With the beginning of the school year, the United States Department of Health and Human Services, Administration for Children and Families, Office of Head Start (OHS) released the final rule for the new Head Start Program Performance Standards (“HSPPS”), the first comprehensive update of Head Start’s regulations since they were originally published in 1975. The effective date for many of the provisions is November 7, 2016, with effective dates for other provisions as late as August 1, 2021.
The final rule not only implements the 2007 amendments to the Head Start Act, but also fulfills OHS’s obligation to make periodic updates to the Head Start standards that reflect current information and research. Hence, in its efforts to revise the standards, OHS relied on decades’ worth of data from programs throughout the nation as well as the latest scientifically based developments on child development.
In addition, OHS took note of the field’s comments to the June 19, 2015, Notice of Proposed Rulemaking (NPRM) by (1) adopting some changes to the proposed rules, (2) making additional changes based on the comments and (3) reverting back to the prior standards in some instances. The resulting standards include some new requirements and some old requirements and the current structure is as follows:
- Part 1301: Program Governance
- Part 1302: Program Operations
- Part 1303: Financial and Administrative Requirements
- Part 1304: Federal Administrative Procedures
- Part 1305: Definitions
For the many Head Start veterans that can cite the old Head Start standards down to the sub-subparagraph number, this massive overhaul and reorganization of the standards might seem like just one more headache. Though there will definitely be an adjustment period getting to know the new rules for the veterans, newbies and everyone else in between, there are at least five reasons why the process will not be as bad as you might think.
- Streamlined Structure. The new streamlined structure of the HSPPS provides a more logical flow and removes duplications and potential inconsistencies from the old standards. For example, there is now one section devoted to all of the definitions of terms throughout HSPPS, rather than separate definition sections within individual parts, thus diminishing the potential for confusion. OHS boasts that it has removed 30% of old standards so that means that there are less standards for Head Start programs to have to train new staff on.
- There’s a “Cheat Sheet” for the Old Standards. In addition to the straightforward structure. Head Start veterans can take advantage of the helpful re-designation table listed in the final rule’s comment section to find the new location of long-standing rules and we will all benefit from the more user-friendly structure of the new HSPPS.
- Greater Focus on Flexibility and Less Focus on Compliance. Another helpful feature of the new standards is the emphasis on flexibility for implementation of the standards, which will allow Head Start programs to tailor their activities to better serve their communities rather than focus on compliance.
- Ongoing T/TA from the Office of Head Start. On September 1st, OHS released a webcast introducing the new standards, and provided details on OHS’s plan to assist Head Start programs implement the new standards through their monthly webinar series other helpful Training and Technical Assistance (T/TA).
- A Break from Monitoring. OHS has recognized that getting to know the new standards will be a challenging task for the field and has therefore, suspended the monitoring for FY 2017 while the Head Start community works to acclimate itself to the new standards.
With all of the benefits of the new regulations, we all know we still have a lot of work ahead of us in understanding and implementing the HSPPS. For more information and a legal perspective on the new Head Start standards, please join us on September 22, 2016, for our first webinar, providing an overview of the major changes in the regulation.