COVID-19 OHS / Federal Resources
Guidance from the Office of Head Start (Federal)
Temporarily Repurposing Head Start and Early Head Start Centers: Partnering to Support Emergency Child Care During the COVID-19 Crisis
The Office of Head Start (OHS) has received many inquiries about temporarily repurposing Head Start and Early Head Start centers closed due to Coronavirus Disease 2019 (COVID-19) to provide child care primarily for children of medical staff and others engaged in responding to the COVID-19 emergency. Local Head Start programs have also been asked to offer staff to care for these children.
First, we want to acknowledge that Head Start programs have always been strong community partners, particularly when disaster strikes. One example, among many, is the critical role that programs played in the wake of Hurricane Katrina. COVID-19 challenges and threatens each individual and community in ways we have never experienced. Because of the unique nature of this threat, activities in which Head Start has willingly engaged may not always be applicable to this growing pandemic.
We expect Head Start programs, even during program closures, to continue to support enrolled children and families in creative and innovative ways. Services during closures include ensuring that enrolled children continue to receive nutritious meals, and that child development and learning experiences and family engagement continue, to the extent possible. We have already heard amazing examples of how programs are continuing to support their children and families in creative ways.
That said, we know many programs are being asked to do more—well beyond their Head Start responsibilities. To support them in their decision-making about taking on responsibilities beyond their Head Start population, we have developed a set of frequently asked questions, which address some regulatory issues, health and safety concerns, and matters of capacity and liability.
Q1: Can Head Start funds be used to support non-Head Start activities during a disaster or pandemic?
A1: No, OHS does not have regulatory or statutory flexibility to approve the use of Head Start funds for non-Head Start services. By law, Head Start funds can only be used to provide Head Start services to eligible children and families.
Q2: If the local Head Start program is closed, can the Head Start program use its facilities and staff to provide emergency child care for first responders' children?
A2: Head Start staff employed by grantees with closed centers should continue to be paid by Head Start. This continued employment is critical to programs' continuity of operations and ability to reopen for children as soon as it is safe to do so. To the extent possible, staff are expected to be engaged in supporting ongoing services to enrolled Head Start children and families. Just as schools are continuing to pay staff and do distance learning, and businesses are continuing with telework, Head Start programs are operating through similar accommodations. We acknowledge that engagement will vary from staff to staff and program to program; however, OHS has directed grantees to continue to pay staff and cover their benefits while programs are closed.
If a grantee offers or directs Head Start staff to support emergency child care operations in its own facilities, Head Start dollars cannot be used for salaries or any other costs associated with the child care operation. Head Start staff may receive wages for hours worked in another child care program, but only if the work they do is outside of the time they are expected to be available to support ongoing services to Head Start children and families. For example, a Head Start teacher working a late afternoon or night shift in an emergency child care setting would be working outside of the normal time for Head Start services and, thus, would be able to pay from the child care organization for that time.
Q3: If the local Head Start facilities are closed, can facilities be leased to another entity with their own emergency child care providers to care for first responders' children?
A3: Yes, Head Start facilities could be used for childcare in the circumstance described in the question. However, no Head Start funds could be used in these arrangements. If a grantee temporarily leases Head Start space to another entity to offer child care to first responders, there are legal, fiscal, and logistical implications.
Head Start grantees must consider these issues carefully when making these decisions:
Legal implications: Head Start programs must ensure lease or use agreements with other child care providers using their buildings expressly allow for quick resumption of Head Start services when it is safe for Head Start staff and children to return to the facilities. Ensuring replacement of materials, and reimbursement of costs associated with damaged equipment should also be covered in the lease or use agreement. Grantees should not have to bear the burden of legal costs related to leases.
Fiscal implications: Since no Head Start funds can be used for non-Head Start services, Head Start programs must ensure that costs for rent, utilities, supplies, and any other costs of operating the temporary childcare program are covered by the lease or use agreement.
Practical implications: The Head Start facility may not have age-appropriate settings for the children who need care. For example, Head Start centers for preschool-aged children may not be age appropriate for infants, and they may not be age appropriate for older school-aged children. Early Head Start classrooms may not be appropriate for children other than infants and toddlers. Those considering these decisions may wish to take these factors into account.
It is also important that safety and infection control issues be considered. We refer those considering such arrangements to U.S. Centers for Disease Control and Prevention (CDC) guidance on child care facilities (forthcoming/currently in review).
Licensing implications: Many Head Start facilities are license-exempt. The licensing entity would need to determine whether a temporary child care program would need to be licensed. If so, the Head Start program should ensure that it would not lose its license-exempt status for the facility once Head Start resumes.
In some states, Head Start facilities are tax-exempt because the organizations operated as non-profits and services are free to participants. If a temporary child care provider operates as a for-profit entity, it must be clear that the tax-exempt status is not jeopardized.
Q4: What are some of the health and safety concerns related to this request?
A4: While Head Start programs have provided support to communities through many natural disasters such as hurricanes and floods, this situation is much different. Programs are not reacting in the aftermath of a disaster, but are trying to reduce the spread of a virus by limiting contact among people. That is the basis for schools and other community closures. We must all bear this distinction in mind as we work together to meet critical ongoing needs. We must also recognize that first responders, medical professionals and support staff, and certain other workers are vital to response, and many do need child care. Balancing these priorities is a critical challenge.
Finally, while grantees may choose to lease their space, they may also assume some oversight of the operation. If the grantee is engaged in any way in the oversight of operation, they are obligated to report to the local authorities any incidents of maltreatment, lack of supervision, or child abuse.
- Head Start grantees should have emergency preparedness plans in place and should defer to their own local procedures first and foremost.
- OHS Information Memorandum on General Disaster Recovery Flexibilities. The IM reviews the levels of flexibility that grantees may have during large scale events/disruption to services.
- OHS has directed all grantees to follow the guidance from your state and local lead agencies. Kentucky COVID-19 CHFS Guidance and CDC guidance.
- Stay in close contact with your Region IV OHS Program Specialist if it becomes necessary to close a Head Start/Early Head Start Center or if you have questions just as you would with any other weather or disaster related incidents.
In response to COVID-19, OHS is advising grantees to coordinate with local health authorities and implement their existing policies and procedures related to closure of Head Start and Early Head Start centers during infectious disease outbreaks. Closure of centers in areas heavily impacted by COVID-19 is an important element of containing and limiting its spread. Many Head Start and Early Head Start programs are following the lead of school systems and local health authorities and closing centers. If program operations are impacted by the COVID-19, please reach out to your Regional Office to inform them of any programmatic changes.
COVID-19 Wages and Benefits
In addition to the general flexibilities in ACF-IM-HS-19-01, the Office of Head Start (OHS) is providing the following additional flexibility regarding wage and benefits for employees impacted by Coronavirus Disease 2019 (COVID-19) closures. In response to COVID-19, OHS is advising grantees to coordinate with local health authorities and implement their existing policies and procedures related to closure of Head Start centers during infectious disease outbreaks. Closure of centers in areas heavily impacted by COVID-19 is an important element of containing and limiting its spread. In recognition of the unique circumstances associated with COVID-19, OHS is directing programs to continue to pay wages and provide benefits for staff unable to report to work during center closures necessary to address COVID-19. During center closures, employees should continue to engage families and to deliver services to the extent possible, remotely. This additional emergency response flexibility is important to ensure critical grants management activities can continue during closures. It will help ensure staff are ready and able to return to work as soon as it is possible to resume operations. This flexibility remains in effect through April 30, 2020 unless further extended by OHS.
Child and Adult Care Food Program (CACFP) Flexibilities
There has been some confusion around the question of whether or not Head Start and Early Head Start programs are permitted to provide meals (grab-and-go, drop-off, etc.) when the program is otherwise closed. NHSA has been working with a variety of federal agencies to address this question and have shared the following guidance:
- Under current statute, USDA (or states) does not have authority to allow Head Start programs to participate in "non-congregate" feeding (grab and go, drop-off etc.). Apparently guidance they put out last week was a bit convoluted and implied child care/head start when it should have only been addressing schools (and summer feeding sites). That said, the authority required to do so is included in House-passed legislation that the Senate is voting on this afternoon (which is expected to pass; 3/18/20). USDA is expected to release guidance/a letter as soon as that is finalized.
Food Program Guidance from OHS
Head Start and Early Head Start programs may provide meals and snacks to children during center closures. The U.S. Department of Agriculture (USDA) has waived its group setting meal requirement for closed schools and authorized special flexibilities for many states. These waivers include the Child and Adult Care Food Program (CACFP). Grantees may work with their state CACFP agency to determine whether similar flexibilities that can support the ongoing availability of meals and snacks for enrolled children are available during Head Start and Early Head Start program closures. In the event of an extended center closure, perishable food should be safely disposed of in a way that minimizes waste, such as donation to a local food bank or distribution to enrolled families.
CACFP, funded through USDA, covers most of the cost of meals and snacks for enrolled Head Start and Early Head Start children. A program must use funds from the USDA Food, Nutrition, and Consumer Services child nutrition programs as the primary source of payment for meal services. Head Start and Early Head Start funds may be used to cover those allowable costs not covered by the USDA.
The Office of Head Start (OHS) reminds programs in affected areas to follow local guidance from health departments and other authorities, including not working when sick, social distancing, and group size limitations. Possible strategies for providing food to children during center closures include the following:
- Programs could assemble bags of food, including formula for enrolled infants, and deliver them to homes in agency school buses or other agency vehicles. Families could come out to collect the bags or they could be delivered to the door.
- Food could be assembled and families could pick it up at a center or other location. Care should be taken to avoid large groups and prevent anyone who is sick from coming to collect food. This could include a "drive-through" station in areas where families have cars.
- Programs could check with local schools, churches, or other community organizations to see if there are partnership opportunities to increase the efficiency of food distribution.
While we often think of disasters as natural events such as hurricanes and earthquakes, health emergencies can also form the basis of a disaster declaration. The guidance from ACF-HS-IM-19-01 General Disaster Recovery Flexibilities can be applied to Head Start and Early Head Start programs impacted by Coronavirus Disease 2019 (COVID-19).
As OHS becomes aware of other flexibilities, we will share it with programs. We encourage Head Start and Early Head Start agencies to meet the needs of affected children and families while keeping staff and families safe. If you have any questions about how to best use grant funds, please contact your Regional Office. In addition, please let OHS know what you are doing to support your children and families during this challenging time on Twitter, using #HeadStartHelps and tagging @OHS_Director.