With the passage of the 2007 amendments to the Head Start Act (the “Act”), Congress announced that existing and future Head Start grants would transition from “indefinite” project periods – i.e. project periods with no set expiration – to five-year project periods. The amendments made clear that only those grantees providing “high-quality and comprehensive” Head Start services would be entitled to an automatic renewal of their awards every five years. Grantees that fall short of the “high-quality and comprehensive” standard must now participate in an open competition in order to maintain Head Start funding for an additional five years.
The 2007 amendments to the Act tasked the Secretary of the Department of Health and Human Services (“HHS”) with developing a system to determine what would comprise a “high-quality and comprehensive” Head Start program, to identify which grantees meet this standard, and to implement the competition requirements in the new law. In fulfillment of this charge, HHS’s Office of Head Start (“OHS”) established the Designation Renewal System (“DRS”), which went into effect in December 2011 and requires grantees to compete for additional five-year funding if they meet the criteria for one of seven triggering conditions.
OHS has created the Aligned Monitoring System (“AMS”) to assist it in assessing grantee performance under the DRS criteria. The AMS is a monitoring mechanism first used in federal fiscal year 2015 through which grantees are subject to up to five separate reviews in five substantive areas over the course of their project periods. The reviews are conducted on-site by a team comprised of subject matter experts who examine grantee performance in the following areas:
- Environmental Health and Safety,
- CLASS™ (for grantees in their second or third year of the project cycle),
- Leadership, Governance, and Management Systems,
- Fiscal Integrity/ERSEA, and
- Comprehensive Services and School Readiness.
The AMS comes in two flavors – the “Differential Monitoring Process” and the “Comprehensive Monitoring Process.”
Comprehensive Monitoring Process
Under the Comprehensive Monitoring Process, review teams will assess a grantee’s compliance in each of the five subject matter areas listed above primarily in the first three years of its grant. A grantee will be subject to the Comprehensive Monitoring Process unless it qualifies for the Differential Monitoring Process described below.
Differential Monitoring Process
The Differential Monitoring Process involves two individual reviews covering 1) Environmental Health and Safety and 2) CLASS™. For obvious reasons – not least of which being the amount of time, attention, and resources that grantees must devote to the individual reviews – grantees will prefer to be subject to the Differential Monitoring Process, rather than the far more onerous Comprehensive Monitoring Process.
So what makes a grantee eligible for review under the Differential Monitoring Process?
In short, the grantee has to overcome two hurdles to be eligible for the less stringent review process. First, the grantee has to show that it has a clean history of compliance and then second, the grantee would have to pass the Head Start Key Indicator – Compliant (“HSKI-C”) review event. By OHS’s standards a clean history of compliance means showing all of the following:
- compliant reviews in the previous cycle,
- no fiscal findings in the last two monitoring cycles,
- a history of clean audits,
- no DRS criteria met, including CLASS®,
- no significant program changes, such as a change in leadership or physical location, and
- positive input from the Regional Office.
If a grantee has a history of compliance, OHS will subject the grantee to the HSKI-C review event. The HSKI-C is an evidence-based indicator tool comprised of 27 compliance measures that OHS has determined are strong indicators of a high quality program and is used by OHS for the sole purpose of determining whether a grantee should receive the Comprehensive Review Process. As a result, the HSKI-C is not used to identify findings.
The HSKI-C serves as the last hurdle a grantee must clear in order to be eligible for the Differential Monitoring Process. To be considered successful, the grantee must pass all 27 compliance measures of the HSKI-C. Only those grantees that show a history of compliance and pass the HSKI-C will be rewarded with the Differential Review Process. If a grantee fails the HSKI-C or received the Differential Review Process during its most recent previous grant cycle, it will have to undergo the Comprehensive Review Process.
We will discuss each of the five review events in detail in future blog posts.
Learn more about the Aligned Monitoring System on our upcoming webinars, “Head Start Monitoring: An In-Depth Look at the Fiscal Review Event” and “Head Start Monitoring: An In-Depth Look at Environmental Health & Safety.”