Monitoring reviews are set to restart this fiscal year, and Head Start programs should be preparing for reviews under the new Head Start Program Performance Standards (HSPPS).
One item that should be high on the list of priorities is ensuring that your program is providing the governing body and policy council with the training and technical assistance required by the new HSPPS. Under 45 C.F.R. § 1301.5 of the HSPPS, Head Start agencies must provide the governing body and policy council with “training and technical assistance or orientation … including training on program performance standards and training indicated in 45 C.F.R. § 1302.12(m) to ensure the members understand the information they receive and can effectively oversee and participate in the programs in the Head Start agency.”
This provision, much like the HSPPS as a whole, contains both prescriptive and flexible elements. The prescriptive requirement concerns eligibility training: a program must provide eligibility training to “all governing body and policy council members within 180 days of the beginning of the term of a new governing body or policy council.” 45 C.F.R. § 1302.12(m)(3). Furthermore, the training must:
(i) Include methods on how to collect complete and accurate eligibility information from families and third party sources;
(ii) Incorporate strategies for treating families with dignity and respect and for dealing with possible issues of domestic violence, stigma, and privacy; and,
(iii) Explain program policies and procedures that describe actions taken against staff, families, or participants who attempt to provide or intentionally provide false information.
45 C.F.R. § 1302.12(m)(1). We consider this provision prescriptive because it instructs the agency of exactly what must be done (training that includes specific items) and when (within 180 days).
The training provision also has flexible elements. Programs must provide training on the performance standards that is sufficient to ensure that the governing body and policy council can fulfill their responsibilities under the Head Start Act. This provision is flexible because it does not specify exactly what training programs must provide and it does not provide any timelines. So, given this flexibility, how should programs ensure that a reviewer will agree that the program’s training program met the requirements of the HSPPS?
As with any area of flexibility in the HSPPS, there are a few things that programs should do to maximize their chances for a successful monitoring review:
- Have a written plan. Get in the habit of thinking responsibility every time that you see flexibility in the HSPPS. Flexibility means that programs have discretion to choose a training program that makes sense for their governing bodies and policy councils, but programs must exercise that discretion. When a reviewer asks what type of training you have provided to the governing body and policy council and why, the program should be able to explain the rationale for the training program is designed. Further, having a plan allows a reviewer who shows up mid-year to see the future training that has been planned for the governing body and policy council, meaning it’s less likely that you’ll be faulted for lacking training on a topic that you simply haven’t gotten to yet.
- Document, document, document. In the governing body and policy council meeting minutes, you should be making a record of any training. Operate under the assumption that if it isn’t in the minutes, it didn’t happen!! Keep training agendas and materials with the minutes so that you can easily find information about the training. Also, follow up with absentee board and policy council members to provide make-up training.
- Advocate for yourself during reviews. Before your review, take time to refresh your memory of the training that the board and policy council have received. Be prepared to justify to a reviewer why the training you have provided is sufficient to satisfy any requirements under the HSPPS.
Want more information about governance under the new HSPPS? Check out our Governance Resource Page for more articles and information. We have also created a brand new Governing Board and Policy Council Training Series to provide comprehensive, concise governance training. Don’t forget to follow us on Twitter and Facebook for more tips on Head Start and the HSPPS!