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INTRODUCTION TO 1304.52

The objective of 45 CFR 1304.52 is to ensure that grantee and delegate agencies recruit and select dynamic, well-qualified staff who possess the knowledge, skills, and experience needed to provide high quality, comprehensive, and culturally sensitive services to children and families in the program. Striving for continuous improvement, Head Start offers staff, as well as consultants, volunteers, and members of policy groups and governing bodies, opportunities and support for ongoing training and development.

Head Start is committed to establishing a learning environment in which children, parents, and staff can teach and learn from one another. This section discusses the organizational structure of agencies, staff qualifications, classroom staffing and home visitor requirements, staff standards of conduct, staff performance appraisals, and staff and volunteer health requirements. Training and development for staff, consultants, volunteers, and members of policy groups and governing bodies also are discussed.

Rationale:

An organizational structure describes how staff and functions are organized to fulfill the program's mission and goals. That structure also may describe how Head Start fits into a larger agency. A well-developed organizational structure establishes clear lines of communication and supervision, helps individuals understand their jobs, and assists staff in the smooth running of the agency. This rationale serves 45 CFR 1304.52(a)(1).

Related Information:

See 45 CFR 1301.31 for requirements regarding personnel policies, and 45 CFR 1306.20 for requirements concerning staffing patterns. See 45 CFR 1304.50, Appendix A: "Governance and Management Responsibilities." for further information regarding the functions and responsibilities of Head Start policy groups.

Guidance:

A grantee or delegate agency's organizational structure may be formulated in many different ways, depending upon the results of the agency's planning process and other requirements set by Federal, State, Tribal, or local regulations. To define their own structure, staff may look first at how Head Start fits into the larger agency of which it is a part, and describe (in words or through an organization chart) where Head Start belongs. Next, staff may describe the structure and staff functions within the Head Start or Early Head Start program itself. They also may prepare a narrative on some of the topics listed below:
  • descriptions of the grantee agency and its departments, including the programs the agency sponsors and the support services it offers, as they relate to the Head Start program,
  • a description of each staff position, including the knowledge, skills, and experience required, and an explanation of the lines of authority and supervision among positions,
  • program staffing, including how the grantee or delegate agency ensures that teacher:child ratios are met, and
  • Policy Council and Policy Committee functions, including relationships among policy groups, governing bodies, and key management staff in both the grantee and delegate agency.

Rationale:

Sound and rational program management requires that responsibilities of staff be clearly stated and that someone be placed in charge of major functions. The way in which the agency chooses to assign these functions to staff is up to the individual agency. Each agency, however, has someone designated as the Head Start director to provide the program with vision and leadership, and to ensure management functions are properly carried out. This rationale serves 45 CFR 1304.52(a)(2)(i)-(iii).

Guidance:

The responsibilities of the Head Start director depend upon the community, staff, and families served, the mission and structure of the organization, and the plans for the delivery of program services. Governing bodies consider the director's responsibilities in areas such as:
  • communication, including interactions with the governing body, agency director, managers of other agency programs, the Policy Council, the Policy Committee, and parents,
  • program planning,
  • day-to-day program management and operations, including personnel administration and supervision,
  • staff training and development, coaching, and mentoring,
  • administration and maintenance of facilities, materials, and equipment,
  • financial administration,
  • assessment of staff and program operations, and
  • community relations and advocacy.

Guidance:

Agencies define the roles of individuals who will manage the delivery of services to children and families. Agencies assess their own size and complexity, geographic factors, and program goals and options as they determine the staffing patterns and job responsibilities of their managers. In some agencies, it may be appropriate to assign the management functions to several individuals, each with responsibility for a discrete portion of services. Regardless of the choice of organizational structure and job titles, this level of management is responsible for leadership, direction, and oversight in areas such as:
  • planning, development, and implementation of operational procedures for the area of service,
  • analyses of trends in the field, as well as data on children and families in the program,
  • community linkages, to locate and access resources for families,
  • staff and parent communication,
  • personnel administration and supervision of staff, and
  • team leadership, team building, staff training and development.

Rationale:

One of the most important determinants of program quality is having qualified staff who interact with children and families and who ensure the provision of quality services. This rationale serves 45 CFR 1304.52(b)(1)-(2).

Related Information:

See 45 CFR 1301.31 for a description of the personnel policies to be used in the hiring process.

Guidance:

The responsibility for ensuring that all staff and consultants have the appropriate knowledge, skills, and experience lies with grantee and delegate agency management in coordination with the appropriate policy groups. In considering the appropriateness of employing a staff member or retaining a consultant's services, managers consider the individual's:
  • training or experience in the area of expertise required by the position,
  • experience in a human services setting, including working with low-income children and families,
  • interpersonal and communication skills, as needed for the position,
  • awareness of and sensitivity to cultural issues and local community practices, including Tribal policies, where appropriate, and
  • education related to the program's requirements for the position.
  • Agency management also take a proactive approach to finding and developing staff. On an ongoing basis, agency staff explore the community to identify individuals who would make successful staff members. They also adopt strategies (e.g., an ongoing mentoring program) to help develop the skills and knowledge of parents and staff already working in the program who wish to advance.

Rationale:

Parents are a vital resource for Head Start, because they are familiar with the Head Start philosophy and services, and because they are familiar with their community. The agency also is an important place for employment opportunities for parents and a vehicle for providing additional skills for parents who are seeking employment or who are already employed. Parents employed by Head Start serve as role models and mentors for other parents. This rationale serves 45 CFR 1304.52(b)(3).

Guidance:

Ways to support and encourage the parents of currently or previously enrolled children to apply for positions for which they qualify include:
  • Providing opportunities for parents to receive skill-development or on-the-job training as part of the agency's parent involvement activities;
  • Posting job vacancies in program settings, the newsletter, and in locations in the community such as churches and other religious centers, schools, clinics, laundromats, and stores; and
  • Describing to parents how they can become qualified for various positions.

Rationale:

To establish an atmosphere of recognition and respect for the beliefs and practices of others, staff and consultants become familiar with the history, traditions, beliefs, and institutions of the cultures in the community served by the program. To meet the needs of families and children, staff and consultants communicate with them in their own language, to the extent possible. This rationale serves 45 CFR 1304.52(b)(4).

Related Information:

See 45 CFR 1304.51(c)(2) on communicating with parents in their primary or preferred language, and 45 CFR 1304.52(g)(2) regarding appropriate staffing strategies for bilingual staff.

Guidance:

Agencies ensure that staff and consultants are familiar with the background and heritage of families in the program by:
  • Recruiting qualified, bilingual staff and consultants who are culturally and ethnically diverse, thus ensuring an appropriate representation of the ethnicities and cultures of enrolled families;
  • Using current and past parents and staff as resources for understanding different cultures;
  • Making use of museums, libraries, artists, poets, writers, storytellers, musicians, and community theater groups to help staff and parents appreciate and enjoy diverse cultures;
  • Offering staff development in anti-bias strategies and approaches to developing skills in accepting cultural differences and in conflict resolution; and
  • Exploring the feasibility of sponsoring joint staff training in issues of cultural diversity with organizations such as local schools, social service groups, and other early childhood development programs.

Rationale:

Leadership and management skills and abilities are essential to overseeing the staff and operations of a comprehensive, quality child and family program. This rationale serves 45 CFR 1304.52(c).

Guidance:

To ensure that an appropriately qualified director is employed, agencies require that the director possess the following attributes:
  • leadership ability,
  • good interpersonal and communication skills, including the ability to work as part of a team, communicate effectively both orally and in writing, receive and provide feedback, and manage dynamic interchanges in meetings,
  • the ability to develop and manage a budget,
  • experience in human services program management, including program planning, operations, and evaluation, and the use of management information systems, and
  • an understanding of the Head Start philosophy and the ability to implement its principle of shared authority and decision-making.

Agencies also may choose to specify levels of education, knowledge, or experience in substantive areas, such as theories of early childhood education and child development or techniques for working in partnership with families and for involving parents in program activities.

Rationale:

Head Start requires that content area experts have specialized knowledge, skills, and experience, and are able to provide oversight that ensures quality services are delivered to children and families. Content area experts can either be on staff or be consultants. This rationale serves 45 CFR 1304.52(d)(1)-(8).

Guidance:

Agencies consider the qualifications of staff and consultants in all content areas to ensure that they support the implementation of a quality program. Agencies have the flexibility to organize staffing patterns in the way most effective for their families. Agencies may choose to employ an individual as a content area expert for each area discussed in the standards; or, agencies may combine content areas. Staff and consultants are available, on an ongoing or regularly scheduled basis, to implement their program area.
  • To ensure that appropriately qualified content area experts are available, agencies employ individuals with the ability to:
  • Plan and administer the required program of services for children and families;
  • Coordinate their program of activities with staff in other content areas and in other community agencies;
  • Engage in ongoing assessment of the quality of services provided;
  • Communicate effectively with others, including giving and receiving feedback on the quality of services;
  • Cooperate successfully as a member of a team;
  • Provide staff training and development, including on-site consultation, coaching, and mentoring to other staff;
  • Furnish supervision for ongoing program development; and
  • Meet any specific content area requirements.

Related Information:

Content area experts in education services must meet the qualifications for classroom teachers specified in section 648A of the Head Start Act, which include:
  • a current Child Development Associate (CDA) credential that is appropriate to the program option(s) used and to the age of the children served, or
  • a State-awarded certificate for preschool teachers that meets or exceeds the requirements for a CDA credential, or
  • an associate, baccalaureate, or advanced degree in early childhood education, or
  • a degree in a field related to early childhood education, with experience in teaching preschool children and a State-awarded certificate to teach in a preschool program.

Guidance:

To ensure that appropriately qualified content area experts in education and child development services are employed, agencies require the general abilities defined in the guidance to 45 CFR 1304.52(d), above, and other specific abilities, such as to:
  • Guide the planning and implementation of a comprehensive child development program that meets the Head Start definition of curriculum in all program options and settings;
  • Put into practice theories and sound principles of child and adult education; and
  • Embrace the role of the parent as the primary educator of the child and promote and support attachment between parent and child.

Guidance:

To ensure that appropriately qualified content area experts in health services are employed, agencies require the general abilities defined in the guidance to 45 CFR 1304.52(d) and other specific abilities, such as to:
  • Link families with an ongoing system of health care, assist parents in the selection of health providers, counsel them about child or family health problems, and promote parent involvement in all aspects of the health program;
  • Negotiate with the Health Services Advisory Committee and local health care professionals and service providers to ensure that services for families are available and accessible;
  • Review, evaluate, and interpret health records and other vital health service data; and
  • Promote health and safety practices in the program and coordinate safety and sanitation procedures, first aid, and emergency medical procedures.

When health staff perform screenings, immunizations, or other health procedures for children, which, by State or Tribal regulation, require the services of a licensed or certified health professional, the agency must employ or contract with individuals possessing those credentials and provide appropriate oversight.

Guidance:

To ensure that appropriately qualified content area experts in nutrition services are employed, agencies identify individuals with characteristics such as the following:
  • experience in menu planning, including the quantity, quality, and variety of food to be purchased;
  • the abilities to interpret nutrition assessment data, provide nutrition counseling for families, and in other ways promote good nutrition habits among children and families; and
  • expertise to assist staff in dealing with children with feeding problems or special nutritional needs.

Agencies that directly provide nutrition services ensure that the employee responsible for those services or the nutrition consultant who supports this staff member possesses a current registration with the Commission on Dietetic Registration of the American Dietetic Association or be eligible, registered, and ready to take the examination. A master's degree (MPH or MS) from an approved program in public health nutrition may be substituted for this registration. Agencies that contract for nutrition services ensure that staff in the agency with which they have contracted possess the necessary qualifications.

Guidance:

To ensure that appropriately qualified mental health professionals provide services to enrolled children and families, agencies identify individuals with characteristics such as the following:
  • knowledge of treatment strategies in the areas of child behavior management and family crisis intervention,
  • the ability to work with families in a supportive manner throughout the diagnostic and referral processes,
  • the ability to work with staff to improve their own health and they, in turn, provide supportive services to families, and
  • the ability to broker the services or to provide counseling and treatment for children and families with diagnosed problems.

In addition, agencies need to ensure that mental health staff and consultants have appropriate State, Tribal, or local license(s) or certification(s).

Guidance:

To ensure that appropriately qualified content area experts in family and community partnerships are employed, agencies hire individuals with the abilities defined in the guidance to 45 CFR 1304.52(d), above, and other specific abilities, such as to:
  • Develop referral systems and procedures and coordinate social service referrals and follow-up;
  • Provide on-site consultation to family and community partnerships staff;
  • Oversee transition services (see 45 CFR 1304.40(h) and 45 CFR 1304.41(c) for descriptions of required transition activities); and
  • Conduct advocacy work.

Guidance:

To ensure that appropriately qualified content area experts in parent involvement services are employed, agencies require individuals with specific abilities, such as to:
  • Oversee the recruitment, training, and scheduling of parent volunteers;
  • Work with the Policy Council and Policy Committee, and serve as a resource for the Parent Committee;
  • Assist parents in developing and scheduling their own social and developmental activities and encourage and support parents in addressing community needs; and
  • Keep other agency staff apprised of parent issues, and assist staff in designing and implementing a comprehensive, well-integrated plan for parent involvement that crosses all service areas.

Related Information:

See 45 CFR Part 1308 for further requirements for content area experts in disability services. In particular, see:
  • 45 CFR 1308.4(m) for the role of the disabilities coordinator in the development of the service plan;
  • 45 CFR 1308.6 for the involvement of the disabilities coordinator in the assessment of children;
  • 45 CFR 1308.18(a) for the requirement that the disabilities coordinator work closely with health staff during the assessment process and any follow-up activities;
  • 45 CFR 1308.18(b) for the requirement that the disabilities coordinator work with the mental health staff and consultants to identify children who show signs of problems;
  • 45 CFR 1308.19(f) for membership on any Head Start Individualized Education Program (IEP) teams; and
  • 45 CFR 1308.20(a) for the requirement that the disabilities coordinator ensure that the nutrition program meets the special needs of children with disabilities.

Guidance:

To ensure that appropriately qualified content area experts in disability services are employed, agencies identify individuals with specific abilities, such as to:
  • Coordinate the process of assessing children, including initial screenings, ongoing developmental, and specialized assessments, to determine if a disability exists;
  • Work with an interdisciplinary team of staff and parents to develop and implement an Individualized Education Program (IEP) or Individualized Family Services Plan (IFSP) for each child with disabilities;
  • Consult regularly with parents and staff on the progress of disabilities services and of the children with disabilities who are enrolled;
  • Work closely with local school districts to ensure the coordination of services; and
  • Advocate in the community for appropriate services for children with disabilities and their families.

In addition, agencies ensure that disabilities staff have a thorough understanding of Federal laws governing services to children with disabilities.

Guidance:

To ensure that an appropriately qualified fiscal officer is available, agencies employ staff or consultants with specific abilities, such as to:
  • Develop, monitor, evaluate, and report on financial control programs and procedures, including compensation and benefits, to policy groups and staff;
  • Develop and maintain accurate charts of accounts, including the allocation of program income and outlays and in-kind contributions;
  • Initiate and direct, in coordination with other staff and parents, cost studies and comparative analyses of alternative operating strategies; and
  • Assist in the resolution of audit exceptions and the implementation of auditors' recommendations and report all findings to management staff and governing bodies.

Qualified fiscal officers include Certified Public Accountants (CPAs), persons holding a bachelor's or master's degree in accounting, and others with demonstrated expertise in fiscal matters. They may be hired directly as Head Start staff (on a part-time or full-time basis), be provided by the grantee or delegate agency as a part of the indirect cost pool, or work under contract on a regularly scheduled basis.

Rationale:

The home visitor's role is that of a resource for parents and a facilitator for learning, in agencies that operate a home-based or combination option. Training and experience in the variety of topic areas listed in the standard are necessary to implement a high quality program. This rationale serves 45 CFR 1304.52(e).

Related Information:

See Head Start Home Visitor Handbook for further guidance.

Guidance:

To ensure that appropriately qualified home visitors are employed, agencies require specific abilities, such as to:
  • Plan and develop with the parents an individualized program for the family, including establishing a caring professional relationship and a climate of mutual trust and respect for the parents;
  • Work with parents to strengthen the family's knowledge of child development, including assisting parents to understand how children grow and learn, and planning and conducting child education activities with the parents which meet the child's intellectual, physical, emotional, and social needs;
  • Assist parents in strengthening the families' knowledge of health and nutrition, including integrating health and nutrition education into the program, coordinating with other staff and parents regarding health screenings for family members, and providing information and referrals, if necessary; and
  • Assist parents to strengthen their knowledge of community resources and support parents in problem solving.

In addition, grantees may require a Child Development Associate (CDA) for Home Visitors, certain college course work, or a particular level of on-the-job training and experience.

Rationale:

Working with infants and toddlers requires specialized knowledge and skills in order to properly address the developmental needs of this age group. This rationale serves 45 CFR 1304.52(f).

Guidance:

Within one year of the effective date of the Final Rule or, thereafter, within one year of hire, staff working with infants and toddlers must obtain a Child Development Associate (CDA) credential for Infant and Toddler Caregivers or an equivalent credential or educational degree that addresses comparable competencies. Teachers who work well with infants and toddlers also have certain specific abilities, such as to:
  • Maintain an open, friendly, and cooperative relationship with each child's family, encourage their involvement in the program, and promote parent-child bonding and nurturing parent-child relationships;
  • Promote feelings of security and trust in infants and toddlers by being warm, supportive, and comforting, and by establishing strong and caring relationships with them;
  • Provide toddlers with experiences and opportunities that allow them to develop curiosity, initiative, problem-solving skills, and creativity, as well as a sense of self and a feeling of belonging to the group; and
  • Conduct developmental screenings of infants' and toddlers' motor, language, social, cognitive, perceptual, and emotional skills.

Rationale:

Research shows that classroom staffing patterns have a powerful effect on program quality. Low child:staff ratios are associated with more positive outcomes for young children and generate more positive social interactions with peers. This rationale serves 45 CFR 1304.52(g)(1).

Related Information:

See the requirements for program staffing patterns, as specified in 45 CFR 1306.33 for home visitors in the home-based program option, and 45 CFR 1306.20 for center-based preschoolers. See 45 CFR 1304.52(g)(4) for staffing and group size requirements for infants and toddlers.

Guidance:

Agencies plan their staffing to ensure that appropriate child:staff ratios are maintained at all times of the day and in all locations, and that staff are allowed adequate time for planning, record-keeping and training. This is especially important in full-day programs, when the numbers of children may change over the course of the day, but the ratios need to be maintained.

Rationale:

Classroom staff members and home visitors who speak a child's home language provide reassurance to the child, support the child's development of a strong sense of identity, and show respect for the values and beliefs of the family. This rationale serves 45 CFR 1304.52(g)(2).

Related Information:

See 45 CFR 1304.21(a)(3)(i)(E) and the Multicultural Principles for Head Start Programs for suggestions on how to show support and respect for a child's home language.

Guidance:

Agencies hire staff who, in addition to speaking English, speak the language of the majority of the children served. Sometimes it is difficult to find qualified bilingual staff who have been trained and certified in early childhood education. To increase the number of qualified adults, agencies:
  • Provide or arrange for staff training to develop needed language skills as a step toward becoming bilingual;
  • Temporarily use parent or community volunteers to facilitate communication;
  • Aggressively recruit staff from community colleges or nearby universities; and
  • Contact community organizations that represent the culture and language of the families served.

Rationale:

Occasions arise in which substitutes are needed to maintain appropriate class sizes and appropriate child:staff ratios, and to ensure that children are always safe. This rationale serves 45 CFR 1304.52(g)(3).

Guidance:

Agencies have less trouble locating substitutes on short notice, if a list of trained area substitutes is maintained. In addition, agencies:
  • Take advantage of a professional referral service that screens potential substitutes;
  • Talk with representatives in other community agencies and with senior citizens and other groups to find substitutes;
  • Join with other early childhood programs in the community to hire a substitute who rotates among these programs; or
  • Consider using parents who are engaged in a training program in early childhood education or develop a training program in early childhood education for parents and volunteers.

Substitutes work under the direct supervision of the content area expert in education, the center director, or another appropriate staff member while they are in the classroom.

Rationale:

Research indicates that having each staff member work with a small number of infants and toddlers is critical for the development of the child and to the quality of the program. This rationale serves 45 CFR 1304.52(g)(4).

Related Information:

See 45 CFR 1304.53(a) concerning Head Start facilities, especially the minimum space requirements established in 45 CFR 1304.53(a)(5).

Guidance:

Agencies ensure that they meet the required child:staff ratios by hiring an appropriate number of trained and qualified teachers and by developing daily staffing plans. In addition, as children grow older and transition to new groups, agencies may choose to move the teacher along with the children.

A group of eight is the maximum number of infants and toddlers assigned to two teachers. In some facilities, space allows a group of eight to be assigned to one room. In other facilities, larger rooms are fitted with appropriate dividers to accommodate more than one group, while ensuring that each group functions separately, and that all of the Program Performance Standards are maintained.

Rationale:

Most of the injuries that occur in preschool programs take place in play areas where children try out their gross motor skills. Staff ensure that all children can be observed to prevent mishaps and so that they can be quickly reached, should any mishap occur. This rationale serves 45 CFR 1304.52(g)(5).

Related Information:

See 45 CFR 1304.52(h)(1)(iii) and 45 CFR 1304.53(a)(9) for further information on the supervision of play areas.

Guidance:

The following are some guidelines for the supervision of outdoor and indoor play areas:
  • Staff make regular checks of the safety and cleanliness of indoor and outdoor play areas, giving themselves time to address any problems they identify (45 CFR 1304.53(b)(1)(vi) specifies that all equipment must be kept safe and in good condition); and
  • Staff in center-based programs develop written schedules for play area supervision to ensure appropriate child:staff ratios are maintained at all times.

Home visitors discuss with parents how these same guidelines apply to the home environment and to public playground settings.

Rationale:

The provision of standards of conduct supports agencies in reinforcing appropriate professional behavior among staff. Written standards of conduct help to guide staff members in making decisions about their actions in potentially controversial or ambiguous situations; and they help protect staff against allegations of misconduct. This rationale serves 45 CFR 1304.52(h)(1)-(3).

Related Information:

Other information pertinent to standards of conduct may be found in the following resources:
  • 45 CFR 1301.31 on personnel policies and 45 CFR 1304.50(d)(1)(x) on the role of the Policy Council and Policy Committee in the approval of such policies;
  • 45 CFR 1304.24(a)(1)(iii) about discussing and identifying with parents appropriate responses to their child's behavior;
  • 45 CFR 1304.21(a)(1)(iii) on providing an environment that supports each child;
  • Multicultural Principles for Head Start Programs, for further guidance related to multicultural issues;
  • 45 CFR 1304.22(b)(3) on the confidentiality of child health conditions;
  • 45 CFR 1304.22(a)(5) on confidentiality relating to suspected child abuse or neglect;
  • 45 CFR 1304.51(g) on effective record-keeping to ensure confidentiality;
  • 45 CFR 1304.52(g)(5) and 45 CFR 1304.53(a)(9) on the supervision of outdoor play areas; and
  • 45 CFR 1304.21(a)(3), 45 CFR 1304.21(b)(2), and 45 CFR 1304.21(c)(iv) on supporting each child's social and emotional development.

Guidance:

Management staff review written policies and procedures to ensure that specific standards about appropriate staff behavior and actions are included, such as child discipline and the confidentiality of information. Guidelines for standards of conduct are a part of the agency's personnel policies, as required by 45 CFR 1301.31. Staff, volunteers, and consultants are introduced to the agency's standards of conduct during their initial orientation, and subsequently trained, if necessary, in the implementation of those standards. Agencies are encouraged to request that staff sign a statement of professional ethics at the beginning of their employment.

To ensure that children of all races, religions, family backgrounds, and cultures are treated with respect and consideration, staff:

  • Encourage adult male involvement in the classroom and other parts of the program;
  • Provide opportunities for intergenerational activities through use of grandparent volunteers and community elders;
  • Provide both boys and girls with equal opportunities to participate in all activities; and
  • Provide books, toys, music, activities, and decorations that reflect the diversity of all children.

To conform with Federal, State, Tribal, and local laws, the confidentiality policy ensures that:

  • Confidential information will be seen by and discussed only with staff members who can demonstrate a need for the information in order to perform their jobs;
  • Staff personnel records will not be disclosed without the written consent of the staff member; and
  • Staff have the right to examine their own personnel files and to respond to the contents of those files.

To determine the degree of supervision that children need and to assign staff members to supervise them, agencies ensure that children are under adult supervision at all times, that required child:staff ratios are maintained, and that no child is ever left alone or unattended.

To ensure the use of positive, non-punitive methods of guidance and discipline, staff:

  • Develop clear, reasonable, consistent, and age-appropriate rules and expectations for children and, to the extent possible, engage children themselves in the rule-setting process;
  • Work with children to help them solve problems, instead of imposing solutions;
  • Reduce the potential need for discipline by anticipating and eliminating sources of trouble whenever possible; and
  • Respect and acknowledge children's feelings.

Agencies provide staff, consultants, and volunteers with regular, ongoing training and mentoring in appropriate disciplinary techniques. Home visitors support parents in guiding children's behavior without using corporal punishment.

Guidance:

To ensure that employees deal appropriately with contracts and other financial awards, agencies define "significant monetary value" in their standards of conduct and request that staff sign a statement at the outset of their employment. In addition, agencies provide relevant staff, governing body, and Policy Council and Policy Committee members with training and supervision in proper methods for awarding and administering contracts or grants with outside agencies or businesses.

To ensure that all staff, consultants, and volunteers are accountable for meeting the agency's standards of conduct, agencies may consult with a legal advisor or a professional in human resources management to define the consequences for violating the standards of conduct. They also provide all staff with training that emphasizes the importance of the standards of conduct and the consequences of breaching them.

Rationale:

All Head Start staff should be actively engaged in a process of professional development. Annual performance reviews provide one opportunity for staff and supervisors to meet, discuss and assess progress, define training and developmental needs, and set new professional goals. This rationale serves 45 CFR 1304.52(i).

Related Information:

Performance appraisals are a part of the personnel policies required by 45 CFR 1301.31. Further requirements concerning training and development may be found in 45 CFR 1304.52(k).

Guidance:

Staff performance reviews are a management process consisting of a number of formal and informal interactions, such as:
Setting standards of performance.
All staff members may benefit from the opportunity to meet with their supervisors and to discuss each others' expectations and goals for subsequent months. One way to make expectations and goals clear is to draw up a performance agreement and to review it during subsequent performance reviews.
Gathering performance data.
There are a variety of ways to gather information on an employee's progress. Staff may keep a log of their own progress, including successes in their job, additional responsibilities they may have taken on, any awards or professional recognition they received, their attendance at training or educational programs, and even comments they have received about their activities from parents and peers, as well as supervisors. Supervisors also may keep an ongoing record of staff performance.
Conducting annual performance review.
Performance reviews should be positive exchanges that
  • acknowledge the achievement of past goals and promote the setting of realistic goals for the future,
  • demonstrate appreciation for employee contributions,
  • provide constructive feedback on employee work, and
  • identify employee training needs and professional development opportunities.


Rationale:

To ensure a safe and healthy environment for children and staff, all staff and regular volunteers should demonstrate that they are in good health. This rationale serves 45 CFR 1304.52(j)(1)-(2).

Related Information:

See the Americans with Disabilities Act and Section 504 of the Rehabilitation Act for specific instructions on requirements that employers may set for employee medical examinations. Employers are permitted to require employees to have medical examinations or to answer medical inquiries that are job-related and justified by business necessity. Inquiries about things that neither affect job performance nor pose a risk to the health or safety of the employee or others may not be sufficiently job-related or necessary.

Guidance:

Agencies consult with their Health Services Advisory Committee (HSAC) as well as obtain legal advice in developing a policy to implement this standard. The HSAC, the local Department of Public Health, or the public schools also may be helpful in determining the required examinations, in addition to the required screening for tuberculosis, and in the periodicity of re-examinations. However, agencies may choose to leave the decision up to each staff member's physician. Agencies may develop a standard form for staff to take with them to their health examination, ensuring first that the form meets the requirements of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.

Related Information:

See 45 CFR 1304.3(20) for a definition of "volunteer."

Guidance:

Everyone who volunteers on a regular basis in an Early Head Start or Head Start program must comply with State, Tribal or local laws regarding the screening for tuberculosis. (These laws may have specific definitions of the term "regular." If not, the agency should define the term.) In States and localities where tuberculin tests are not required for adults coming into contact with children, agencies should consult with the Health Services Advisory Committee regarding the need for the tuberculin screening of volunteers. Note that screening may not be necessary for the occasional volunteer (a person who comes in from time to time). However, agencies may offer tuberculin screening at a health fair or of a parent education activity as a way of promoting the identification and treatment of health issues among parents and volunteers.

Test results from the tuberculin screening are kept in confidential files. If an individual tests positive, agencies follow the protocols set out by the Centers for Disease Control and Prevention or the State, Tribe, or locality on how to manage communicable diseases. The applicable protocol should be available from the local Health Department. Agencies develop, with the assistance of their local Health Service Advisory Committee, policies that address volunteers who test positive to tuberculosis screening.

The Health Services Advisory Committee may suggest requiring other health screenings and procedures for volunteers and, in fact, State or Tribal requirements may mandate additional screenings or tests. For example, in most States and on American Indian reservations, volunteers who assist with food preparation must meet specific health clearance standards. Such information should be included in the volunteer plan or volunteer handbook, if the agency has one.

Rationale:

Caring for children and families with complex challenges can be taxing for staff and may generate problems such as stress and "burnout." Therefore, agencies should make special efforts to support staff and let them know that their job challenges are understood. This rationale serves 45 CFR 1304.52(j)(3).

Guidance:

In providing information on mental health and wellness, agencies consider implementing measures to assist staff in coping with job-related stress, such as:
  • Including topics or informational resources on job-related stress, mental health, and wellness in staff training and development activities;
  • Sponsoring mental and physical wellness programs, such as exercise groups or staff support groups;
  • Providing employees with information on or confidential referrals to community agencies, including community mental health centers and/or alcohol and drug counseling centers; and
  • Providing, or brokering, professional Employee Assistance Programs (EAPs).

Rationale:

One of the most important determinants of program excellence is the presence of a well-trained, qualified staff. In order for staff to do their jobs effectively and to meet the changing needs of the children and families served, agencies must have a system that supports staff in a process of continuous learning. A structured approach to continuous learning addresses both program philosophy and individual job requirements. Two critical areas to be addressed in this approach are child abuse and neglect and family and child transitions. This rationale serves 45 CFR 1304.52(k)(1)-(3).

Related Information:

Pre-service and in-service training opportunities are mandated by 45 CFR 1306.23 to assist staff and volunteers in acquiring or increasing the knowledge and skills required to fulfill their job responsibilities.

See 45 CFR 1304.52(b) for a description of staff qualifications; 45 CFR 1304.52(j) for requirements related to staff and volunteer health; and 45 CFR 1304.52(i) for the link between staff performance appraisals and staff development needs, and training.

See 45 CFR 1304.22(a)(5) on establishing local policies and procedures for the reporting of suspected child abuse and neglect, and 45 CFR 1301.31(e) and the Appendix to 45 CFR 1301.31 for requirements regarding child abuse and neglect. All staff need to be knowledgeable about their legal and professional responsibilities with regard to reporting suspected child abuse and neglect by parents, staff members, and others, in accordance with the provisions of Federal, State, Tribal, or local law.

See 45 CFR 1304.40(h) on parent involvement in transition activities. Also see 45 CFR 1304.41(c)(1)(iv) on the joint training of Head Start and other agency staff in transition services, and 45 CFR 1304.41(c)(2) concerning transition planning for children leaving Early Head Start.

Guidance:

Staff training and development is a continuous, creative process, individualized to meet the goals of each employee while responsive to the overall program. An effective training and staff development system includes an orientation as well as ongoing opportunities that develop each staff member's skills and knowledge. Strategies to support the implementation of this system range from individualized coaching to formal college course work.

The orientation process is critical for all new staff, consultants, and volunteers, and includes the goals and philosophy of Head Start and:

  • the mission and vision of the grantee,
  • an introduction to and an explanation of the Head Start Program Performance Standards and how they apply to the specific program options, settings, and services, and
  • program policies and procedures, including standards of conduct.

A structured approach to ongoing staff development:

  • Is ongoing and supports the individual needs of staff;
  • Builds on prior staff development activities and includes follow-up activities;
  • Links to employees' performance appraisals;
  • Uses a variety of approaches and current technology;
  • Builds on the principles of adult learning; and
  • Makes use of locally available resources.

To determine the elements of a training and development system, agencies consider the following process:

  • assessment of staff and program goals and needs,
  • design of a training and staff development plan,
  • implementation of the plan, and
  • evaluation of the process.

Each agency can decide the appropriate topics and target groups for its staff development opportunities through its assessment process. However, certain topics - specifically, child abuse and neglect and transition to and from Early Head Start or Head Start - are included in this structured approach.

Staff who have an ongoing relationship with families and are in families' homes on a regular basis need support concerning the issue of identifying and reporting suspected child abuse and neglect. To ensure that staff understand this responsibility, agencies:

  • Provide staff with a copy of relevant laws;
  • Organize a variety of training opportunities on how to identify and report child abuse and neglect; and
  • Assign one individual the responsibility of supporting staff in their efforts to prevent, identify, and report child abuse and neglect.

Examples of methods that support successful transitions include:

  • Preparing children and their families for transitions;
  • Assisting parents in advocating for their children in the school system and in exercising their rights and responsibilities concerning the education of their children;
  • Supporting parents in identifying and selecting child care;
  • Maintaining ongoing communication and cooperation between the Early Head Start or Head Start program and the elementary school or other child care setting by
    • encouraging elementary school or other child care teachers to visit Early Head Start and Head Start to understand its philosophy or encouraging joint training with elementary school teachers and other providers of child development services,
    • developing effective methods for transferring records, and
    • continuing transition activities throughout the year; and
  • Developing written transition plans, and individualizing the plans, as appropriate, to meet the needs of children with disabilities.

Rationale:

Governing body and policy group members must have information about Head Start to develop the knowledge and skills needed to make informed decisions and to understand their own roles in governing an effective program. This rationale serves 45 CFR 1304.52(k)(4).

Related Information:

See 45 CFR 1304.50 and Appendix A to that section for a discussion of the structure and function of the governing bodies and policy groups; see Linking Our Voices, a video-based training that is used for orientation and ongoing training of policy group members.

Guidance:

Agencies may use a variety of methods to familiarize members of the governing body and Policy Council or Policy Committee with Head Start and their program oversight responsibilities. These methods or strategies may include an orientation session for new members, video presentations, information packets, and staff presentations. Broad topics for orientation include:
  • the agency's history, mission statement, and organizational structure,
  • their roles and responsibilities in governing, organizing, and operating the program, and
  • the goals, underlying philosophy, and performance standards of Early Head Start and Head Start.

To ensure that the training of policy group members is not limited to initial orientation, but also includes ongoing training, grantee and delegate agencies should schedule policy group training activities on a regular basis. The availability of a variety of group and one-on-one training opportunities assists policy groups and individual members to build upon their existing skills and knowledge. It is important to support new policy group members through mechanisms such as establishing one-on-one mentoring programs and the building of training elements into every policy group meeting.

Last Modified: 09/20/2004

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