Head Start: Progress and Challenges in Implementing Transportation Regulations

GAO-06-767R July 27, 2006
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Summary

The leading cause of death for children ages 3 to 7 is motor vehicle traffic crashes. Head Start, a federal early care and education program run by local grantees and targeted at low-income children, currently serves approximately 900,000 children, and transports many of them to and from Head Start centers across the country. While not required to do so, many Head Start grantees offer transportation as a way to make Head Start more widely available to the eligible population, especially very poor children. To address concerns about transporting children safely, the 1992 Head Start Improvement Act directed the Office of Head Start, housed within the U. S. Department of Health and Human Services (HHS), to develop transportation regulations to ensure the safety and effectiveness of transportation services made available to children by Head Start grantees. Head Start issued these regulations in 2001. To provide Congress with information that it requested on the regulations and their implementation, we determined: (1) the research and cost information Head Start considered in establishing the transportation regulations; (2) the actions Head Start grantees have taken to implement the vehicle, restraint, and bus monitor requirements of the regulations and the number of grantees that have sought waivers and extensions; and (3) the associated expenses and effects of implementing the regulations on grantees and their transportation partners.

Concerning the research and cost information that Head Start considered, we found that the Office of Head Start considered safety research and data in developing the regulations. Research and safety data from the National Highway Traffic Safety Administration (NHTSA), the National Transportation Safety Board (NTSB)--an independent federal agency charged with investigating transportation accidents and identifying safety improvements--and the National Academy of Science's Transportation Research Board shows that buses--both school buses and other types, such as transit buses--have lower fatality rates than other modes of transportation. The requirement for a bus monitor was based on Head Start's conclusion that young children on a bus should be supervised. Although the Office of Head Start did not research the need for monitors, it based this requirement on the belief that preschool- age children and younger who ride a bus should be supervised by an adult monitor in case the driver becomes disabled. The Office of Head Start no longer has supporting documentation for its cost estimate of $18.9 million for implementing the regulations. Without this documentation, we cannot determine the reliability of the data Head Start used to develop its estimates. Regarding grantees' actions to implement the regulations and the extent to which they sought extensions and waivers, we found that grantees have made progress in implementing the regulations. Approximately 64 percent report that they have finished implementing the regulations while 18 percent reported being almost finished. Almost all grantees reported primarily using a vehicle type that complies with the regulations. Ninety-seven percent of grantees reported primarily using either a school bus (93 percent) or the alternative vehicle allowed by the regulations (4 percent) to transport Head Start children on a daily basis. Grantees reported taking a variety of actions to meet the restraint and monitor requirements. Most grantees reported (1) either buying restraints and retrofitting their buses with them, or having had vehicles with restraints already in them; and (2) adding the bus monitor responsibilities to duties of existing staff or having had monitors already in place. Some transit agencies and other transportation providers who work with Head Start are facing difficulties in using the alternative vehicle. This is due to a lack of guidance for adapting it to transport other populations in addition to Head Start children. Fewer grantees requested more time to implement the restraint and monitor provisions in 2006 compared to 2004, but the number of waiver requests is unknown. In 2006, 19 percent of grantees submitted extension requests, dropping from 30 percent in 2004. As for waivers requested under the general waiver authority provided for in the regulations, the Office of Head Start officials stated that they were unaware that any were submitted. With respect to the costs and effects on grantees associated with implementing the regulations, we found that many grantees reported some cost effects from implementing the regulations, but noted that they were facing other budgetary pressures. Fifty-six percent of grantees reported no more than moderate cost effects on their transportation budgets from implementing the vehicle, restraint, or monitor requirements while 44 percent reported experiencing large or very large increases associated with one or more of these requirements. Grantees are experiencing effects to transportation services or program operations as a result of implementing the regulations. Fifty-eight percent of grantees reported at least one effect on transportation services as a result of the regulations, most often noting that they changed transportation routes (83 percent) or reduced transportation services (50 percent). Finally, some grantees are facing difficulties sustaining transportation partnerships.



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:
Marlene S. Shaul
Government Accountability Office: Education, Workforce, and Income Security
(202) 512-6778


Recommendations for Executive Action


Recommendation: In order to determine the ability of grantees to provide transportation services and to define the waiver process, the Office of Head Start should systematically track transportation services provided by grantees so that the Bureau can determine changes in the availability of these services, especially any reduction in them.

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

Status: In process

Comments: Product issued 7/27/06; awaiting agency action. Agency comment indicated that it would consider the recommendation but that it had information collection implications that would need to be fully considered before a final decision could be made.

Recommendation: In order to determine the ability of grantees to provide transportation services and to define the waiver process, the Office of Head Start should establish a waiver process that specifies criteria for submitting waivers, including more specific guidance on what constitutes "good cause," lists the responsible entities for review and approval, and documents the receipt, review, and final disposition of each waiver. Should any waiver requests submitted require Head Start to address issues concerning vehicles, the waiver process should include consultation with NHTSA and the Federal Transit Administration (FTA) as appropriate.

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

Status: In process

Comments: Product issued 7/27/06. Agency comment indicated support for the recommendation. Awaiting agency action.

Recommendation: In order to determine the ability of grantees to provide transportation services and to define the waiver process, the Office of Head Start should, once a process has been established, take steps to ensure that grantees and regional staff know about it and understand how it works.

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

Status: In process

Comments: Product issued 7/27/06. Agency comment indicated support for the recommendation.

Recommendation: In order to enable grantees and transit agencies to better coordinate transportation services, the Department of Transportation, in consultation with Head Start, should develop guidance on adapting the alternative vehicle to incorporate ADA requirements and communicate this guidance to Head Start grantees and transit agencies.

Agency Affected: Department of Transportation

Status: In process

Comments: US DOT has study in process - expected to have study completed in August 2007.

Recommendation: In order to enable grantees and transit agencies to better coordinate transportation services, the Department of Transportation, in consultation with Head Start, should determine if certain safety features could be incorporated into transit buses used by Head Start grantees to provide a level of safety comparable to school buses or alternative vehicles in transporting preschoolers. If this determination cannot be made before the remaining deadlines expire, the Office of Head Start, in consultation with DOT, should determine on a case-by-case basis whether grantees using transit vehicles with child safety restraints can continue to do so until such a determination can be made. If DOT determines that transit vehicles with appropriate safety features would afford suitable protections, the Office of Head Start should adopt these features into the final Head Start transportation regulations.

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

Status: In process

Comments: Product issued 7/27/06. FTA noted in its comments that it has an ongoing research project aimed at developing a small bus that would meet both safety and mobility goals for a broad range of users.

Agency Affected: Department of Transportation

Status: In process

Comments: US DOT has study in process - expected to have study completed in August 2007