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J - Staffing Requirements and Program
Options
J – 001 What is a degree in
a related field?
J – 002 If a Head Start agency
experiences an event such as a severe hurricane or tornado, that disrupts the
ability of the program to operate for a significant amount of time, can the
grantee apply for a compliance waiver of the requirement for 128 (or 160) days
of class operations per year?
J – 003 Is there
a policy on the length of time that teachers in a center-based program should
spend on a home visit? Similarly, is there a policy on the length of time of a
socialization activity in a home-based program?
J –
004 Do Family Child Care providers delivering Head Start services through
a partnership agreement with a Head Start grantee need to meet the teacher
credentialing requirements outlined in the Head Start Act for teachers in a
center based program?
J – 005 What is meant by
the term "regular volunteer" as specified in the Head Start Program Performance
Standard regarding tuberculin screening?
J –
006 If a State imposes a requirement that individuals must be
fingerprinted in order to complete a criminal background check, do all potential
Head Start new hires have to comply?
J – 007 We
have some parents who sometimes volunteer in the classroom by helping the
teachers with whatever is necessary. In essence they are doing the job of an
"Assistant Teacher". Does the regulation require these volunteers to specify
exactly what they did, i.e. read a story, cleaned up after lunch, prepared the
cots for naptime etc. or can they just put it down as "Teacher’s
Assistant"?
J – 008 If a Head Start program is
collaborating with a pre-K program, and classrooms include both Head Start and
pre-K children, can a program operate a double session model and enroll 20
children in both the morning and afternoon sessions?
J – 009 Who is qualified to provide dental preventive
services?
J – 010 If a parent has a teaching
certificate from another country can the non-federal share be matched at the
teaching wage when volunteering in the classroom?
J –
011 State daycare rules and Head Start’s rules sometimes differ. Which
rule must Head Start programs comply with? Why?
J –
012 Are Head Start programs required to provide free meals to assigned
classroom staff and volunteers?
J – 013 To
ensure we meet the goal of having 50% of our teachers with an AA or BA in
education, our program has emphasized teaching staff pursuit of the AA or BA
degree. We have staff enrolled in BA programs that have the "equivalent" of an
AA degree (i.e. enough units/credits to constitute an AA). Can staff in pursuit
of the BA who have enough credits to constitute an AA (but no AA
diploma/certificate) count as qualified teaching staff?
J – 014 What should the content of child abuse training for
Head Start staff include? Who should conduct the training? Who should receive
the training?
J – 015 What is the minimum
number of days for an Early Head Start program?
J –
016 Can a Head Start program exceed the class size limitations of 1306.32
if additional classroom staff is made available?
J –
017 Can Head Start funds be used to pay parents’ admission to, say, a
museum as part of a field trip for which the parent has
volunteered?
J – 018 If a center-based program
enrolls a child with only a few months remaining in the program year, is the
program still required to have two home visits and two parent-teacher
conferences?
J – 019 If a program employs as a
teacher assistant a Head Start parent with a CDA, can they promote that person
to the position of teacher?
J – 020 Can a Head
Start program require teachers to pursue their AA/BA degree to meet the mandate
and will the agency have to pay overtime if the teachers attend school after
work?
J – 021 Can two children share a slot
(i.e. one child attends Head Start for three days a week and the other child for
the remaining two days)? Would it be appropriate for a classroom to have more
than 20 children on its roster if the schedule were planned so that there were
never more than 20 children in the classroom at the same time?
J – 022 In 1306.33(b) "Home visits must be conducted by
trained home visitors with the content of the visit jointly planned by the home
visitor and the parents." In this case, please define "parent." We have several
non-traditional families in which the significant person in the child's life may
not be a biological or adoptive parent. Two specific cases we currently have
include a lesbian couple who have adopted a baby, in which only one mother's
name is on the birth certificate, yet they both are the child's "parents." Does
a home visit count if it is with the mother who is not on the birth certificate?
Another example is a significant other that the mother has been with for many
years. The man is not the child's biological father and they are not married,
yet they both feel that they are the child's "parents." Does a home visit count
if it is with this person?
J – 023 Do children
need to be present at EHS/HS educational home visits?
J – 024 Do children need to be present at EHS parent
conferences?
J – 025 Can staff enrolled in a
program that will result in a BA degree in ECE who have enough credits to
constitute an AA degree, but have no AA diploma, be counted as eligible
teachers?
J – 026 In the home-based option, are
children and parents required to attend all "socializations" unless a valid
reason for absence is documented?
J – 027 Do
the Head Start teacher requirements apply on days that the regular classroom
teacher is absent?
J – 028 I have a parent who
is refusing a Home Visit and lives within walking distance of our program. She
even went as far as sending us a notarized letter stating that she is forbidding
any Head Start staff from coming to her house although we have explained the
Head Start mandate on Home Visits and the benefits of a Home Visit. Can this
child still be in Head Start? Are Home Visits required? What if we do not have
the required two home visits on this child?
J –
029 Is there any policy regarding a home-based family who never attends
socializations?
J – 030 Are home-based visit
reports required with a parent signature?
J –
031 The Head Start Reauthorization memorandum refers to Teacher Assistants.
What is the definition for Teacher Assistant, please? Is it different from
Teacher Aide, or the same thing?
J – 032 When
are Head Start agencies required to ensure teachers pay back financial
assistance if the teacher leaves before teaching for 3 years after receiving a
degree?
J – 033 The new Head Start Act states
that Early Head Start (EHS) teachers must have “a minimum of a child development
associate credential, and have been trained in early childhood development” and
that “teachers have been trained in early childhood development with focus on
infant and toddler development”. The teachers in our EHS program all have a BS
in Early Childhood Education or a closely related field, such as child
development. In addition to this, all staff who do not have documented training
in infant/toddler development are required to take an infant/toddler development
course. Since a BS is a more advanced degree than a CDA are our teachers still
required to obtain a CDA in addition to their BS?
J –
034 I am a Program Manager. I would like clarification on the
reauthorization requirement that states if teachers receive financial assistance
for college that they must agree to work for 3 years or repay. Does this just
refer to teachers who are earning their Bachelors or Associates degree
also?
J – 035 Do you have to have an associate’s
degree to teach Head Start?
J – 036 Realizing
that it will take some time before everyone is familiar with all the details of
the re-authorization act passed in December, I have a specific question
regarding staff credentials for EHS teachers. The reauthorization indicates that
all EHS instructional personnel must have, at a minimum, their Child Development
Associate credential. It furthers states that:
- Nationally, 50% of HS teachers to have B.S. by 9/30/13
- Classrooms w/o B.S.-qualified teacher must have AA by 9/30/11
Are
these two provisions specifically required of Head Start teachers? Are they also
required of EHS teachers? The regulations and all subsequent communications do
not clearly articulate the differences. As a stand-alone EHS grantee, we need to
know what applies only to EHS and what applies to both EHS and HS.
J – 037 Under the section on "Staff qualifications and
training", there are references to EHS and HS teachers, but I wasn't sure if
there were instances where reference to HS teachers may relate to both EHS and
HS teachers. E.g., When it indicates that "all Head Start teachers must, by
October 1, 2011, have at least an AA degree..." does this read as HS only, or
imply EHS teachers as well? Thank you.
J –
038 Do we make our own criminal records check policy or follow state
law?
J – 039 Is a name check okay or must
fingerprinting be done for criminal records checks?
J
– 040 Do parent/teacher conference days and teacher home visit days count
toward the planned days of service per year requirements?
J – 041 Can home visits begin on the first day of the program
year?
J – 042 If a family’s weekly home visit is
scheduled for the same day as socialization and the family attends the
socialization, can their attendance at the socialization also be counted as a
weekly home-visit?
J – 043 What is the Teach For
America program referred to in the December 12, 2007 amendments to the Head
Start Act, Section 648A(a)(3) Alternative Credentialing and Degree
Requirements?
J – 001 What is a degree in a related field?
OHS – PC – J – 001What is a degree in a related field?
This Policy Clarification is currently under review. 
J – 002 If a Head Start agency experiences an event such as a severe hurricane or tornado, that disrupts the ability of the program to operate for a significant amount of time, can the grantee apply for a compliance waiver of the requirement for 128 (or 160) days of class operations per year?
OHS – PC – J – 002If a Head Start agency experiences an event such as a severe hurricane or tornado, that disrupts the ability of the program to operate for a significant amount of time, can the grantee apply for a compliance waiver of the requirement for 128 (or 160) days of class operations per year?
Yes. In accordance with 45 CFR 1306.36, a Head Start agency may apply for a compliance waiver to the Director of the Office of Head Start. The request should describe the efforts made by the grantee to comply with the "number of days" requirement, an explanation of why compliance is not currently possible, and the grantee’s plans to assure it will be able to meet Head Start standards in its next program year. The request should be accompanied by relevant supporting evidence, and a copy of the entire request should be sent through your Regional Office Program Manager.
Requirement
45 CFR 1306.36
April 25, 2007
J – 003 Is there a policy on the length of time that teachers in a center-based program should spend on a home visit? Similarly, is there a policy on the length of time of a socialization activity in a home-based program?
OHS – PC – J – 003 Is there a policy on the length of time that teachers in a center-based program should spend on a home visit? Similarly, is there a policy on the length of time of a socialization activity in a home-based program?
There are no mandated time requirements for either of the two activities noted above.
However, when teachers schedule the two required home visits to each enrolled child’s family, they should allow sufficient time to learn about the child's family and allow adequate time for parents to ask questions about the program and inquire about their child's participation. While it seems reasonable that most home visits conducted by teachers could be done in sixty - ninety minutes, teachers need to be responsive and flexible to families' needs during the time of the visit.
When scheduling the required socialization activities for children enrolled in home-based programs (at least two such activities per month must be provided) programs are encouraged to schedule these for a period of approximately 3 ½ hours. This will afford the grantee ample time to plan and implement meaningful activities for both the parents and children.
Programs are encouraged to discuss their plans to meet these requirements with their Policy Council (Committee).
Informal Guidance
May 23, 2007
J – 004 Do Family Child Care providers delivering Head Start services through a partnership agreement with a Head Start grantee need to meet the teacher credentialing requirements outlined in the Head Start Act for teachers in a center based program?
OHS – PC – J – 004 Do Family Child Care providers delivering Head Start services through a partnership agreement with a Head Start grantee need to meet the teacher credentialing requirements outlined in the Head Start Act for teachers in a center based program?
This Policy Clarification is currently under review.
J – 005 What is meant by the term "regular volunteer" as specified in the Head Start Program Performance Standard regarding tuberculin screening?
OHS – PC – J – 005 What is meant by the term "regular volunteer" as specified in the Head Start Program Performance Standard regarding tuberculin screening?
If State, Tribal or local law does not include a definition for "regular volunteers", the Head Start program is expected to establish policy or procedures covering "regular volunteer" requirements locally. 45 CFR 1304.52(j)(2) requires that "regular volunteers must be screened for tuberculosis in accordance with State, Tribal, or local laws. In the absence of State, Tribal or local law, the Health Services Advisory Committee must be consulted regarding the need for such screenings". 45 CFR 1304.3(a)(20) defines a volunteer as "an unpaid person who is trained to assist in implementing ongoing program activities on a regular basis under the supervision of a staff person…"
Requirement
45 CFR 1304.52(j)(2); 45 CFR 1304.3(a)(20)
June 19, 2007
J – 006 If a State imposes a requirement that individuals must be fingerprinted in order to complete a criminal background check, do all potential Head Start new hires have to comply?
OHS – PC – J – 006 If a State imposes a requirement that individuals must be fingerprinted in order to complete a criminal background check, do all potential Head Start new hires have to comply?
Please refer to ACF-PI-HS-08-04.
Requirement
Section 648A(g) of the Head Start Act
June 26, 2007
Revised October 10, 2007
Revised September 24, 2008
J – 007 We have some parents who sometimes volunteer in the classroom by helping the teachers with whatever is necessary. In essence they are doing the job of an "Assistant Teacher". Does the regulation require these volunteers to specify exactly what they did, i.e. read a story, cleaned up after lunch, prepared the cots for naptime etc. or can they just put it down as "Teacher’s Assistant"?
OHS – PC – J – 007 We have some parents who sometimes volunteer in the classroom by helping the teachers with whatever is necessary. In essence they are doing the job of an "Assistant Teacher". Does the regulation require these volunteers to specify exactly what they did, i.e. read a story, cleaned up after lunch, prepared the cots for naptime etc. or can they just put it down as "Teacher’s Assistant"?
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
J – 008 If a Head Start program is collaborating with a pre-K program, and classrooms include both Head Start and pre-K children, can a program operate a double session model and enroll 20 children in both the morning and afternoon sessions?
OHS – PC – J – 008 If a Head Start program is collaborating with a pre-K program, and classrooms include both Head Start and pre-K children, can a program operate a double session model and enroll 20 children in both the morning and afternoon sessions?
No. A Head Start program operating a double session model in which any Head Start children are being served cannot enroll more than 17 children in a class (15 in a three year old class), irrespective of how many of the children in the class are Head Start enrollees. However, programs may, consistent with the provisions of 1306.36, request a waiver of this requirement. Such a waiver should be submitted to your OHS Regional Office.
Requirement
45 CFR 1306.3(g); 1306.32(a)(4) and (a)(6); 1306.36
July 3, 2007
J – 009 Who is qualified to provide dental preventive services?
OHS – PC – J – 009 Who is qualified to provide dental preventive services?
Each State determines those qualifications necessary for the provision of preventive dental services. Programs should consult with their State Health Agency to determine the requirements in their State.
Requirement
45 CFR 1304.20(a)(1)(iii)
July 13, 2007
J – 010 If a parent has a teaching certificate from another country can the non-federal share be matched at the teaching wage when volunteering in the classroom?
OHS – PC – J – 010 If a parent has a teaching certificate from another country can the non-federal share be matched at the teaching wage when volunteering in the classroom?
No. To value a volunteer’s time at the rate of a professional position would require that individual meet the minimum requirements of that position; in this case to have at least a CDA.
Informal Guidance
July 13, 2007
J – 011 State daycare rules and Head Start’s rules sometimes differ. Which rule must Head Start programs comply with? Why?
OHS – PC – J – 011 State daycare rules and Head Start’s rules sometimes differ. Which rule must Head Start programs comply with? Why?
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
J – 012 Are Head Start programs required to provide free meals to assigned classroom staff and volunteers?
OHS – PC – J – 012 Are Head Start programs required to provide free meals to assigned classroom staff and volunteers?
Yes. Since the Head Start Program Performance Standard 1304.23(c)(4) requires assigned classroom staff and volunteers to eat together with children, family style, programs must pay for their meals.
Informal Guidance
July 13, 2007
J – 013 To ensure we meet the goal of having 50% of our teachers with an AA or BA in education, our program has emphasized teaching staff pursuit of the AA or BA degree. We have staff enrolled in BA programs that have the "equivalent" of an AA degree (i.e. enough units/credits to constitute an AA). Can staff in pursuit of the BA who have enough credits to constitute an AA (but no AA diploma/certificate) count as qualified teaching staff?
OHS – PC – J – 013 To ensure we meet the goal of having 50% of our teachers with an AA or BA in education, our program has emphasized teaching staff pursuit of the AA or BA degree. We have staff enrolled in BA programs that have the "equivalent" of an AA degree (i.e. enough units/credits to constitute an AA). Can staff in pursuit of the BA who have enough credits to constitute an AA (but no AA diploma/certificate) count as qualified teaching staff?
Please refer to ACF-IM-HS-08-12.
Requirement
Section 648A of the Head Start Act
July 19, 2007
Revised September 24, 2008
J – 014 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 – J – 014 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
J – 015 What is the minimum number of days for an Early Head Start program?
OHS – PC – J – 015 What is the minimum number of days for an Early Head Start program?
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
J – 016 Can a Head Start program exceed the class size limitations of 1306.32 if additional classroom staff is made available?
OHS – PC – J – 016 Can a Head Start program exceed the class size limitations of 1306.32 if additional classroom staff is made available?
A grantee may request a waiver of the class size requirement. Any such request should be sent to the Director of the Office of Head Start, with a copy to your Regional Office, with a detailed explanation as to why a waiver is being requested. Absent an approved waiver, a grantee may not exceed Head Start’s class size requirements.
Requirement
45 CFR 1306.32
August 8, 2007
J – 017 Can Head Start funds be used to pay parents’ admission to, say, a museum as part of a field trip for which the parent has volunteered?
OHS – PC – J – 017 Can Head Start funds be used to pay parents’ admission to, say, a museum as part of a field trip for which the parent has volunteered?
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
J – 018 If a center-based program enrolls a child with only a few months remaining in the program year, is the program still required to have two home visits and two parent-teacher conferences?
OHS – PC – J – 018If a center-based program enrolls a child with only a few months remaining in the program year, is the program still required to have two home visits and two parent-teacher conferences?
Programs should make every attempt to work out a schedule with the enrolled child’s parents to assure both, two home visits and two parent-teacher conferences are held. If this proves not possible, programs need to document the reasons for this in the child’s folder.
Informal Guidance
September 17, 2007
J – 019 If a program employs as a teacher assistant a Head Start parent with a CDA, can they promote that person to the position of teacher?
OHS – PC – J – 019 If a program employs as a teacher assistant a Head Start parent with a CDA, can they promote that person to the position of teacher?
Currently, there is nothing in the Head Start statute that would preclude a program from hiring an individual who has only a CDA credential (i.e. no ECE degree) as a teacher. Should Head Start requirements change in terms of teacher qualifications, that teacher, as, of course, all other teachers would have to meet those new requirements.
Informal Guidance
September 17, 2007
J – 020 Can a Head Start program require teachers to pursue their AA/BA degree to meet the mandate and will the agency have to pay overtime if the teachers attend school after work?
OHS – PC – J – 020Can a Head Start program require teachers to pursue their AA/BA degree to meet the mandate and will the agency have to pay overtime if the teachers attend school after work?
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
J – 021 Can two children share a slot (i.e. one child attends Head Start for three days a week and the other child for the remaining two days)? Would it be appropriate for a classroom to have more than 20 children on its roster if the schedule were planned so that there were never more than 20 children in the classroom at the same time?
OHS – PC – J – 021 Can two children share a slot (i.e. one child attends Head Start for three days a week and the other child for the remaining two days)? Would it be appropriate for a classroom to have more than 20 children on its roster if the schedule were planned so that there were never more than 20 children in the classroom at the same time?
In general, such a practice would be neither developmentally appropriate nor consistent with the requirements of 45 CFR 1306.32. Most children enrolled in Head Start are expected to participate in the full schedule of Head Start classroom activities offered. The only reference to a shared enrollment slot in the Head Start Program Performance Standards occurs in 45 CFR 1308.4(j)(4) which requires programs to plan their services so they could accommodate reduced schedules prescribed by individualized education programs (IEPs) for some children with disabilities.
In these special circumstances, it may be allowable to have more than 20 children on a classroom’s roster if, consistent with the provisions of 1306.36, the program requests and receives approval of a waiver. Such a waiver request should be submitted to your OHS Regional Office.
However, programs are not required to develop shared slots when children’s IEPs require part-time participation in a classroom. It is acceptable for an enrollment slot to be regarded as fully occupied by a child whose IEP calls for a part-time classroom schedule, recognizing that programs will often expend additional staff time to implement such individualized schedules.
Informal Guidance
October 10, 2007
J – 022 In 1306.33(b) "Home visits must be conducted by trained home visitors with the content of the visit jointly planned by the home visitor and the parents." In this case, please define "parent." We have several non-traditional families in which the significant person in the child's life may not be a biological or adoptive parent. Two specific cases we currently have include a lesbian couple who have adopted a baby, in which only one mother's name is on the birth certificate, yet they both are the child's "parents." Does a home visit count if it is with the mother who is not on the birth certificate? Another example is a significant other that the mother has been with for many years. The man is not the child's biological father and they are not married, yet they both feel that they are the child's "parents." Does a home visit count if it is with this person?
OHS – PC – J – 022 In 1306.33(b) "Home visits must be conducted by trained home visitors with the content of the visit jointly planned by the home visitor and the parents." In this case, please define "parent." We have several non-traditional families in which the significant person in the child's life may not be a biological or adoptive parent. Two specific cases we currently have include a lesbian couple who have adopted a baby, in which only one mother's name is on the birth certificate, yet they both are the child's "parents." Does a home visit count if it is with the mother who is not on the birth certificate? Another example is a significant other that the mother has been with for many years. The man is not the child's biological father and they are not married, yet they both feel that they are the child's "parents." Does a home visit count if it is with this person?
Head Start regulations at 45 CFR 1306.3 define "Head Start parent" as "a Head Start child’s mother or father, other family member who is a primary caregiver, foster parent, guardian or the person with whom the child has been placed for purposes of adoption pending a final adoption decree." Furthermore, 45 CFR 1304.3 defines "family," in part, as all persons "living in the same household who are (A) Supported by the income of the parent(s) or guardian(s) of the child enrolling or participating in the program." Both examples described above describe family circumstances encompassed by the Head Start definitions of "Head Start parent" and "family." Home visits must be conducted by trained home visitors and the content of such visits may be jointly planned by the home visitor and so-called non-traditional parents. Any other conclusion would result in the Head Start child and family not receiving full benefit of all available and required Head Start services.
Requirement
45 CFR 1306.3; 45 CFR 1304.3
October 10, 2007
J – 023 Do children need to be present at EHS/HS educational home visits?
OHS – PC – J – 023 Do children need to be present at EHS/HS educational home visits?
Head Start programs should in general work with all families to assure that children will be present during the home visit. However, there may be some occasions when the home visitor and parent decide that due to the sensitive nature of a particular issue to be discussed, the child should not be present. A child’s presence is not a requirement of any particular home visit and a home visit should not be canceled because of a child’s absence.
Informal Guidance
October 23, 2007
J – 024 Do children need to be present at EHS parent conferences?
OHS – PC – J – 024 Do children need to be present at EHS parent conferences?
Children do not need to be present at EHS parent conferences. A parent may certainly choose to bring the EHS child to such a conference and the program may encourage the child’s attendance if thought appropriate, but there is no requirement that the child attend a parent conference.
Informal Guidance
October 23, 2007
J – 025 Can staff enrolled in a program that will result in a BA degree in ECE who have enough credits to constitute an AA degree, but have no AA diploma, be counted as eligible teachers?
OHS – PC – J – 025 Can staff enrolled in a program that will result in a BA degree in ECE who have enough credits to constitute an AA degree, but have no AA diploma, be counted as eligible teachers?
No. Staff must have an AA degree (or other qualifying certificate). Having enough credits for an AA but not having an AA degree is not, by itself, qualifying.
Requirement
45 CFR 1306.21
November 6, 2007
J – 026 In the home-based option, are children and parents required to attend all "socializations" unless a valid reason for absence is documented?
OHS – PC – J – 026 In the home-based option, are children and parents required to attend all "socializations" unless a valid reason for absence is documented?
A Head Start program should contact a family that misses a socialization experience to determine the reasons. Programs should work with parents to help them understand that the socialization experience is an integral and important part of a home-based program design and it is important to attend as many meetings as possible. If the reasons for missing it relate to something the program is or is not doing (i.e. not providing transportation) the program should review its current practice to assure it is doing all it can to make it possible for families to attend. Children should not be disenrolled because of failure to attend socialization.
Informal Guidance
November 6, 2007
J – 027 Do the Head Start teacher requirements apply on days that the regular classroom teacher is absent?
OHS – PC – J – 027 Do the Head Start teacher requirements apply on days that the regular classroom teacher is absent?
Occasional absences due to unexpected sick leave do not require a Head Start program to hire a substitute with (as of this writing) a CDA or relevant college degree. However, if the regular teacher is going to be out of the classroom for an extended period of time (i.e. maternity leave), or on a regular and predictable basis (i.e. attending college on Tuesdays and Thursdays), the program would be expected to use a substitute that met the minimum teacher requirements in effect at the time. Programs are strongly encouraged to assure that at least some of their teacher assistants meet Head Start teacher requirements.
Informal Guidance
November 20, 2007
J – 028 I have a parent who is refusing a Home Visit and lives within walking distance of our program. She even went as far as sending us a notarized letter stating that she is forbidding any Head Start staff from coming to her house although we have explained the Head Start mandate on Home Visits and the benefits of a Home Visit. Can this child still be in Head Start? Are Home Visits required? What if we do not have the required two home visits on this child?
OHS – PC – J – 028I have a parent who is refusing a Home Visit and lives within walking distance of our program. She even went as far as sending us a notarized letter stating that she is forbidding any Head Start staff from coming to her house although we have explained the Head Start mandate on Home Visits and the benefits of a Home Visit. Can this child still be in Head Start? Are Home Visits required? What if we do not have the required two home visits on this child?
The purpose of home visits is to help parents and staff learn more about each other and the behavior and development of the children in the different environments, home and Head Start (HS) or Early Head Start (EHS). Hopefully, staff will gain an understanding of the family and home environment where the child lives, and the parents will gain an understanding of how they can maximize their roles as the first and most important educators of their children, and they will be able to work together to support the development of the child(ren).
Though HS and EHS programs are directed in 45 CFR 1304.40(i) to make two home visits a year to each child’s family, exceptions are made for parents who expressly forbid such visits. Parent participation in Early Head Start and Head Start cannot be a condition of the child’s participation, and children cannot be dropped from HS enrollment if their parents choose to not have home visits. In such cases, the HS program should continue to try to work with the parents, and look to increase the number of parent-teacher contacts to four, in place of the required two home visits and two parent-teacher contacts. These contacts can take place at the program site, or in other neutral places that afford some privacy, such as a library or a park.
Documentation of these efforts should be kept at the program to show that the program has done all it can to encourage the parent(s) to participate in home visits and/or four parent teacher contacts.
Requirement
45 CFR 1304.40(i) ; 45 CFR 1306.32(b)(8)
January 7, 2008
J – 029 Is there any policy regarding a home-based family who never attends socializations?
OHS – PC – J – 029Is there any policy regarding a home-based family who never attends socializations?
There is no Head Start regulation that can force parents to participate, nor any that allows a child to be dropped from the program due to lack of parent participation. You should assess the reasons contributing to the parent's non-participation and see what can be done to support attendance. The expectation regarding parent participation in group socializations and the benefits of that experience should be communicated to all families during recruitment, orientation, and ongoing parent education. (See related item OHS – PC – J – 026).
Informal Guidance
January 7, 2008
J – 030 Are home-based visit reports required with a parent signature?
OHS – PC – J – 030Are home-based visit reports required with a parent signature?
There is no specific Head Start requirement for parent signatures on home visit reports or forms. You should follow your local requirements for such procedures. It is recommended that programs maintain documentation of program services delivered to children and families.
Informal Guidance
January 7, 2008
J – 031 The Head Start Reauthorization memorandum refers to Teacher Assistants. What is the definition for Teacher Assistant, please? Is it different from Teacher Aide, or the same thing?
OHS – PC – J – 031The Head Start Reauthorization memorandum refers to Teacher Assistants. What is the definition for Teacher Assistant, please? Is it different from Teacher Aide, or the same thing?
The Head Start Act, as amended does not define "Teaching Assistant" but reading section 648A (a)(2)(B) as a whole makes clear that such individuals are center-based classroom staff involved in the education of children, but not required to meet the Head Start teacher qualification requirements. Therefore, there is no reason to distinguish between individuals some Head Start programs may call "Teaching Assistants" and others may call "Teacher Aides" or some other term. The important distinction is on the role of the individual in providing assistance to the Head Start teacher in the education of children in center-based classrooms, not on their job title.
Requirement
Sec. 648A(a)(2)(B) of the Head Start Act
January 22, 2008
J – 032 When are Head Start agencies required to ensure teachers pay back financial assistance if the teacher leaves before teaching for 3 years after receiving a degree?
OHS – PC – J – 032When are Head Start agencies required to ensure teachers pay back financial assistance if the teacher leaves before teaching for 3 years after receiving a degree?
As required by the statute, the Department will establish requirements concerning financial assistance for teachers to pursue a degree. When these requirements are issued, the Office of Head Start will alert grantees.
Requirement
Section 648A(a)(6) of the Head Start Act
February 12, 2008
J – 033 The new Head Start Act states that Early Head Start (EHS) teachers must have “a minimum of a child development associate credential, and have been trained in early childhood development” and that “teachers have been trained in early childhood development with focus on infant and toddler development”. The teachers in our EHS program all have a BS in Early Childhood Education or a closely related field, such as child development. In addition to this, all staff who do not have documented training in infant/toddler development are required to take an infant/toddler development course. Since a BS is a more advanced degree than a CDA are our teachers still required to obtain a CDA in addition to their BS?
OHS – PC – J – 033The new Head Start Act states that Early Head Start (EHS) teachers must have “a minimum of a child development associate credential, and have been trained in early childhood development” and that “teachers have been trained in early childhood development with focus on infant and toddler development”. The teachers in our EHS program all have a BS in Early Childhood Education or a closely related field, such as child development. In addition to this, all staff who do not have documented training in infant/toddler development are required to take an infant/toddler development course. Since a BS is a more advanced degree than a CDA are our teachers still required to obtain a CDA in addition to their BS?
If EHS teachers have a Bachelors degree in early child education or a related field, this would satisfy the requirement for a “minimum of a CDA.”
Requirement
Section 645A(h)(1) of the Head Start Act
April 29, 2008
J – 034 I am a Program Manager. I would like clarification on the reauthorization requirement that states if teachers receive financial assistance for college that they must agree to work for 3 years or repay. Does this just refer to teachers who are earning their Bachelors or Associates degree also?
OHS – PC – J – 034I am a Program Manager. I would like clarification on the reauthorization requirement that states if teachers receive financial assistance for college that they must agree to work for 3 years or repay. Does this just refer to teachers who are earning their Bachelors or Associates degree also?
The service requirements in Section 648A(a)(6)(A)(B) specifically refer to teachers who receive assistance to pursue baccalaureate or advanced degrees in early childhood education or a baccalaureate or advanced degree and coursework equivalent to a major related to early childhood education. It does not apply to teachers pursuing an Associates degree.
Requirement
Section 648A(a)(6)(A)(B) of the Head Start Act
April 29, 2008
J – 035 Do you have to have an associate’s degree to teach Head Start?
OHS – PC – J – 035Do you have to have an associate’s degree to teach Head Start?
There is currently (as of May, 2008) no requirement that an individual have an associate’s degree to be a Head Start teacher. However, on October 1, 2011 all Head Start programs must assure that every Head Start teacher has an associate’s degree in early childhood education (or a degree in a related field and coursework equivalent to a major relating to early childhood education with experience teaching preschool-age children) or have been granted a waiver to this requirement because the Head Start program can demonstrate they have attempted unsuccessfully to recruit individuals with a qualifying degree. If a waiver has been granted the Head Start program then must assure that each classroom has, at a minimum, a teacher with a CDA or a state awarded certificate for preschool teachers that meets or exceeds the requirements for a CDA.
Requirement
Section 648A(a)(2)(A), (3)(A), (3)(B), (4)(A), and (4)(B)
May 8, 2008
J – 036 Realizing that it will take some time before everyone is familiar with all the details of the re-authorization act passed in December, I have a specific question regarding staff credentials for EHS teachers. The reauthorization indicates that all EHS instructional personnel must have, at a minimum, their Child Development Associate credential. It furthers states that:
- Nationally, 50% of HS teachers to have B.S. by 9/30/13
- Classrooms w/o B.S.-qualified teacher must have AA by 9/30/11
Are these two provisions specifically required of Head Start teachers? Are they also required of EHS teachers? The regulations and all subsequent communications do not clearly articulate the differences. As a stand-alone EHS grantee, we need to know what applies only to EHS and what applies to both EHS and HS.
OHS – PC – J – 036Realizing that it will take some time before everyone is familiar with all the details of the re-authorization act passed in December, I have a specific question regarding staff credentials for EHS teachers. The reauthorization indicates that all EHS instructional personnel must have, at a minimum, their Child Development Associate credential. It furthers states that:
- Nationally, 50% of HS teachers to have B.S. by 9/30/13
- Classrooms w/o B.S.-qualified teacher must have AA by 9/30/11
Are these two provisions specifically required of Head Start teachers? Are they also required of EHS teachers? The regulations and all subsequent communications do not clearly articulate the differences. As a stand-alone EHS grantee, we need to know what applies only to EHS and what applies to both EHS and HS.
The requirements for Head Start teachers for Associates degrees by 9/30/2011 and nationally for 50% Bachelors degrees do not apply to Early Head Start teachers.
Requirement
Section 645A(h)
May 8, 2008
J – 037 Under the section on "Staff qualifications and training", there are references to EHS and HS teachers, but I wasn't sure if there were instances where reference to HS teachers may relate to both EHS and HS teachers. E.g., When it indicates that "all Head Start teachers must, by October 1, 2011, have at least an AA degree..." does this read as HS only, or imply EHS teachers as well? Thank you.
OHS – PC – J – 037Under the section on "Staff qualifications and training", there are references to EHS and HS teachers, but I wasn't sure if there were instances where reference to HS teachers may relate to both EHS and HS teachers. E.g., When it indicates that "all Head Start teachers must, by October 1, 2011, have at least an AA degree..." does this read as HS only, or imply EHS teachers as well? Thank you.
The requirements that by October 1, 2011 each Head Start classroom that does not have a teacher with a BA or advanced degree must have a teacher with an associate degree in early childhood education, or an associate degree in a related field and coursework equivalent to a major in early childhood education with experience teaching pre-school children does not apply to Early Head Start.
Current Head Start regulations require Early Head Start teachers to have a CDA credential for Infants and Toddler Caregivers within one year of hire as a teacher of infants and toddlers. By September 30, 2010, all Early Head Start teachers must have, at a minimum, a CDA credential and have been trained (or have equivalent coursework) in early childhood development. By September 30, 2012 all Early Head Start teachers must be trained (or have equivalent coursework) in early childhood development with a focus on infant and toddler development.
Requirement
Section 648A(a)(3)(B) and Section 645A of the Head Start Act
May 20, 2008
J – 038 Do we make our own criminal records check policy or follow state law?
OHS – PC – J – 038Do we make our own criminal records check policy or follow state law?
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
J – 039 Is a name check okay or must fingerprinting be done for criminal records checks?
OHS – PC – J – 039Is a name check okay or must fingerprinting be done for criminal records checks?
Head Start agencies may obtain either name-based criminal record checks or fingerprint-based criminal record checks 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
J – 040 Do parent/teacher conference days and teacher home visit days count toward the planned days of service per year requirements?
OHS – PC – J – 040Do parent/teacher conference days and teacher home visit days count toward the planned days of service per year requirements?
No. The number of planned days of service per year consists of “planned class operations.” Parent/teacher conferences and home visits are not “planned class operations” and therefore do not count toward the planned days of service requirements.
Requirement
45 CFR 1306.32(b)(3)
June 25, 2008
J – 041 Can home visits begin on the first day of the program year?
OHS – PC – J – 041Can home visits begin on the first day of the program year?
Yes, the Home Visits can begin on the first day of a Head Start or Early Head Start home based program, unless the parent does not consent.
Informal Guidance
July 31, 2008
J – 042 If a family’s weekly home visit is scheduled for the same day as socialization and the family attends the socialization, can their attendance at the socialization also be counted as a weekly home-visit?
OHS – PC – J – 042
If a family’s weekly home visit is scheduled for the same day as socialization and the family attends the socialization, can their attendance at the socialization also be counted as a weekly home-visit?
No. Since a Home Visit and Socialization are two distinct activities, and have different purposes, one cannot be a substitute for the other.
A Home Visit is an opportunity for the Home Visitor to work directly with the parent(s) while focusing on the parent(s) and child working together to promote the child’s progress. The purpose of the Home Visit is to help the parents improve their parenting skills and to assist them in the use of the home as the child’s primary learning environment.
A Socialization provides opportunities for the child to play with other children, for the parents to meet and socialize (build relationships), as well as to work with their own children. The primary purpose of Socialization is to emphasize peer group interactions through age-appropriate activities in a Head Start classroom, community facility, home or on a field trip.
Requirement
45 CFR 1306.33
July 31, 2008
J – 043 What is the Teach For America program referred to in the December 12, 2007 amendments to the Head Start Act, Section 648A(a)(3) Alternative Credentialing and Degree Requirements?
OHS – PC – J – 043
What is the Teach For America program referred to in the December 12, 2007 amendments to the Head Start Act, Section 648A(a)(3) Alternative Credentialing and Degree Requirements?
Teach For America (TFA) is a national organization that recruits outstanding college graduates and professionals who commit to teach two years in urban and rural public schools in the effort to eliminate educational inequity and expand educational opportunity. TFA’s website has extensive information about the program.
- How are TFA candidates qualified to apply for Head Start teacher positions?
The Head Start Act of 2007 establishes the following qualifications for an early childhood TFA teacher candidate:
- a baccalaureate degree in any field
- admission to the TFA program
- a passing score on a rigorous early childhood content exam, such as the Praxis II
- participation in a TFA summer training institute that includes teaching preschool
- continuation of ongoing professional development and support from TFA professional staff
- Are there costs for a Head Start program to hire a TFA candidate as a teacher?
There are some costs associated with TFA teachers. More information is available on TFA’s website, or by calling 202-552-2400.
- Do TFA teacher-candidates have hiring preference for Head Start teacher vacancies?
No. Head Start programs follow the same locally and legally required hiring procedures for TFA applicants that they do for all other teacher applicants.
- Do TFA teachers make a commitment to teach for a certain amount of time?
The TFA program requires a two-year commitment from corps members.
Informal Guidance
October 1, 2009
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