Q1: If programs are serving a reduced number of children, is the over-income percentage based on the program’s current capacity or their funded enrollment?
A1: The 10% of over-income enrollment is based on the program's actual enrollment. Programs should use the number of enrolled children rather than funded enrollment to calculate this percentage.

We know programs need to be able to plan for over-income slots, and that is more easily accomplished using the funded enrollment. However, when programs' actual enrollment differs greatly from funded enrollment, the number of over-income slots should be based on actual enrollment to remain consistent with the intent of the law. The Office of Head Start (OHS) recognizes that enrollment numbers may fluctuate and will not be penalizing programs as they navigate this period.

The pandemic has created and exacerbated longstanding disparities and inequities for families who have been marginalized for decades. The number of children and families in poverty has grown significantly during this time. OHS recognizes that prioritizing low-income families is especially needed to ensure we are serving children and families with the greatest needs.

Q2: What should programs do if enrolled families do not want to participate in in-person services?
A2: The priority is to enroll children and families who are most in need of in-person comprehensive 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 there is no slot available at a time that a family is ready, 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.

Q3: Is temperature taking still considered a mitigation strategy when providing transportation?
A3: 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 noncontact thermometer.

Do not transport:

• Individuals with a fever of 100.4F (38C) 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

Q4: If my program is thinking about shifting slots between approved program options or within the service area, what should we consider?
A4: Programs considering any shifts within the approved service delivery models or service area as stated in the Notice of Award should first engage in discussions with their Regional Office. Any considerations must include:

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

Q5: What constitutes a Change in Scope request?
A5: A Change in Scope request is defined in the Uniform Guidance at 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 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

Q6: Can programs use American Rescue Plan (ARP) or other COVID-19 relief funding to support staff?
A6: Yes, programs can use ARP and other sources of COVID-19 relief funding to provide supports for staff. Specific examples are given 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

Grant 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

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Last Updated: December 28, 2022