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E – 001 Is the term of a Policy Council member limited to three years total even if the individual relocates to another area/program?
E – 002 Can individuals serve as voting members of both the Governing Board and the Policy Council?
E – 003 How can a Policy Council participate in the hiring and termination of staff who are employed by a school district?
E – 004 How can a Head Start program hire an individual in an emergency situation during which it is not possible to first obtain Policy Council approval?
E – 005 What training should governing body members receive?
E – 006 45 CFR Part 1304.50(f) states that Head Start programs must enable low-income members of the program’s Policy Council, Policy Committee or Parent Committee to participate fully in their group’s responsibility, including, if necessary, reimbursements for reasonable expenses incurred by the members. Are programs mandated to provide reimbursements to over-income members?
E – 007 What approval decisions must be made by Policy Councils?
E – 008 If a parent is a Policy Council alternate, but does not actually vote for anything during an entire program year, must the grantee still count that as one of the three terms that the parent is allowed to serve on a Policy Council?
E – 009 How many terms can the President of the governing body serve?
E – 010 Can a parent member of the Policy Council be hired as a temporary or regular part-time employee of the Head Start agency?
E – 011 What can you do if you suspect that a member of the governing body is receiving or taking advantage of Head Start funds?
E – 012 Are "policies", "plans" and "procedures" interchangeable terms in the Program Performance Standards, or do they have different meanings? Are programs required to have separate documents on file to demonstrate compliance with requirements for these three activities when the Program Performance Standards say they must be "written"? Please explain.
E – 013 What should the content of child abuse training for Head Start staff include? Who should conduct the training? Who should receive the training?
E – 014 We operate an Early Childhood Education Center on an Indian Reservation that includes both an Infant Toddler program funded with federal and Tribal dollars, and a Preschool Program funded with federal Head Start and Tribal dollars. Both programs follow the Head Start Performance Standards and there is a single Policy Council that serves both programs. The Policy Council has 11 members. Six members (55 %) are parents of enrolled Head Start children, three are parents of children enrolled in the Infant Toddler program, and two are appointed representatives of our local school board and the tribal council. Is the composition of our Policy Council in compliance with the Head Start Performance Standards?
E – 015 If a current staff person applies for a vacant position within the program and this is considered to be a lateral transfer or promotion, and the staff person is determined to be the successful candidate, is Policy Council approval necessary?
E – 016 Can a Head Start Director terminate staff without getting an approval from the Policy Council or the Board?
E – 017 Are Head Start agencies at will to develop employee polices and procedures or are there standards/guidelines that must be followed?
E – 018 If a parent committee officer has misused funds from a fundraiser for the center and has a felony charge for fraud, can they be an officer the next upcoming year?
E – 019 By the end of August at the delegate agency where I work, Parent Involvement coordinators will be establishing the Parent Committees in each of the centers and the Policy Committee. Our written procedures gives the opportunity to Parent Committees to organize with a board even if this parent elected to the board is a staff or member of their immediate families. BUT they are not permitted to serve on the Policy Committee. Only parents that are not staff or are not members of their immediate families CAN serve on the Policy Committee.
My question is if this procedure is in compliance with the regulation below 1304.50(b)(6)
(6) No grantee or delegate agency staff (or members of their immediate families) may serve on Policy Councils or Policy Committees except parents who occasionally substitute for regular Early Head Start or Head Start staff. In the case of Tribal grantees, this exclusion applies only to Tribal staff who work in areas directly related to or which directly impact upon any Early Head Start or Head Start administrative, fiscal or programmatic issues.
E – 020 Can a Head Start center change its hours without parents’ input?
E – 021 What are the membership requirements of the governing body?
E – 022 Are tribal governments exempt or excluded from the governing body composition requirements?
E – 023 Concerning the new requirements for Board Members, what constitutes a background and expertise? Do they have to have a Bachelor degree in the area or work experience or what?
E – 024 May a governing body form an advisory committee (or sub-board) to oversee responsibilities related to program governance?
E – 025 Do community representatives on the Policy Council now have to be elected by the parents?
E – 026 We have the following questions regarding the governing body licensed attorney requirement:
- Does "licensed attorney" include an attorney who is licensed in a state other than the one in which the Head Start program is located?
- Does "licensed attorney" include an attorney who is retired, and registered with the state bar but no longer required to maintain continuing legal education courses?
E – 027 What are the governing body membership requirements?
E – 028 What are the selection and election requirements concerning members of the Policy Council?
E – 029 What is a “conflict of interest” in a Head Start agency? What guidance can the Office of Head Start (OHS) provide to Head Start agencies trying to address possible conflict of interest situations involving governing body members?
E – 030 Can members of the governing body be reimbursed for child care and/or mileage expenses for attending board and committee meetings?
E – 001 Is the term of a Policy Council member limited to three years total even if the individual relocates to another area/program?
OHS – PC – E – 001 Is the term of a Policy Council member limited to three years total even if the individual relocates to another area/program?
If a member of the Policy Council completes three years of service on a Policy Council for one program, it should prevent the individual from serving on another Policy Council if that individual should relocate to another area.
The Head Start Program Performance Standards at 45 CFR 1304.50(b)(5) has determined that Policy Councils and Policy Committees must limit the number of one-year terms any individual may serve on either body to a combined total of three terms.
Requirement
45 CFR 1304.50(b)(5)
July 11, 2006
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E – 002 Can individuals serve as voting members of both the Governing Board and the Policy Council?
OHS – PC – E – 002 Can individuals serve as voting members of both the Governing Board and the Policy Council?
Programs have flexibility when deciding Board and Policy Council membership procedures and rules. The regulations state that the Board and Policy Council cannot have identical membership but that does not mean that a member of the Board is prohibited from being a voting member of the Policy Council and conversely a Policy Council member could also be a voting member of the Board as long as such an arrangement is in the by-laws of the Board and the Policy Council.
Informal Guidance
March 15, 2007
E – 003 How can a Policy Council participate in the hiring and termination of staff who are employed by a school district?
OHS – PC – E – 003 How can a Policy Council participate in the hiring and termination of staff who are employed by a school district?
With the increase of Head Start – State Pre-Kindergarten partnerships, there have been numerous instances of shared human, fiscal and material resources by Head Start agencies and local school districts. In some cases, these partnerships pose new challenges for the implementation of shared governance.
The Head Start philosophy and regulations support the participation of parents through shared governance in decisions about their local Head Start program. For example, the Policy Council must approve decisions to hire or terminate any person who “works primarily for the Early Head Start or Head Start program of the grantee or delegate agency”. If a Head Start agency pays the school district for the services of the district’s employees (or claims the value of their services as non-federal share), the Head Start agency should determine whether the dollar amount constitutes more than half of the particular individual’s compensation. If it does, the Policy Council shares approval authority with the governing body and key management staff over the hiring and termination of the school district employee’s employment, in so far as it involves working in the Head Start program.
In addition, whether or not the employee meets the “works primarily for” criteria, a Policy Council still has a role to play in participating in decisions about the status of school district employees playing significant roles in the Head Start program. When a Head Start agency transfers the performance of substantive programmatic work, such as teaching or administration, to a third party, such as a school district, that transfer constitutes a “change in scope”. A “change of scope” requires the prior approval of the Regional Office. In order to obtain prior approval, a grantee must submit to the Regional Office in its annual grant application (or proposed modification) a description of proposed collaboration. Consistent with the provisions of 45 CFR Part 1304.50(d), this grant application must be approved by the Policy Council. Grantees that are pursuing cooperative relationships with school districts are encouraged to involve the Policy Council early on in any discussions with the school so that issues can be addressed as the agreement is being developed and all parties involved will have a clear understanding of the nature of the collaboration.
Informal Guidance
April 23, 2007
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E – 004 How can a Head Start program hire an individual in an emergency situation during which it is not possible to first obtain Policy Council approval?
OHS – PC – E – 004 How can a Head Start program hire an individual in an emergency situation during which it is not possible to first obtain Policy Council approval?
A decision by a Head Start grantee (or delegate agency) to hire or terminate any person who works primarily for the Head Start program requires the approval of the program’s Policy Council (or Policy Committee). However, there may occasionally be situations that necessitate a program finding a suitable replacement for an important staff position before it is possible to obtain Policy Council approval. For example, a key member of the staff who performs critical functions for the program might be involved in a serious accident during a weekend. Such situations, although uncommon, do occur and pose risks to the continuing capacity of the Head Start program to provide uninterrupted services to children and families. The Office of Head Start expects all Early Head Start and Head Start grantees and delegate agencies to develop policies and procedures for the emergency hiring of personnel. These policies and procedures should be included in the agency’s personnel policies or bylaws, or both. The policies and procedures should address emergency hiring procedures, including a discussion of how to assure the Policy Council is afforded a timely opportunity to fulfill their staff hiring and termination approval responsibilities.
Head Start agencies are reminded that before employing an individual they are required to obtain a criminal background check.
See ACF-PI-HS-08-04.
Informal Guidance
April 23, 2007 Revised September 25, 2008
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E – 005 What training should governing body members receive?
OHS – PC – E – 005 What training should governing body members receive?
This Policy Clarification is currently under review. ![Go to top](https://webarchive.library.unt.edu/web/20130302170154im_/https://eclkc.ohs.acf.hhs.gov/hslc/images/top_ic.gif)
E – 006 45 CFR Part 1304.50(f) states that Head Start programs must enable low-income members of the program’s Policy Council, Policy Committee or Parent Committee to participate fully in their group’s responsibility, including, if necessary, reimbursements for reasonable expenses incurred by the members. Are programs mandated to provide reimbursements to over-income members?
OHS – PC – E – 006 45 CFR Part 1304.50(f) states that Head Start programs must enable low-income members of the program’s Policy Council, Policy Committee or Parent Committee to participate fully in their group’s responsibility, including, if necessary, reimbursements for reasonable expenses incurred by the members. Are programs mandated to provide reimbursements to over-income members?
No. Programs are mandated to provide reimbursement only to low-income families. Programs, at their discretion, may, however, provide reasonable reimbursement to all members.
Requirement
45 CFR 1304.50(f)
June 19, 2007
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E – 007 What approval decisions must be made by Policy Councils?
OHS – PC – E – 007 What approval decisions must be made by Policy Councils?
This Policy Clarification is currently under review. ![Go to top](https://webarchive.library.unt.edu/web/20130302170154im_/https://eclkc.ohs.acf.hhs.gov/hslc/images/top_ic.gif)
E – 008 If a parent is a Policy Council alternate, but does not actually vote for anything during an entire program year, must the grantee still count that as one of the three terms that the parent is allowed to serve on a Policy Council?
OHS – PC – E – 008 If a parent is a Policy Council alternate, but does not actually vote for anything during an entire program year, must the grantee still count that as one of the three terms that the parent is allowed to serve on a Policy Council?
No. If a parent alternate does not actually cast a vote during a program year, that individual did not actually serve as a Policy Council member. He/she would be allowed to serve up to three terms as a Policy Council member if elected or re-elected.
Requirement
45 CFR 1304.50(b)(5)
July 3, 2007
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E – 009 How many terms can the President of the governing body serve?
OHS – PC – E – 009 How many terms can the President of the governing body serve?
45 CFR 1304.50(g)(1) requires the governing bodies of Head Start grantees and delegate agencies to have written policies that define the roles and responsibilities of the governing body members. However, neither the Head Start statute nor regulations govern such issues as limitations on the number of terms an officer or member of the governing body may serve. Such term limits remain an internal organizational matter.
Informal Guidance
July 13, 2007
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E – 010 Can a parent member of the Policy Council be hired as a temporary or regular part-time employee of the Head Start agency?
OHS – PC – E – 010 Can a parent member of the Policy Council be hired as a temporary or regular part-time employee of the Head Start agency?
In accordance with 45 CFR 1350(b)(6), an individual may not serve on the Policy Council and also be hired as a temporary or regular employee of the Head Start agency.
However, there is one exception permitted. A parent member of the Policy Council may "occasionally substitute for regular Early Head Start or Head Start staff."
Requirement
45 CFR 1350(b)(6)
July 13, 2007
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E – 011 What can you do if you suspect that a member of the governing body is receiving or taking advantage of Head Start funds?
OHS – PC – E – 011 What can you do if you suspect that a member of the governing body is receiving or taking advantage of Head Start funds?
Any allegations of misuse of Head Start grant funds or concerns about the use of such funds should be addressed to the Regional Office and should include as much factual detail and specificity as possible.
Informal Guidance
July 13, 2007
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E – 012 Are "policies", "plans" and "procedures" interchangeable terms in the Program Performance Standards, or do they have different meanings? Are programs required to have separate documents on file to demonstrate compliance with requirements for these three activities when the Program Performance Standards say they must be "written"? Please explain.
OHS – PC – E – 012 Are "policies", "plans" and "procedures" interchangeable terms in the Program Performance Standards, or do they have different meanings? Are programs required to have separate documents on file to demonstrate compliance with requirements for these three activities when the Program Performance Standards say they must be "written"? Please explain.
The terms "policies", "plans" and "procedures" are all concerned with directing or guiding present and future action by the governing body and Policy Council, management, and staff of the Head Start program. These terms are not interchangeable. Although they have some similarity, the three terms are progressively more specific in their focus.
The governing body and Policy Council have responsibility for developing or approving policies for a Head Start program. When the program leadership decides what organizational goals to achieve and chooses a definite course of action, they explain through policy what the program’s course of action is and will be. Policy determines or guides future decisions important to the Head Start mission. Policies are statements of ways that an organization intends to achieve its mission and various goals.
Plans may be the responsibility of the governing body and Policy Council, management or staff. Plans are concerned with breaking down what needs to be done to accomplish a goal into a series of steps to be carried out over a specified period of time, by particular assigned individuals, in a particular location(s). Plans typically include schedules of events or activities. They tend to focus on when, where and who will carry out the series of steps necessary to achieve the goal.
Procedures may be the responsibility of the governing body and Policy Council, management or staff. Procedures focus on how individuals and groups are to perform their responsibilities, in carrying out specific steps or protocols. A set of instructions may detail the sequence, timing and execution of specified actions necessary to complete a task(s) or step(s). Procedures are a particular way to get something done for the organization.
A particular policy may require a plan(s) and procedures. The Program Performance Standards do not prescribe that these be separate or integrated documents. Written policies, plans, and procedures may be separate documents, or they may be integrated, at the discretion of each program.
Informal Guidance
July 31, 2007
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E – 013 What should the content of child abuse training for Head Start staff include? Who should conduct the training? Who should receive the training?
OHS – PC – E – 013 What should the content of child abuse training for Head Start staff include? Who should conduct the training? Who should receive the training?
Child abuse and neglect training for Head Start staff is particularly important due to the serious consequences for Head Start children when it occurs, and also when it goes undetected or unaddressed by the adults who are involved with those children directly impacted. The individual(s) who trains Head Start staff must be qualified to train on the local, state, and federal requirements concerning child abuse and neglect. The knowledge, skills and experience in the field of child abuse and neglect generally resides in the local child protective services agency. Head Start programs should collaborate with child protective services agencies to determine the appropriate training content and qualifications of trainers. The child protection agency may directly provide the training to Head Start staff, or they may co-train with appropriate Head Start staff trainers. If a particular child protection agency is over-burdened, the Head Start program should request referral to another qualified training resource(s) available in the community. For example, in some areas the local school district has qualified social workers to train school personnel on child abuse and neglect identification and reporting. These trainers may be made available to Head Start through partnership agreements. There may be other qualified trainers available as well. The Head Start program must document agreements and decisions concerning training content, and trainer qualifications. Programs should maintain an ongoing record of training conducted, names and qualifications of trainers, and names and positions of trainees.
At a minimum, the content of training should include identification and reporting of child abuse and neglect, State statute requirements concerning child abuse and neglect, the Head Start program’s plan, including procedures for responding to suspected or known child abuse and neglect, and any collaborative agreements between Head Start and the child protective services agency. Training should also include policies and procedures for the identification and reporting of child abuse and neglect allegedly committed by Head Start agency personnel.
Since all Head Start staff come in contact with Head Start children and their families in the course of performing their various responsibilities, the training should be provided to all Head Start staff. The governing body and Policy Council should also be provided appropriate training on child abuse and neglect to ensure that they have the necessary knowledge to provide oversight to Head Start management on the implementation of local, State and federal requirements.
Requirement
45 CFR 1304.52(k)(3)(i)
July 31, 2007
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E – 014 We operate an Early Childhood Education Center on an Indian Reservation that includes both an Infant Toddler program funded with federal and Tribal dollars, and a Preschool Program funded with federal Head Start and Tribal dollars. Both programs follow the Head Start Performance Standards and there is a single Policy Council that serves both programs. The Policy Council has 11 members. Six members (55 %) are parents of enrolled Head Start children, three are parents of children enrolled in the Infant Toddler program, and two are appointed representatives of our local school board and the tribal council. Is the composition of our Policy Council in compliance with the Head Start Performance Standards?
OHS – PC – E – 014 We operate an Early Childhood Education Center on an Indian Reservation that includes both an Infant Toddler program funded with federal and Tribal dollars, and a Preschool Program funded with federal Head Start and Tribal dollars. Both programs follow the Head Start Performance Standards and there is a single Policy Council that serves both programs. The Policy Council has 11 members. Six members (55 %) are parents of enrolled Head Start children, three are parents of children enrolled in the Infant Toddler program, and two are appointed representatives of our local school board and the tribal council. Is the composition of our Policy Council in compliance with the Head Start Performance Standards?
This Policy Clarification is currently under review. ![Go to top](https://webarchive.library.unt.edu/web/20130302170154im_/https://eclkc.ohs.acf.hhs.gov/hslc/images/top_ic.gif)
E – 015 If a current staff person applies for a vacant position within the program and this is considered to be a lateral transfer or promotion, and the staff person is determined to be the successful candidate, is Policy Council approval necessary?
OHS – PC – E – 015 If a current staff person applies for a vacant position within the program and this is considered to be a lateral transfer or promotion, and the staff person is determined to be the successful candidate, is Policy Council approval necessary?
Yes. In accordance with 45 CFR 1304.50(d)(1)(xi) Policy Council approval is required for hiring of any person who works primarily for the Early Head Start or Head Start program. This would apply to hiring a current staff person for a new position.
Requirement
45 CFR 1304.50(d)(1)(xi)
August 21, 2007
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E – 016 Can a Head Start Director terminate staff without getting an approval from the Policy Council or the Board?
OHS – PC – E – 016 Can a Head Start Director terminate staff without getting an approval from the Policy Council or the Board?
Staff cannot be fired without Policy Council approval. (The only exception is that if a grantee’s personnel policies permit, a probationary employee can be terminated without Policy Council approval.) If the Board has delegated, in writing, responsibility for decisions related to the termination of staff to the Executive or Head Start Director a staff member can be terminated without explicit authority from the Board. It is expected, however, that even when firing decisions have been delegated, the Board will be regularly apprised of any personnel changes.
Requirement
45 CFR 1304.50(d)(1)(xi)
September 26, 2007
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E – 017 Are Head Start agencies at will to develop employee polices and procedures or are there standards/guidelines that must be followed?
OHS – PC – E – 017 Are Head Start agencies at will to develop employee polices and procedures or are there standards/guidelines that must be followed?
Each Head Start grantee should develop its own policies and procedures that reflect that grantee’s particular needs. However, grantees must assure any such policies and procedures conform to all relevant local, state and federal statutes such as, for example, compliance with the Fair Labor Standards Act.
Requirement
45 CFR 1301.31
September 26, 2007
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E – 018 If a parent committee officer has misused funds from a fundraiser for the center and has a felony charge for fraud, can they be an officer the next upcoming year?
OHS – PC – E – 018 If a parent committee officer has misused funds from a fundraiser for the center and has a felony charge for fraud, can they be an officer the next upcoming year?
Head Start regulations governing Parent Committees at 45 CFR 1304.50(a)(1)(iii), 1304.50(a)(2), 1304.50(a)(3), and 1304.50(e) establish standards for Parent Committee structure and minimum responsibilities related to shared governance. However, specific operational procedures governing membership on Parent Committees—and mechanisms for removal—are assigned to the discretion of local programs. In the situation described, it is up to the local program as specified in Parent Committee procedures to determine the grounds for removal of a Parent Committee member or the conditions for serving as a Parent Committee officer. It remains, however, the expectation of ACF as the funding agency that local programs will take every measure to ensure Federal funds are safeguarded and not misused by Policy Councils, Policy Committees, or Parent Committees.
Informal Guidance
October 10, 2007
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E – 019 By the end of August at the delegate agency where I work, Parent Involvement coordinators will be establishing the Parent Committees in each of the centers and the Policy Committee. Our written procedures gives the opportunity to Parent Committees to organize with a board even if this parent elected to the board is a staff or member of their immediate families. BUT they are not permitted to serve on the Policy Committee. Only parents that are not staff or are not members of their immediate families CAN serve on the Policy Committee.My question is if this procedure is in compliance with the regulation below 1304.50(b)(6)(6) No grantee or delegate agency staff (or members of their immediate families) may serve on Policy Councils or Policy Committees except parents who occasionally substitute for regular Early Head Start or Head Start staff. In the case of Tribal grantees, this exclusion applies only to Tribal staff who work in areas directly related to or which directly impact upon any Early Head Start or Head Start administrative, fiscal or programmatic issues.
OHS – PC – E – 019 By the end of August at the delegate agency where I work, Parent Involvement coordinators will be establishing the Parent Committees in each of the centers and the Policy Committee. Our written procedures gives the opportunity to Parent Committees to organize with a board even if this parent elected to the board is a staff or member of their immediate families. BUT they are not permitted to serve on the Policy Committee. Only parents that are not staff or are not members of their immediate families CAN serve on the Policy Committee.My question is if this procedure is in compliance with the regulation below 1304.50(b)(6)(6) No grantee or delegate agency staff (or members of their immediate families) may serve on Policy Councils or Policy Committees except parents who occasionally substitute for regular Early Head Start or Head Start staff. In the case of Tribal grantees, this exclusion applies only to Tribal staff who work in areas directly related to or which directly impact upon any Early Head Start or Head Start administrative, fiscal or programmatic issues.
Head Start regulations at 45 CFR 1304.50(b)(6) do not cover the composition of Parent Committees established at the center level as required by 1304.50(a)(1)(iii). Therefore, parents may serve on center-level Parent Committees even if they are also employed by the Head Start agency or members of their immediate families are so employed. Programs should keep in mind that 45 CFR 1304.50(a)(2) requires that Parent Committees be comprised "exclusively of the parents of children currently enrolled at the center level for center-based programs."
Requirement
45 CFR 1304.50(a)(2)
October 10, 2007
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E – 020 Can a Head Start center change its hours without parents’ input?
OHS – PC – E – 020 Can a Head Start center change its hours without parents’ input?
A change in the time a center is open would be considered a change in the program design and, as such, must be authorized by the OHS Regional Office through a revised budget request that requires Policy Council approval.
Requirement
45 CFR 1304.50(d)(i)
November 20, 2007
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E – 021 What are the membership requirements of the governing body?
OHS – PC – E – 021 What are the membership requirements of the governing body?
The governing body membership must include the following:
- One or more members with a background and expertise in fiscal management and accounting.
- One or more members with a background and expertise in early childhood education and development.
- One or more licensed attorneys familiar with Head Start governing body issues.
- Additional members who reflect the community and include parents of formerly or currently enrolled Head Start children.
- Other members selected for their expertise in education, business administration, or community affairs.
Note: If a Head Start agency is unable to include members for any of the first three categories (1-3) above, the governing body must obtain the services of a consultant or other individual with the required background and expertise to work with the governing body instead.
Requirement
Sec. 642(c)(1)(B) of the Head Start Act
January 22, 2008
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E – 022 Are tribal governments exempt or excluded from the governing body composition requirements?
OHS – PC – E – 022 Are tribal governments exempt or excluded from the governing body composition requirements?
Please refer to OHS – PC – E – 027.
February 6, 2008 Revised February 23, 2009
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E – 023 Concerning the new requirements for Board Members, what constitutes a background and expertise? Do they have to have a Bachelor degree in the area or work experience or what?
OHS – PC – E – 023 Concerning the new requirements for Board Members, what constitutes a background and expertise? Do they have to have a Bachelor degree in the area or work experience or what?
Section 642(c)(1)(B) of the Head Start Act establishes composition requirements for all Head Start agency governing bodies. In general, governing body membership should include at least one member with “a background and expertise in fiscal management or accounting” and at least one member with “a background and expertise in early childhood education and development.” In addition, governing body membership should include “a licensed attorney familiar with issues that come before the governing body.” It is our expectation that Head Start agencies will take action to include such individuals as members on their governing bodies. However, section 642(c)(1)(B)(vi) authorizes governing bodies to secure consultants or other individuals with the relevant expertise and qualifications described at section 642(c)(1)(B)(i)-(iii) to “work directly with the governing body” if individuals with the required background and expertise are not available to actually serve as members.
The Head Start Act does not define or describe “a background and expertise” by reference to educational qualifications or credentials. It is reasonable, however, for us to expect Head Start agencies to secure the membership or services of individuals with demonstrated experience in fiscal management or accounting, early childhood education and development, and legal issues that routinely come before Head Start governing bodies. All Head Start agencies should bear in mind that their Head Start governing bodies are required by the Head Start Act to “have legal and fiscal responsibility for administering and overseeing programs” under the Head Start Act.
Requirement
Section 642(c)(1)(A)(B) and (E)(i) of the Head Start Act
February 6, 2008
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