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Office of Head Start skip to primary page contentActing Director Patricia Brown

Information Memorandums (IMs) - 2004

Key Changes to PRISM (FY 2005)
[Attachment for Information Memorandum] ACYF-IM-HS-04-06

One of the major changes for FY 2005 is an increased emphasis on describing interrelated areas of noncompliance among services and systems. Interrelated areas of noncompliance may describe system-to-service interrelationships (i.e., a systems failure underlies a pervasive failure in service delivery) and system-to-system interrelationships (i.e., a systems failure underlies a pervasive failure in another system). Interrelationships are discussed throughout the Guide, and the section on developing the draft Head Start Review Report in the On-Site Activities chapter provides detailed direction on writing interrelated areas of noncompliance.

The Head Start Bureau (Bureau) continues its emphasis on improving fiscal monitoring. The Fiscal Checklist has been substantially revised for FY 2005 and uses a "risk-based" approach. Using this framework, the Fiscal Checklist now includes a set of prioritized indicators (i.e., "red flags") designed to identify underlying fiscal problems early. These indicators focus first on those areas that, if irregularities were present, would likely have the greatest adverse impact on the fiscal health of the grantee. In addition to the "red flag" indicators, the new Fiscal Checklist includes an updated list of questions that directly assess compliance with specific program requirements. Finally, the checklist assesses fiscal health in each of two major areas: internal controls and governance.

In addition, the Bureau is encouraging review teams to more closely examine several other areas during PRISM reviews. These include: transportation services; grantee compliance with other Federal, Tribal, State and local licensing requirements; and enrollment and income eligibility. These areas will be described in more detail later in this section.

Also new for FY 2005, the Bureau is emphasizing the conduct of grantee self-assessments. Grantees are reminded that the conduct of self-assessments help to ensure delivery of high-quality services to children and their families, and assist the grantee (and its delegates, when applicable) in preparing for a Federal monitoring review.

REPORT WRITING AND COVER LETTER CHANGES
Report Writing Changes
In an effort to increase emphasis on the interrelatedness of systems, services, and partnerships, and improve the method for delivering review decisions to the grantee, several changes have been made to the structure and contents of Head Start Review Report for FY 2005. The following is a list of these changes:

  • Renamed "Area Summary" to "Area Strengths" and eliminated discussion of areas of noncompliance in this section.
  • "Multiple methods and sources" are no longer required when discussing a grantee's strengths in the "Area Strengths" section of the Head Start Review Report.
  • As part of the increased emphasis on system-to-service and system-to-system interrelationships for FY 2005, language about how to write and cite stand-alone and interrelated areas of noncompliance in the Head Start Review Report is included.
  • Deficiency decisions are now included within the Head Start Review Report (as well as still in the cover letter).
  • Starting in FY 2005, a list of all of the citations constituting an area of noncompliance or deficiency (as determined by the responsible HHS official or designee) will automatically be generated and placed at the end of each respective Core Question's Areas of Noncompliance section. Next to each citation will be the corresponding review decision - either "noncompliant" or "deficient".
  • Beginning in FY 2005, the responsible HHS official (or designee) must, in addition to tracking corrective action through the corrective action screen, generate a follow-up report upon receipt and approval of a certification of compliance letter. These actions will help improve tracking of corrective action data.

Cover Letter Changes
Beginning in FY 2005, the web-based PRISM Software will support the generation of cover letters (with the exception of follow-up review and notice of termination cover letters) to accompany the Head Start Review Report sent to the grantee.

PROCEDURAL AND POLICY CHANGES

  • As part of the Head Start Bureau's efforts to identify potential income eligibility-related areas of noncompliance, all review teams must complete the new Income Eligibility Data Collection Form through the review of a sample of income eligibility determination records.
  • Review teams will be asked to enter funded and actual enrollment data into the PRISM software.
  • A greater emphasis will be placed on ascertaining grantee compliance with other Federal, Tribal, State and local requirements.
  • We will be providing more specific information about the new initiative in the near future.
  • When possible, new reviewers will be placed on teams with coach reviewers as the new reviewers are learning their responsibilities.

CHANGES TO THE PRISM GUIDE
Term and Structure Changes
The term "applicable standards" has been replaced with "program requirements" for FY 2005. "Program requirements" refers to requirements as specified in the Head Start Act, the Head Start Program Performance Standards, and other relevant Federal, State, and local regulations.

Additionally, the structure of the Guide was altered with the addition of a new appendix, entitled "Reviewer Information." This appendix, which appears after the Forms Appendix and before the Resources Appendix, includes information on reviewer job qualifications and descriptions, and supplemental information for certain reviewer processes as noted throughout the Guide.

New and Revised Forms
For FY 2005, a Community Partnerships Information Form has been added to the Forms Appendix. The intent of this form is for reviewers to gain background information and knowledge about the types and roles of the community partnerships present in the Head Start/Early Head Start programs before the interview protocol so more time can be spent during the interview protocol discussing the outcomes of the partnerships. In addition, many of the forms in this appendix have been revised slightly for FY 2005. Major changes occurred in two forms - the Summary of Review Decisions Worksheet and the Team Assignment Worksheet.

The Summary of Review Decisions form has been moved from its previous location in the PRISM Instrument to the Forms Appendix. This form was revised to allow the team leader to better map decision-making throughout the week. The form tracks the following elements for each Core Question as the review week progresses: issues raised by team members, follow-up items, possible citations, related citations and Core Questions, and potential strengths. Instructions for the Summary of Review Decisions Worksheet is located in front of the worksheet.

FY 2005 revisions to the Team Assignment Worksheet aims to better capture focus-child and family information. The section of the form that addresses focus-children and family assignments has been moved to the end of the form and moved into a new table format that includes columns for the grantee to write in background information and for the review team to coordinate logistical arrangements.

Additionally, the Grantee's Advance Activities Checklist, Team Leader's Advance Activities Checklist, and the Selection Process have been updated with minor revisions for FY 2005.

Reviewer Information and Resources Appendix
The Reviewer Code of Conduct, previously located in the Forms Appendix, has been updated for FY 2005 and moved to the new Reviewer Information Appendix.

The URLs listed in the Resources Appendix were updated to ensure that all are accurate and the websites remain in working order.

CHANGES TO THE PRISM INSTRUMENT
Several changes were made to the PRISM Instrument, including:

  • Each Core Question and its corresponding notes page have been revised so they appear back-to-back on the same page.
  • Addition of OMB Circular citations to Core Question 8 (Fiscal Management).
  • Moved a revised version of the Summary of Review Decisions Worksheet to the Forms Appendix.
  • Changes to the Content Area Experts Interview Protocol, Staff Group Interview Protocol, Community Partnerships Interview Protocol, and the Governing Body Interview Protocol. Additionally, a What's New for Interview Protocols was added following the Core Question pages.
  • Added two new sign-in sheets to use for the interviews. One sign-in sheet is for the Policy Council and Family Group Interviews, while the other is a general sign-in sheet to be used for all other interviews. Instructions for using these sign-in sheets are located immediately preceding the General Sign-In Sheet.
  • Revised the Fiscal Checklist consistent with the discussion appearing at the front of this section.
  • Revised and renamed the Bus Ride Checklist to the Transportation Services Checklist. The Transportation Services Checklist now better reflects the scope of Transportation Services and related program requirements. It should be used on all PRISM reviews, whether the grantee provides transportation services or not. In addition, the checklist's broader focus invites multiple reviewers to participate in information gathering. This allows the review team to ascertain compliance with transportation-related program requirements in the context of the grantee's other systems and services.
  • Added an Income Eligibility Data Collection Form and accompanying instructions.

The Head Start Bureau will continue to make modifications to PRISM as we learn from our experiences. We appreciate the support of and efforts made by grantees, reviewers and regional office staff to implement the changes in the monitoring system over the last several years. As always, our goal in monitoring is to work with local programs to ensure that high quality services are provided to all Head Start children and their families.

See also:
     Program Review Instrument for Systems Monitoring (PRISM) for FY 2005 (ACYF-IM-HS-04-06)