Head Start: A More Comprehensive Risk Management Strategy and Data Improvements Could Further Strengthen Program Oversight

GAO-08-221 February 12, 2008
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Summary

In February 2005, GAO issued a report that raised concerns about the effectiveness of the Department of Health and Human Services (HHS) Administration for Children and Families' (ACF) oversight of about 1,600 local organizations that receive nearly $7 billion in Head Start grants. GAO was asked to report on (1) ACF's progress in conducting a risk assessment of the Head Start program and ensuring the accuracy and reliability of data from its annual Program Information Report (PIR) survey of grantees, (2) efforts to improve on-site monitoring of grantees, and (3) how data are used to improve oversight and help grantees meet program standards. For this report, GAO surveyed a nationally representative sample of Head Start program directors and interviewed ACF officials. GAO also reviewed ACF studies on the validity of PIR data and conducted tests of data from the 2006 PIR database.

ACF has not undertaken a comprehensive assessment of risks that may limit Head Start's ability to meet federal program objectives, despite GAO's 2005 recommendation, and little progress has been made to ensure that the data from its annual PIR survey of grantees, which could facilitate such an assessment, are reliable. To conduct a comprehensive risk assessment, ACF needs to identify external and internal risks, estimate their significance, and decide how to best manage them. While ACF says it is working to establish two systems to address programwide risk, our analysis suggests that these systems fall short of that goal. The first system, by which ACF assesses grantees before providing new funds each year, only assesses risk posed to the program by poorly performing grantees and does not allow for a broader assessment of other sources of risk, such as improper payments to contractors. The second system, a new, integrated management information system, has been in development for over 4 years and it is not clear how it will facilitate a more comprehensive risk assessment for the Head Start program. Both initiatives depend, in part, on data from the annual PIR survey of grantees, which have been found to be unreliable. ACF has taken steps to improve oversight of Head Start grantees by implementing a more rigorous process for certifying reviewers who conduct on-site monitoring visits, implementing new processes to improve the consistency of reviews, and working to establish a system for evaluating reviews on an ongoing basis. Now, ACF verifies reviewers' qualifications and requires them to pass online tests in writing and computer literacy. Reviewers must also complete ongoing training and are evaluated by their peers at the end of each review. ACF has also taken a number of steps to improve the consistency and objectivity of reviews, including developing a Web-based data collection tool to facilitate information gathering, assigning review team leaders from outside the grantee's home region to increase independence, and centralizing the review and preparation of monitoring reports. ACF is also working to establish an ongoing system for evaluating its on-site review process. ACF uses data to track grantee performance and target assistance to underperforming grantees, but weaknesses may have hindered these efforts to improve grantee performance. For example, ACF does not have clear criteria for determining which grantees need additional oversight as part of its refunding analysis. Such decisions are made on an ad-hoc basis, which may result in grantees with similar problems receiving different levels of oversight. Moreover, prior to the December 2007 reauthorization of Head Start, ACF was limited in its ability to increase competition for grants to replace underperforming grantees. Under the new law, ACF will have more flexibility to open competition for Head Start grants to other prospective grantees when current grantees fail to deliver high-quality, comprehensive Head Start programs.



Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Implemented" or "Not implemented" based on our follow up work.

Director:
Team:
Phone:
Cornelia M. Ashby
Government Accountability Office: Education, Workforce, and Income Security
(202) 512-8403


Recommendations for Executive Action


Recommendation: To improve its management and oversight of the Head Start program, HHS's Assistant Secretary for Children and Families should more fully implement our 2005 recommendation by developing a strategic and comprehensive approach to assessing Head Start programwide risks. A comprehensive, programwide risk assessment should take all program risks into account. Specifically, a comprehensive risk assessment should include an assessment of risks arising from external sources, such as social and demographic changes that may affect the availability or demand for Head Start program services, as well as from internal sources, such as underperforming grantees, differences in how regional offices implement program policies and procedures, or the availability of sound data to help manage the program. A comprehensive risk assessment should also include strategies for minimizing risks that could significantly limit the ability of ACF and grantees to help grantees deliver high-quality programs.

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

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: To improve its management and oversight of the Head Start program, HHS's Assistant Secretary for Children and Families should look for cost-effective ways to expand ACF's efforts to comply with the Improper Payments Information Act of 2002 and to address our 2005 recommendation by collecting data on and estimating the extent of improper payments made for unallowable activities and other unauthorized purposes. These should take into account various aspects of the program and should not be limited to improper payments to grantees that enroll too many children from families that do not meet the program's income eligibility requirement.

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

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: To improve its management and oversight of the Head Start program, HHS's Assistant Secretary for Children and Families should take additional steps to ensure the accuracy of PIR data by determining which elements of the PIR are essential for program management and focus resources on a streamlined version of the PIR that would be required annually of all grantees, with the responses verified periodically. If additional information is needed to produce national estimates of a wider range of Head Start program services, ACF should include the relevant, additional data items in an expanded version of the PIR, which could be administered to a random, representative sample of grantees each year.

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

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: To improve its management and oversight of the Head Start program, HHS's Assistant Secretary for Children and Families should develop clear criteria for determining which grantees require more thorough reviews--such as special, on-site reviews--as a result of its refunding analysis system.

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

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.