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INTRODUCTION TO 1304.51
The objective of 45 CFR 1304.51
is to establish dynamic and cohesive management systems that support
continuous improvement and foster commitment to providing the highest
level of services to children and families in accordance with legislation,
regulations, and policies.
Management systems and procedures are part of each program's on-going
and organized approach to managing Head Start services. They are
all connected and inter-related with each impacted by the others
and all influencing and influenced by program services. The graphic
below is intended to convey this message. With all of these systems,
the emphasis is as much on the process involved in their implementation
as it is on the product that may come from implementation.
The standards in this section are written to allow
grantees great flexibility in designing the approach that will work
best in their program and community. Through designing and implementing
effective systems for program
planning, communication, record-keeping, reporting, and program
self-assessment and monitoring, each Head Start program has greater
ability to integrate the various functions of Head Start and provide
high quality services to children and families.
Rationale:
Program planning occurs in a continuous cycle, involving key members
of the Head Start community. Planning, therefore, is critical for
setting clear program goals and for defining an organized approach
to program services driven by the specific priorities of the community.
This rationale serves 45 CFR 1304.51(a)(1)(i)-(iii).
Related Information:
Many planning activities are mandated by regulations, including:
- completion of the Community Assessment (see 45 CFR 1305.3 and
45 CFR 1304.51(a)(1)(i)),
- formulation of long-range program goals and short-term program
and financial objectives (see 45 CFR 1304.51(a)(1)(ii)),
- involvement of policy groups in formulating long-range goals
and short-term objectives (see 45 CFR 1304.50(d)(1)(iv)),
- development of written plan(s) for implementing services in
all program areas (see 45 CFR 1304.51(a)(1)(iii)), and
- completion of program self-assessments and agency and delegate
monitoring activities (see 45 CFR 1304.51(i)).
Also see 45 CFR 1304.50(d)(iii) and 45 CFR 1304.51(a)(2), on involving
policy groups in program planning.
Guidance:
Program planning is an active and dynamic process in which ideas and
strategies are shared, discussed, and updated as local circumstances
and the needs of children and families change. Planning involves key
members of the Head Start community, including staff, parents, governing
body, policy group, advisory committee members and community representatives;
and any plan represents the viewpoints of persons affiliated with
all program options and all agency locations. The planning process
also results in a written plan or a series of plans that describe
an agency's approach to serving children and families. This plan or
series of plans will impact all program products and processes so
that all aspects of the program reflect an integrated approach to
services.
Planning strategies include:
- Orienting participants to the mission, goals, and philosophy
of the agency and the Head Start program; and
- Scheduling times for planning that are appropriate and convenient
for those involved, paying special attention to the kinds of accommodations
that parents may require in order to participate.
Planning begins with the Community Assessment, through which agencies
collect data about community strengths, needs, and resources. Agencies
use these data to make decisions about the types of services they
will provide for children and families. Examples of decisions that
agencies make on the basis of the Community Assessment include:
- the program options and settings the agency will provide, such
as the center-based, home-based, combination or family child care
locations, and the hours of operation,
- the organizational structure it will use to implement these
options,
- the kinds of staff skills and experience the agency needs, including
the staff composition necessary to reflect the languages, cultures,
and heritage of members of the community, and
- the services that the agency will provide directly and those
it will provide through community collaboration and referrals.
Agencies consider the ways in which they could collaborate with
other local service providers in conducting the Community Assessment
and in interpreting its results. For example, agencies could conduct
joint, initial Community Assessments or annual updates with other
organizations, such as child care agencies and other organizations
serving young children and their families. They could also meet
with representatives of such organizations to discuss the roles
each agency plays in meeting identified community interests and
need or to leverage local resources.
Goal setting is an ongoing, dynamic process that stems from the
Community Assessment and helps to establish agreed-upon priorities
about what the agency expects to accomplish in the short- and long-term.
Once established, goals and objectives are periodically reviewed
and revised to respond to changes in the community.
It is helpful to distinguish between long-range program goals and
short-term program and financial objectives in the planning process.
Program goals are usually broad statements of what the program wants
to accomplish in an overall sense and in each of the program areas.
Program and financial objectives include specific steps that need
to be taken to accomplish the long-range goals. The target date
for achieving short-term objectives is often one year or less.
A written plan or set of plans is an outcome of a process of program
planning that documents the agency's strategies for implementing
the Head Start Program Performance Standards and other applicable
regulations, along with its own goals and objectives. For example,
an agency may choose to prepare a single "strategic plan"
which comprehensively discusses the results of the planning process.
Another agency may choose to write separate plans for each service
area. Agencies are encouraged to "tailor" plans to their
own requirements. In addition, the outcomes of the planning process
may include changes in grantee procedures (e.g., Community Assessment,
recruitment) or documents (e.g., statement of goals and objectives,
curriculum for children).
The process for developing the written plan(s) can vary widely
from agency to agency. However, the process invariably includes
developing a strategy for involving parents, staff, and policy group
members in the development of the plan or plans.
As needed, consultants may be called upon to assist with preparing
specific sections of the plan. Staff also can consult with the Health
Services Advisory Committee in developing sections of the plan dealing
with Early Childhood Development and Health Services.
Rationale:
Policy group members are involved in reviewing program plan(s) to
ensure they adequately reflect the needs and concerns of enrolled
children and their families. This rationale serves 45
CFR 1304.51(a)(2).
Guidance:
Written plans are meant to be "working documents." Therefore,
a review of plans and agency progress toward meeting the objectives
of those plans could be a regularly scheduled topic at staff and policy
group meetings. Examples of strategies for involving staff and policy
group members in the regular review of plans include:
- Introducing staff and policy group members to program plans
through small group orientation sessions;
- Providing updated information about program plans in regular
bulletins or newsletters; and
- Organizing program staff and policy group members into committees
or subcommittees charged with making necessary revisions or updates
to the program plans or selected portions of those plans.
Rationale:
A communication system ensures the exchange of information that allows
individuals to become fully involved in program activities and to
make group decisions that promote a quality program. To be effective,
information flows to and from parents, staff, governing bodies, delegate
agencies and community groups. This rationale serves 45
CFR 1304.51(b)-(f).
Related Information:
More specific guidance on communication with parents, governing bodies
and policy groups, staff, and delegate agencies is provided in 45
CFR 1304.51(c). For information about communicating with community
partners, see 45 CFR 1304.41(a).
Guidance:
When establishing systems of communication, agencies consider the
following issues:
- What information is important to members of the Head Start community;
- When people need to receive information;
- How the information should be communicated; and
- Whether communication flows both to and from parents, governing
bodies, delegate agencies, policy groups, staff, and the general
community in a timely fashion.
Communication comes in many forms: informal and formal, written
and face-to-face, verbal and non-verbal, textual and graphic. Strategies
used to communicate often can be as important as the content of
the message being communicated.
Related Information:
Head Start regulations require effective communication with families
in a language that each family understands (see 45 CFR 1304.52(b)(4)),
and the conduct of specific activities that enhance staff-parent communication,
including:
- opportunities for engaging in a family partnership agreement
process (see 45 CFR 1304.40(a)(2)),
- home visits involving parents, home visitors or teachers, and,
as appropriate, the enrolled child, and other staff members (see
45 CFR 1306.33 and 45 CFR 1304.40(i)),
- staff-parent conferences conducted as needed, but at least twice
a year (see 45 CFR 1304.40(e)(5)),
- representation by parents and staff on Individualized Education
Program (IEP) development teams (see 45 CFR 1308.19), and
- ongoing communication with parents regarding follow-ups that
address identified health needs (see 45 CFR 1304.20(c)(1)).
See 45 CFR 1304.40(e)(3) for additional information on communicating
with parents regularly, and 45 CFR 1304.50(d)(2)(ii), on policy
group and Parent Committee communications with parents.
Guidance:
The communication system includes opportunities for agencies to share
and receive information on program activities, goals, and philosophy,
as well as opportunities for parents to share and receive feedback
on their child. Such communication is carried out in a variety of
ways, such as:
- orientation activities,
- regular, informal telephone or face-to-face conversations, or
notes in the parents' preferred language, and
- newsletters.
To make communication efforts more effective, the agency communicates,
to the extent possible, in the parent's preferred language. Examples
of ways to communicate with parents in their primary or preferred
language include:
- Collaborating with local community organizations, such as ethnic
associations and refugee or immigrant aid agencies, for assistance
in communicating with parents; and
- Drawing upon parents and members of the local community to obtain
bilingual staff and interpretation services and to ensure sensitivity
to family culture and heritage (see 45 CFR 1304.52(g)(2)).
Related Information:
See 45 CFR 1304.50(d)(1)(ii) for information on communication between
governing bodies and policy groups.
Guidance:
As a part of the communication system, agencies use strategies to
ensure that members of governing bodies and policy groups understand
the information specified in this Performance Standard and its implications.
Strategies include:
- Providing new members of governing bodies and policy groups
with an orientation packet, as described in the guidance to 45
CFR 1304.52(k)(4), and with the appropriate training necessary
to understand and participate in collective decision-making;
- Ensuring that policy group and governing body members have adequate
preparation time to review and "digest" material they
receive from the agency; and
- Facilitating discussions and an open exchange of ideas on program
plans, policies, procedures, and reports at the meetings of policy
groups and governing bodies.
Guidance:
An effective staff communication system supports the ongoing exchange
of information among staff, is focused on quality of services, and
represents the best interests of children and families. Effective
formal and informal communication methods include:
- Establishing a supportive climate in which open and frequent
staff communication is encouraged and appreciated, so that staff
can freely share their ideas and concerns and provide constructive
feedback to their colleagues and supervisors;
- Considering various ways that regularly scheduled staff meetings
at all levels of the agency can be used to facilitate staff input
and discussions; and
- Utilizing computer technology to support and enhance staff communication
and to minimize geographical constraints -through electronic bulletin
board systems, electronic mail, and Internet access.
Guidance:
It is the responsibility of each grantee agency to design procedures
for ensuring that delegate agencies receive, understand, and respond
to pertinent information in a timely manner. Strategies to accomplish
this include:
- Bringing representatives from the delegate agencies together
when new regulations, plans, policies, program instructions or
information memoranda are released by the Head Start Bureau or
the grantee agency;
- Providing regular informational meetings, newsletters, a central
library of resources, and joint staff training and technical assistance;
- Designating regular grantee staff liaisons to delegate agencies;
and
- Making use of current technologies (such as conference calling,
electronic bulletin boards, and E-mail) that minimize communication
constraints related to distance.
Rationale:
Effective record-keeping and reporting systems provide the information
needed to individualize programs for children and families, to monitor
the quality of program services, to assist in program planning and
management, and to ensure the delivery of quality services. These
systems also provide documentation that agencies are meeting program
requirements and other Federal, Tribal, State, and local laws. To
ensure that privacy rights are respected in these systems, safeguards
are developed and maintained. This rationale serves 45
CFR 1304.51(g)-(h).
Related Information:
Agencies are required to develop written confidentiality policies
to ensure that all staff are aware of and implement those policies
correctly (see 45 CFR 1304.52(h)(1)(ii)).
Regulation 45 CFR 1304.41(c)(1)(i) requires agencies to coordinate
with schools and other agencies to ensure that relevant child records
are transferred to and from other child placements or schools, which
includes transfers among Head Start migrant programs and centers.
State or Tribal law may dictate the length of time that certain records are
maintained; and recipients of Federal grants are required to maintain
their records, in principle, for a minimum of three years.
Guidance:
In building an effective record-keeping system, agencies consider
what information they need to collect, who needs to receive it, and
how it should be stored. The following factors are considered when
establishing and maintaining record-keeping systems:
- Use of standard forms.
- Standard forms simplify information collection and record keeping,
if they are designed in a way that minimizes unnecessary writing.
- Recording and storage of useful information.
- Staff are encouraged to review periodically the usefulness of
recorded information and to avoid the unnecessary paperwork and
files associated with information duplication.
- Confidentiality of information.
- The agency's policy on confidentiality of information incorporates
the following:
- Controlling access to files and prohibiting parents and
volunteers from reviewing any records other than their own;
- Developing family permission forms for the release of information
to and from agencies or individuals, and storing forms signed
by the responsible adult; and
- Familiarizing relevant staff with all laws governing confidentiality
policies, particularly as they pertain to interagency collaborations
in which information about children and families is shared.
- Use of computer technology.
- If used properly, computers allow staff to:
- Share information readily across wide geographical distances;
- Quickly aggregate financial or program data for use by program
planners or decision makers;
- Generate and produce standard forms used regularly by agencies;
and
- Up-date, store, and retrieve program records quickly and
easily.
- Transfer of records.
- When children and families transition from Head Start, records
go with them with parental consent. Especially among migrant programs,
where grantees assist with the rapid transfer of records to the
families' next destination, effective record-keeping systems ensure
a smooth, timely transfer.
Guidance:
The following are strategies to consider when designing and implementing
effective and efficient reporting systems:
- Identification of critical reports.
- Staff are encouraged to consult with each of their funding sources
and with their State and local licensing agencies for complete
lists of reports that agencies may be required to produce in areas
such as personnel qualifications, facilities and property, and
health, safety, and sanitation. In addition, management staff
may wish to consult with governing bodies and policy groups to
determine the discretionary reports that will allow those groups
and staff to most effectively plan and manage the program and
its finances.
- Report content and structure.
- Agencies produce reports that are clear, accurate, and readable.
These reports will help staff, governing bodies, and policy groups
with varying levels of experience and education to make informed
decisions concerning the program.
- Frequency of reports.
- Establishing a time schedule for the release of reports allows
staff, governing bodies, and policy groups to schedule meetings
when up-to-date information is available.
Guidance:
Examples of official reports that are likely to be required of local
agencies include:
- reports required by the Head Start Bureau, HHS or other offices,
including Program Information Reports (PIRs), financial audit
reports, and reports of financial status and expenditures (SF-269s),
- annual returns filed by independent non-profit agencies with
the Federal Internal Revenue Service (IRS) and, in some States,
with State agencies,
- forms providing information on payroll taxes, such as Social
Security (FICA) taxes, withholding of income taxes, Federal unemployment
(FUTA) and State unemployment taxes,
- reports of meals served, menus, and training provided for the
USDA meal programs,
- program enrollment reports, including attendance reports for
children whose care is partially subsidized by another public
agency, and
- other reports required by Federal, State, Tribal, or local law.
Rationale:
As a method of measuring agency accomplishments, strengths, and weaknesses,
self-assessment allows for the continuous improvement of program plans
and service delivery methods; and for the enhancement of program quality
and timely responses to issues that arise in the community, the program,
and among enrolled families. The self-assessment process also provides
an opportunity for involving parents and community stakeholders, and
for making staff more aware of how the program is viewed by its consumers.
This rationale serves 45 CFR 1304.51(i)(1)-(3).
Related Information:
See 45 CFR 1304.50(d)(1)(viii) for information on policy group participation
in the annual self-assessment.
Guidance:
A critical element to a successful self-assessment is the ongoing
participation and oversight of the policy groups. After considering
the following suggested steps, each grantee and delegate agency establishes
its own structured self-assessment process:
- Specify a time schedule.
- As part of the continuous cycle of program planning, self-assessments
are scheduled in a way that responds flexibly to the agency's
need for review and evaluation.
- Select a self-assessment team.
- Depending upon the specific focus of the self-assessment, consider
including staff, policy group members, parents, representatives
from community organizations, governing body members, and staff
from other Head Start agencies on the self-assessment team. Staff
may participate in reviews of program areas outside their own
area of responsibility to build a broader base of staff expertise,
perspective, and understanding of how the organization works as
a team.
- Provide training about the self-assessment process.
- Agencies are encouraged to provide all members of the Head Start
community with information concerning the purposes of the self-assessment,
the agency's preferred methods of accomplishing an assessment,
and the agency's policy on confidentiality. Members of the self-assessment
team can be assigned specific roles and be trained for those roles.
- Assess the program
- by collecting information about program practices, and comparing
that information with the goals and objectives established in
program plans and with the Head Start Program Performance Standards
and other relevant Federal, Tribal, State, and local regulations.
All aspects of program operations can thus be evaluated. Agencies
are encouraged to draw upon a variety of monitoring tools, in
addition to the Head Start Program Performance Standards and monitoring
instruments used by the Federal government, to help them with
their task.
- Analyze and share findings.
- Agencies are encouraged to analyze assessment findings and to
openly discuss what the data have to say about agency strengths,
weaknesses, and accomplishments with staff, policy groups, and
governing bodies. Grantee agencies also may consider sharing self-assessment
findings with Regional Office staff, before Federal reviews, in
order to improve linkages between self-assessment and Federal
monitoring processes.
- Develop and implement action plans.
- Strong action plans identify the specific steps that agencies
need to take in order to build on program strengths and to implement
the changes necessary to correct areas of weakness. Plans indicate
where responsibility for change lies and the time frames in which
change should occur.
- Make evaluations ongoing.
- The impact of proposed changes are evaluated during subsequent
self-assessments, to ensure that the results of the changes are
beneficial to the program and to the children and families served.
Rationale:
Ongoing, regular monitoring by grantee agencies helps to assess grantee
and delegate operations, to ensure that necessary steps are being
taken to meet Federal regulations as well as local goals and objectives,
and to ensure that appropriate interventions are taken in a timely
manner. Ongoing monitoring also helps to build trust and strong partnerships
between grantee and delegate agencies, which allow them to share best
practices and program strengths and to support one another's progress
toward program excellence.
Related Information:
See 45 CFR 1304.51(h)(1) concerning the maintenance of reporting systems
to control program quality and maintain program accountability. See
45 CFR 1304.51(d) and (e) on the maintenance of regular and effective
communication with governing bodies and policy groups and among staff.
Guidance:
Internal grantee monitoring is an ongoing process in which an agency
analyzes program reports, self-assessment findings, written plans,
and other important documents to determine whether its program of
services and fiscal operations are in compliance with Federal regulations.
Grantees with delegate agencies are encouraged to use their own
monitoring responsibilities as an opportunity to build cooperative
relationships between grantee and delegate agency staff. Strategies
that help agencies build these interdependent relationships include:
- Holding regular meetings between the staff of each agency, to
decide how the groups can best work together to support one another's
program goals and services;
- Ensuring the participation of grantee agency staff and parents
on the self-assessment teams of delegate agencies, as well as
on those of their own programs; and
- Providing training and technical assistance in areas identified
by grantee or delegate agency staff or governing bodies.
Related Information:
A process for appeals to grantees by current or prospective delegate
agencies is established in 45 CFR Part 1303, Subpart C; 45 CFR 1304.60,
and 45 CFR 1304.61.
Guidance:
In order to assist delegate agencies' governing bodies in their oversight
responsibilities, grantee agencies:
- Develop strong cooperative partnerships with delegate agencies
that allow grantees to support delegates' efforts to reach their
goals and to both implement quality services and identify problems
early (see 45 CFR 1301.51(i)(2) for additional information);
- Establish mentoring relationships so that well-performing delegate
agencies assist those who are performing less well;
- Promptly inform delegate agency governing bodies of any problems
identified through the grantee agency's work with and review of
the delegate agency programs or through the Federal monitoring
process;
- Enter into dialogue with delegate agencies to address any disagreements
about identified deficiencies;
- Work with delegate agencies to set priorities for addressing
areas of deficiency in delegate agency operations, including the
development of the quality improvement plan (QIP);
- Establish schedules to ensure that deficiencies in delegate
agency operations are corrected in a timely manner; and
- Specify the consequences of deficiencies that are not corrected
and mutual grantee and delegate agency responsibilities for correcting
them.
Last Modified:
09/20/2004
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