Head Start

A faith-based organization that is a Head Start program may use space in its facilities to provide Head Start services without removing religious art, icons, scriptures, or other religious symbols.

In addition, a faith-based Head Start program retains its authority over its internal governance, and it may retain religious terms in its organization’s name, select its board members on a religious basis, and include religious references in its organization’s mission statements and other governing documents.

Head Start grantees and delegate agencies may not engage in inherently religious activities, such as worship, religious instruction, or proselytizing, as part of the services they provide as Head Start programs. If a Head Start program conducts such activities, the activities must be offered separately, in time or location, from the Head Start program and participation must be voluntary.

Requirement

45 CFR 87.1

July 11, 2006

Head Start regulations preclude the charging of fees to parents for Head Start services. However, if a program incurs expenses to compensate employees for the caring of a child after the Head Start program has ended, parents may be charged a reasonable fee for “after care”. In all cases, fees should be collected by the program and not the employee who is providing "after care" services.

Requirement

45 CFR 1305.9; 42 USC 9840(b); 2 CFR 215.2(x); 45 CFR 92.25(b)

March 15, 2007

In regards to staff volunteering time there are three important considerations:

1. In order to be allowable as non-federal share a particular cost would have to be allowable as “federal share”. That is, these costs would have to be expended on an activity that is consistent with all relevant laws and regulations.
2. The activity being done by the Head Start staff must not in any way be part of the person’s job responsibilities.
3. The work must truly be voluntary; there can be no hint that the employee was in any way made to feel that there was no choice in the matter of volunteering. In addition, an employee cannot earn ‘comp’ time or other benefit in exchange for or as a reward for volunteering. 

If the three above conditions are met then a staff’s time as a volunteer engaged in an activity is allowable and can be claimed toward a grantee’s non-federal share, valued at a rate for the type of work being done, not necessarily at the employee’s Head Start salary. For example, the time of a Head Start teacher volunteering to help paint the outside of a Head Start center should be valued at the rate of a painter not of a teacher.

In terms of donating materials, the only types of materials that can be counted as non-federal share are those that the program could use grant funds to purchase. So for example, donated classroom supplies would be considered as allowable non-federal share. Clothing for Head Start children could not generally be counted as non-federal share, as Head Start grantees are not authorized to use grant funds to purchase clothing for routine use by Head Start enrolled children and families. However, there are situations where a Head Start child may need a change of clothes during program hours of operation, and if the agency has received donated clothes (including diapers) that are kept on hand for such situations, the value of the clothes could be counted as non-federal share.

Requirement

2 CFR 215.23(a); 2 CFR 215.23(c)-(d); 45 CFR 92.24

April 23, 2007

If a grantee owns a building that was not purchased with Head Start (or other federal) grant funds and is operating a Head Start program in that building, that grantee may calculate a ‘depreciation and use’ allowance for the building and include those costs as non-federal share. For example, a grantee is using a building that it owns to operate a Head Start program. The building is worth, say, $500,000 and has a 25 year useful life. The annual depreciation and use charge for this building is $20,000. The grantee, if Head Start was using the entire building, could include the $20,000 as non-federal share. If Head Start is occupying less than the whole building, the non-federal share would be calculated proportionately based on what percentage of the building was being used by Head Start.

Requirement

45 CFR 92.24(e); 2 CFR 215.23(g)

April 23, 2007

Head Start agencies may use Head Start funds to pay the costs of the agency’s membership in business, technical, professional, civic or community organizations. Such membership dues or fees should be included in the annual grant application or supplemental application subject to the review and approval of the Regional Office.

Expenditure of Head Start funds for the membership dues of individual agency staff may be allowable if an organization doesn’t accept agency memberships or, if an agency membership would be more expensive. In either case, the grantee would need to be able to demonstrate the advantages of an individual membership to the Head Start program. Any membership dues or fees should be included in the annual grant application or supplemental application subject to the review and approval of the Regional Office.

Requirement

2 CFR 215.23(a); 45 CFR 92.24(a)

April 23, 2007 
Revised July 31, 2007

If a Head Start child’s teacher (or home visitor) provides the child’s parents with written plans or guidance as to the types of activities that need to be done with the child at home in order to support the child’s Head Start experience these activities may, when fairly valued, be counted as non-federal share. The "countability" of the parent’s efforts hinge on doing things with the enrolled child that support the child’s Head Start experience, that are articulated by the teacher (or home visitor) and that support the curriculum used by the program. General parenting duties do not constitute activities that can be counted as non-federal share, unless these activities meet the requirements noted above. The valuation of the parent’s time should, unless a program can demonstrate otherwise, be valued at the rate of a teacher’s assistant.

Requirement

2 CFR 215.23(a); 45 CFR 92.24(a); 45 CFR 1304.40(e)(1); 45 CFR 1304.40(e)(3)

April 25, 2007

No. In accordance with 45 CFR 87.1(c) organizations that receive direct financial assistance from the Department of Health and Human Services, including the Office of Head Start, "may not engage in inherently religious activities, such as worship, religious instruction, or proselytization, as part of the programs or services funded with direct financial assistance from the Department."

Requirement

45 CFR 87.1(c)

April 26, 2007

No. The requirement pertains only to Head Start grantees.

This Policy Clarification is based on ACF-PI-HS-06-01 and the regulation below.

Requirement

45 CFR 74.25(c)(2); 45 CFR 92.30(d)(3)

May 8, 2007

Grantees are allowed to provide incentive payments to staff related to performance or achievement but only as part of incentive program established by the grantee in policy.

2CFR Part 230, Appendix B(8)(j) says, Incentive compensation to employees based on cost reduction or efficient performance, suggestion awards, safety awards etc. are allowable to the extent that the overall compensation is determined to be reasonable and such costs are paid or accrued pursuant to an agreement entered into in good faith between the organization and the employees before the services were rendered, or pursuant to an established plan followed by the organization so consistently as to imply, in effect, an agreement to make such payment.

The above regulation is applicable to private non-profit grantees. While there is no exact equivalent in 2CFR225, applicable to state, local and tribal governments, 2CFR225, Appendix B(8)(a)(1) says in part that to be allowable personal compensation cost must be reasonable ‘and conform(s) to the established policy of the governmental unit.’ Therefore the same principle would apply. The program must be established in grantees policies.

Thus, for example, an impromptu payment to staff (bonus) motivated by the fact that there is a Head Start budget surplus and staff have ‘done a good job’ would not be allowable. However, the kind of system described in the question would be an example of an allowable incentive payment as long as grantee policies, and probably most appropriately the personnel policies, describe the incentive program.

T/TA funds may be used for this purpose.

Requirement

2 CFR 230, Appendix B(8)(j) ; 2 CFR 225, Appendix B(8)(a)(1)

May 8, 2007

Yes. A graduation ceremony is an acceptable activity for a Head Start program to sponsor and it is permissible to use the Head Start center for such an event and for Head Start staff to participate in the graduation ceremony. However, it is important to note that Head Start grant funds may not be used to cover any of the costs of such an event (i.e. special clothing, refreshments, etc.). Programs can seek to get such items donated to the program or parents can raise funds through appropriate fund raising activities. However, the value of such donations cannot be claimed as non-Federal share.

Requirement

2 CFR 225, Appendix B(14); 2 CFR 230, Appendix B(14)

May 22, 2007
Revised July 15, 2008

Requirement

2 CFR 215.25(c)(6); 2 CFR 225, Appendix B(15); 2 CFR 230, Appendix B(15)(b); ACF Grants Policy Statement, Part II-1 (incorporated into terms and conditions of all Head Start grant awards)

May 22, 2007

Requirement

45 CFR 1305.2(f); 2 CFR 215.25(c)(6); 2 CFR 225, Appendix B(15); 2 CFR 230, Appendix B(15)(b); ACF Grants Policy Statement, Part II-1 (incorporated into terms and conditions of all Head Start grant awards)

June 12, 2007

Requirement

2 CFR 215.23(d); 45 CFR 92.24(c)

June 12, 2007

Requirement

2 CFR 215.23(h)(1); 45 CFR 92.24(e)

June 19, 2007

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

If fingerprinting is required in order to complete the criminal record check, all Head Start new hires in that State will have to comply.

Please Note: OHS is currently reviewing the criminal record check policy.

Requirement

Section 648A. (g) of the Head Start Act

June 26, 2007
Revised January 12, 2009

A Head Start grantee may permit a community organization, including a faith based organization, to use a Head Start facility (in which there is Federal interest) when it is not in use for Head Start purposes. For example, a community organization could be allowed to hold a class in the evening in a Head Start classroom. If there are costs to the grantee, such as heating, lighting or other utilities, OHS expects the Head Start grantee to collect reasonable compensation for those costs.

Informal Guidance

June 26, 2007

Requirement

45 CFR 1304.20(a)(1)(ii)(A)-(B); 45 CFR 1304.20(b)(5); 45 CFR 1304.20(c)(5)

July 3, 2007

Grantees which are units of local, state government or Tribal governments need to be guided by 45 CFR Part 92 and Private non-profit grantees and institutions of higher education need to be guided by 45 CFR Part 74.

If the small items mentioned above had an acquisition cost of less than $5,000 and the supplies, in aggregate, do not currently exceed $5,000 in fair market value, the grantee may use them in another federally funded program or sell the items and record the proceeds as program income to its Head Start grant. The manner of sale is not specified and given the likely value of the items described above, the garage sale or flea market would be acceptable. As with any financial transaction grantees must keep a record of the transaction, including a description of what was sold, for how much it sold and the bookkeeping entry of the program income.

In the case of equipment (an item with an acquisition cost of $5,000 or more and a useful life of at least one year) with a current fair market value of at least $5,000 the grantee may keep the equipment for use elsewhere as long as the federal government is reimbursed, at fair market value. If the equipment is no longer needed by the grantee, the Grants Officer of the ACF regional office originating the grant should be contacted for disposal instructions.

If the current fair market value is below $5,000, state, local or Tribal governments may retain, sell or otherwise dispose of such equipment with no further obligation to ACF. (45 CFR 92.32(e)(1)). Non-profit grantees may sell the equipment but the proceeds must be treated as program income to the Head Start grant and reported on final Financial Status Report (SF – 269) for the applicable budget period. If there is uncertainty as to the value of an item, it is always safest to request disposal instructions from the ACF Grants Officer.

Requirement

2 CFR 215.34(b)-(g); 2 CFR 215.35; 45 CFR 92.32(c); 45 CFR 92.32(e)-(f); 45 CFR 92.33

July 3, 2007

Informal Guidance

July 3, 2007

Yes, such a practice is acceptable. However, grantees need to carefully evaluate the cost effectiveness of such an approach. Where a grantee receives funding from multiple sources it is important in any such arrangement that the cost of this program be allocated over all of the benefiting programs in an equitable way using a documented methodology. Grantees must maintain records documenting how this (as well as other) shared costs are allocated among all parts of the organization that benefit from incurring the cost. Grantees must have a cost allocation system in place and the allocation should be based on actual cost. Many states and local governments, such as counties and local school districts, are self insured.

Informal Guidance

July 3, 2007

It would be sufficient to simply categorize the parent’s activity as ‘Teacher’s Assistant’, assuming there is a ‘Teacher Assistant’s’ job description maintained by the Head Start program. Grantees should use the same procedure for any of the jobs for which there are paid employees and, therefore, job descriptions. For volunteer activities for which there is not a job description, grantees that anticipate using those volunteer services on an ongoing basis should establish a position description for that volunteer activity and in the description explain the basis for arriving at the hourly compensation level that will be used for claiming non-federal share. For example, if a grantee twice a year has a volunteer Saturday Center Clean-up Day that grantee might create a position description for a maintenance worker (assuming it does not already have one) and describe the duties and basis for valuing the service. Then on the individual timesheets for all the volunteers the grantee would only have to put Activity: Maintenance Worker (Volunteer). When a grantee does not have a valid position description it will have to create individual documentation for a particular volunteer activity, including a description of the work, the basis for valuation etc. As an alternative to developing job descriptions for all of the volunteer donated activity, programs may choose to identify and describe the activity on the volunteer time sheet.

Grantees are reminded that irrespective of how they determine the type of work performed by the volunteer (and, therefore, its value to the program), the use of volunteer time as match must include the establishment of a wage scale based upon the grantee agency’s internal scale or prevailing wages in the area. All volunteer time needs to be carefully documented by time sheets with the hours recorded and be verifiable from the grantee’s records; i.e. the date, times and location of the volunteer service and corroborated by the signature of both the volunteer and the volunteer’s supervisor. Programs may choose to use a monthly time sheet for regular volunteers or daily time sheets for occasional volunteers.

Requirement

2 CFR 215.23(d), 45 CFR 92.24(c)(1)

July 3, 2007

The limitations on what can be counted as non-federal share is an issue of what would be an allowable cost to be charged to the Head Start grant. That is largely defined by the Head Start program performance standards which describe what a grantee is expected to provide in terms of services to children and families. A good gauge of whether something would be allowable as non-federal share is whether it could be justified as a federal cost charged to your grant. The purchase of clothing for children and families would not be an allowable use of federal funds (and therefore non-federal) because providing such an activity is beyond the scope of the purposes of the Head Start program. The language at 1304.40(b) is under the heading of "Accessing community services and resources" and is not meant to suggest that Head Start programs could use grant funds to directly provide such services or resources.

Please note: Donated clothing used for class room activities (e.g. dress-up time) or rain coats for use in inclement weather are examples of allowable in-kind contributions.

Requirement

2 CFR 215.23(a), 45 CFR 92.24(b)(7)

July 3, 2007

Grantees are expected to follow standard government procurement procedures and to solicit bid estimates from several potential contractors. However, there may occasionally be situations in which competitive bid procedures would not make sense given there is only one organization which produces the product needed by the grantee (i.e. a specific piece of software). In this situation grantees should clearly document the process they followed and explain on what basis they concluded that a sole source contract was appropriate. Grantees should discuss any such situation with their OHS Regional Office before making any non-competitive contract award.

Requirement

2 CFR 215.43; 2 CFR 215.44(e)(2); 45 CFR 92.36(d)(4); 45 CFR 92.36(g)(2)

July 13, 2007

If the Head Start program itself is conducting a fund raising effort or receives a donation these funds need to be considered as program income and your OHS Regional Office needs to be advised that your program has generated program income. Program income can only be used for purposes consistent with the Head Start grant and, therefore, could not be used, for example, to give Head Start children gift certificates.

However, if the fund raising was done by an entity other than the Head Start program; i.e. friends of ABC Head Start, then whatever monies were collected from the fund raising event could be used at the discretion of the entity doing the fund raising including, if so desired, giving Head Start children gift certificates. This entity could also use funds that were donated to it at its own discretion consistent, of course, with any applicable state or local requirements.

Requirement

2 CFR 225, Appendix A(C)(1); 2 CFR 230, Appendix A(A)(2)

July 13, 2007

Indirect costs are those costs which cannot be associated with only one program (funding source) in a grantee. Payroll costs, accounting costs, the salary of an executive director are examples of costs that benefit all the different programs in a grantee organization. To cover these costs grantees are given an indirect cost rate by the grantee’s cognizant federal agency (the agency that is the grantee’s largest source of federal funding). There is no direct relationship between indirect costs rates and Administrative/Development costs except that most (but not all; i.e. a nurse) items in an indirect cost pool are considered as administrative costs. However, irrespective of a grantee’s indirect cost rate, no grantee can incur development and administrative costs that exceed 15% of its total budget (federal and non-federal) unless the grantee has been given a waiver by OHS.

Requirement

2 CFR 225, Appendix A(F); 2 CFR 230, Appendix(C); 45 CFR 1301.32

July 13, 2007

No, federal dollars can only be used to provide those services required by Head Start statute or regulation to enrolled children and families.

Requirement

2 CFR 225, Appendix A(C)(1); 2 CFR 230, Appendix A(A)(2)

July 13, 2007

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

If State law or local requirements are more comprehensive or more stringent than federal requirements, State law or local requirements must be followed.

Requirement

45 CFR 1306.30(c)

July 13, 2007

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

2 CFR 225, Appendix A(C)(1); 2 CFR 230, Appendix A(A)(2); 45 CFR 1304.40(e)(2); 45 CFR 1306.33(c); 45 CFR 1310.12 ; 1310.15(c) ; and 1310.16

July 19, 2007

Head Start programs must seek all alternative sources of funding for the costs to provide enrolled children health services. Such sources could include Medicaid/EPSDT, CHIP or services provided by your community doctor at no or reduced cost to your program. However, when a program is unable to find alternative funding sources to cover the costs of all required health services, the program should use Head Start grant funds to cover these costs. This should be made clear in your annual budget submission or, as appropriate, in your budget revision request.

Requirement

45 CFR 1304.20(c)(5)

July 19, 2007

Yes, Head Start funds may be used to cover the costs of professional medical and dental services, including health insurance co-payment or deductible, for Head Start children but only when no other source of funding is available.

Requirement

45 CFR 1304.20(c)(5)

July 31, 2007

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(b)(7)

July 31, 2007

Head Start programs should strive to assure an equitable allocation of both non-federal share and administrative costs among Head Start and Early Head Start. However, grantees will be assessed for compliance with these requirements only against their total grant award (i.e. Head Start and Early Head Start).

Informal Guidance

July 31, 2007

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)(1); 45 CFR 1304.52(k)(3)(i)

July 31, 2007

Grant funds may not be obligated after the end of the annual budget period designated on the grant award. Consequently, the unobligated balance reflected on the final financial status report should, in most cases, be the same as the amount reported as unobligated on the second semiannual report. There may be circumstances, however, where the grantee, on further examination of its records, determines that it over/understated its unobligated balance on its second semiannual report. In such a case, the correct unobligated amount should be entered on the final report. It would not be necessary to amend the second semiannual report.

Grantees are reminded that they have the ability to liquidate obligations within ninety days of the end of their budget period.

Requirement

45 CFR 1304.51(h)(2)

August 8, 2007

All current Early Head Start programs were initially funded as part of a competitive process in which one of the requirements was that they operate a full year program; i.e. 48-52 weeks per year. Any grantee seeking to change the terms of that initial agreement would need to submit such a request to its OHS Regional Office. The Regional Office will, after conferring with OHS Headquarters, advise the grantee as to whether or not its request has been approved. Absent any explicit approval from the Regional Office, EHS services should be provided through, in effect, a full year model.

Informal Guidance

August 8, 2007

Yes. State pre-K funds, appropriated by the state legislature and not in any way tied to federal funds may be used as non-federal share in the Head Start grant, regardless of the fact that these state funds are being matched with Head Start grant funds.

Requirement

2 CFR 215.23(a); 45 CFR 92(b)(7)(iv)

August 8, 2007

Yes. Admission costs for a parent volunteer on a field trip are an allowable charge against the Head Start grant. Programs, however, are cautioned to be aware of potential cost implications related to having more parents along on a field trip than is necessary to assure appropriate oversight of the children on the field trip.

Requirement

2 CFR 225, Appendix A(C)(1); 2 CFR 230, Appendix A(A)(2)

August 8, 2007

If the activities are part of the Head Start program’s curriculum and if the home visitor has given the parent, in writing, instructions as to what that parent can do at home to better implement that program’s curriculum, such time can be counted as non-federal share.

Requirement

2 CFR 215.23(a); 45 CFR 92.24(a); 45 CFR 1304.40(e)(1)-(e)(3)

August 8, 2007

Yes. The 15% administrative cap applies to the total grant; i.e. the federal and non-federal share.

Requirement

45 CFR 1301.32(a); 2 CFR 225, Appendix A(D)(1); 2 CFR 230, Appendix A(A)(1)

September 17, 2007

If a Head Start program can demonstrate that it is to the program’s detriment to seek any particular reimbursement from another party, the program should submit a request to its responsible OHS Regional Office, with a detailed explanation, as to why they propose to not pursue that reimbursement.

Informal Guidance

September 17, 2007

All Head Start programs must meet Head Start’s non-federal share requirements; i.e. 20% of the total grant (or 25% of the federal grant). A program may or may not, at the program’s discretion, choose to include in its grant proposal more than the minimally required non-federal share, but there is no requirement to do so.

Informal Guidance

September 17, 2007

All Head Start grantee claims of non-federal share need to be reasonably documented and fairly valued. While there is not a specific requirement that a receipt accompany a donation, it is helpful for the program to have such a receipt in determining the donation’s value and a receipt will minimize the likelihood that the appropriateness of the grantee’s non-federal share will be called into question by an auditor or by the grantee’s OHS Regional Office.

Requirement

2 CFR 215.23(a)(1); 45 CFR 92.24(b)(6); 45 CFR 1304.51(h)

September 17, 2007

If a grantee determines that it will not need all of the funds for which it has budgeted, i.e., because of unexpected vacancies, the grantee may use these funds for other purposes related to its Head Start grant. The grantee must receive prior approval from its Regional Office only if it is proposing to use these funds to purchase any equipment valued at more than $25,000 or if it is proposing to use these funds in a manner that would substantially change the nature of its Head Start program (i.e., a change in program option). Any unspent grant funds as of the end of the grantee’s budget period are no longer available to the grantee without written permission from the grantee’s Regional Office.

Informal Guidance

September 26, 2007

This Policy Clarification is currently under review.

This Policy Clarification is currently under review.

Yes. A volunteer’s rate should be determined based on the nature of the work being done and the experience and education brought to the job by the volunteer. A program may include, in this valuation, a fringe benefit rate for the volunteer that is comparable to the grantee’s average fringe benefit rate.

Requirement

2 CFR 215.23(d); 45 CFR 92.24(c)

September 26, 2007

Yes. As discussed at Head Start regulation 45 CFR Part 1310.2(a), home-based programs are excluded from meeting the vehicle requirements of 45 CFR Part 1310.12(a). Therefore, children in home-based programs may be transported in vehicles other than a school bus or allowable alternate vehicle and the costs incurred by parents in transporting their children to socialization activities may be counted as non-federal share.

Requirement

2 CFR 215.23(a); 45 CFR 92.24(a); 45 CFR Part 1310.2(a); 45 CFR Part 1310.12(a)

September 26, 2007

No. While Head Start staff may not be paid wages that exceed those paid for comparable positions in the community, there is no corollary requirement that all Head Start staff must be paid the same wages as others in the community holding comparable positions.

Requirement

2 CFR 215.23(a); 45 CFR 92.24(a)

September 26, 2007

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

Yes, Head Start programs may reimburse staff for costs incurred in traveling to locations away from their normal duty station. The grantee’s policies in this regard should be clearly articulated and available to all staff.

Requirement

45 CFR 1301.31(a); 45 CFR 1301.31(a)(4); 45 CFR 1304.52(k)

September 26, 2007

Neither the Head Start Act nor the Head Start program’s regulations address the issue of whether a grantee can require an employee to pursue a degree as a condition of their employment, or the issue of whether a grantee must pay overtime to such an employee who is attending school after the work day. If a grantee is planning to require a teacher to pursue their AA/BA degree through an after-work program, OHS recommends that the grantee obtain legal advice on the requirements of Federal and state law applicable in such situations.

Informal Guidance

September 26, 2007
Revised September 21, 2009

This Policy Clarification is currently under review.

This Policy Clarification is currently under review.

Yes, grantee and delegate agencies often seek other public or private funding to expand services or assure the highest quality services to their Head Start children and families. A reasonable amount of staff time may be spent writing applications for these additional funds.

Requirement

2 CFR Part 225, Appendix A(C)(1)(a); 2 CFR Part 230, Appendix A(A)(2)(a)

November 6, 2007

No. A program should calculate the value of the time volunteered by a foster grandparent by determining a fair market rate for the type of work being done by the grandparent at the Head Start program (salary and fringe benefits) and subtracting from that rate the reimbursement being given that foster grandparent for the time he or she is volunteering at the Head Start program. A foster grandparent, for example, who is doing work that is valued at $10 per hour and whom is given a stipend equal to $1 per hour may be charged as non-federal share at a rate of $9 per hour.

Requirement

45 CFR 74.23; 45 CFR 92.24

November 6, 2007

Yes. The requirements of 45 CFR Part 1310 regarding the type of vehicle in which children must be transported do not apply to home-based programs. Therefore, children may be transported in vehicles other than school buses and allowable alternate vehicles and the costs of that transportation may be covered by the Head Start grant or, alternatively, be counted as non-federal share.

Requirement

45 CFR 1310

November 6, 2007

Yes, in that the books will be an important part of each child’s Head Start experience their value may be included as non-federal share.

Requirement

2 CFR 215.3

November 6, 2007

No. To be claimed as non-federal share a “parent volunteer” must be engaged in activities that are integral and necessary to a Head Start program. Simply having lunch is not such an activity; helping with the preparation of the lunch or assisting in other ways that benefit the children’s lunchtime experience can be counted as non-federal share.

Informal Guidance

November 6, 2007

Yes. Head Start grantees can incur reasonable costs related to informing the community about their Head Start program, including information on how interested parents can apply to have their child enrolled and how community members can volunteer their services.

Requirement

2 CFR 225, Appendix B; 2 CFR 230, Appendix B; 45 CFR 74.27(a); 45 CFR 92.22(b)

November 20, 2007

Yes. The hiring and firing of any staff member whose salary is paid primarily with Head Start grant funds (i.e. Head Start pays more than 50% of the individual’s salary) must be approved by the Policy Council.

Requirement

45 CFR 1304.50(d)(1)(x) and (xi)

November 20, 2007

Yes. Time spent by Policy Council members in training or conferences that are designed to enable them to better perform their responsibilities may be counted as non-federal share.

Informal Guidance

November 20, 2007

A reasonable amount of staff time spent applying for other grants to expand or improve Head Start services is an allowable Head Start grant cost. The conditions under which a grantee may engage in other forms of fund-raising are restricted. In this regard, grantees should refer to ACYF-PI-HS-06-06, Fund-raising, issued 5/10/2006. Funds from other grant awards or those obtained through permissible fund-raising activities do not have to be deducted from the original Head Start grant.

Requirement

2 CFR 225 and 230; 45 CFR 74.24; 45 CFR 92.25

November 20, 2007

Yes, Head Start grantees may allow their facilities to be used by local government authorities as polling sites in a general election.

Grantees that allow their facilities to be used for polling places in general elections are reminded that they must be careful not to violate any of the specific provisions of Section 656(b) restricting political activities. Section 656(b)(1) of the Head Start Act, 42 U.S.C. § 9851(b)(1), prohibits grantees from engaging in “(A) any partisan or nonpartisan political activity associated with a candidate, or contending faction or group, in an election for public or party office, or (B) any activity to provide voters or prospective voters with transportation to the polls or similar assistance in connection with any such election.” Under paragraph (b)(2), “No funds appropriated under this subchapter may be used to conduct voter registration activities. Nothing in this subchapter prohibits the availability of Head Start facilities during hours of operation for the use of any nonpartisan organization to increase the number of eligible citizens who register to vote in elections for Federal office.”

Requirement

Section 656(b)(1)(A)(B) and (2) of the Head Start Act [42 U.S.C. 9851]

February 11, 2008
Revised July 23, 2008
Revised July 28, 2008

The Head Start Act requires that criminal record checks be obtained as required by State, tribal, or Federal law so Head Start agencies may not establish their own policies.

Requirement

Section 648A(g) of the Head Start; 42 U.S.C. 9843A(g)

May 20, 2008

Head Start agencies may obtain either name-based criminal record checks or fingerprint-based criminal record check unless applicable State, tribal, or Federal law specifies one or the other. For either method, the Head Start agency must provide assurance that the identity of the individual employee subject to the criminal record check is verified. Head Start agencies may not require prospective employees to obtain their own criminal record checks because there would be no way to verify that the information contained on the record had not been altered.

Informal Guidance

May 20, 2008

Yes. If a Head Start agency decides to use electronic signatures, the Office of Head Start guidance is as follows: The use of electronic signatures should be documented in the organization’s written policies and procedures, and proper internal controls should be established to safeguard assets and reduce the risk of fraud or abuse. Those controls should include a clear segregation of duties to identify authorized personnel and limit access to the signature plate, die, key, stamp, electronic card, etc. Grantees should also refer to regulations 45 CFR 74.21 and 45 CFR 92.20 which describe standards for financial management systems.

Informal Guidance

June 30, 2008

This Policy Clarification is currently under review.

Yes. Because the Head Start Act defines specific circumstances when interest costs are allowed and because the Act takes precedence over regulations, Head Start grantees are only allowed to charge interest costs to a Head Start grant (either as federal share or as non-federal share) in two circumstances:

1. When purchasing vehicles for use in the Head Start program; and,
2. As a part of the costs of facilities projects when the grantee has submitted a request as described in 45 CFR 1309 and prior written approval has been given by OHS; this includes:
   1. Purchase of a facility (including modular buildings) for Head Start use.
   2. Construction of a facility for Head Start use.
   3. Major renovation of a facility for Head Start use.

Requirement

Sec. 644(f)(2) and 644(g)(2) of the Head Start Act

July 15, 2008

Yes. The use of funds for advertising costs which are solely for specific purposes necessary to meet the requirements of the Federal award are allowable. Maintaining full enrollment is a requirement of the grant award. Therefore using Head Start funds to place an ad for enrollment in local newspapers is an allowable cost since the ad is necessary to meet the requirements of the program.

Requirement

2 CFR 230 (OMB Circular A-122) Appendix B.1.c(4)

July 15, 2008

The Regional Office is responsible for the review and approval of the use of unobligated funds after a budget period ends. The grantee is responsible for the proper administration of all delegate agency funds. Each grantee should have a contract, MOU or similar agreement with each delegate agency that specifies policies and procedures for addressing budget changes. These agreements may include procedures for carryover requests specifying what documentation the grantee requires of delegates to explain why funds were unexpended and to explain how delegates can make a request to the grantee for the continued use of funds. After the grantee completes the review of the documentation, the grantee may submit a request to the Regional Office for approval. If the Regional Office approves the request, a Financial Assistance Award (FAA) authorizing the use of the funds will be issued.

Requirement

45 CFR Parts 74 and 92

July 21, 2008

Every Head Start grantee’s service area must be approved, in writing, by the responsible OHS official. Head Start regulations specify that service areas must be non-duplicating and non-overlapping. Before the Regional Office approves a new grant, the service area is checked to see that it is not duplicating and not overlapping with other Head Start grantees. Some exceptions to this requirement may be permitted for American Indian/Alaska Native (AIAN) grantees serving children in areas near reservations.

Informal Guidance

July 21, 2008

No. A grantee is required to submit a budget revision requesting prior approval when the cumulative transfers among direct cost budget categories would exceed 25 percent of the total approved budget (which includes direct and indirect costs, whether chargeable to Federal funds or required matching or cost sharing) for that budget period or $250,000, whichever is less.

Requirement

HHS Grants Policy Statement (GPS), Part II.

July 21, 2008

The time used to provide special education and/or related services by a therapist provided by a Local Education Agency (LEA) may be considered by the Head Start program as volunteer time for in-kind match purposes to the extent that part or all of the therapists pay is from non-federal sources. In that case, and assuming none of those non-federal resources are being used to match any other federal grant, the proportion of the therapist’s salary (and fringe benefits) coming from non-federal sources should be used to calculate the non-federal share that can be claimed for that therapist’s work in the Head Start program. Calculations on the value of the service must be consistent with the rate of a therapist with similar credentials and experience plus an appropriate amount of fringe benefits.

Requirement

45 CFR 74.23; 45 CFR 92.24; HHS Grants Policy Statement, II-49; 45 CFR 1308.4(h)(1-7), (i),(j)(1-5)

September 9, 2008
Revised September 10, 2008

A service which benefits a program or lends to the accomplishment of program objectives is considered an in-kind contribution. For example, a mother who is providing volunteer services in a classroom may be supporting young children in their learning. This contributes to the program objective of children increasing their interest in books, identifying letters, and reading. A person who baby-sits while the Head Start mother volunteers leads to accomplishing this goal for the program and may be considered an allowable in-kind cost.

Requirement

HHS Grants Policy Statement, II-48 and II-49; 45 CFR 74.23; 45 CFR 92.24; 2 CFR 230, Appendix B.12.

November 4, 2008

Parent involvement and participation in Head Start and Early Head Start programs are an integral function for the proper and efficient accomplishment of program objectives for all grantees. Parent involvement can be separated into two categories. There are activities that 1) primarily benefit the parent and their child; or 2) provide a good or service to benefit the program. A parent involvement activity that primarily benefits the parent and their child is not considered an allowable cost for an in-kind match. An activity that provides a good or service to benefit the program is considered an allowable cost for an in-kind match.

Examples of each category are provided below in this guidance. The list is not meant to be inclusive of all parent involvement activities but provides a sampling to illustrate the differences between the categories.

Parent involvement activities that primarily benefit the parent and child include items such as parent orientation; home visits including pre-natal, newborn or postpartum visits; staff-teacher conferences; socialization activities; parent education or training; meetings and activities related to family goal setting with the family partnership agreement; participation in specific activities that are related to a child’s developmental or educational plan, Individualized Family Service Plan or Individualized Education Plan; field trips; or transition meetings.

Examples of parent involvement activities that provide a good or service to benefit the program include participation in a health services advisory committee or other advisory committee; participating in outreach efforts for recruitment; participating in community partnerships with other parents or community members; supporting a lending library, health fair or other program activity; providing assistance in a classroom or on a field trip; reviewing menus for the program; or participating in an employment interview.

To determine if a parent involvement activity is allowable as an in-kind match a Head Start program should ask these questions:

1. Does the parent involvement activity primarily benefit the parent or child? If the answer is yes, then the activity is not allowable as an in-kind match.
2. Does the parent involvement activity provide a good or service to benefit the program? If the answer is yes, then the activity is allowable as an in-kind match.

Please also refer to OHS-PC-A-006

Requirement

Sections 640(b) and 642(b)(1)(2) and (3) of the Head Start Act; Head Start Program Performance Standards; 45 CFR 74.23(a) and (d); and 45 CFR 92.24(a) and (b)

May 15, 2009

Yes, Head Start agencies may claim non-federal match for the value of the volunteer services of governing body and policy council members.

Requirement

Sections 640(b) and 642(c)(1) and (2) of the Head Start Act; 45 CFR 74.23(a) and (d); and 45 CFR 92.24(a), (b) and (c)

May 26, 2009