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AAFCPAs highlights key items new to Head Start eligibility standards

In March, 2015, the Office of Head Start, an office of the U.S. Department of Health and Human Service (HHS), Administration for Children and Families, issued updated performance standards for Head Start programs.  AAFCPAs reminds our clients that the updated standards will be utilized in Head Start monitoring visits beginning October 1, 2015.

AAFCPAs offers the following summary for your convenience to highlight key items new to Head Start eligibility standards:

Option for a Phone Interview

Head Start program staff must conduct an in person interview with families.  If an in-person interview is not possible, there is now an option to conduct a phone interview of the family.  Program staff must document why an in-person interview could not be conducted.

Maintaining Eligibility Determination Records

Head Start program staff must create an eligibility determination record for each program participant.  The Head Start program must maintain these records for as long as the participants are enrolled in the program and for one year after the family is no longer enrolled in the program.  Eligibility records must include the following:

  • Copies of documents used to verify eligibility (W-2 forms, or pay stubs):
    • Pay records must be for the prior 12 months.
      • Written statements from employers that substantiate pay for the prior 12 months are acceptable.
    • If there is no income to report, program staff may accept a written declaration if they:
      • Document the efforts they made to verify income and explain how the family’s income was calculated or
      • Receive verification from a third party if the family consents.
    • A statement that Head Start program staff have made reasonable efforts to verify information.
    • A statement that identifies whether a family is income eligible or categorically eligible (if a child is homeless or in foster care.

For families that have income to report, Head Start program staff must:

  • Use all family income for the relevant time period.
  • State the total family income for the relevant time period.
  • State if a pregnant woman or child qualifies as low-income.

Verifying Categorical Eligibility

Families are categorically eligible if the child is homeless or in foster care. Determination records should include:

  • A court order, other legal or government issued documents, or statements from officials, homeless providers or schools received from the family.
  • A description of the program staff’s efforts to verify the accuracy of the information and documentation that the family is categorically eligible.
  • A written statement that describes efforts to determine that a child is homeless and describe the child’s living situation and the specific condition under the homeless definition.

Program Policies and Procedures

A program must establish policies and procedures that describe all actions taken against staff which violate Federal and program eligibility requirements.

Training

A program must train all members of the governing body, policy council, management and staff who are determining program eligibility.  Trainings must:

  • Include methods on how to collect complete and accurate eligibility information.
  • Incorporate strategies for treating families with dignity and respect in dealing with possible issues of domestic violence, stigma and privacy.
  • Explain program policies and procedures for families or staff that provide false information.
  • Occur within 90 days of the effective date of this rule or 90 days of hire for management and staff.
  • Occur within 180 days of the effective date of this rule or within 180 days of the start of the term of the governing body or policy council member.

HHS will begin to take a closer look at adherence to the standards during their monitoring visits beginning October 1.  AAFCPAs advises grantees and delegate agencies to understand and implement these performance standards now, if you have not already, to ensure you meet HHS’s expectations for strong program management.

If you have any question about implementing the new Head Start performance standards, please contact your AAFCPA partner, or David Kelleher, CPA, CGMA at 774.512.4042, dkelleher@nullaafcpa.com.

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About the Author

Dana Marks
Dave has been serving AAF clients since 1997. He has extensive experience providing assurance, tax, and business advisory solutions to nonprofit organizations and closely-held companies. Dave’s diverse nonprofit client base includes: community development centers, independent schools, human and social services organizations, and early education and care (EEC) agencies. Dave has extensive nonprofit tax experience, advising clients on complex issues such as unrelated business income tax, state filing requirements, related party and executive compensation disclosures. He also helps clients identify and address risks related to their Uniform Financial Report (UFR) and other funding source regulations. Dave specializes in providing federal and state audits to the firm's clients in accordance with Uniform Guidance/Single Audit and Government Auditing Standards.

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