Recommendations for Executive Action

1. Status: Open

   Priority recommendation

   Comments: In February 2020, HHS told us that the Administration for Children and Families (ACF) is developing a Fraud Risk Assessment template for all of its programs (including the Office of Head Start) and is on track to complete the initial Fraud Risk Assessment for its pilot program by June 30, 2020. Upon completion of the Fraud Risk Assessment for the ACF pilot program, ACF anticipates completing its initial Fraud Risk Assessment for OHS, by March 31, 2021. We will assess these actions once completed.

   Recommendation: The Director of OHS should perform a fraud risk assessment for the Head Start program, to include assessing the likelihood and impact of fraud risks it faces. (Recommendation 1)

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

2. Status: Closed - Implemented

   Comments: In March 2020, Office of Head Start (OHS) officials confirmed that they had explored options for additional risk-based monitoring of the program, including covert testing, in response to GAO's recommendation. Specifically, these officials stated that they decided to begin significantly increasing their unannounced examinations of grantees as part of their fiscal year 2020 monitoring procedures. The officials stated that they believed that unannounced site visits, coupled with additional review of attendance data and other risk-based approaches, represented a good balance of risk-based monitoring without jeopardizing the program's mission of reaching at-risk families. The officials also told us that they had explored covert testing as an option, but believed the risks associated with covert testing outweighed the benefits. For example, the officials noted that conducting covert testing might change the mindset of intake staff at Head Start grantees to look at applicants as an adversary or fraudster by default, and this mindset might lead the intake staff to treat the applicants in a way that would inappropriately jeopardize the applicants' access to the program. By exploring and implementing these additional risk-based approaches to monitoring the program, OHS has taken an important steps to prevent fraud, waste, and abuse in Head Start.

   Recommendation: As part of the fraud risk assessment for the Head Start program, the Director of OHS should explore options for additional risk-based monitoring of the program, including covert testing. (Recommendation 2)

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

3. Status: Open

   Comments: HHS did not concur with this recommendation. In February 2020, HHS stated that OHS regularly evaluates its effectiveness of its workflows to determine how to best adjust the system to support effective follow-up. HHS also stated that, for Fiscal Year 2020, OHS has updated its internal workflow timelines to increase responsiveness to identified findings and ensure grantee support. We will continue to monitor HHS's efforts in this area.

   Recommendation: The Director of OHS should establish procedures to monitor and evaluate OHS's new internal workflows for monitoring reviews, to include establishing a baseline to measure the effect of these workflows and identify and address any problems impeding the effective implementation of new workflows to ensure timeliness goals for monitoring reviews are met. (Recommendation 3)

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

4. Status: Closed - Implemented

   Comments: In February 2020, OHS provided us information indicating that it revised its onsite monitoring guidance to include the use of grantee attendance data for verifying the reliability of enrollment data that grantees submit to OHS. Specifically, OHS updated its Fiscal Year 2020 onsite monitoring guidance to include an expanded section dedicated to enrollment verification. This guidance states that, as part of monitoring reviews, grantees will provide OHS reviewers the source documentation (including attendance data) for the last 4 months of enrollment numbers submitted to OHS. By taking these steps to verify the accuracy of grantees' enrollment data, OHS will help ensure that grantees are serving all children they are funded to serve.

   Recommendation: The Director of OHS should adopt a risk-based approach for using attendance records to verify the reliability of the enrollment data OHS uses to ensure grantees serve the number of families for which they are funded, such as during OHS's monitoring reviews. (Recommendation 4)

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

5. Status: Open

   Comments: In February 2020, OHS told us that it is finalizing program guidance that will address when a child's slot should be considered vacant due to absenteeism and what a program should do fill it. OHS stated that it anticipates having a final paper published by summer, 2020. We will continue to monitor OHS's efforts in this area.

   Recommendation: The Director of OHS should provide program-wide guidance on when a student's slot should be considered vacant due to absenteeism. (Recommendation 5)

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

6. Status: Open

   Comments: In February 2020, OHS told us that it is developing a toolkit of resources specifically designed to offer best practice tips for Early Head Start programs on how to track attendance and services to pregnant women. OHS is surveying the Head Start community to better determine what resources are already available and how programs in different regions and cities track services to pregnant women. OHS anticipates a rollout for the toolkit by summer, 2020.

   Recommendation: The Director of OHS should develop and implement a method for grantees to document attendance and services under EHS pregnancy programs. (Recommendation 6)

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

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