Child Care Facilities: Federal Agencies Need to Enhance Monitoring and Collaboration to Help Assure Drinking Water is Safe from Lead

GAO-20-597 Published: Sep 28, 2020. Publicly Released: Oct 01, 2020.
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Fast Facts

Children exposed to lead can experience serious developmental delays. Many young children spend significant amounts of time in child care settings, including Head Start centers.

We conducted a nationally-representative survey of Head Start centers. Based on that survey, we estimate that:

26% tested for lead in their drinking water; 10% of those found lead and all took action to remediate

43% had not tested

31% did not know if they had tested

We made 4 recommendations to federal agencies to promote lead testing of water in child care facilities and to improve collaboration across the federal government to do so.

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Highlights

What GAO Found

The Department of Health and Human Services' (HHS) Office of Child Care (OCC) provides states with resources and technical assistance to help determine if drinking water in child care facilities is safe from lead. However, the office does not require that drinking water be tested because there is no requirement to do so under the OCC-administered Child Care and Development Block Grant, a key federal funding source for states to subsidize child care. Nonetheless, some states require child care providers to test their drinking water for lead.

HHS's Office of Head Start (OHS) has performance standards that require grantees to provide safe drinking water to children, but OHS does not ensure grantees comply with them. For example, OHS does not require grantees to test their water or document that it is safe from lead, nor does OHS check grantees' compliance with this standard during monitoring reviews. According to an OHS official, the office limits the number of standards it monitors to more efficiently use its limited resources. However, without documentation, OHS does not have reasonable assurance that Head Start grantees provide safe drinking water. In fact, an estimated 43 percent of Head Start centers had not tested their drinking water for lead in late 2018 or 2019, and 31 percent did not know whether they had tested, according to GAO's nationwide survey. (See figure.)

Estimated Percent of Head Start Programs That Tested Centers' Drinking Water for Lead

Note: These results are generalizable to the population of Head Start centers that receive their water from a public water system. A majority of Head Start centers (an estimated 84 percent) receive their water from these systems. GAO's survey was administered from October 2019 to January 2020 and asked Head Start centers to report information based on the 12 months prior to completing the survey. The thin bars display the 95 percent confidence intervals for each estimate.

The Environmental Protection Agency (EPA) has awarded grants to help child care facilities test for lead in drinking water, but has not taken sufficient action to ensure its 2019 Memorandum of Understanding (MOU) with OCC and OHS, which encourages lead testing, is being executed. EPA officials said they plan to meet semi-annually, in part to track progress toward achieving the MOU's outcomes. However, EPA has not yet reached agreement with its MOU partners regarding their roles and responsibilities, nor determined how it will routinely update and monitor the MOU. Without these actions, EPA, OCC, and OHS efforts are lacking practices identified as critical to effective interagency collaboration, according to GAO's prior work.

Why GAO Did This Study

Children who are exposed to lead can experience serious developmental delays. Many young children spend significant amounts of time in child care settings. GAO was asked to review efforts to address lead in drinking water at child care facilities.

This report discusses (1) how OCC oversees and supports states' use of Child Care and Development Fund funding to determine that drinking water in child care facilities is safe from lead, (2) how OHS ensures Head Start grantees provide drinking water that is safe from lead, and (3) the extent to which EPA collaborates with OCC and OHS to support lead testing in child care facilities. GAO reviewed relevant laws, regulations and documents, and conducted a generalizable survey of 762 Head Start centers. To obtain information on lead testing and remediation, GAO also visited or interviewed 11 child care providers and Head Start grantees in four states that were selected for geographic variation and the presence of state laws for lead in drinking water.

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Recommendations

GAO is making four recommendations, including that OHS require grantees to document that water provided to children is safe from lead, and for EPA and HHS to improve their collaboration. HHS concurred with our recommendations. EPA neither agreed nor disagreed with our recommendations but said it believed they were redundant with existing activities. GAO continues to believe these recommendations are warranted.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Health and Human Services The OHS Director should require Head Start grantees to document that water provided to children has been tested for lead. OHS could determine various ways that are feasible and efficient for grantees to satisfy this requirement; for example, verification could be done through OHS' current grantee data collection or monitoring processes. (Recommendation 1)
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HHS agreed with this recommendation, noting that it was consistent with the Head Start Program Performance Standards (45 C.F.R. ?1302.44 (a)(2)(ix)), and has begun taking steps to implement it. HHS noted that the Office of Head Start (OHS) has continued to refine its monitoring protocols after it updated its monitoring training and started collecting information. Specifically, in fiscal year 2022 OHS provided a sample of findings from reviews focused on grantee processes for lead inspections, a recently revised protocol. In fiscal year 2023, OHS further refined its monitoring protocols by asking grantees to show how they protect children from exposure to lead in paint or water in their facilities. However, reviewers have not yet used the fiscal year 2023 protocols for at least one year of monitoring. GAO will close this recommendation once OHS has used the fiscal year 2023 protocols when monitoring at least one year. We await the agency's progress on these efforts.
Department of Health and Human Services The Assistant Secretary for the Administration for Children and Families should direct OCC and OHS to develop an agreement with EPA on their roles and responsibilities in implementing the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. For example, these agreements may include the ways in which guidance and information will be shared with states and Head Start grantees, such as through webinars or email, and how frequently. (Recommendation 2)
Open
HHS agreed with this recommendation and reported that it has worked closely with EPA to implement it. For example, in the fall of 2020, EPA met with OCC and OHS multiple times to identify their roles and responsibilities and discussed proposed activities for 2021 and 2022. According to HHS, OHS and OCC will continue to develop activities related to the implementation of the MOU. As of July 2022, we will continue to monitor the progress of this effort.
Environmental Protection Agency The Assistant Administrator of the Office of Water should develop an agreement with HHS's Offices of Child Care and Head Start on their roles and responsibilities in implementing the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. For example, these agreements may include the ways in which guidance and information will be shared with states and Head Start grantees, such as through webinars or email, and how frequently. (Recommendation 3)
Open
At the time of the report, EPA neither agreed nor disagreed with this recommendation and considered it to be redundant with existing activities. In our review of the workplans, EPA described some steps taken, including awarding 51 WIIN Act grants, receiving annual grantee reports, and holding a three-part webinar series on reducing lead in drinking water in schools and child care facilities in June and July 2022. However, EPA has not provided documentation of OCC's and OHS's roles and responsibilities and other related information. Once EPA provides this information, GAO will determine if there is sufficient information to close the recommendation.
Environmental Protection Agency The Assistant Administrator of the Office of Water should direct the Office of Water to specify how it will track progress toward the outcomes of the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities and determine how it will regularly monitor and update the MOU. For example, the Office of Water could develop performance measures for each of the MOU's outcomes. In addition, the Office of Water could submit annual reports on progress toward achieving the MOU's outcomes or it could plan to update the agreement at specific intervals. (Recommendation 4)
Open
At the time of the report, EPA neither agreed nor disagreed with this recommendation and considered it to be redundant with existing activities. Since the report was issued, EPA has taken additional steps to implement the MOU, including developing tools for child care facilities to assist them with lead testing and remediation efforts. In our review of the workplans, EPA described some steps taken, including holding meetings with MOU partners and developing documents, such as a recordkeeping and reporting document for collecting drinking water samples for lead testing in child care facilities and small schools. However, EPA has not provided documentation on how it plans to track progress toward meeting the MOU's outcomes or on how it will determine how it plans to regularly monitor and update the MOU. Once EPA provides this information, GAO will determine if there is sufficient information to close the recommendation.

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