Recovery Act: Head Start Grantees Expand Services, but More Consistent Communication Could Improve Accountability and Decisions about Spending

In FY12, the Office of Head Start (OHS) issued informal guidance on its Web site clarifying monthly reporting requirements, but did not clarify yearly reporting requirements. In 2015, the agency published a final rule on Head Start Eligibility Determination that took effect March 12, 2015 (https://www.federalregister.gov/articles/2015/02/10/2015-02491/head-start-program). OHS defined the term "enrolled" and revised the definition of "enrollment" to ensure that the requirements are clear to all grantees and consistent with information that grantees are required to report monthly and in the annual Program Information Report (PIR). In the PIR, a child or a pregnant woman is enrolled once they have attended class or received a service. The rule defines "enrolled" as a child who has been accepted and attended at least one class, has received at least one home visit, or has received at least one direct service while pending completion of necessary documentation for attendance in a center, based on state and local licensing requirements. For Early Head Start, enrollment includes all pregnant women that have been accepted and received at least one direct service. "Enrollment" is defined as the number of participants in an Early Head Start, a Head Start, a Migrant or Seasonal, or an American Indian Alaska Native Head Start program.

After our recommendation was issued, HHS reported the Office of Head Start was reviewing the risk management process to ensure it was consistently performed and documented in its centralized data system and that it had taken related steps, such as requiring the grant officer to identify known or suspected risks prior to an on-site review. In 2012, HHS further reported that all Recovery Act Head Start and Early Head Start expansion programs had become permanent grantees and that reviews of permanent grantees now include an improved pre-review planning process to inform the scope and staffing of the on-site review. According to HHS, this process includes review of grantee information, including financial information, in collaboration with the regional office. Data sources HHS reports are reviewed include the program information report, issues tracking reports, fiscal data, enrollment trends, and past compliance information. For first year and triennial reviews, the fiscal information form is also reviewed to determine whether fiscal risks require a more thorough fiscal review.