Head Start

Within our Federal Grants practice, over the years our attorneys have garnered significant experience with clients who run federal Head Start and Early Head Start (collectively, “Head Start”) programs across the country. Our attorneys counsel these clients on matters stemming from the Head Start Act, the Head Start Program Performance Standards, and specific program guidance from the Office of Head Start (OHS) at the Administration for Children and Families (ACF). We also help Head Start clients to untangle the many federal grants rules on financial requirements, procurements, property, and non-federal share. We also help clients determine how best to prepare for and respond to monitoring reviews and audits. Our assistance allows clients to achieve compliance within these heavily-regulated programs, and to obtain the knowledge to be able to run your program effectively, efficiently, and within the bounds of the law.

Coupled with our regulatory compliance counseling and trainings for Head Start programs, we also advise and counsel organizations running Head Start programs that need assistance challenging program monitoring findings, government audits, cost disallowances or grant terminations. Not only have we advised numerous programs on how to fix specific non-compliances and deficiencies, but on behalf of our clients, we have challenged decisions at the OHS level, and brought Head Start client matters before the Health and Human Services Departmental Appeals Board and in the federal courts.

Representative Activities:

Interpreting the Head Start Act and the Head Start Program Performance Standards and program guidance;
Advising on Head Start requirements, options and obligations;
Analyzing OMB Common Rules and other federal rules for Head Start programs;
Drafting “Delegate” (Sub-recipient) and Contractor Agreements;
Negotiating with OHS on various client matters;
Challenging monitoring review and audit findings, cost disallowances and grant terminations;
Teaching about Head Start compliance matters.

Managing a federal funded program as complex as Head Start is a difficult process, and to do so there are many regulatory compliance issues to take into account. We work to help organizations navigate the many rules that apply and how to allocate costs between and amongst multiple funding streams, to the satisfaction of federal funders and auditors.

Representative HHS Departmental Appeals Board Decisions:

Norwalk Economic Opportunity Now, Inc., No. 2002 (2005)
South Plains Community Action Agency, No. 1639 (1997)
Home Education Livelihood Program, Inc., No. 1598 (1996)

We also encourage Head Start programs to proactively prepare themselves in understanding and developing systems, policies and procedures to stay in compliance through our trainings program – view our training schedule here.