HSPPS and Program Governance
In the Office of Head Start’s (OHS) recent Showcase video on Program Governance, OHS noted that Program Governance is the first subpart of the HSPPS and that this should “send a message.” OHS also commented that “if the governance structure is not solid then a program is at risk.” If that doesn’t make you sit up and take note, how about this report to Congress noting that for FY 2014, failing to report to the governing body and policy council was the number one noncompliance finding, showing up on the reviews of nearly a quarter of grantees nationwide?
The new HSPPS provide the perfect opportunity to review your program’s policies and procedures to make sure they follow the Program Governance regulations and implement best practices. As you embark on your review, ask yourself these questions:
- Does our program get data in front of the governing body and policy council? The HSPPS require programs to use data to continuously improve outcomes. The governing body and policy council share this responsibility. Programs should have a procedure in place to ensure that data from their continuing assessments are effectively communicated to the governing body and policy council. The governing body and policy council, for their part, should be seriously considering the data and using it to make informed decisions. Ideally, the minutes for governing body and policy council meetings will clearly show this process.
- Has our program notified OHS that we plan to use advisory committees? Advisory committees are allowed under the new HSPPS, but if you plan to use an advisory committee to oversee key responsibilities, you must notify OHS. Unsure of what “key” responsibilities include? Our advice is to err on the side of caution and notify HHS about advisory committees that are on the line.
- Do we have a policy about reimbursing low-income policy council members? The HSPPS do not define “low income,” and OHS has made clear that it is up to each program to develop its own policies and procedures regarding reimbursement. Make sure that you develop a policy that allows for meaningful participation by all members of the policy council. And – as always – remember that a policy isn’t worth the paper it’s printed on if your program doesn’t follow the policy. Provide training on the reimbursement policy and perform periodic reviews to make sure that the reimbursement policy is being followed faithfully.
- Does our program give parent committees a meaningful role in governance? To make sure that parent committees are more than ceremonial, programs must ensure, among other things, that the policy council and Head Start staff are advised of the parent committee’s views, and that the parent committee has some role in recruiting and screening employees.
- Do we provide regular training? Ongoing training should be a part of all aspects of a Head Start program and governance is no exception! At a minimum, the governing body, advisory committee(s) and policy council must be trained on the HSPPS and eligibility.
- Does our impasse policy pass muster? If your impasse policy does not include mediation and arbitration, it will be inadequate come November 7. But be careful how you amend your policy. Many lawyers will tell you that arbitration can be just as expensive as going to court. Your policy should have clear limits on the time and procedures for arbitration.
Want to know more? Check out our September 29 webinar on “What Head Start Leaders Need to Know: Performance Standards Changes to Governance.” And don’t forget to follow us on Twitter and Facebook for more tips on Head Start and the HSPPS!