations while 18 percent reported being almost finished. Almost all grantees reported primarily using a vehicle type that complies with the regulations. Ninety-seven percent of grantees reported primarily using either a school bus (93 percent) or the alternative vehicle allowed by the regulations (4 percent) to transport Head Start children on a daily basis. Grantees reported taking a variety of actions to meet the restraint and monitor requirements. Most grantees reported (1) either buying restraints and retrofitting their buses with them, or having had vehicles with restraints already in them; and (2) adding the bus monitor responsibilities to duties of existing staff or having had monitors already in place. Some transit agencies and other transportation providers who work with Head Start are facing difficulties in using the alternative vehicle. This is due to a lack of guidance for adapting it to transport other populations in addition to Head Start children. Fewer grantees requested more time to implement the restraint and monitor provisions in 2006 compared to 2004, but the number of waiver requests is unknown. In 2006, 19 percent of grantees submitted extension requests, dropping from 30 percent in 2004. As for waivers requested under the general waiver authority provided for in the regulations, the Office of Head Start officials stated that they were unaware that any were submitted. With respect to the costs and effects on grantees associated with implementing the regulations, we found that many grantees reported some cost effects from implementing the regulations, but noted that they were facing other budgetary pressures. Fifty-six percent of grantees reported no more than moderate cost effects on their transportation budgets from implementing the vehicle, restraint, or monitor requirements while 44 percent reported experiencing large or very large increases associated with one or more of these requirements. Grantees are experiencing effects to transportation services or program operations as a result of implementing the regulations. Fifty-eight percent of grantees reported at least one effect on transportation services as a result of the regulations, most often noting that they changed transportation routes (83 percent) or reduced transportation services (50 percent). Finally, some grantees are facing difficulties sustaining transportation partnerships.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: In order to enable grantees and transit agencies to better coordinate transportation services, the Department of Transportation, in consultation with Head Start, should determine if certain safety features could be incorporated into transit buses used by Head Start grantees to provide a level of safety comparable to school buses or alternative vehicles in transporting preschoolers. If this determination cannot be made before the remaining deadlines expire, the Office of Head Start, in consultation with DOT, should determine on a case-by-case basis whether grantees using transit vehicles with child safety restraints can continue to do so until such a determination can be made. If DOT determines that transit vehicles with appropriate safety features would afford suitable protections, the Office of Head Start should adopt these features into the final Head Start transportation regulations.

    Agency Affected: Department of Health and Human Services: Administration for Children and Families: Head Start Bureau

    Status: Closed - Implemented

    Comments: The Federal Transit Administration prepared a report that analyzes the feasibility of adapting or constructing the Multifunction School Activity Bus to meet technical standards required by the Americans with Disabilities Act's (ADA). As of June 2010, this report is in final draft and was sent to the National Highway Traffic Safety Administration (NHTSA) and the Department of Health and Human Services' (HHS) Office of Head Start for review and concurrence. Also in 2010, OHS reported that vehicles which meet the structural, but not the crash avoidance, safety of school buses are permissible for use of transporting Head Start children.

    Recommendation: In order to enable grantees and transit agencies to better coordinate transportation services, the Department of Transportation, in consultation with Head Start, should develop guidance on adapting the alternative vehicle to incorporate ADA requirements and communicate this guidance to Head Start grantees and transit agencies.

    Agency Affected: Department of Transportation

    Status: Closed - Implemented

    Comments: The Federal Transit Administration has prepared a report that analyzes the feasibility of adapting or constructing the Multifunction School Activity Bus to meet technical standards required by the Americans with Disabilities Act's (ADA). As of June 2010, this report is in final draft and was sent to the National Highway Traffic Safety Administration (NHTSA) and the Department of Health and Human Services' (HHS) Office of Head Start for review and concurrence.

    Recommendation: In order to determine the ability of grantees to provide transportation services and to define the waiver process, the Office of Head Start should, once a process has been established, take steps to ensure that grantees and regional staff know about it and understand how it works.

    Agency Affected: Department of Health and Human Services: Administration for Children and Families: Head Start Bureau

    Status: Closed - Implemented

    Comments: ACF issued instructions in a memo dated 10/11/2006 to Early Head Start (EHS) and Head Start grantees and delegate agencies that details procedures for seeking and obtaining a Head Start transportation waiver. In 2009, ACF reported that OHS had issued approximately 200 waivers per year. Regional offices maintain a spreadsheet of requests and related actions, and all requests are maintained electronically in each grant file.

    Recommendation: In order to determine the ability of grantees to provide transportation services and to define the waiver process, the Office of Head Start should establish a waiver process that specifies criteria for submitting waivers, including more specific guidance on what constitutes "good cause," lists the responsible entities for review and approval, and documents the receipt, review, and final disposition of each waiver. Should any waiver requests submitted require Head Start to address issues concerning vehicles, the waiver process should include consultation with NHTSA and the Federal Transit Administration (FTA) as appropriate.

    Agency Affected: Department of Health and Human Services: Administration for Children and Families: Head Start Bureau

    Status: Closed - Implemented

    Comments: The Office of Head Start (OHS) has established a waiver process that specifies criteria for submitting waivers, including more specific guidance on the reasons for which grantees may request approval, and the reasons for which waiver requests not be granted. ACF issued a memo dated 10/11/2006 that specifies three circumstances where waivers will not be granted: for EHS children for the child restraint requirement; for transporting children in any vehicle other than a bus, i.e., van, for the child restraint requirement; and for transporting Head Start children where there are adult non-Head Start riders for the monitoring requirement. OHS has not found it necessary to consult with NHTSA and FTA as the few requests received regarding vehicles included the use of vans, which are expressly prohibited.

    Recommendation: In order to determine the ability of grantees to provide transportation services and to define the waiver process, the Office of Head Start should systematically track transportation services provided by grantees so that the Bureau can determine changes in the availability of these services, especially any reduction in them.

    Agency Affected: Department of Health and Human Services: Administration for Children and Families: Head Start Bureau

    Status: Closed - Implemented

    Comments: In 2007, OHS began systematically tracking the number of children receiving transportation services by grantee, by delegate and by program type (Head Start or Early Head Start) through its annual Program Information Report survey.

    Recommendation: In order to enable grantees and transit agencies to better coordinate transportation services, the Department of Transportation, in consultation with Head Start, should determine if certain safety features could be incorporated into transit buses used by Head Start grantees to provide a level of safety comparable to school buses or alternative vehicles in transporting preschoolers. If this determination cannot be made before the remaining deadlines expire, the Office of Head Start, in consultation with DOT, should determine on a case-by-case basis whether grantees using transit vehicles with child safety restraints can continue to do so until such a determination can be made. If DOT determines that transit vehicles with appropriate safety features would afford suitable protections, the Office of Head Start should adopt these features into the final Head Start transportation regulations.

    Agency Affected: Department of Health and Human Services: Administration for Children and Families: Head Start Bureau

    Status: Closed - Implemented

    Comments: The Department of Transportation's (DOT) response in 2006 indicated that transit buses do not share the same characteristics with Multifunction School Activity Buses, or other appropriately equipped vehicles used for transporting Head Starts students. In light of this distinction, DOT's Federal Transit Administration (FTA) prepared a report focusing on identifying means to increase the level of occupant protection afforded children including preschool-aged children traveling to Head Start programs on buses suitable for a public transit service. As of June 2010, the report is in final draft and was sent to the National Highway Traffic Safety Administration (NHTSA) and the Department of Health and Human Services' (HHS) Office of Head Start for review and concurrence.

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