Supporting statement 0970-0148 5-19-15

OMB Clearance Package

Head Start Performance Standards

SUPPORTING STATEMENT

Head Start Performance Standards - OMB 0970-0148

(Combines existing OMB Control number 0970-0423, 0970-0148 & 0970-0193)

1. Justification

1. Circumstances Making the Collection of Information Necessary

Head Start Performance Standards are the result of a legislative mandate to administer a high quality comprehensive child development program that serves low-income pregnant women, infants and toddlers, preschoolers and their families. The information collection aspects of the Performance Standards are a part of the many actions that local agencies must take to ensure they administer quality programs for Head Start children and families. It is important to note that the information collection items included in the Performance Standards are entirely record-keeping requirements for local Head Start programs; these records are intended to act as a tool for grantees and delegate agencies to be used in their day-to-day operations. Such records are maintained by the grantees and delegate agencies and are not information items that must be collected and forwarded to the Federal government. Of course, programs are monitored for overall compliance with the Performance Standards, including the record-keeping aspects.

Background on Head Start Performance Standards Information Collections – 1998

The Head Start program is authorized under the Head Start Act (the Act), as amended (42 U.S.C. 9801 et seq.). The Act outlines the intent of Congress for the program; types of services offered; population served; and reporting, evaluation, and administrative requirements. The Head Start Program Performance Standards (45 CFR 1301–1311) outline the mandatory regulations that grantees and delegate agencies must implement to operate a Head Start or Early Head Start program. The Performance Standards define the objectives and features of a quality program and provide a structure for monitoring and enforcing quality standards. The required information collections of the Head Start Performance Standards are found at 45 CFR Part 1301, 1304, and 1309, specifically:

• 45 C.F.R. 1301 describes the requirements for grantee agencies in the submission of audits, accounting systems certifications and other provisions applicable to personnel management. (See OMB control number: 0970-0423)

• 45 C.F.R. 1304 describes the requirements for Early Childhood Development and Health Services, Family and Community Partnerships and Program Design and Management. (See OMB control number: 0970-0148)

• 45 C.F.R. 1309 describes the requirements when applying for a Head Start grant in conformance with the Act. It also specifies the measures which must be taken to protect the Federal interest in facilities purchased with grant funds. (See OMB control number: 0970-0193)

Head Start Performance Standards Information Collections – NPRM, 2015

In the Improving Head Start for School Readiness Act of 2007, Congress instructed the Office of Head Start to update its performance standards by regulation and “ensure that any such revisions in the standards do not result in the elimination of or any reduction in quality, scope, or types of health, educational, parental involvement, nutritional, social, or other services.” This NPRM revises the Head Start program performance standards, last revised in 1998, to meet Congress’s requirements and improve the quality of Head Start. The proposed performance standards incorporate extensive consultation with experts and findings from scientific research, reflect best practices, lessons from program input and innovation, integrate recommendations from the Secretary’s Advisory Committee Final Report on Head Start Research and Evaluation, and reflect this Administration’s deep commitment to improving the school readiness of young children. The proposed program performance standards will improve the quality of services, reduce bureaucratic burden on programs, and improve regulatory clarity and transparency. They provide a clear road map for current and prospective grantees to provide high quality Head Start services and to strengthen the outcomes of the children and families they serve.

The following collections are information collections proposed within the NPRM:

• (Completely New) Section 1303.20-24, in paragraph (b), we propose information collections related to the protection for the privacy of child records. Programs must collect parental written consent before disclosing personally identifiable information from child records, must provide an annual notice that notify parents of their rights described in §1303.20 through 1303.24, applicable definitions in 1305, and a description of PII that may be disclosed without parental consent, and programs must maintain, with each child’s record, a list of all individuals, agencies, or organizations that have requested or obtained access to PII from child records and their expressed interests.

• Section 1302.33, in paragraph (c)(2), we propose a new requirement to codify best practice in assessing dual language learners. Specifically, we require programs to assess dual language learners in the language or languages that best capture their skill level that in some cases requires programs to administer language assessments to dual language learners in both their home language and English, utilizing an interpreter as needed. This proposal reflects best practice already used by many Head Start programs and research that demonstrates that children who are dual language learners have different learning experiences across their two languages.

• Section 1302.90, we propose to strengthen background check procedures by requiring both state/local/tribal and federal criminal background checks, as well as clearance through available child abuse and neglect and sex offender registries. Making this requirement consistent with the Office of Child Care’s requirement will minimize burden on programs that operate with both Head Start and Child Care Development Funds. Additionally, we propose to require programs perform background checks every five years for current staff. This will increase the record-keeping burden related to criminal record checks.

Combining OMB Control Numbers 0970-0423, 0970-0148 & 0970-0193

In this NPRM, we propose to rearrange and renumber Head Start program performance standards under subchapter B at 45 CFR Chapter XIII. We believe our efforts will provide current and prospective grantees an organized road map on how to provide high quality Head Start services.

We include redesignation and distribution tables in the NPRM to help the public readily locate current sections and provisions we propose to rearrange and renumber. The three existing and approved collections reflect the previous structure of the performance standards and do not aligned with the proposed standards. Since the bulk of the information collection requirements in the proposed standards are found in OMB Control Number 0970-0148 and information collection requirements in 0970-0423 and 0970-0193 are being removed, we are proposing to combine the three packages into this one.

2. Purpose and Use of the Information Collection

The goal of the Head Start Program Performance Standards is to ensure that all children and families enrolled in Head Start are offered high quality services that are responsive to their needs. The information collection requirements are designed to support this goal.

Local program staff will use the required information collections and record keeping to support and improve the day-to-day operation and management of their programs in order to assure quality. Federal staff, in their role as program monitors, will use the information and records to assure compliance and promote quality through the provision of training and technical assistance.

3. Use of Improved Information Technology and Burden Reduction

Head Start encourages grantees to acquire electronic recordkeeping systems and allows for the expenditure of grant funds to meet the acquisition costs of automated recordkeeping systems.

4. Efforts to Identify Duplication and Use of Similar Information

In complying with those regulations that require information collection, agencies are specifically directed to use and build upon existing information, whenever it exists. It is the intent of these regulations that duplicity of efforts be avoided, and that information collection occurs only when information is not available from another source.

5. Impact on Small Businesses or Other Small Entities

Not applicable, large numbers of small business and small entities are not impacted.

6. Consequences of Collecting the Information Less Frequently

If requirements in the Performance Standards for record-keeping and other information collection are not met, a comprehensive assessment of the quality of Head Start programs could not be assured. The Performance Standards provide both a uniform definition of quality services for over 2,800 programs operated by community-based organizations nationwide and a regulatory structure for the monitoring and enforcement of these standards. Without appropriate collection of the information required by the standards, assurances of quality services and consequently compliance with regulations could not be guaranteed.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

Not applicable. None of the circumstances described apply in the collection of this information.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

During the development of the proposed Performance Standards in the NPRM, we sought extensive input to develop the NPRM. Beginning in 2008 and continuing through 2014, we convened consultations, listening sessions, and focus groups that involved child development experts, subject matter experts, early childhood education program administrators, representatives from Indian tribes, Head Start staff, parents, and other constituent groups. We heard from tribal leaders in our annual tribal consultations. We consulted with national organizations and agencies with particular expertise and longstanding interests in early childhood education. In addition, we analyzed the types of technical assistance requested by and provided to Head Start agencies and programs. We reviewed findings from monitoring reports and gathered information from programs and families about the circumstances of those populations served by Head Start programs. We considered advances in research-based practices with respect to early childhood education and development, and the projected needs of expanding Head Start services. We also drew upon the expertise of federal agencies and staffs responsible for related programs in order to obtain advice on how to promote quality across all Head Start settings and program options. We reviewed the study on developmental outcomes and assessments for young children by the National Academy of Sciences. We also reviewed the standards and performance criteria established by state Quality Rating and Improvement Systems, national organizations, and policy experts in early childhood development, health, safety, maternal health, and related fields. For a full detailed description of the revisions from this multi-year process, please see the NPRM.

In sum, we propose to completely reorganize the regulatory structure to be more logical and easier to understand and implement; reduce bureaucratic burden on local programs by streamlining, simplifying, and significantly reducing the total number of regulations; strengthen standards for program services to reflect research and best practice and improve quality, and; completely overhaul and update the education standards to improve classroom practices and child outcomes. Together, these proposed revisions will support an increase in intensity, focus, and effort on high quality service delivery. The NPRM represents our effort to provide a clear roadmap for current and prospective grantees to provide high-quality Head Start services, regardless of setting. The NPRM will dramatically improve the quality of Head Start services and bolster their impact on the children and families we serve.

9. Explanation of Any Payment or Gift to Respondents

Not applicable.

10. Assurance of Confidentiality Provided to Respondents

Not applicable.

11. Justification for Sensitive Questions

Not applicable.

12. Estimates of Annualized Burden Hours and Costs

The Head Start program provides a high quality child development program, including a comprehensive set of health, social, education and parent involvement services, and nutrition assistance to children and families.

This NPRM proposes three new burdens while also removing previously required information collections. For informational purposes, collections of information that will no longer be required which will decrease the burden on grantees are described below:

• Head Start Grants Administration – The NPRM, at §1301, removed requirements for the submission of annual audits and accounting systems certifications.

• Appeal Procedures for Head Start Grantees and Current or Prospective Delegate Agencies – The NPRM removed the appeal procedures by delegate agencies in Part 1303. It also removed the appeal procedures by a grantee of a suspension continuing for more than 30 days now that suspensions can no longer last more than 30 days.

• Head Start Program Performance Standards Record Keeping – Numerous record-keeping requirements were removed, specifically: 1) documentation of the level of effort undertaken to establish community partnerships; 2) written records of roles and responsibilities for each governing body members; 3) the annual written and approval of plans for implementation services for each program area; 4) removing the prescribed list of topics and procedures that must be written into personnel policies; and 5) the record-keeping of surrounding community services and resources.

• Purchase, Construction and Major Renovation of Head Start Facilities – Some requirements were removed that involved a collection of information, specifically: 1) the submission of drawings and specifications; 2) submission of costs related to installation of modular unit; 3) submission of a statement of the procurement procedure for modular units; and 4) obtaining an independent analysis of the cost comparison.

The burden hour chart in the next page estimates an annual burden of 2,414,313 hours. Please note that the total annual burden includes currently approved information collections from the existing Head Start Performance Standards. This estimate is based on FY’14 information regarding the number of children and families served and the section numbers are based on the NPRM structure. For some items, burden hours are calculated for individual children and families, for others the burden hours are calculated for grantee and delegate agencies. The Burden Hours table on the next page and corresponding item by item narrative that follows the table indicate the basis for each calculation.

The total burden for the three proposed collections as estimated in the NPRM is 1,019,473 hours. Parental consent is the only completely new proposed collection.

Burden Hours for Head Start Program Performance Standards

Standard	Hours	Occurrences	Hours Burden
Child Health and Developmental Assessment
1302.33(c)(2) Dual Language Learners Assessment** (not completely new)	2.00	332,651	665,302
1302.42(b) Child Health and Developmental Assessment	0.50	1,061,620	530,810
1304.42(c) Record observations for ongoing care	0.50	1,061,620	530,810
1302.42(e) Documents lack of available funds from other sources for assessment and treatment	0.50	2,850	1,425
SUBTOTAL			1,728,347
Child Nutrition
1302.42(b)(4) Record nutrition-assessment data 1304.44(a)(1) Record info on family eating patterns, nutrition, health problems	0.166 (10 min.)	1,061,620	176,937
1302.42(b)(5) Record info on community nutritional issues	0.25	2,850	713
SUBTOTAL			177,650
Records on Child Medication
1302.47(b)(7)(v) Maintaining records on the administration of medication	0.50	2,850	1,425
SUBTOTAL			1,425
Community Partnerships
1302.53 (b) & (d) Joint agreements, procedures, or contracts with community organizations and memorandum of understanding with the appropriate local entity responsible for managing publicly funded preschool programs in the service area of the program	0.166 (10 min.)	2,850	475
SUBTOTAL			475
Program Governance
1301.4(e) Policy group reimbursement 1301.5(a) Procedures for resolving internal disputes	0.50	2,850	1,425
SUBTOTAL			1,425
Management Systems and Procedures
1302.102(a)-(d) Program planning includes formulation of program goals and objectives, community assessment, status reports to the governing body, conducting a self-assessment, and continual evaluation and implementation of data towards improvement	38.00	2,850	108,300
SUBTOTAL			108,300
Human Resources Management
1302.93(a) Ensure all staff has an initial health examination and periodic re-examination	0.25	23,853	5,963
1302.94(a) Regular volunteer screening for tuberculosis	0.166 (10 min.)	2,850	475
SUBTOTAL			6,438
Deficiencies and Quality Improvement Plans
1302.102(d)(3) If deficient, EHS or HS program submits Quality Improvement Plan	10.00	100	1,000
SUBTOTAL			1,000
Personnel Policies
1302.90(a) Written personnel policies for staff	0.50	2,850	1,425
1302.90(b)(1)(i)-(iv),(b)(4) Criminal record checks** (not completely new)	0.33 (20 min.)	73,591	24,530
SUBTOTAL			25,955
Parent Consent
1303.22-24 Parental Consent, Annual Notice, and Recordkeeping of PII Disclosure**	0.33 (20 min.)	988,923	329,641
SUBTOTAL			329,641
Head Start Facilities Purchase, Major Renovation and Construction
1303.42-53 Applications for the purchase, construction or renovation of facilities; record retention and submission of documents on facilities	41.00	225	9,225
SUBTOTAL			9,225
TOTALS			2,389,881
**Total for Proposed Collections (as estimated in NPRM)			1,019,473
Total for Existing and Currently Approved Collections			1,370,408

Key: 1,061,620 = total children, 988,923 = total families, 2,850 = total programs, 238,529 = total staff

Burden Hour Estimates for Performance Standards

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

Not applicable. Monetary costs associated with information collection requirements for Head Start are the salaries of the staff performing the duties. Costs are assumed by the Federal Government through the provision of program operating costs.

14. Annualized Cost to the Federal Government

Not applicable.

15. Explanation for Program Changes or Adjustments

There is an adjustment to previously approved collections due to an increase in the number of responses using FY 2014 estimates.

The burdens from collections no longer required are excluded and the burdens of new collections in the NPRM are added.

16. Plans for Tabulation and Publication and Project Time Schedule

There are no plans to publish information resulting for the compiling of children and families records in connection with Head Start program services.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

OMB expiration date will be displayed on the Head Start Performance Standards.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

Not applicable.

2. Statistical Methods(used for collection of information employing statistical methods)

No Statistical Methods of Analysis are conducted.

1. Respondent Universe and Sampling Methods

Not applicable.

2. Procedures for the Collection of Information

Not applicable.

3. Methods to Maximize Response Rates and Deal with Nonresponse

Not applicable.

4. Test of Procedures or Methods to be Undertaken

Not applicable.

5. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

Not applicable.

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