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Testimony:

Before the Committee on Education and Labor, House of Representatives:

United States Government Accountability Office: 
GAO:

For Release on Delivery: 
Expected at 1:30 p.m. EDT:
Tuesday, May 18, 2010:

Head Start:

Undercover Testing Finds Fraud and Abuse at Selected Head Start Centers:

Statement of Gregory D. Kutz, Managing Director: 
Forensic Audits and Special Investigations:

GAO-10-733T: 

GAO Highlights:

Highlights of GAO-10-733T, a testimony before the Committee on 
Education and Labor, House of Representatives. 

Why GAO Did This Study:

The Head Start program, overseen by the Department of Health and Human 
Services and administered by the Office of Head Start, provides child 
development services primarily to low-income families and their 
children. Federal law allows up to 10 percent of enrolled families to 
have incomes above 130 percent of the poverty line—GAO refers to them 
as “over-income.” Families with incomes below 130 percent of the 
poverty line, or who meet certain other criteria, are referred to as “
under-income”. Nearly 1 million children a year participate in Head 
Start, and the American Recovery and Reinvestment Act provided an 
additional $2.1 billion in funding. 

GAO received hotline tips alleging fraud and abuse by grantees. In 
response, GAO investigated the validity of the allegations, conducted 
undercover tests to determine if other centers were committing fraud, 
and documented instances where potentially eligible children were put 
on Head Start wait lists. The investigation of allegations is ongoing. 

To perform this work, GAO interviewed grantees and a number of 
informants and reviewed documentation. GAO used fictitious identities 
and bogus documents for proactive testing of Head Start centers. GAO 
also interviewed families on wait lists. Results of undercover tests 
and family interviews cannot be projected to the entire Head Start 
program. In a corrective action briefing, agency officials agreed to 
address identified weaknesses. 

What GAO Found:

GAO received allegations of fraud and abuse involving two Head Start 
nonprofit grantees in the Midwest and Texas. Allegations include 
manipulating recorded income to make over-income applicants appear 
under-income, encouraging families to report that they were homeless 
when they were not, enrolling more than 10 percent of over-income 
children, and counting children as enrolled in more than one center at 
a time. GAO confirmed that one grantee operated several centers with 
more than 10 percent over-income students, and the other grantee 
manipulated enrollment data to over-report the number of children 
enrolled. GAO is still investigating the other allegations reported. 

Realizing that these fraud schemes could be perpetrated at other Head 
Start programs, GAO attempted to register fictitious children as part 
of 15 undercover test scenarios at centers in six states and the 
District of Columbia. In 8 instances staff at these centers 
fraudulently misrepresented information, including disregarding part 
of the families’ income to register over-income children into under-
income slots. The undercover tests revealed that 7 Head Start 
employees lied about applicants’ employment status or misrepresented 
their earnings. This leaves Head Start at risk that over-income 
children may be enrolled while legitimate under-income children are 
put on wait lists. At no point during our registrations was 
information submitted by GAO’s fictitious parents verified, leaving 
the program at risk that dishonest persons could falsify earnings 
statements and other documents in order to qualify. In 7 instances 
centers did not manipulate information. The table provides details on 
two of GAO’s successful enrollments. To see selected video clips of 
GAO enrollments, see [hyperlink, http://www.gao.gov/products/gao-10-
733T/]. 

Table: Fictitious Over-Income Children Successfully Enrolled in Head 
Start Centers by GAO: 

State: New Jersey; 
Test: Income exceeds poverty guidelines; 
Case details: 
* A Head Start associate disregarded over $23,000 worth of income in 
order to qualify the family as under-income. 
* The Head Start associate said with regard to the father’s income 
documentation, “Now you see it, now you don’t.”

State: Texas; 
Test: Income exceeds poverty guidelines; 
Case details: 
* A Head Start associate disregarded over $20,000 worth of income in 
order to qualify the family as under-income. 
* With respect to the income documentation, the associate stated “we 
see this, but we don’t see this,” explaining that if both parents’ 
incomes were counted the family would be over-income and on a wait 
list. 

Source: GAO. 

[End of table] 

In addition, GAO found that most of the 550 Head Start centers 
contacted had wait lists. GAO also found that 2 centers where it 
enrolled fictitious children later became full and developed wait 
lists after the fictitious children had been withdrawn. Only 44 
centers reported that they had openings. GAO interviewed families on 
wait lists from other centers and found that many stated that their 
incomes were at or below the federal poverty level. In some cases, 
families stated they had experienced some type of domestic violence, 
or were receiving some type of public assistance, a group 
automatically eligible for Head Start. GAO did not attempt to verify 
family statements. 

View [hyperlink, http://www.gao.gov/products/GAO-10-733T] or key 
components. For more information, contact Gregory Kutz at (202) 512-
6722 or kutzg@gao.gov. 

[End of section]

Mr. Chairman and Members of the Committee:

Thank you for the opportunity to discuss our ongoing investigation 
into fraud and abuse at selected Head Start locations. The Head Start 
program, overseen by the Department of Health and Human Services' 
(HHS) Administration for Children and Families, and administered by 
the Office of Head Start (OHS), is one of the largest federal early 
childhood programs. It gives grants to local organizations to provide 
preschool education and other services to low-income children and 
their families. In fiscal year 2010, the Congress appropriated $7.2 
billion to serve approximately 900,000 children through approximately 
1,600 Head Start grantees nationwide.[Footnote 1] The American 
Recovery and Reinvestment Act of 2009 (Recovery Act) provided an 
additional $2.1 billion in funding for Head Start and Early Head 
Start. According to OHS, Recovery Act funds are to be used for staff 
training, facilities upgrades, and cost-of-living increases and are 
intended to allow certain programs to serve an additional 59,000 
children and their families.

In August 2008, we received allegations through GAO's FraudNet hotline 
that a Midwest nonprofit Head Start center manipulated information so 
over-income or otherwise ineligible families would appear to qualify 
for the program and the grantee would meet enrollment numbers required 
as a condition of receiving Head Start funds. In October 2009, we 
received additional allegations that a Texas nonprofit Head Start 
center was also enrolling over-income or otherwise ineligible children 
in the program in order to meet funded enrollment numbers. Based on 
the significance of these claims, we (1) investigated the allegations 
of fraud and abuse at these two Head Start grantees, (2) conducted 
undercover tests to determine if other grantees were committing 
similar abuses, and (3) documented instances in which potentially 
eligible children were put on wait lists for Head Start services at 
other centers.[Footnote 2]

To investigate the allegations of fraud and abuse we received through 
our FraudNet hotline, we interviewed informants and the two Head Start 
grantees in the Midwest and Texas. We reviewed grant documentation and 
enrollment information reported to OHS by grantees. Our investigation 
of allegations related to these two cases is ongoing. We plan to issue 
a final report once the investigation is complete.

To conduct undercover testing, we created fictitious identities and 
bogus documents, including pay stubs and birth certificates, in order 
to attempt to register over-income or otherwise potentially ineligible 
families and their children at 13 Head Start centers located in 
California, Maryland, New Jersey, Pennsylvania, Texas, Wisconsin and 
the Washington, D.C. metropolitan area. We also attempted to register 
two eligible families and their children to determine if centers would 
count these children toward reported enrollment numbers. We chose 
these centers for two reasons: they indicated that they had openings 
for new enrollees; and they were located either in states with a 
significant proportion of Head Start funding, the same geographic area 
as a GAO office, or in the same geographic area as the two programs 
accused of committing fraud. We created 15 fictitious scenarios and 
used fabricated documentation during our in-person applications. 
Scenarios were designed to determine if other Head Start centers were 
engaging in actions similar to those that were the basis of the 
allegations we received about centers in the Midwest and Texas. We 
used publicly available hardware, software, and materials to fabricate 
our supporting documentation. In situations in which our fictitious 
parents were told to bring our fictitious child to class, we monitored 
centers by making follow-up phone calls, to determine if centers still 
had openings in order to ensure that we were not occupying a space 
that could be used by an actual, eligible child. Subsequent to our 
applications, we requested, as GAO, that the centers provide us all 
information regarding the submitted applications and information as to 
whether these fictitious children ever were counted on center 
attendance records.

In order to document situations of families waiting to enroll in Head 
Start, we identified centers with wait lists through calls we made to 
approximately 550 centers and contacted families on these wait lists. 
We asked applicants for information on the length of time they spent 
on a wait list, the family's economic situation, and whether they had 
been affected by being waitlisted for Head Start services. We did not 
attempt to verify the accuracy of the information that families 
provided to us. We cannot project the results of our investigation of 
allegations, undercover tests, and family interviews to the entire 
Head Start program. We conducted our investigation from October 2008 
through April 2010 in accordance with the standards prescribed by the 
Council of the Inspectors General on Integrity and Efficiency.

Background:

The Head Start program was established in 1965 to deliver 
comprehensive educational, social, health, nutritional, and 
psychological services to low-income families and their children who 
are below the age of compulsory school attendance. These services 
include preschool education, family support, health screenings, and 
dental care. Head Start was originally aimed at 3-to 5-year-olds. A 
companion program, called Early Head Start, began in 1994, and focuses 
on making these services available to pregnant women and children from 
birth to 3 years of age. Head Start operates both full-and part-day 
programs--most only during the school year. The Migrant and Seasonal 
Head Start program is designed to meet the specific needs of migrant 
and seasonal farm worker families. OHS makes Head Start grants 
directly to approximately 1,600 local organizations, including 
community action agencies, school systems, tribal governments and 
associations, and for-profit and nonprofit organizations. To 
accomplish Head Start's goals, the Congress provided $7.2 billion in 
federal funds for fiscal year 2010, as well as $2.1 billion in 
Recovery Act funds.

Head Start statutes and regulations establish several primary 
eligibility criteria, one of which a child must generally meet in 
order to enroll in the program. These primary criteria include: the 
child's family earns income below the federal poverty level; the 
child's family is eligible or, in the absence of child care, would 
potentially be eligible for, public assistance; the child is in foster 
care; or the child is homeless. However, Head Start programs may also 
fill up to 10 percent of their slots with children from families who 
do not meet any of the above criteria, but who "would benefit" from 
participation in the program.[Footnote 3] We refer to these children 
and their families as "over-income." There is no cap on the income 
level for the over-income families. If the Head Start program has 
implemented policies and procedures that ensure the program is meeting 
the needs of children eligible under the primary criteria and 
prioritizes their enrollment in the program, then the program may also 
fill up to 35 percent of their slots with children from families with 
income between the federal poverty line and 130 percent of the poverty 
line. Programs filling slots under this provision are subject to 
additional reporting requirements. Children from families with incomes 
below 130 percent of the poverty line, and children that qualify under 
one of the primary eligibility criteria, are referred to as "under-
income" for the purposes of this testimony. In addition, unless a 
program applies for and receives a waiver, at least 10 percent of each 
program's total slots must be filled with children with disabilities 
who are determined to be eligible for special education and related 
services or early intervention services. To qualify for the Migrant 
and Seasonal Head Start program, families must have changed their 
residence within the preceding 24 months for the purpose of engaging 
in certain agricultural work, and the families' incomes must come 
primarily from this type of work. In enrolling families in Head Start, 
program staff are to review documentation of income and employment to 
certify that each family is eligible. Head Start services are to be 
provided free of charge to eligible families.

OHS assigns each grantee a specific number of children and families it 
is required to serve, known as the funded enrollment. Head Start 
statutes and regulations require grantees to maintain enrollment at 
100 percent of the funded enrollment level. If a child stops attending 
the program, after the grantee has attempted, unsuccessfully, to get 
the child back in regular attendance, the grantee must reopen that 
spot as a vacancy and no more than 30 calendar days may elapse before 
the grantee fills the vacancy; otherwise, OHS considers the grantee 
underenrolled.[Footnote 4] To facilitate the prompt filling of 
vacancies, Head Start statutes and regulations require each grantee to 
maintain a wait list that ranks children according to its selection 
criteria and to select those with the greatest need for services. 
Grantees report enrollment numbers monthly, and those that are 
underenrolled for 4 consecutive months must receive technical 
assistance from OHS and work to develop and implement a plan to 
eliminate underenrollment. A grantee that continues to operate with 
less than 97 percent of its funded enrollment level may have its grant 
amount recaptured, withheld, or reduced by OHS. According to HHS, 
funds for 30 grantees were reduced in 2006. A Head Start grantee may 
also be terminated from participation in the program for continuously 
failing to meet other performance, education, administrative, and 
financial management standards that have been established by HHS.

Allegations of Fraud and Abuse Involving Two Head Start Grantees:

We are currently investigating the two allegations of fraud and abuse 
that we received involving Head Start nonprofit grantees in the 
Midwest and Texas. In Texas, individuals we spoke with told us that 
the grantee encouraged enrollment of over-income families in order to 
meet enrollment requirements. We were able to confirm, through records 
obtained from the grantee, that 9 of the grantees' 28 centers had more 
than 10 percent over-income families enrolled. The percentage of over- 
income families in the 28 centers ranged from centers with no over- 
income enrollments to one center where 44 percent of the families it 
enrolled were over-income. Two families enrolled by this grantee had a 
reported income in excess of $110,000. However, the grantee as a whole 
did not report having more than 10 percent over-income families 
enrolled. An aggregate accounting of all centers operated directly by 
one grantee is permitted under the law for determination of the 10 
percent over-income limit, therefore, we could not substantiate this 
allegation. Individuals we spoke with also told us that Head Start 
staff encouraged parents to report that they were homeless when they 
were not in order to qualify them for the program. Records we obtained 
indicate that 22 percent of all children enrolled by the grantee were 
classified as "homeless"--a group considered at-risk and categorically 
eligible for Head Start services regardless of income. Our concern, 
based on the allegation, is that some portion of these families 
classified as homeless in grantee records were actually over-income 
families that were not, in fact, homeless, but were encouraged to 
report that they were in order to qualify. In addition, we spoke with 
several individuals who described a number of fraudulent activities 
that they had witnessed. We are in the process of attempting to 
determine if other allegations are true, including:

* classifying children as disabled when they were not,

* counting children in enrollment figures after they had left the 
program, and:

* allowing staff to use company vehicles for personal use.

For the Midwest Migrant and Seasonal Head Start program, we were able 
to confirm through documents obtained from the grantee that more than 
50 children were moved from one center to other centers with vacancies 
during the last 60 days of the grant period. According to OHS 
regulations, if fewer than 60 days remain in the grantee's program 
year at the time a child leaves the program, the grantee can choose 
not to fill the vacancy without OHS considering the grantee 
underenrolled. By using this process, the grantee was able to make 
records appear that both centers had reached full enrollment, when in 
fact 63 children were counted at more than one center. In addition, we 
spoke with several individuals who alleged that numerous fraudulent 
activities were occurring at the program. We are in the process of 
attempting to determine if other allegations are true, including:

* manipulating family income documentation to make over-income 
families appear to meet Head Start poverty guidelines,

* enrolling families who do not meet the specific program requirements 
for the Migrant Head Start program, including earning at least 51 
percent of the household income through agricultural work and 
migrating for work within the past 24 months, and:

* misappropriation of property purchased with Head Start funds.

It is important to note that ultimate determination as to whether 
these allegations are true is a significant challenge because of the 
minimal requirement for records requested of families to be maintained 
by grantees. For example, there is no requirement for grantees to 
maintain support for income, such as pay stubs and Internal Revenue 
Service Form W-2. In addition, as the proactive testing in the next 
section discusses, and as alleged, it is possible the grantee records 
have been fraudulently altered including showing that children who are 
actually from over-income families are under-income.

Undercover Tests Show the Head Start Program Is Vulnerable to Fraud 
and Abuse:

Our undercover tests determined that the types of eligibility and 
enrollment fraud schemes allegedly perpetrated by the two grantees are 
occurring at other Head Start locations around the country. Posing as 
fictitious families, we attempted to register children at Head Start 
centers in California, Maryland, New Jersey, Pennsylvania, Texas, 
Wisconsin, and the Washington, D.C. metropolitan area. For 13 of these 
tests our fictitious families were over-income or had disqualifying 
characteristics. For 2 additional tests, our fictitious families did 
not have any disqualifying characteristics and were under-income. 
These 2 tests were designed to determine whether a Head Start center 
would count our fictitious children toward enrollment numbers even if 
our children never attended the program. For our tests, we contacted 
each center in advance and were instructed in all cases to bring 
certain documents necessary for enrollment, which included income 
documentation.

In 8 out of 13 eligibility tests, our families were told they were 
eligible for the program and instructed to attend class. In all 8 of 
these cases, Head Start employees actively encouraged our fictitious 
families to misrepresent their eligibility for the program. In at 
least 4 cases, documents we later retrieved from these centers show 
that our applications were doctored to exclude income information for 
which we provided documentation, which would have shown the family to 
be over-income. Employees at seven centers knowingly disregarded part 
of our families' income to help make over-income families and their 
children appear to actually be under-income. This would have had the 
effect of filling slots reserved for under-income children with over-
income children. At two centers, staff indicated on application forms 
that one parent was unemployed, even though we provided documentation 
of the parents' income. A Head Start employee at one center even 
assured us that no one would verify that the income information 
submitted was accurate. For the 2 tests in which our family did not 
have disqualifying characteristics, we were accepted into the program 
once and not accepted in the other. In the test where our eligible 
child was accepted into the program, the scenario was designed to test 
how long the center would keep a child who never attended the program 
on enrollment records before counting the spot as a vacancy and 
attempting to fill it with another child. Due to our concerns about 
occupying a slot for an actual child, we were forced to contact the 
center and voluntarily withdraw our fictitious child before sufficient 
time elapsed that would have allowed us to make a determination 
regarding how long the center would have kept our child on enrollment 
records. However, the enrollment of our family that appeared eligible 
for the program as well as our other successful tests highlight the 
ease with which unscrupulous parents could fabricate documentation 
designed to make it appear as though their children were under-income 
or otherwise eligible for the program. Our fictitious pay stubs and W-
2s were made using information found on the Internet, commercially 
available word processing software, and a printer. At no point during 
our registrations was any of the information contained in fictitious 
documentation submitted by our parents verified, which indicates that 
the program is vulnerable to beneficiary fraud in addition to grantee 
fraud. For all 9 cases in which we were told that we were eligible for 
the program, we are taking steps to determine whether our fictitious 
children were counted on enrollment or attendance records.

Table 1 provides details on our approved applications, followed by our 
unsuccessful applications. We withdrew our fictitious families from 
the programs as soon as we documented that there were fewer than two 
openings at a center. To view selected video clips of these undercover 
enrollments, go to [hyperlink, 
http://www.gao.gov/products/gao-10-733T/].

Table 1: Head Start Enrollment Scenarios:

Information manipulated: 

Case: 1; 
State: California; 
Undercover scenario: Outside of service area; 
Undercover scenario: 
* A Head Start associate encouraged parent to provide falsified 
information about the family's address in order to make the family 
eligible for services by the center. 

Case: 2; 
State: New Jersey; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* A Head Start associate disregarded over $23,000 worth of income in 
order to qualify the family of three (mother, father, and child) as 
under-income; 
* The Head Start associate said with regard to the father's income 
documents, "Now you see it, now you don't" after handing back one of 
two pay stubs provided; 
* The Head Start associate explained that there were over 30 vacancies 
at the center. 

Case: 3; 
State: Pennsylvania; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* A Head Start associate disregarded over $23,000 worth of income in 
order to qualify the family of three (mother, father, and child) as 
under-income; 
* In addition, we told the Head Start associate that the mother also 
received some cash income from a part-time job. The associate replied 
"that's your business." 

Case: 4; 
State: Texas; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* A Head Start associate disregarded over $20,000 worth of income in 
order to qualify the family of three (mother, father, and child) as 
under-income; 
* With respect to the disregarded income, the associate stated "we see 
this, but we don't see this," explaining that if both parents' incomes 
were counted the family would be on a long wait list for over-income 
families; 
* Our bogus applicant was assured that the government would never come 
back to verify the income. 

Case: 5; 
State: Texas; 
Undercover scenario: Income exceeded poverty and agricultural 
guidelines; 
Undercover scenario: 
* A Head Start associate disregarded $11,700 in nonagricultural work 
in order to qualify the family of three (mother, father, and child) 
for migrant Head Start services. A requirement of migrant Head Start 
programs is that the families income must be derived primarily from 
certain agricultural work; 
* Including the disregarded salary would have also put the family over 
130 percent of the poverty guideline. 

Case: 6; 
State: Wisconsin; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* A Head Start associate disregarded over $23,000 worth of income in 
order to qualify the family of three (legal guardians grandmother, and 
grandfather, and child) as under-income; 
* The Head Start associate said that she chose to report only the 
grandmother's income because it was lower than the grandfather's 
income. 

Case: 7; 
State: Wisconsin; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* A Head Start associate disregarded over $23,000 worth of income in 
order to qualify the family of three (legal guardians grandmother, and 
grandfather, and child) as under-income; 
* The Head Start associate said that she chose to count only one 
guardian's income so the family would qualify. 

Case: 8; 
State: Washington, D.C.; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* A Head Start associate disregarded $9,600 worth of cash income in 
order to enroll the family of three (mother, father, and child) as 
under-income. After we reported the family's cash income, the Head 
Start associate stated "We don't need any extra; we need to keep you 
low"; 
* The Head Start associate explained that if nine more children were 
not enrolled by the end of the week, she might have to make staff cuts. 

Not approved or No Evidence of Manipulation: 

Case: 9; 
State: Washington, D.C.; 
Undercover scenario: None-fictitious children were eligible; 
Undercover scenario: 
* The fictitious family of three (father, and two children) met 
program and income requirements and was approved with bogus documents. 
The test was also designed to see whether the Head Start center would 
count our fictitious children who never attended the program toward 
enrollment figures; 
* The Head Start center left the fictitious children on the enrollment 
records for a month; 
* We voluntarily withdrew our fictitious children from the center due 
to concerns about occupying a slot for an actual child. Because of 
this withdrawal, we were unable to determine how long the center would 
have kept our children on enrollment records. 

Case: 10; 
State: California; 
Undercover scenario: None-fictitious children were eligible; 
Undercover scenario: 
* The fictitious family of three (mother, father, and child) met 
program and income requirements. The test was designed to see whether 
the Head Start center would count our fictitious children toward 
enrollment figures; 
* The application was accepted by in-take staff at Head Start center, 
but the main program office never called the family to complete 
enrollment procedures. 

Case: 11; 
State: California; 
Undercover scenario: Income exceeded poverty guidelines and outside 
service area; 
Undercover scenario: 
* The income for the family of three (mother, father, and child) was 
$50,000--more than double what poverty guidelines allow; 
* A Head Start associate denied our application because our address 
showed we lived outside the center's service area. 

Case: 12; 
State: California; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* The income for the family of three (mother, father, and child) was 
$12,000 more than allowed for the family to be considered income-
eligible; 
* A Head Start associate denied this application because the family 
was over-income; 
* The Head Start associate explained that families often lie about 
being separated or divorced in order to reduce their income and that 
Head Start is not strict about checking whether that is true. 

Case: 13; 
State: Maryland; 
Undercover scenario: Child already enrolled in another Head Start 
center; 
Undercover scenario: 
* The fictitious single mother of one stated that she wanted to enroll 
the child in this Head Start center certain days of the week and 
another nearby center on other days of the week--a violation of the 
program's requirement that children be continuously enrolled; 
* The Head Start associate denied the application because we claimed 
that the child was already enrolled in another Head Start center. 

Case: 14; 
State: Texas; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* The income for the family of two (mother and child) was $2,000 more 
than allowed for the family to be considered income-eligible; 
* We submitted initial paperwork, but were told that our application 
could not be processed further because we did not provide a full 12 
months of pay stubs. 

Case: 15; 
State: Washington, D.C. metropolitan area; 
Undercover scenario: Income exceeded poverty guidelines; 
Undercover scenario: 
* The income for the family of three (mother, father, and child) was 
$75,000--more than triple what poverty guidelines allow; 
* We submitted a prescreening application indicating that the family 
was over-income and were never contacted by Head Start employees to 
continue the enrollment process. 

Source: GAO: 

[End of table] 

We also identified a key vulnerability during our investigation that 
could allow over-income children to be enrolled in other Head Start 
centers: income documentation for enrollees is not required to be 
maintained by grantees. According to HHS guidance, Head Start center 
employees must sign a statement attesting that the applicant child is 
eligible and identifying which income documents they examined, such as 
W-2s or pay stubs; however, they do not have to maintain copies of 
them. We discovered that the lack of documentation made it virtually 
impossible to determine whether only under-income children were 
enrolled in spots reserved for under-income children.

Eligible Children May Not Receive Head Start Services Because of 
Significant Wait Lists:

We are concerned that eligible children at other centers do not 
receive services for which they are in need, given the vulnerabilities 
to fraud and abuse we found through our undercover tests. At 2 of the 
9 centers where we enrolled fictitious children, we were later told, 
after withdrawing our children from the program, that the center was 
at full enrollment and was not accepting more children at that time. 
During the course of our work, we contacted approximately 550 Head 
Start centers to determine whether they had space for our fictitious 
children. We found that the majority of the centers stated that they 
had no open slots for enrollment, but maintained wait lists per 
program requirements. We found only 44 centers stated they had any 
openings. We interviewed 21 families on wait lists and found that the 
majority stated their income was at or below the federal poverty 
level. In some cases, families had experienced some type of domestic 
violence or were receiving some other type of public assistance, a 
group targeted specifically for assistance by Head Start program 
guidelines. We did not attempt to verify this information.

Head Start Center Wait Lists Were Substantial:

The length of these wait lists varied considerably; however, several 
of the centers we contacted had lengthy wait lists. For example, one 
grantee we contacted in Texas, which serves approximately 4,260 
children in 36 centers, had over 1,150 children on its wait list. 
Another Head Start grantee told us that they average around 500 
children on their wait list. A representative from one Pennsylvania 
Head Start center we contacted stated that there were around 120 
applicants on the center's wait list. Furthermore, a review of media 
sources reveals that Head Start centers around the country face 
similar challenges meeting their communities' demand for services. We 
queried a news media search engine and found numerous reports of 
lengthy waiting lists to enroll in Head Start programs in many parts 
of the country. For example, according to one Florida newspaper, the 
state of Florida has 8,000 students on wait lists for Head Start 
programs. Another newspaper in Indiana, reported that a program in 
Indiana that serves 380 students has 170 students on the wait list. It 
is important to note that we found a discrepancy in enrollment levels 
among the centers we called. While several grantees had lengthy wait 
lists, other grantees were eager to accept our fictitious, over-income 
children to fill their rolls. The center in New Jersey that accepted 
our fictitious over-income family told us that it had more than 30 
openings. Another center in California, which did not accept our 
application, told us that it had 40 part-day openings.

Eligible Applicants Cannot Be Admitted Because of Lack of Space:

We contacted 21 families who at the time of interview were on wait 
lists for Head Start programs. We received a list of 1,600 wait list 
applicants from a Head Start grantee in Texas--of these we were able 
to speak to 11 applicants. We also received a wait list of 30 
applicants for services in Pennsylvania--of these we were able to 
speak to 10 applicants. We asked applicants for information on the 
length of time they spent on the wait list, on the family's economic 
situation, and whether they had been affected by being waitlisted for 
Head Start services. Several of the applicants we spoke with described 
circumstances that made them especially strong candidates for Head 
Start, including receiving other types of public assistance, such as 
Medicaid or Supplemental Nutrition Assistance, or having histories of 
domestic abuse. Additionally, several applicants reported that family 
members were unable to accept work opportunities as a result of not 
enrolling in Head Start, or experienced additional financial strain 
because they had to pay child care costs. Many applicants also cited 
concerns that their children would not be adequately prepared for 
school. Given the fraud committed by several grantees we investigated, 
and the relative ease with which GAO employees posing as fictitious 
parents were able to qualify for Head Start services, it is likely 
that some over-income or otherwise ineligible children are currently 
enrolled in Head Start programs while low-income children are put on 
wait lists and do not receive necessary services. For example, when a 
center manipulates information to make it appear that an over-income 
family is a low-income family this takes up a Head Start slot set 
aside for a low-income family. Table 2 summarizes the experiences of 
10 applicants we contacted. We did not attempt to verify the 
applicants' statements.

Table 2: Summary of Selected Head Start Wait List Families:

Case: 1; 
State: Pennsylvania; 
Months wait-listed: 4 months; 
Case details[A]: 
* The mother, a single parent of three children, is unemployed; 
* The family has experienced domestic violence and is in an abuse 
protection program; 
* The family is enrolled in several public assistance programs, 
including receiving Supplemental Nutrition Assistance Program (SNAP) 
benefits; 
* The mother stated that enrolling the child in Head Start would allow 
her to look for work and help her child prepare for kindergarten. 

Case: 2; 
State: Pennsylvania; 
Months wait-listed: 6 months; 
Case details[A]: 
* The mother, a single parent of three children, earns $150 to $200 
per week--less than half of what poverty guidelines allow; 
* The family is enrolled in several public assistance programs, 
including Medicaid and SNAP benefits; 
* The mother was told that her son was waitlisted because of a lack of 
government funding; 
* The child's grandmother cannot work because she must care for the 
child. 

Case: 3; 
State: Pennsylvania; 
Months wait-listed: 1 month; 
Case details[A]: 
* The mother, a single parent of three children, is unemployed; 
* The mother has experienced domestic violence and the family receives 
SNAP benefits; 
* The mother received a letter from the Head Start center stating that 
her child was eligible, but had been put on the wait list because the 
center had no openings for funding reasons; 
* The mother cannot work because she is taking care of her child.

Case: 4; 
State: Texas; 
Months wait-listed: 2 months; 
Case details[A]: 
* The mother, a single parent caring for two children, earns $1,025 
per month--$6,000 a year below the poverty level; 
* The mother works nights, and sleeps only a few hours a day as a 
result of not having child care for her son during the day. 

Case: 5; 
State: Texas; 
Months wait-listed: 3 months; 
Case details[A]: 
* The family of four lives on $290 per week--$7,000 per year below the 
poverty level; 
* The family is enrolled in Medicaid; 
* The mother cannot work because she must take care of the child. 

Case: 6; 
State: Pennsylvania; 
Months wait-listed: 2 months; 
Case details[A]: 
* The single mother is unemployed, but her aunt provides for the 
family, giving them $150 every 2 weeks; 
* The family does not receive any type of public assistance; 
* The mother is concerned about the child's education as a result of 
not attending Head Start. 

Case: 7; 
State: Texas; 
Months wait-listed: 1 month; 
Case details[A]: 
* The mother, a single parent of two children, is unemployed and 
receives $500 per month in child support; 
* The family is on two public assistance programs: Women Infants and 
Children (WIC) and Medicaid; 
* The family has experienced domestic violence; 
* The mother has offers for work but cannot accept them because she 
must care for the child. 

Case: 8; 
State: Texas; 
Months wait-listed: 2 months; 
Case details[A]: 
* The mother, a single parent of four children, made $1,000 per month, 
almost $14,000 a year below the poverty line. Since applying for Head 
Start services, she has become unemployed; 
* The family is on two public assistance programs: Medicaid and SNAP 
benefits; 
* The family has faced domestic violence, but the Head Start center 
did not ask the parent whether they had; 
* When the mother was working, she had to pay over $300 a month to 
hire a babysitter to take care of her child. 

Case: 9; 
State: Pennsylvania; 
Months wait-listed: 2 months; 
Case details[A]: 
* Both parents are unemployed, and the family lives with brother who 
currently provides for them; 
* The mother feels that the child is missing out on an education as a 
result of not attending Head Start. 

Case: 10; 
State: Pennsylvania; 
Months wait-listed: 7 months; 
Case details[A]: 
* The family of three is $8,000 a year under the poverty guidelines 
earning $200 a week; 
* The family is on several public assistance programs, including WIC, 
Medicaid and SNAP benefits; 
* The applicant is concerned that his child will not be able to speak 
English when he starts school. 

Source: GAO:

[A] Statements made by parents were not verified by GAO. 

[End of table] 

Corrective Action Briefing:

On April 20 and April 23, 2010, we briefed OHS and HHS officials on 
the results of our work. Officials indicated that HHS would work 
quickly to address the weaknesses we identified. We suggested a number 
of potential actions the agency should consider to minimize Head Start 
fraud and abuse, including the following:

* Creating an OHS program management fraud hotline for individuals to 
report fraud, waste, and abuse. These tips could be investigated by 
the program, the HHS Inspector General, or both;

* Establishing more stringent income verification requirements, 
documentation requirements, or both by Head Start employees 
responsible for certifying family eligibility, such as maintaining 
income documentation provided by the applicant (e.g., pay stubs or W-
2s); and:

* Conducting undercover tests, such as the ones we describe in our 
report, as a management oversight function.

Agency officials indicated that they would consider these suggestions. 
They also told us that they would make sure that grantee staff 
received training regarding the proper way to validate income 
documentation.

Mr. Chairman, this concludes my statement. I would be pleased to 
answer any questions that you or other members of the committee may 
have at this time.

Contacts and Acknowledgments:

For additional information about this testimony, please contact 
Gregory D. Kutz at (202) 512-6722 or kutzg@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this statement.

[End of section] 

Footnotes: 

[1] OHS awards Head Start funds directly to local organizations, 
called grantees. Many Head Start grantees contract out the operation 
of services to delegate agencies that operate programs at the 
community level. Throughout this testimony we refer to both grantees 
and delegates as grantees.

[2] Wait lists were documented because potentially eligible children 
could have been displaced by ineligible children fraudulently enrolled 
in the program.

[3] A Head Start program operated by an Indian tribe or a program 
located in certain remote areas with small populations may enroll 
additional children who do not meet one of the primary criteria.

[4] If fewer than 60 days remain in the grantee's program year at the 
time an enrollment vacancy occurs, the grantee can choose not to fill 
the vacancy without OHS considering it underenrolled.

[End of section] 

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