L – 001 Can the costs and time incurred by parents in transporting their children to and from a Head Start center be counted as non-federal share?
L – 002 Can the costs and time incurred by a school district in transporting Head Start children to and from a Head Start program be counted as non-federal share?
L – 003 Does a program have to comply with the 45 CFR 1310 regulations concerning Head Start Transportation when the agency only uses, arranges for, or employs bus drivers with buses to transport the children to and from the centers?
L – 004 Do the Head Start transportation regulations apply to providing transportation for enrolled children to special services such as speech therapy?
L – 005 Do the Head Start transportation regulations apply to providing transportation to enrolled children to and from dental appointments?
L – 006 Are children’s backpacks considered "properly stored and secured" if these items are held in children’s hands or on their laps?
L – 007 How many bus monitors should be on each bus?
L – 008 Does training in pedestrian safety have to be provided to parents and children in Early Head Start home based programs? If so, how do we meet the requirement of training within the first 30 days of the program year when we go year-round?
L – 009 Can children be on a bus for more than one hour when being transported to and from the program?
L – 010 Can children be on the bus for more than one hour when being transported to and from dental and medical services?
L – 011 Are field trips considered a Transportation Service and, as such, subject to the requirements for the use of a school bus or allowable alternate vehicle, bus monitors, child restraint systems, etc.?
L – 012 Are programs obligated to transport parents upon request to and from Head Start/EHS centers?
L – 013 Can program funds be used to reimburse families for mileage expenses to and from socialization activities in the home-based program option?
L – 014 Can programs count, as non-federal share, the time spent by a parent walking his/her child to the Head Start center?
L – 015 Please clarify if a program that does not offer any transportation services may count as non-federal share the costs incurred by parents in transporting their children to and from the Head Start center.
L – 016 Do programs providing transportation services for children enrolled in Combination Option need to meet the provision of the Head Start transportation regulations related to child safety restraint systems, bus monitors, and the use of school buses or allowable alternative vehicles?
L – 017 If a child enrolled in a center-based program has been transported to the center on a school bus and needs to be taken home because of head lice or illness because the parent does not have transportation, can a van be used to transport that child home?
L – 018 Do high-back school bus seats alone meet the requirements for "child restraint systems" for transporting children ages three to five years?
L – 019 Does the requirement that the seat behind the Head Start child either be unoccupied or that the occupants of that seat be restrained apply to the use of all child restraint systems?
L – 020 If our program does not provide transportation to one of our sites for children without disabilities, must we provide transportation to that site for children with disabilities?
L – 021 If Pedestrian Safety Training is provided to parents and children within the first 30 days of the program year – is the program required to provide the same, on an individual basis, for all late enrollees?
L – 022 If a bus monitor leaves the bus to pick up or deliver a child to their home or center, does this create a child/monitor ratio problem on the bus even if the driver is still on the bus? If a parent has a disability and is unable to bring their child to the curb for transportation pickup, can we refuse to provide transportation?
L – 023 What restraint requirements must be met for a child weighing over 50 pounds riding a Head Start school bus?
L – 001 Can the costs and time incurred by parents in transporting their children to and from a Head Start center be counted as non-federal share?
OHS – PC – L – 001
Can the costs and time incurred by parents in transporting their children to and from a Head Start center be counted as non-federal share?
See Program Instruction ACF-PI-HS-07-04.
Requirement
45 CFR 1310.12(a); 2 CFR 215.23(a); 45 CFR 92.24(a)
April 23, 2007
Revised June 26, 2007
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L – 002 Can the costs and time incurred by a school district in transporting Head Start children to and from a Head Start program be counted as non-federal share?
OHS – PC – L – 002
Can the costs and time incurred by a school district in transporting Head Start children to and from a Head Start program be counted as non-federal share?
Yes. In order to be allowable as non-federal share a particular cost would have to be allowable as “federal share”. The cost of transporting Head Start children, consistent with the provisions of 45 CFR 1310, is an allowable cost for which Head Start grant funds can be used. Therefore, transportation services provided to Head Start children by a local school system, on school buses, at no or reduced cost to the grantee may be counted as non-federal share as long as all other applicable Head Start transportation services requirements are met or a waiver is in effect. The monetary value of transportation services as well as such services provided at a reduced cost must be determined in accord with the appropriate cost principles.
Requirement
2 CFR 215.23(a); 45 CFR 92.24(a)
April 23, 2007
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L – 003 Does a program have to comply with the 45 CFR 1310 regulations concerning Head Start Transportation when the agency only uses, arranges for, or employs bus drivers with buses to transport the children to and from the centers?
OHS – PC – L – 003
Does a program have to comply with the 45 CFR 1310 regulations concerning Head Start Transportation when the agency only uses, arranges for, or employs bus drivers with buses to transport the children to and from the centers?
Yes. The regulations pertain to agencies that provide transportation services directly or through another arrangement with a private or public transportation provider.
Requirement
45 CFR 1310.2(a)
April 25, 2007
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L – 004 Do the Head Start transportation regulations apply to providing transportation for enrolled children to special services such as speech therapy?
OHS – PC – L – 004
Do the Head Start transportation regulations apply to providing transportation for enrolled children to special services such as speech therapy?
Yes. Head Start programs that provide transportation to special services at regularly scheduled times and at pre-arranged sites must comply with the Head Start transportation regulations, including the use of bus monitors and child restraint systems , unless there is an approved waiver in place. Transportation to special services is included in the definition of Transportation Services. (See 45 CFR 1310.3). Each agency must specify any special transportation requirements for a child with a disability when preparing the child's Individual Education Plan (IEP) or Individual Family Service Plan (IFSP), and ensure that in all cases special transportation requirements in a child's IEP or IFSP are followed. (See 45 CFR 1310.22).
Requirement
45 CFR 1310.3; 1310.22
June 12, 2007
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L – 005 Do the Head Start transportation regulations apply to providing transportation to enrolled children to and from dental appointments?
OHS – PC – L – 005
Do the Head Start transportation regulations apply to providing transportation to enrolled children to and from dental appointments?
No. Dental appointments are considered incidental trips and are not included under the definition of Transportation Services, 45 CFR 1310.3.
Requirement
45 CFR 1310.3
June 12, 2007
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L – 006 Are children’s backpacks considered "properly stored and secured" if these items are held in children’s hands or on their laps?
OHS – PC – L – 006
Are children’s backpacks considered "properly stored and secured" if these items are held in children’s hands or on their laps?
45 CFR 1310.15(b) requires that "Baggage and other items transported in the passenger compartment are properly stored and secured and the aisles remain clear and the doors and emergency exits remain unobstructed at all times". Programs should consider the best method of meeting this requirement based on their own circumstances and the safety of the children being transported when developing and implementing transportation procedures.
State and local regulations may specify additional requirements for baggage transport.
Requirement
45 CFR 1310.15(b); 45 CFR 1304.22(d)(1)
June 26, 2007
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L – 007 How many bus monitors should be on each bus?
OHS – PC – L – 007
How many bus monitors should be on each bus?
45 CFR 1310.15(c) requires that there be at least one bus monitor on board at all times, with additional bus monitors provided as necessary, such as when needed to accommodate the needs of children with disabilities.
The needs of the children being transported should be considered when deciding how many bus monitors are necessary. Bus populations can vary and programs are in the best position to determine what type of support the children being transported require. For example, if large numbers of very young children or children requiring special assistance are on one particular bus due to geographical routing, that bus may require more monitors.
Check state and local regulations as some states apply staff-child ratios to the bus.
Requirement
45 CFR 1310.15(c)
June 26, 2007
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L – 008 Does training in pedestrian safety have to be provided to parents and children in Early Head Start home based programs? If so, how do we meet the requirement of training within the first 30 days of the program year when we go year-round?
OHS – PC – L – 008
Does training in pedestrian safety have to be provided to parents and children in Early Head Start home based programs? If so, how do we meet the requirement of training within the first 30 days of the program year when we go year-round?
Yes. 45 CFR 1310.21(a) applies to all enrolled Head Start and Early Head Start children. In some cases, particularly with very young infants, the training may be primarily parent-directed. Year-round programs generally have a program year begin and end date that may be designated according to local school year, program funding year, annual PIR year, etc., and this date can be used to plan training within the first 30 days of the program year.
Requirement
45 CFR 1310.21(a)
June 26, 2007
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L – 009 Can children be on a bus for more than one hour when being transported to and from the program?
OHS – PC – L – 009
Can children be on a bus for more than one hour when being transported to and from the program?
Yes. The time a child is in transit to and from the Head Start or Early Head Start program must not exceed one hour unless there is no shorter route available or any alternative shorter route is either unsafe or impractical. Each agency providing transportation services must ensure that in planning fixed routes the safety of the children being transported is the primary consideration. Programs should make every attempt to minimize time spent in transit for children. Programs must establish procedures for making exceptions and a record of the exception rationale and decision must be kept in each affected child’s file.
Requirement
45 CFR 1320(a)–(b)(1)
June 26, 2007
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L – 010 Can children be on the bus for more than one hour when being transported to and from dental and medical services?
OHS – PC – L – 010
Can children be on the bus for more than one hour when being transported to and from dental and medical services?
Yes. Dental and medical services are considered incidental trips. Incidental trips such as might be required to transport small groups of children to and from necessary services are excluded under the definition of Transportation Services (45 CFR 1310.3). However, programs are encouraged to use the safest mode of transportation available; i.e. school buses or allowable alternate vehicles, whenever children are in transport. Programs should make every attempt to minimize time spent in transit for children.
Requirement
45 CFR 1310.3
June 26, 2007
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L – 011 Are field trips considered a Transportation Service and, as such, subject to the requirements for the use of a school bus or allowable alternate vehicle, bus monitors, child restraint systems, etc.?
OHS – PC – L – 011
Are field trips considered a Transportation Service and, as such, subject to the requirements for the use of a school bus or allowable alternate vehicle, bus monitors, child restraint systems, etc.?
Yes. Transportation Services (45 CFR 1310.3) are defined in the regulation as "the planned transporting of children to and from sites where an agency provides services funded under the Head Start Act. Transportation services can involve the pick-up and discharge of children at regularly scheduled times and pre-arranged sites, including trips between children's homes and program settings." Field trips are pre-planned and pre-arranged, and children are receiving direct component services. (45 CFR 1306.3(c))
Requirement
45 CFR 1310.3; 45 CFR 1306.3(c)
June 26, 2007
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L – 012 Are programs obligated to transport parents upon request to and from Head Start/EHS centers?
OHS – PC – L – 012
Are programs obligated to transport parents upon request to and from Head Start/EHS centers?
Programs need to develop their own policies about transporting parents to and from the Head Start center. Such policies should consider whether the bus or transportation insurance allows for this. A parent needing transportation, for example, to participate in a socialization visit or to volunteer at the center may be provided such transportation. This transportation could be arranged by having the parent accompany his/her child on the bus or, if necessary, by having an employee drive to the parent’s home to pick up the parent and transport the parent to the center. Grantees are not mandated to provide such transportation, but are encouraged to do so when it will better enable the parent to participate in activities that are designed to improve the Head Start program and/or improve the parent’s ability to act as their child’s primary educator (for example, transporting a parent to attend an adult literacy class at the Head Start center).
Informal Guidance
July 3, 2007
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L – 013 Can program funds be used to reimburse families for mileage expenses to and from socialization activities in the home-based program option?
OHS – PC – L – 013
Can program funds be used to reimburse families for mileage expenses to and from socialization activities in the home-based program option?
Head Start agencies may use funds to reimburse families for transporting their children to and from socialization activities in the home-based program option.
Transportation services to children served under the home-based option for Head Start and Early Head Start services are excluded from the requirements of 45 CFR 1310.12, 1310.15(c), and 1310.16 related to the use of school buses and allowable alternate vehicles, child restraint systems, and bus monitors.
Requirement
45 CFR 1310.12; 1310.15(c); 1310.16
July 19, 2007
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L – 014 Can programs count, as non-federal share, the time spent by a parent walking his/her child to the Head Start center?
OHS – PC – L – 014
Can programs count, as non-federal share, the time spent by a parent walking his/her child to the Head Start center?
No. If a Head Start/Early Head Start program transports a Head Start child to a center, that child becomes Head Start’s responsibility from the time the child boards the bus. If a program is not providing transportation, the child becomes Head Start’s responsibility at the time the child enters the Head Start center. Any activities prior to either of these times is not considered to be part of the Head Start day and, therefore, not chargeable to the Head Start grant, as either federal or non-federal share.
Requirement
2 CFR 215.23(a); 45 CFR 92.24(a)
July 31, 2007
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L – 015 Please clarify if a program that does not offer any transportation services may count as non-federal share the costs incurred by parents in transporting their children to and from the Head Start center.
OHS – PC – L – 015
Please clarify if a program that does not offer any transportation services may count as non-federal share the costs incurred by parents in transporting their children to and from the Head Start center.
No. No center-based Head Start program may claim as non-federal share the costs for transporting Head Start children to and from the Head Start center unless these children are being transported on a vehicle that meets the requirements of 45 CFR Part 1310.12(a).
Requirement
45 CFR 1310.12(a); 2 CFR 215.23(a); 45 CFR 92.24(a)
September 26, 2007
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L – 016 Do programs providing transportation services for children enrolled in Combination Option need to meet the provision of the Head Start transportation regulations related to child safety restraint systems, bus monitors, and the use of school buses or allowable alternative vehicles?
OHS – PC – L – 016
Do programs providing transportation services for children enrolled in Combination Option need to meet the provision of the Head Start transportation regulations related to child safety restraint systems, bus monitors, and the use of school buses or allowable alternative vehicles?
Yes. Under 45CFR 1310.2, Applicability, the only transportation services currently excluded from the requirements of 45 CFR 1310.12, 1310.15(c), and 1310.16 are those provided to children enrolled in the home-based option.
Requirement
45 CFR 1310.2, Applicability
September 26, 2007
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L – 017 If a child enrolled in a center-based program has been transported to the center on a school bus and needs to be taken home because of head lice or illness because the parent does not have transportation, can a van be used to transport that child home?
OHS – PC – L – 017
If a child enrolled in a center-based program has been transported to the center on a school bus and needs to be taken home because of head lice or illness because the parent does not have transportation, can a van be used to transport that child home?
Yes. Under the definition of transportation services, this would be considered incidental transportation. Programs should take care to be certain all applicable federal, state and local safety laws are followed, including those related to the use of child safety restraint systems.
Requirement
45 CFR 1310.3
September 26, 2007
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L – 018 Do high-back school bus seats alone meet the requirements for "child restraint systems" for transporting children ages three to five years?
OHS – PC – L – 018
Do high-back school bus seats alone meet the requirements for "child restraint systems" for transporting children ages three to five years?
No. High-back school bus seats alone do not meet the requirement for the use of child restraint systems. Very young children do not receive adequate protection from this type of compartmentalization and therefore must be seated in FMVSS approved child restraint systems.
Requirement
45 CFR 1310.3; 49 CFR 571.213
September 26, 2007
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L – 019 Does the requirement that the seat behind the Head Start child either be unoccupied or that the occupants of that seat be restrained apply to the use of all child restraint systems?
OHS – PC – L – 019
Does the requirement that the seat behind the Head Start child either be unoccupied or that the occupants of that seat be restrained apply to the use of all child restraint systems?
No. The requirement that the seat behind the Head Start child either be unoccupied or have restrained occupants applies only in those situations where Head Start children are seated in harness-style child restraint systems that attach directly to the seat back. See 49 CFR Part 571 (Federal Motor Vehicle Safety Standards) Standard No. 213, Child restraint systems, S5.6.1.11.
Requirement
49 CFR Part 571 (Federal Motor Vehicle Safety Standards) Standard No. 213, Child restraint systems, S5.6.1.11
September 26, 2007
Revised October 10, 2007
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L – 020 If our program does not provide transportation to one of our sites for children without disabilities, must we provide transportation to that site for children with disabilities?
OHS – PC – L – 020
If our program does not provide transportation to one of our sites for children without disabilities, must we provide transportation to that site for children with disabilities?
When a child’s participation in Head Start is part of their Individualized Education Program (IEP), the IEP should include transportation as a related service if transportation is necessary to enable the child’s participation (45CFR 1308.4(o)(5). Head Start funds may be used to provide this transportation, even if this service is not typically provided to children at that site. The local education agency (LEA) responsible for assuring free and appropriate public education (FAPE) must assure that services outlined in the IEP are provided, and this LEA may also provide or support the transportation costs. The general responsibilities and resources for providing transportation to a child with a disability enrolled in Head Start should be addressed in your program’s local interagency disabilities services agreement with your LEA partner. Head Start regulations require programs to plan their collaboration with LEAs so that children with disabilities enrolled in Head Start will receive services they need (1308.4(h)(6)).
Requirement
45 CFR 1308.4(o)(5); 1308.4(h)(6)
October 10, 2007
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L – 021 If Pedestrian Safety Training is provided to parents and children within the first 30 days of the program year – is the program required to provide the same, on an individual basis, for all late enrollees?
OHS – PC – L – 021
If Pedestrian Safety Training is provided to parents and children within the first 30 days of the program year – is the program required to provide the same, on an individual basis, for all late enrollees?
Children who are late enrollees in Head Start and Early Head Start have the same need for transportation and pedestrian safety education as do those who begin services at the start of the program year. The purpose of the requirement that each agency provide transportation and pedestrian safety education of children and parents within the first 30 days of the program year is to assure that children and their families have the tools they need to keep them safe as soon as possible after program entry. Programs provide ongoing education in these areas and should plan and implement individualized training for new enrollees and their families within 30 days of enrollment.
Requirement
45 CFR 1310.21(a)
April 29, 2008
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L – 022 If a bus monitor leaves the bus to pick up or deliver a child to their home or center, does this create a child/monitor ratio problem on the bus even if the driver is still on the bus? If a parent has a disability and is unable to bring their child to the curb for transportation pickup, can we refuse to provide transportation?
OHS – PC – L – 022
If a bus monitor leaves the bus to pick up or deliver a child to their home or center, does this create a child/monitor ratio problem on the bus even if the driver is still on the bus? If a parent has a disability and is unable to bring their child to the curb for transportation pickup, can we refuse to provide transportation?
Safety is the first consideration when transporting Head Start children. It is assumed that the bus is parked when children are coming to and from the vehicle. Programs must have procedures that include teaching staff and parents the use of effective pedestrian safety practices to escort children to and from the bus.
Occasionally, it may be necessary for the bus monitor to escort the child/ren to and from the bus and their home or center. In those circumstances, children on the vehicle are under the supervision of the bus driver and secured in appropriate child restraint systems, and the bus monitor is within sight and sound of the vehicle.
Transportation services cannot be refused due to a parent's inability to bring their child to the door of the vehicle. Every effort should be made to accommodate the transportation needs of children and families.
Requirement
45 CFR 1310.20
June 17, 2008
L – 023 What restraint requirements must be met for a child weighing over 50 pounds riding a Head Start school bus?
OHS – PC – L – 023
What restraint requirements must be met for a child weighing over 50 pounds riding a Head Start school bus?
Head Start Program Performance Standard 45 CFR 1310.11(a) states:
Effective June 21, 2004, each agency providing transportation services must ensure that each vehicle used to transport children receiving such services is equipped for use of height- and weight-appropriate child safety restraint systems.
This Standard is available online on the Early Childhood Learning and Knowledge Center (ECLKC) web site at: http://eclkc.ohs.acf.hhs.gov/hslc/Program Design and Management/Head Start Requirements/Head Start Requirements/1310/1310.11 Child Restraint Systems..htm
Information regarding the proper use of child safety restraint systems is available online at: http://eclkc.ohs.acf.hhs.gov/hslc/Program Design and Management/Transportation/Transportation PathFinder?menu=VIEW&Act=NHTSA&id=4&title=Proper Use of Child Safety Restraint Systems in School Buses
Requirement
45 CFR 1310.11(a)
August 11, 2008
Revised August 18, 2008
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