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INTRODUCTION TO 1304.50
The objective of 45 CFR 1304.50
is to ensure that each grantee and delegate agency has an established
policy group and a well-functioning governing body that share responsibility
for overseeing the delivery of high quality services to children
and families in accordance with Head Start legislation, regulations,
and policies. Through the Policy Council and Policy Committee -
groups with policy-making authority at the grantee and delegate
agency levels, respectively - and through the local Parent Committees,
parents and other community representatives are empowered to actively
participate in the shared decision-making process.
This section describes the formal structure of shared governance,
outlining the composition and responsibilities of policy groups,
Parent Committees, and governing bodies. The standards also discuss
policy group and Parent Committee reimbursements and the need for
internal dispute mechanisms. Finally, the chart "Governance
and Management Responsibilities" in Appendix A of this section
restates the responsibilities and outlines the interactions of policy
groups, governing bodies, and agency management staff.
Related Information:
See 45 CFR 1306.3(h) for the definition of a Head
Start parent.
Rationale:
A formal structure of program governance provides parents and other
community representatives with the authority and opportunity to
participate in shared decision-making concerning program design
and implementation. This rationale serves 45
CFR 1304.50(a)(1)-(5).
Guidance:
Although the formal structure of governance will
vary across local agencies, policy groups and Parent Committees
are required for all. Each agency has only one policy group.
Policy groups - the Policy Council at the grantee agency level
and the Policy Committee at the delegate agency level - have policy-making
authority and, therefore, are governed by locally determined bylaws
that ensure clarity and consistency in function and purpose.
Parent Committees provide every parent of an enrolled child with
the opportunity to assist in the development of activities that
address their interests and needs and that support the education
and healthy development of their children.
Agencies provide parents, community representatives, community
partners, and staff with training regarding program governance and
shared decision-making, so they may understand and support the purpose
of the Policy Council, Policy Committee, and Parent Committee.
Guidance:
All parents of enrolled children are automatically
members of a Parent Committee. The Parent Committee may choose to
develop smaller groups to facilitate in-depth discussions of significant
issues before such issues are considered by the larger Parent Committee.
The formation of subgroups also encourages the participation of
those who feel more comfortable expressing opinions in smaller groups.
The Parent Committee may choose to structure meetings around a breakfast,
potluck meal, or other social event, to encourage participation
by as many parents as possible.
Related Information:
See 45 CFR 1304.52(k)(4) on providing training to
members of the Policy Councils and Policy Committees.
Guidance:
Because shared decision-making is a critical element
of ongoing planning, it is important for agencies to maintain effective
grantee Policy Councils, delegate Policy Committees, and Parent
Committees from one year to the next. The following are suggestions
for encouraging the parents of newly enrolled children to participate
in policy groups and Parent Committees:
- Discuss policy groups and Parent Committees during recruitment;
- Display posters, show videos, or use other means to provide
information about the role and importance of the policy groups
and Parent Committees and about the nature and timing of the
election process;
- Provide opportunities for outgoing members of policy groups
to play an active role in recruiting, meeting with, welcoming,
training, and providing one-on-one mentoring to potential new
members; and
- Invite new parents to observe Policy Council or Policy Committee
meetings.
Although outgoing parents from Policy Councils or Policy Committees
may not have children in Head Start at the beginning of the next
program year, it is important that parents complete their term and
continue in a policy-making role until new parents are elected and
seated. It may be necessary to develop procedures to maintain the
participation of outgoing parents or to elect parents to complete
an unexpired term, if parents have left the area, as is often the
case in migrant programs.
In order to meet the mandate for parental involvement, a new grantee
or delegate agency needs to form an appropriate interim policy group
that represents potential Head Start parents, as well as other community
members. This interim body is immediately involved in start-up program
planning, the development of interim procedures, and the hiring
of staff.
Guidance:
In situations where a grantee delegates the entire
Head Start program to one delegate agency, the Policy Council takes
on all policy responsibilities. Grantees have procedures that describe
how decisions are made involving the grantee governing body, the
delegate governing body, and the Policy Council.
Related Information: See 45 CFR 1304.50(g) for information on governing
body responsibilities, and the chart, "Governance and Management
Responsibilities," in Appendix A to this section, which describes
the roles and responsibilities of the governing body, the Policy
Council and the Policy Committee, and key management staff.
Guidance:
Agencies review membership lists and bylaws to ensure
that memberships and functions of the governing body and the policy
group are not identical. Communication between the groups is improved
if there is at least one representative from the governing body
serving on the policy group and at least one representative from
the policy group serving on the governing body.
Rationale:
Established procedures for electing parent members
and selecting community representatives ensure consistency and fairness
in the selection of policy group members. It is essential that families
receiving services play an active role in making decisions about
such services, and that the Head Start program reflects the community
as a whole. This rationale serves 45
CFR 1304.50(b)(1)-(7). Guidance:
The following are suggestions for the governing
body and policy group review of procedures for parent elections:
- Inform all parents of their vital role in program governance;
- Ensure that there is a fair method of nomination, either by
parents nominating themselves or by other parents nominating
them; nominations should be placed only with the consent of
the nominee;
- Provide proportionate representation to parents in all program
options and settings. If agencies operate programs serving different
geographical regions or ethnic groups, to adopt policies to
ensure that all groups being served will have an equal opportunity
to serve on policy groups; and
- Consider using Parent Committees to facilitate the process
of nominating and electing parents to the Policy Council or
Policy Committee.
Parents are involved in every step of the process for selecting
community representatives. Parents may be involved, for example,
in discussions of the issues of interest and the types of community
representatives needed in the coming year, as well as in developing
methods for soliciting and screening potential candidates.
When nominating parent members or selecting community representatives
to policy groups, consider:
- The willingness and ability of the potential members to contribute
time and effort to the program and to serve as mentors and role
models, as well as resource persons;
- The diversity of the group of individuals nominated, with
consideration being given to the programs or program options
in which the children of nominees are enrolled;
- The agency's goals and the information generated by the Community
Assessment; and
- The desirability of having representation from the governing
body to the policy group, in order to improve communication
between the two groups.
Agencies and policy groups establish procedures for monitoring
the three-year limit for both parents and community representatives.
Agencies also develop volunteer opportunities that allow former
policy group members to use their skills and experience to support
program activities and operations. If agencies view and present
the opportunity of serving on policy groups as a time to learn new
skills and to gain self-confidence in a supportive environment,
parents will understand the value of leaving a policy group after
a few years, and of moving into other leadership roles in school
organizations and in the larger community.
Personnel policies and bylaws address potential conflicts of interest
between agency employment and membership on a Policy Council or
Policy Committee. For example, agencies may consider developing
policies that define "occasional substitute" and that
determine at what point in the hiring process a candidate for a
Head Start position must resign his or her membership from a policy
group, that is, upon application or upon hiring.
Rationale:
Policy groups are established and charged with the
specific functions outlined in paragraphs (d), (f), (g), and (h)
of this section and in the chart, "Governance and Management
Responsibilities," in Appendix A of this section, in order
to ensure that parents have the opportunity to be involved in shared
decision-making. Policy groups provide a vehicle for parents to
assume leadership roles in representing the collective interests
of all families. This rationale serves 45
CFR 1304.50(c), (d), (f), (g), (h), and Appendix A of this section.
Guidance:
Formal systems of communication and a thoughtful
plan of ongoing training serve as a critical foundation to the development
of effective working partnerships among the policy group, the governing
body, and key management staff. To further support cooperative relationships,
grantee and delegate agencies:
- Develop a consultation and approval process that is integrated
between the policy group and governing body in order to expedite
agency decision-making concerning the Head Start program;
- Establish written procedures for many of the policy approval
functions of the governing body and the Policy Council or Policy
Committee;
- Recognize that having organized and agreed upon practices
reduces the time and effort needed to conduct business and reduces
conflict between the groups;
- Recognize the role of staff in developing policy issues for
consideration, discussion, and approval by both the policy group
and the governing body; and
- Provide information to the policy groups in a timely manner
in order to support effective decision-making.
Related Information:
See function (I)(e) in the chart, "Governance and
Management Responsibilities," in Appendix A of this section.
Guidance:
The agency's planning process provides for the involvement
of the governing body and the Policy Council or Policy Committee
at strategic points during the development of all funding applications.
The following are suggestions for involving grantee Policy Councils
and delegate Policy Committees in a meaningful review of applications
and related materials:
- Consider the funding application as part of an ongoing planning
process, and involve members in the decision-making process
early on, before the applications and related materials are
drafted;
- Provide timely training on the interrelated nature of budgets
and program planning (see 45 CFR 1304.52(k)(4)); and
- Provide frequent information on program progress and expenditures
to create a climate in which agency decision-making is supported
by adequate and ongoing information about agency activities
(see 45 CFR 1304.51(h)(1) on financial and program reporting
systems).
Related Information:
See function (II)(c) in the chart, "Governance and
Management Responsibilities," in Appendix A of this section. Also
see 45 CFR 1304.51(d) for information on communication between the
Policy Council or Policy Committee and the governing body.
Guidance:
Shared decision-making presents a variety of challenges.
Suggested strategies for successful shared decision-making follow:
- Develop written procedures describing how the sharing of responsibilities
across the functions specified in the chart in Appendix A of
this section will be implemented;
- Ensure that the Policy Council, the Policy Committee, and
the governing body receive regular and accurate information
about program planning, policies, and agency operations through
the communication system required by 45 CFR 1304.51(a); and
- Support open channels of communication between the grantee
Policy Council or the delegate Policy Committee and the relevant
governing body through such measures as
- the exchange of minutes from meetings,
- forums for open discussions between the groups,
- joint meetings on specific issues or concerns,
- the participation of policy group members in staff meetings,
and
- concurrent membership of selected individuals on both
the governing body and policy group.
Related Information:
See functions (I)(a) and (b) in the chart, "Governance
and Management Responsibilities," in Appendix A of this section.
Also, see 45 CFR 1304.51(a) on program planning, and specifically,
45 CFR 1304.51(a)(1)(ii) on formulating long-range goals and short-term
objectives.
Guidance:
Active policy group participation in program planning
is critical to the continuous process of program improvement. The
following are suggestions for involving Policy Councils and Policy
Committees in program planning and in shaping the program's philosophy
and long- and short-range goals and objectives:
- Ensure that members are aware of established agency time frames
and procedures for program planning;
- Ensure that the Policy Council and Policy Committee participate
in discussions concerning program vision;
- Establish subcommittees, as needed, to work with the director,
the governing body, and appropriate staff on developing and
analyzing program plans, long-range goals and short-term objectives
for each program area;
- Obtain recommendations from Parent Committees;
- Provide input on relevant community issues;
- Review financial statements of the program and explore program
resources to determine if adequate resources exist to support
goals and objectives; and
- For Policy Councils of agencies with delegate agencies, ensure
that the grantee agency's planning procedures describe how delegate
agencies will integrate their planning activities into those
of the grantee.
Related Information:
See functions (I)(c) in the chart, "Governance and
Management Responsibilities," in Appendix A of this section.
Guidance:
Approval of delegate agencies and their service
areas is a shared decision of the Policy Council and the governing
body. The provision of all information to both groups in a time-sequenced
manner supports and facilitates the agency's decision-making processes
and minimizes conflict as well.
Related Information:
See functions (II)(a) in the chart, "Governance
and Management Responsibilities," in Appendix A of this section;
and see 45 CFR 1304.50(b)(1) regarding policy group composition
and formation.
Guidance:
See cross-references under "Related Information"
for this standard.
Related Information:
See functions (I)(d) and (b) in the chart, "Governance
and Management Responsibilities," in Appendix A of this section.
Guidance:
To facilitate the meaningful participation of policy
group members in the periodic reviews of criteria for recruitment,
selection, and enrollment priorities, policy group members need
to be familiar with the requirements of 45 CFR 1305. They are encouraged
to examine how the enrollment process is working in relationship
to these requirements as well as their understanding of the program
philosophy and the needs of children and families in the community.
Related Information:
See functions (I)(g) and (b) in the chart, "Governance
and Management Responsibilities," in Appendix A of this section.
Guidance:
As active participants in the ongoing process of
annual self-assessment, as required under 45 CFR 1304.51(i), the
Policy Council and Policy Committee consider the extent to which:
- The time schedule for self-assessment is reasonable;
- An appropriate assessment team has been formed, which includes
parents and adequate representation from the community;
- The self-assessment team receives training on how to conduct
an assessment;
- All team members are fully aware of the results of the last
self-assessment, as well as of the Federal monitoring review;
- The measures used to conduct the self-assessment adequately
evaluate the program;
- Findings from the self-assessment are reported to the Policy
Council, Policy Committee, Parent Committees, and governing
bodies; and
- Improvement plans are appropriate and feasible in terms of
resources and time frames.
- Policy groups also review the agency's procedures to ensure
that an annual independent audit is conducted, in accordance
with 45 CFR 1301.31, and copies of the audit are available to
them.
Related Information:
See function (III)(a) in the chart, "Governance
and Management Responsibilities," in Appendix A of this section;
45 CFR 1301.31 on personnel policies; and 45 CFR 1304.52(h) on standards
of conduct for program staff, consultants, and volunteers.
Guidance:
Policy groups are knowledgeable about personnel
policies, because of their roles in approving or disapproving decisions
to hire or terminate staff. Elements to consider during the review
of personnel policies include:
- The effectiveness of the personnel policies in securing qualified
staff who can provide appropriate services and who reflect the
families served;
- The potential need for modifications or addendums to agency-wide
personnel policies and procedures, so that program staff are
treated in accordance with 45 CFR 1301.31; and
- The possible desirability of focusing the review on a particular
area, such as benefits, recruitment, promotion procedures, salaries,
job descriptions, or grievance procedures, during any given
year.
Related Information:
See functions (III)(b)-(e) in the chart, "Governance
and Management Responsibilities," in Appendix A of this section;
and see 45 CFR 1304.50(e)(3) on Parent Committee involvement in
the recruitment and screening of Head Start employees.
Guidance:
A method for including the Policy Council or Policy
Committee in the approval or disapproval of decisions to hire or
terminate individuals working for the program is essential. Some
roles of the Policy Council or Policy Committee are to:
- Actively participate in the personnel process through such
means as establishing a personnel committee that is charged
with making recommendations to the full Policy Council or Policy
Committee;
- Ensure that positions are openly advertised;
- Work with Parent Committees to implement the recruitment,
selection, and approval process;
- Encourage parents to understand the employment process and
to apply for jobs for which they are qualified; and
- Participate in the approval process, without taking responsibility
for directly hiring or terminating individuals, because this
is a management function.
To avoid barriers to hiring staff on a timely basis, migrant programs
and other programs with geographical constraints develop guidelines
for securing input from policy group members who are not living
in the local area at the time of the hiring process.
Related Information:
See 45 CFR 1304.51(b) regarding communication with
the community.
Guidance:
Members of policy groups play an active role in
listening to parents and community agencies by:
- Supporting parents in being effective spokespeople in the
community by providing training in such areas as communication
and listening skills;
- Being members of grantee and delegate agency governing bodies
and other community boards in order to share information about
services for children and their families;
- Reporting back to parents, keeping them informed about policy
group actions through Parent Committee meetings, program newsletters,
bulletin boards, and one-on-one contacts;
- Ensuring that staff provide basic information, such as copies
of the Head Start Program Performance Standards, bylaws, notices,
and general information, to all interested parties;
- Being familiar with resources in the community;
- Fostering positive community relationships; and
- Becoming advocates and leaders at local, State, Tribal, and
Federal levels.
Related Information:
See 45 CFR 1304.40(d)(3) on parent participation
in the program, and 45 CFR 1304.51(c) on communication with families.
Guidance:
The Policy Council and Policy Committee play important
leadership roles in working with the Parent Committees to encourage
all parents to participate in the activities of the Parent Committees
and policy groups, as well as in other program activities. Effective
methods for communicating the importance of parent participation
vary, depending upon the parents and program. One suggestion is
for members of these groups to work with staff in developing a handbook
addressing parental rights, responsibilities, and opportunities.
Related Information:
See 45 CFR 1304.50(e) on Parent Committee responsibilities.
Guidance:
Parent Committees are allowed broad latitude when
planning, coordinating, and organizing activities. Grantee Policy
Councils and delegate Policy Committees, as well as staff, are available
to support the Parent Committees in planning these activities, as
needed, by:
- Encouraging parents to discuss all parent activities that
the program currently sponsors and to assess the effectiveness
of those activities;
- Obtaining input from parents about what they would like to
do in the program;
- Assisting in securing funding, personnel, and other resources
to support desired activities;
- Discussing when to use parent activity funds to help carry
out proposed activities; and
- Encouraging Parent Committees to take responsibility for submitting
a recommended budget for parent activity funds for the following
year to the Policy Council or Policy Committee.
Related Information:
See 45 CFR 1304.41(a)(3) for information on volunteer
outreach.
Guidance:
In order to assist in recruiting volunteers and
in mobilizing community resources, Policy Councils and Policy Committees:
- Work with the Parent Committees to encourage parent participation;
- Identify how volunteers and community resources can extend
program services;
- Assess the types and quality of volunteer opportunities;
- Suggest where to look for community volunteers and resources;
- Supplement agency volunteer outreach efforts; and
- Collaborate with local foundations and other organizations
to mobilize resources.
Related Information:
See function (II)(e) in the chart, "Governance and
Management Responsibilities," in Appendix A of this section; and
see 45 CFR 1304.51(b) regarding communication with the community.
Guidance:
The following are suggested procedures for fostering
good community relations and resolving community complaints:
- Foster positive community relations by being proactive with
local agencies;
- Conduct outreach to community agencies or individuals to solicit
constructive suggestions for quality improvement;
- Establish a follow-up process to respond to all community
inquiries; and
- Develop procedures that describe specific steps in the process
for addressing community concerns and for resolving complaints
and make copies of such procedures available widely.
Rationale:
Parent Committees provide all parents with a broad
range of opportunities to participate in the shared decision-making
process. This rationale serves 45
CFR 1304.50(e)(1)-(3). Related Information:
See 45 CFR 1304.40, Family Partnerships, sections
(a)(4), (a)(5), (d), (e) and (f) for information on parent involvement,
parent education programs, and other interactions with parents.
Guidance:
Parent Committees contribute to program development
and operations in many ways, including, but not limited to:
- Electing policy group representatives;
- Becoming involved in the development of the program's curriculum
and approach to child development and education (see 45 CFR
1304.21(a)(2)(i) and 45 CFR 1304.40(e)(1));
- Designing program activities planned for various program settings,
group socialization experiences, and weekly home visits;
- Locating resources to carry out program activities;
- Bringing parents together to share common interests;
- Working with the Policy Council or Policy Committee to support
program development and implementation; and
- Planning programs and activities for parents and staff. Parent
Committees are encouraged to discover and discuss what parents
would like to do and what they would like to learn; and to discuss
how these ideas can be carried out with or without staff assistance.
In addition, Parent Committee members play a vital role in the
recruitment and screening of employees. Within the guidelines established
by the Policy Council or Policy Committee, members of Parent Committees:
- Assist agencies to determine how and where to recruit potential
employees;
- Help determine the selection criteria; and
- Participate in the interview process.
Guidance:
Reimbursements to low-income members for reasonable
expenses in fulfilling their group responsibilities are provided
by the grantee or delegate agency from grant funds. Agency procedures
and policy group bylaws may contain definitions of necessary reimbursement
and reasonable expenses, which may include:
- travel, lodging, and per diem expenses, in line with agency
policies for staff travel,
- child care expenses, and
- other expenses deemed appropriate.
Related Information:
See functions (II)(b),(f) and (g) of the chart,
"Governance and Management Responsibilities," in Appendix A of this
section; 45 CFR 1304.50(d)(1)(ii) about shared decision-making between
the governing body and the appropriate policy group; 45 CFR 1304.51(h)(1)
concerning financial reporting systems; and 45 CFR 1304.52(k)(4)
about training.
Guidance:
The responsibilities of the governing body include,
but are not limited to:
- Ensuring compliance with Federal laws and regulations, including
the Head Start Program Performance Standards, as well as applicable
State, Tribal, and local laws and regulations, including laws
defining the nature and operations of the governing body;
- Understanding the Head Start philosophy and the role of parents
and the Policy Council or Policy Committee in the Head Start
shared governance structure, including the need to secure approval
of policies and procedures by the grantee Policy Council or
delegate Policy Committee;
- Being fiscally and legally accountable for overseeing the
Head Start program, including taking general responsibility
for guiding and directing planning, general procedures, and
human resources management, as outlined in the chart, "Governance
and Management Responsibilities" in Appendix A to this section;
and
- Ensuring that their agency develops an internal control
structure to
- safeguard Federal funds,
- comply with laws and regulations that have an impact on
financial statements,
- detect or prevent noncompliance, and
- receive audit reports and direct and monitor staff implementation
of corrective actions.
In addition, members of the governing body support the program
by:
- Identifying and developing resources to augment Federal funds;
- Visiting or volunteering in classrooms and other program activities;
- Becoming involved in the self-assessment process;
- Initiating joint training opportunities with the Policy Council
or Policy Committee;
- Establishing mentoring programs which match governing body
members with members of the policy groups or other interested
individuals; and
- Obtaining feedback from parents and community members about
the quality of services.
Guidance:
The governing body and relevant policy group of
each grantee or delegate agency have the responsibility for writing
and following their own procedures for resolving internal disputes.
It is important to develop and formally adopt dispute resolution
policies on a proactive basis. Therefore, agencies:
- Consider using community resources to assist in developing
resolution procedures and in resolving disputes;
- Set procedures for seeking outside assistance from community-based
organizations for the negotiation, mediation or arbitration
of disputes that threaten to disrupt services to children and
families; and
- Ensure that new policy group members are made aware of the
process.
Related Information:
See paragraphs (c), (d), (f), (g), and (h) of this
section, as well as 45 CFR 1304.51(a) and 45 CFR 1304.52 (a) and
(c) for further guidance on governance and management responsibilities.
Guidance:
The chart, "Governance and Management Responsibilities,"
Appendix A to 45 CFR 1304.50, restates the responsibilities and
outlines the interactions of governing bodies, policy groups, and
agency management staff.
Knowledge of the connections between all elements represented by
the chart is critical to understanding the responsibilities of each
individual or group. The chart provides a "bridge" linking the governance
structure described in 45 CFR 1304.50 with the management functions
described in 45 CFR 1304.51 and 45 CFR 1304.52.
To effectively implement shared decision-making, members of governing
bodies, policy groups, and agency management teams adopt a holistic
view of the complete system of program design and management and
of how this system is integrated with the entire set of Head Start
Program Performance Standards.
1304.50 Appendix A: Governance and Management Responsibilities
(Table missing)
Last Modified: 09/20/2004
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