Disclaimer: In light of the Omicron variant and the Vaccine and Mask Requirements to Mitigate the Spread of COVID-19 in Head Start Programs Interim Final Rule with Comment Period (IFC), the Office of Head Start (OHS) cautions that while majority of the information included in these FAQs remains factual, some pieces may no longer be accurate or up-to-date. For the most up to date guidance, please consult OHS COVID-19 Updates.

Flexibilities

We heard the public health emergency (PHE) declaration may be ending soon. What does that mean for programs?

On Jan. 27, 2020, the Secretary declared the COVID-19 pandemic a PHE. Once the declaration is made, it remains in effect for 90 days and can be extended. The latest extension was effective April 16, 2022, and will expire July 15, 2022. Current administrative and fiscal flexibilities that are tied to the PHE are applicable throughout its duration unless a finite expiration date is noted.

Regardless of whether the PHE declaration continues or ends, the IFC on mask and vaccine requirements remains in effect in non-enjoined states, as do the CDC recommendations on COVID-19 prevention.

What are the current administrative and fiscal flexibilities tied to the PHE?

For specific flexibilities, program should refer to ACF-IM-HS-21-01 Updated Coronavirus Disease 2019 (COVID-19) Fiscal and Administrative Flexibilities. The following provisions are tied to the PHE:

• Exemption of certain procurement requirements
• Extension of financial and other reporting
• Waivers and other flexibilities
  • Governing body approvals
  • Nonfederal match waivers
  • Administrative cost waivers

On March 29, 2022, OHS extended the prior approval waiver requirements to allow recipients to continue responding to COVID-19. Recipients may use funds from their current operating awards to respond to and recover from the impacts of COVID-19. Recipients may use the following waivers of prior approval requirements:

• Prior approval for the purchase of equipment
• Budget modifications
• Procurement by noncompetitive proposals

These waivers are in effect until White House M-21-20 expires or is rescinded.

An application is submitted prior to the expiration of the PHE, taking advantage of the nonfederal match flexibility, but still pending with OHS. Will programs have to go back and write a full justification for the nonfederal match waiver?

No. Recipients submitting applications or amendments, in accordance with the active flexibilities, will not be required to make flexibility-related revisions at the expiration of the PHE. Regional Offices will continue to review, analyze, and evaluate requests like they normally would, but applications and amendments will not be returned simply to make flexibility-related adjustments. As these applications and amendments were submitted during a period when the relevant fiscal and administrative flexibilities were in effect, the flexibilities would continue to apply. This is inclusive of applications and amendments currently under consideration or submitted prior to the end of the PHE.

Please ensure you’re communicating with your Regional Office whenever contemplating changes or revisions within your program.

Our program had unobligated funds as a result of staff vacancies. Is there anything we can do with the funds?

Yes. The U.S. Department of Health and Human Services (HHS) Grants Policy Statement indicates that carryover of unobligated balances is limited to approved purposes. Recipients with unobligated funds may request a carryover. However, funds must be used for the same intended purposes for which they were originally awarded.

It is important that recipients generate expenditure reports throughout the budget period, so they are aware of any savings and plan accordingly. Budget revisions may require prior approval and additional time will be needed for review and approval from the Regional Office.

Can COVID-19 funds be used for facilities?

Yes. COVID-19 funds can be used for facilities. Coronavirus Aid, Relief, and Economic Security (CARES) and Coronavirus Response and Relief Supplemental Act (CRRSA) funds must be used to prevent, prepare for, and respond to activities related to the coronavirus. Should a recipient seek to use these funds for facilities, it must be in connection with prevention, preparation, and response activities around COVID-19. American Rescue Plan (ARP) funds do not have the same limitations and can be applied to activities carried out under the Head Start Act, as referenced in ACF-PI-HS-21-03.

Depending on the breadth and scope of the project, the requirements of 45 CFR §1303.44 may also apply which would require a separate application for the purchase, construction, or major renovation of a facility. At a minimum, if the project was not included in the initial application and the funds were not originally allotted for facilities activities, a budget revision will be necessary to adjust funding levels to the appropriate object class categories (i.e., Construction and/or Equipment). Additionally, recipients are strongly encouraged to engage with the Regional Office early in project planning to discuss process, impact for the program, and other possible considerations unique to the request.

Program Operations

If data indicates COVID-19 cases are increasing in a program’s service area, can services be provided virtually?

Yes. In cases where a program is experiencing high COVID-19 transmission in their service area, programs may temporarily use virtual and remote services. All programs are expected to have plans in place to adjust for changes in community conditions, such as high community transmission of COVID-19, that may result in temporary use of virtual and remote services for a short-term basis. These plans must be established within a program’s policies and procedures.

Virtual and remote services can create instability and stress for children and families, as they disrupt children's opportunities for learning, socialization, nutrition, continuity, and routine. As such, programs must communicate with their Regional Office about any proposed short-term use of virtual or remote services in response to a surge or high transmission in COVID-19 cases. Further, programs would need to reassess with their program specialist should their virtual and remote services extend beyond two weeks.

If parents are reluctant to enroll their child due to COVID-19, can we provide services virtually until they are comfortable?

The priority is to enroll children and families who are most in need of in-person services. In-person slots cannot be held for families who have decided they do not want their child to return to an in-person service program.

Programs and families may opt for regular check-in points to reassess a family's readiness to return. If at a time they are ready and there is no slot available, families should be added to the waitlist. If families continue to express hesitancy for in-person services, staff and families should explore alternative placements that will better meet families' needs for virtual services.

Will OHS consider approving program options such as hybrid or remote services?

No. Virtual and remote services for children are considered an interim strategy in the presence of an emergency or disaster and will not be approved as a locally-designed option. While OHS supports the use of virtual and remote services, they are not an acceptable replacement for in-person comprehensive services. OHS recognizes that programs have discovered new virtual strategies for engaging families and reinforcing learning and development at home. Innovations in virtual practice should be used as enhancements rather than substitutes for approved program options and service delivery.

What resources and supports can OHS offer to support recipients with families hesitant to return due to safety issues?

Consistent, honest, and respectful communication with families is a cornerstone of Head Start family engagement. Engagement strategies and current channels of communication with families provide excellent avenues to talk about vaccination. OHS encourages Head Start programs to explore vaccine outreach and support community activities:

• Reach out to your local health departments and clinics to share articles, blogs, and social media messages
• Adapt and deliver COVID-19 vaccine messages from the U.S. Centers for Disease Control and Prevention (CDC) that will resonate in your program
• Become a vaccine site for families

Programs understand how the expectation to return to in-person applies to children attending centers. However, do the same expectations apply to children enrolled in the home-based option?

Yes, the expectations for in-person services are the same for the home-based, center-based, family child care, and locally-designed program options. The goal is moving toward full in-person comprehensive services for all children and families, contingent upon CDC, state, and local health department guidance, and in consideration of local school district decisions.

While OHS acknowledges some parents and home visitors have expressed hesitation to return for various reasons, programs should continue efforts to recruit and transition families and staffs' return to address their concerns.

How can programs support safe home visits?

Head Start staff supporting the home-based option should first assess their own risk of transmitting infection prior to each home visit or socialization. Programs should contact families prior to a home visit and socializations and ask about the following indicators:

• Signs or symptoms of a respiratory infection, such as fever (subjective or confirmed >100.4 F or higher), cough, sore throat, or shortness of breath
• Contact with someone with COVID-19, known exposure to someone with suspected or confirmed COVID-19, or ill with respiratory illness within the last 14 days

If the response from staff or the family is yes to either of the items above, the home visiting program should not conduct the face-to-face visit or socialization and proceed with an alternative mode for the visit (e.g., telephone or video communication). The program should also be in contact with the family to discuss when it would be safe and appropriate to resume in-person home visits and socializations.

If none of the indicators are positive, Head Start staff who make home visits or participate in socializations should continue to take precautions to prevent the spread of COVID-19. As a precaution, Head Start staff should:

• Maintain a distance of at least 6 feet between the Head Start staff and family members during a visit, and, if possible, conduct the home visit or socialization outside or in an alternate space
• Use properly fitted masks to reduce the risk of asymptomatic spread of the disease
• Exit the home immediately and notify the program supervisor if any person is found to be ill in the home
• Minimize contact with frequently touched surfaces
• Use a hand sanitizer that contains at least 60% alcohol before and after the visit
• Avoid touching eyes, nose, and mouth

Can programs apply for a waiver for the requirement that 10% of slots be occupied by children eligible for services under the Individuals with Disabilities Education Act (IDEA)?

Programs must demonstrate ongoing efforts to recruit and enroll children eligible for services under the IDEA to meet the 10% requirement. If a program experiences a barrier in meeting the 10% enrollment requirement, it must submit a waiver request through the Regional Office after the halfway point in the program year and no later than one month after the close of the program year.

What constitutes a change in scope request?

A “change in scope request” is defined in the Uniform Guidance at 45 CFR §75.308 as a change in scope or the objective of the project or program even if there is no associated budget revision requiring prior written approval.

Some examples of a change in scope request would include:

• Head Start to Early Head Start conversion
• Part-day to full-working-day conversion
• Enrollment reduction
• Add or remove a program option
• Other programmatic change

If we are struggling to reach and maintain full enrollment, should we submit an enrollment reduction or conversion request?

The decision to request an enrollment reduction or conversion should not be based solely on the fact that a program is underenrolled. Programs should regularly update their community assessment to reflect current needs, trends, and characteristics of the Head Start-eligible children and families in the service area. This data should then be used to inform programmatic decisions, including planning, service delivery, recruitment and selection criteria, program options, location of centers, staffing patterns, etc. Decisions should be based on actual changes in the community and not anticipated changes. An equally important consideration is that enrollment reductions and conversions are permanent adjustments to a program’s funded enrollment slots.

What are the most common reasons programs have identified when submitting a change in scope request?

Programs have identified the following justifications.

Enrollment Reductions

• Increase staff compensation
• Recruitment and retention
• Changes in minimum wages laws
• Lack of viable classroom space

Conversions

• Identified community need for infant and toddler services
• Proliferation of preschool services in the community

Locally-designed Option

• Mixed service delivery better meets family’s needs
• Center-based services during the school year, alternate services in the summer
• Combination option for families preferring fewer center-based days
• Increase in group size to serve more toddlers (24-36 months)

If we are interested in submitting a change in scope request to address changing community needs, when should we submit that request to ensure we receive a response prior to the start of the upcoming program year?

A change in scope request can be submitted at any time, either within a baseline or continuation application or as an amendment. Programs should identify an implementation date, then determine a timeframe for application submission. An implementation date may also support how a program submits its request. Consideration should be given to an implementation date that causes the least amount of disruption to service delivery, children, and families. For example, a program planning to implement a change in scope request at the beginning of the next school year would need to consider submitting the request in early spring.

OHS encourages programs to engage in ongoing dialogue with their Regional Office. Program specialists can offer guidance in the development of the request and navigation of appropriate application type based on the implementation timeline.

There is a lot of planning that goes into a change in scope. Is there a route programs can explore that will allow a quick response to changing community need?

Yes. Programs considering any adjustments to approved service delivery models should engage in consultation with their Regional Office. Options that do not require a formal change in scope request include:

• Shifting of slots between existing approved program options, provided the program is not requesting to discontinue options currently offered or add an option not currently approved per the Notice of Award
• Shifting of slots within the designated service area per the Notice of Award

Any considerations must include:

• Compliance with the Head Start Program Performance Standards
• Decisions based on community need
• Alignment with the current budget

Transportation

What recommendations does OHS have for safely transporting children?

School buses and allowable alternate vehicles are generally the safest mode of transportation for children. They are also necessary for many children and families to participate in Head Start programs. Implementing safe practices is essential when providing transportation services during the COVID-19 pandemic. When making decisions about transporting children, programs should consult local health officials and other state and local authorities, to the extent feasible.

Supporting safety among transportation staff:

• Require staff who are sick to stay home or send home sick staff
• Wear masks
• Keep hands clean

Supporting safety among children and families:

• Follow safe transportation strategies
• Improve ventilation
• Conduct health checks
• Distance children from each other
• Help children understand physical distancing
• Wear gloves

Clean vehicles between each use:

• Clean hard and nonporous surfaces with detergent or soap and water when visibly dirty
• Employ methods and products that are effective on COVID-19 and safe for use with restraint systems
• For soft and porous surfaces, remove visible contamination and clean with appropriate cleaners indicated for these surfaces

Is temperature-taking still considered a mitigation strategy when providing transportation?

Yes. Conducting health checks, including taking temperatures of all children and staff before they board the vehicle, is a strategy to ensure Head Start vehicles are safe places for transportation staff and children. Programs may consider training and equipping bus monitors to use a non-contact thermometer.

Do not transport:

• Individuals with a fever of 100.4 F (38 C) or above or who show signs of illness
• Individuals who have been in close contact (within 6 feet) of someone who has tested positive for or is showing symptoms of COVID-19

Eligibility, Recruitment, Selection, Enrollment, and Attendance (ERSEA)

When can programs begin using the 2022 poverty guidelines?

The HHS Poverty Guidelines for 2022 went into effect on Jan. 12, 2022. Programs can begin using these guidelines immediately.

Many programs across the federal government, as well as state governments and nonprofit organizations, rely on these guidelines to determine family eligibility for systems and services. Typically, there has been a 1-2% increase in the thresholds to account for inflation, but the 2022 poverty guidelines increased by 4-5%.

How do I know what documents to collect when determining income eligibility?

To verify eligibility based on income, program staff must use tax forms, pay stubs, or other proof of income to determine the family income for the relevant time period (45 CFR §1302.12).

Programs should have policies and procedures to support eligibility determination. They must train the appropriate staff on applicable regulations and program policies and procedures, including policies which identify participants and the frequency in which training is given.

Is the first $10,200 of unemployment still excluded from determining income eligibility?

No. All unemployment will be used to determine eligibility. Expanded unemployment benefits ended on Sept. 6, 2021. Unlike stimulus checks which do not count as taxable income, unemployment payments are taxed and will need to be included when determining eligibility.

In the 2020 tax year, taxes were waived on up to $10,200 received in unemployment for those making less than $150,000. There was no such tax break in the 2021 tax year for those who received unemployment benefits.

What is the difference between the over-income category and the 101-130% income category as it relates to income eligibility?

Children who would benefit from Head Start services, but whose family income exceeds the poverty guidelines, may be enrolled if such participants only make up 10% of a program’s enrollment.

Consistent with 45 CFR §1302.12(d)(1)(i-ii), programs may enroll an additional 35% of children whose family incomes are below 130% of the poverty line. Programs choosing to enroll participants in this category, must:

• Establish and implement outreach and enrollment policies and procedures to make sure eligible pregnant people and children, including those with disabilities, are served first
• Be able to report the criteria outlined in 45 CFR §1302.12(d)(2)(i-vii) to the Regional Office

What should a program do if it fills over-income slots based on full funded enrollment, then actual enrollment drops?

It is important to document the program’s actual enrollment level at the time the 10% over income was calculated. Programs should also document how actual enrollment declined over time. Enrolled children already being served should not be removed or disenrolled from the program. This includes children enrolled as over-income.

Full Enrollment Initiative

How does this information impact ACF-PI-HS-21-04 Office of Head Start (OHS) Expectations for Head Start Programs in Program Year (PY) 2021–2022 that was issued last spring?

Programs should continue to follow OHS expectations outlined in ACF-PI-HS-21-04 by working toward full enrollment and providing in-person comprehensive services for all enrolled children, regardless of program option.

Does this change the expectations for full enrollment?

No. Programs should continue to work toward full enrollment and in-person comprehensive services, contingent upon CDC, state, and local health department guidance, and in consideration of local school districts’ decisions. All programs are expected to continue providing or move toward providing in-person services, as local health conditions allow. During this time, programs should continue to:

• Review their updated community assessment
• Adjust recruitment strategies and selection criteria in response to community data
• Consider their staffing plan and how best to support staff wellness
• Engage in planning for in-person comprehensive service for all enrolled children

Programs must communicate closely with their Regional Office during this time and discuss how they will reach full in-person enrollment consistent with their approved program options.

Workforce

What resources and supports can OHS offer to support recipients with workforce issues?

Recruiting and retaining qualified staff have been long-standing challenges in early childhood education. To address staff challenges, programs may consider hiring individuals as teaching assistants or aides and work with those individuals to develop a plan for achieving the required degree or credential to move into a lead teaching position. Programs are strongly encouraged to work with interested parents and assist them with achieving necessary credentials to move into teaching or other staff positions. Additional strategies to recruit, train, and retain qualified staff may include the following.

• Consider staffing schedules and other benefits to support staff
• Create a culture of belonging
• Understand what drives staff motivation
• Develop collaborative efforts and initiatives to enrich the early childhood workforce
• Promote staff and family well-being

Can programs use ARP or other COVID-19 relief funding to support staff?

Yes, programs can use ARP and other sources of COVID-19 relief funding to provide supports for staff. Specific examples are provided in more detail in ACF-PI-HS-21-03, including around:

• Planning sessions with staff
• Staff wellness and mental health support
• Additional staff
• Professional learning and development for staff
• Other personnel costs

Recipients are in the best position to understand the needs of their staff and the circumstances of their communities. If programs keep in mind the cost principles — necessary, reasonable, and allocable — along with adequate documentation and supportive written policies and procedures, they can answer questions for their own unique supports. We encourage programs to engage in those discussions with their Regional Offices.

Can programs provide staff with financial incentives (e.g., retention or recruitment bonuses) using ARP funds?

Yes. Financial incentives can be a powerful tool to promote staff retention and recruitment, particularly for positions that are difficult to fill or experiencing high turnover. Many employers within and outside of the education sector are appealing to workers by offering financial incentives, such as retention and hiring bonuses. Such incentives vary widely both in monetary amount and distribution schedule.

OHS strongly encourages all programs to use ARP funds, base grant operations funds, and any other sources of COVID-19 relief funds to offer competitive financial incentives to staff to help stabilize their workforce in the near term. Please be mindful of any applicable grant requirements that must be met, including period of availability for different funding sources.

OHS encourages programs, including those who have already offered such incentives, to reevaluate the amount of monetary incentives that are necessary and reasonable to retain and recruit staff. OHS reminds programs that any financial incentives are subject to an established written policy of the grant recipient for allowability.

Which Head Start staff are eligible for a qualification waiver?

A program may request a waiver of up to three years for the qualification requirements for a Head Start center-based preschool teacher. To be considered for the waiver, a Head Start preschool teacher must meet these two criteria:

• Be enrolled in a program that grants a qualifying degree, and such degree will be completed in a reasonable time not to exceed three years. As outlined in the Head Start Act, a qualifying degree includes:
  • At least an associate degree in early childhood education; or
  • Associate degree in a related field and coursework equivalent to a major relating to early childhood education, with experience teaching preschool-age children
• Have at least one of the following:
  • Current Child Development Associate (CDA) credential appropriate to the age of children being served
  • State-awarded certificate for center-based preschool teachers that meets or exceeds the requirements for a CDA

What does the process look like for requesting a qualification waiver for a Head Start center-based preschool teacher?

Programs submit waiver requests to their Regional Office for approval. Waiver requests must include the following information:

• Evidence the Head Start agency has unsuccessfully attempted to recruit an individual who has at least an associate degree in early childhood education or in a related field and the required coursework and experience
• Evidence that each individual for whom a waiver is requested meets the requirements listed in the previous response

A qualification waiver may be submitted for an individual teacher for a period not to exceed three years. OHS Regional Office staff review and determine whether to grant approval for a qualification waiver request.

Is there a qualifications waiver available for Early Head Start teachers?

No. The Head Start Act does not include a provision for qualification waivers for Early Head Start teachers working with infants and toddlers.

What is an “active professional development plan?”

An active professional development plan is a written plan for a staff person seeking a particular degree or credential.

This plan should:

• Reflect a reasonable timeframe for completion of the target degree or credential
• Demonstrate how the staff person is actively working towards completion of the degree or credential (e.g., enrolled in coursework; scheduled to take a required examination; awaiting degree award after completing all necessary requirements)

Programs can choose to use Head Start funding to offset costs for staff associated with obtaining a degree or credential. A program is responsible for conducting ongoing oversight to make sure staff are making progress and meeting timelines for achieving degrees or credentials.

How can programs increase their applicant pool?

OHS encourages programs to:

• Develop a pool of substitute staff and, for those who are successful and interested, start them on a credential attainment path. Parents, other community members, and college students may all be good sources of potential substitutes and eventual staff.
• Intentionally recruit current and former Head Start parents to serve in the program. Parents could start as volunteers and move into employment after completing necessary background checks and credentials.
• Start an apprenticeship program. Programs could consider using ARP funds to cover one-time costs associated with starting an apprenticeship program. Many TA resources are available to support interested early childhood education (ECE) programs. 

Are Head Start staff eligible for Public Service Loan Forgiveness?

Many Head Start staff are likely eligible for Public Service Loan Forgiveness (PSLF).

PSLF is available to borrowers with certain types of federal student loans who work for a qualifying employer. Many Head Start programs are qualifying employers because they are operated by non-profit, government, or school organizations.

There is currently a time-limited waiver for PSLF that allows for payments to be counted towards forgiveness that were not previously considered. The limited waiver is available to those who are eligible and apply before Oct. 31, 2022.

The Administration for Children and Families (ACF) and the U.S. Department of Education (ED) recently hosted a joint webinar, Public Service Loan Forgiveness for the ECE Workforce, on the PSLF program and the time-limited waiver.

IFC

Does the vaccine requirement apply to Part B/C providers, including special education and related service providers for preschoolers and infants and toddlers?

No. These providers are not covered by the vaccine requirement. Part B/C providers are not considered staff of the Head Start program and there is no contractual relationship.

At this point in the year, how should programs implement the vaccine requirement for partners, such as school districts or other partnerships in service delivery, understanding that contracts and memoranda of understanding (MOUs) are in place?

Early Head Start-Child Care Partnerships are covered to the same extent as standard Head Start and Early Head Start programs. For other provider relationships, programs should work to resolve issues with contracts or MOUs, including for staff working with enrolled children, that arise from the IFC in a manner that minimizes disruption of services to children and families for the balance of the PY 2021-2022. Programs should make decisions that cause the least amount of disruption and also support programs to safely get through this program year.

Do the IFC requirements apply to those observing in Head Start programs for purposes of Quality Rating and Improvement System (QRIS) or licensing? Or individuals conducting fire inspections?

The vaccine requirement in the IFC rule does not apply to those inspecting programs for purposes like QRIS, health and fire safety, and licensing. These individuals are not service providers nor are they working directly with enrolled Head Start children and families; rather they are serving in an observational or inspection role.

Per the IFC, these individuals do need to be masked as part of the universal masking requirement.

What do the updates to the CDC recommendations mean for Head Start programs?

The CDC released recommendations on COVID-19 community levels which will help individuals and communities make choices on what precautions they want to take, based on the level of disease burden in their community. The CDC recommends that people should wear masks depending on the level of COVID-19 in their community. As a result, the CDC recommendations differ from the masking requirement in the IFC for Head Start programs.

At this time, the IFC remains the applicable regulation for Head Start programs except in those parts of the country where OHS is subject to preliminary injunctions and temporary restraining orders which prevent implementation and enforcement of the rule. Head Start programs should continue to follow the requirements laid out in the IFC in all states not subject to preliminary injunctions or temporary restraining orders.

While reviewing the new CDC recommendations, OHS will not evaluate compliance with the mask requirement in its program monitoring. This pause on monitoring for compliance with the mask requirement will apply to all programs. Before resuming monitoring for compliance with the mask requirement, OHS will provide the grant recipient community with at least two weeks’ notice prior to implementing any changes.

OHS advises Head Start programs on the importance of using layered mitigation strategies to reduce transmission. These strategies —masking, testing, physical distancing, handwashing, cleaning, and ensuring well-ventilated spaces — remain critically important to protect the health and safety of staff, children, and families. Head Start programs serve children under 5 years of age, who are not yet eligible for vaccination, and some of whom may be more susceptible to complications from COVID-19.

Monitoring

How will OHS monitor the vaccine and masking requirements?

During the Focus Area Two monitoring review, the onsite team will review the recipient’s process for documenting vaccination status. The grant recipient should have documentation of the total number of staff who are fully vaccinated and any who are exempt. The review team will select a random sample to verify the vaccination status of sampled staff (i.e., proof of vaccinations).

The CDC released new recommendations on COVID-19 community levels which will help individuals and communities make choices on what precautions they may want to take, based on the level of disease burden in their community. While reviewing the new CDC recommendations, OHS will not evaluate compliance with the mask requirement in its program monitoring. This pause on monitoring for compliance with the mask requirement will apply to all programs.

What documentation of vaccination status or testing will OHS require during monitoring reviews?

Grant recipients should have a process and tracking system that includes the required proof of vaccination (e.g., vaccine card), testing procedures, and if exempt, proof of testing or intent to test at least weekly. The grant recipient should maintain documentation on the total number of staff, how many are fully or partially vaccinated, and how many have exemptions.

Will OHS issue a monitoring finding if the program has difficulty determining the vaccine status of partners and others not employed by the program who provide services to enrolled children?

No. If partners or others not employed by the Head Start program do not provide the recipient documentation of vaccination status, the program should give the review team the policies and procedures used to maintain a safe environment for children. These policies could include signs that require consistent and correct use of masks, as well as testing of partners or others not employed by the Head Start program who do not provide their vaccination documentation or status. OHS encourages programs to review CDC’s COVID-19 Guidance on Operating Early Care and Education/Child Care Programs in developing those policies and procedures.

Will OHS issue deficiencies for masking or vaccine requirements?

Programs who do not meet the expectations around the development of policies and procedures for documenting vaccination status and implementing the masking requirement may receive an area of concern or non-compliance.

Non-compliances identified during a monitoring review and not corrected within the required timeframe result in deficiencies. Recipients should make every effort to correct any finding identified during reviews to ensure they are not elevated.

Last Updated: December 9, 2022