Head Start
A More Comprehensive Risk Management Strategy and Data Improvements Could Further Strengthen Program Oversight Gao ID: GAO-08-221 February 12, 2008In February 2005, GAO issued a report that raised concerns about the effectiveness of the Department of Health and Human Services (HHS) Administration for Children and Families' (ACF) oversight of about 1,600 local organizations that receive nearly $7 billion in Head Start grants. GAO was asked to report on (1) ACF's progress in conducting a risk assessment of the Head Start program and ensuring the accuracy and reliability of data from its annual Program Information Report (PIR) survey of grantees, (2) efforts to improve on-site monitoring of grantees, and (3) how data are used to improve oversight and help grantees meet program standards. For this report, GAO surveyed a nationally representative sample of Head Start program directors and interviewed ACF officials. GAO also reviewed ACF studies on the validity of PIR data and conducted tests of data from the 2006 PIR database.
ACF has not undertaken a comprehensive assessment of risks that may limit Head Start's ability to meet federal program objectives, despite GAO's 2005 recommendation, and little progress has been made to ensure that the data from its annual PIR survey of grantees, which could facilitate such an assessment, are reliable. To conduct a comprehensive risk assessment, ACF needs to identify external and internal risks, estimate their significance, and decide how to best manage them. While ACF says it is working to establish two systems to address programwide risk, our analysis suggests that these systems fall short of that goal. The first system, by which ACF assesses grantees before providing new funds each year, only assesses risk posed to the program by poorly performing grantees and does not allow for a broader assessment of other sources of risk, such as improper payments to contractors. The second system, a new, integrated management information system, has been in development for over 4 years and it is not clear how it will facilitate a more comprehensive risk assessment for the Head Start program. Both initiatives depend, in part, on data from the annual PIR survey of grantees, which have been found to be unreliable. ACF has taken steps to improve oversight of Head Start grantees by implementing a more rigorous process for certifying reviewers who conduct on-site monitoring visits, implementing new processes to improve the consistency of reviews, and working to establish a system for evaluating reviews on an ongoing basis. Now, ACF verifies reviewers' qualifications and requires them to pass online tests in writing and computer literacy. Reviewers must also complete ongoing training and are evaluated by their peers at the end of each review. ACF has also taken a number of steps to improve the consistency and objectivity of reviews, including developing a Web-based data collection tool to facilitate information gathering, assigning review team leaders from outside the grantee's home region to increase independence, and centralizing the review and preparation of monitoring reports. ACF is also working to establish an ongoing system for evaluating its on-site review process. ACF uses data to track grantee performance and target assistance to underperforming grantees, but weaknesses may have hindered these efforts to improve grantee performance. For example, ACF does not have clear criteria for determining which grantees need additional oversight as part of its refunding analysis. Such decisions are made on an ad-hoc basis, which may result in grantees with similar problems receiving different levels of oversight. Moreover, prior to the December 2007 reauthorization of Head Start, ACF was limited in its ability to increase competition for grants to replace underperforming grantees. Under the new law, ACF will have more flexibility to open competition for Head Start grants to other prospective grantees when current grantees fail to deliver high-quality, comprehensive Head Start programs.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-221, Head Start: A More Comprehensive Risk Management Strategy and Data Improvements Could Further Strengthen Program Oversight
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
February 2008:
Head Start:
A More Comprehensive Risk Management Strategy and Data Improvements
Could Further Strengthen Program Oversight:
GAO-08-221:
GAO Highlights:
Highlights of GAO-08-221, a report to congressional requesters.
Why GAO Did This Study:
In February 2005, GAO issued a report that raised concerns about the
effectiveness of the Department of Health and Human Services (HHS)
Administration for Children and Families‘ (ACF) oversight of about
1,600 local organizations that receive nearly $7 billion in Head Start
grants. GAO was asked to report on (1) ACF‘s progress in conducting a
risk assessment of the Head Start program and ensuring the accuracy and
reliability of data from its annual Program Information Report (PIR)
survey of grantees, (2) efforts to improve on-site monitoring of
grantees, and (3) how data are used to improve oversight and help
grantees meet program standards. For this report, GAO surveyed a
nationally representative sample of Head Start program directors and
interviewed ACF officials. GAO also reviewed ACF studies on the
validity of PIR data and conducted tests of data from the 2006 PIR
database.
What GAO Found:
ACF has not undertaken a comprehensive assessment of risks that may
limit Head Start‘s ability to meet federal program objectives, despite
GAO‘s 2005 recommendation, and little progress has been made to ensure
that the data from its annual PIR survey of grantees, which could
facilitate such an assessment, are reliable. To conduct a comprehensive
risk assessment, ACF needs to identify external and internal risks,
estimate their significance, and decide how to best manage them. While
ACF says it is working to establish two systems to address programwide
risk, our analysis suggests that these systems fall short of that goal.
The first system, by which ACF assesses grantees before providing new
funds each year, only assesses risk posed to the program by poorly
performing grantees and does not allow for a broader assessment of
other sources of risk, such as improper payments to contractors. The
second system, a new, integrated management information system, has
been in development for over 4 years and it is not clear how it will
facilitate a more comprehensive risk assessment for the Head Start
program. Both initiatives depend, in part, on data from the annual PIR
survey of grantees, which have been found to be unreliable.
ACF has taken steps to improve oversight of Head Start grantees by
implementing a more rigorous process for certifying reviewers who
conduct on-site monitoring visits, implementing new processes to
improve the consistency of reviews, and working to establish a system
for evaluating reviews on an ongoing basis. Now, ACF verifies
reviewers‘ qualifications and requires them to pass online tests in
writing and computer literacy. Reviewers must also complete ongoing
training and are evaluated by their peers at the end of each review.
ACF has also taken a number of steps to improve the consistency and
objectivity of reviews, including developing a Web-based data
collection tool to facilitate information gathering, assigning review
team leaders from outside the grantee‘s home region to increase
independence, and centralizing the review and preparation of monitoring
reports. ACF is also working to establish an ongoing system for
evaluating its on-site review process.
ACF uses data to track grantee performance and target assistance to
underperforming grantees, but weaknesses may have hindered these
efforts to improve grantee performance. For example, ACF does not have
clear criteria for determining which grantees need additional oversight
as part of its refunding analysis. Such decisions are made on an ad-hoc
basis, which may result in grantees with similar problems receiving
different levels of oversight. Moreover, prior to the December 2007
reauthorization of Head Start, ACF was limited in its ability to
increase competition for grants to replace underperforming grantees.
Under the new law, ACF will have more flexibility to open competition
for Head Start grants to other prospective grantees when current
grantees fail to deliver high-quality, comprehensive Head Start
programs.
What GAO Recommends:
GAO recommends that ACF develop a more strategic approach to assessing
risks to the Head Start program, expand its efforts to collect data on
and estimate improper payments, improve the accuracy of data from its
annual PIR survey, and develop clear criteria for providing additional
assistance for high-risk grantees. ACF agreed with the latter two
recommendations and emphasized progress already made toward developing
a comprehensive risk assessment process and reducing improper payments.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-221]. For more information, contact
Cornelia Ashby at (202) 512-7215 or ashbyc@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
ACF Has Not Undertaken a Comprehensive Risk Assessment, and Data
Reliability and Other Challenges Remain:
ACF Improved On-site Monitoring by Strengthening Review Processes and
Is Working to Establish a System to Evaluate Reviews:
ACF Uses Data to Identify Grantees in Need of Assistance, but
Weaknesses Have Hindered Efforts to Improve Grantee Performance:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Health and Human Services:
Appendix III: GAO Contacts and Staff Acknowledgments:
Appendix IV: Related GAO Products:
Tables:
Table 1: Summary of Results for PIR Data Consistency Tests, 2006 PIR
Database:
Figures:
Figure 1: Changes to Reporting Structure for ACF Staff Working on Head
Start:
Abbreviations:
ACF: Administration for Children and Families:
HSES: Head Start Enterprise System:
HHS: Department of Health and Human Services:
OMB: Office of Management and Budget:
PIR: Program Information Report:
T/TA: Training and technical assistance:
United States Government Accountability Office:
Washington, DC 20548:
February 12, 2008:
Congressional Requesters:
In February 2005, we issued a report that raised concerns about the
effectiveness of oversight of the Head Start program. We made a number
of recommendations to improve the Department of Health and Human
Services (HHS) Administration for Children and Families' (ACF)
oversight of local organizations that receive Head Start program grants
and the grantees' financial management.[Footnote 1] Head Start is one
of the largest federal early childhood programs. In fiscal year 2007,
Head Start provided nearly $7 billion to 1,604 local organizations that
provide a wide range of services to over 900,000 primarily low-income
children, from birth to age 5, and their families. These services are
aimed at improving the social competence, learning skills, and health
and nutrition status of low-income children so that they can begin
school ready to learn. ACF spent $25.6 million in fiscal year 2006 to
conduct its oversight activities.
Since our 2005 report, ACF has implemented a number of changes designed
to improve its monitoring and other oversight of grantees. However,
policymakers have raised new concerns about the scope of these changes
and whether they are likely to strengthen the performance of Head Start
grantees, suggesting a need to reassess ACF's monitoring and oversight
activities. To respond to your request for more information about ACF's
monitoring and oversight of the Head Start program, we examined:
1. ACF's progress in conducting a risk assessment of the Head Start
program and ensuring the accuracy and reliability of data from its
annual Program Information Report (PIR) survey of grantees,
2. ACF's efforts to improve its on-site monitoring processes, and:
3. ACF's use of data to improve oversight and help grantees meet
performance standards.
To address these objectives, we visited and interviewed Office of Head
Start and ACF officials and their staff in Washington, D.C. We
interviewed staff from all of ACF's 10 regional offices and reviewed
relevant documentation from each of these offices. We administered a
Web-based survey to a nationally-representative sample of Head Start
and Early Head Start program directors.[Footnote 2] We selected our
sample of directors from the population of directors whose programs
were the subject of ACF's on-site reviews from October 2005 through
March 2007 using a newly revised on-site review process. In total, we
surveyed 329 program directors, asking them about their experiences
during the most recent on-site reviews, and their views about the
changes to the process. Of the 329 program directors, 261 responded--
for a response rate of 79 percent. Throughout this report, when we
refer to our survey results, we use the terms "program directors" and
"grantees" interchangeably. Finally, we tested the reliability of two
of ACF's administrative databases--the first contains data on the
results of each grantee's on-site review, and the second contains data
from ACF's annual PIR survey of grantees. To assess the reliability of
on-site review data, we relied on our 2005 assessment of the
reliability of these data, performed additional electronic tests of
data elements used for an analysis of the extent of repeat on-site
review findings, and reviewed new information about the database. Based
on our previous and updated assessments, we find the on-site review
data used for our analysis of on-site review findings to be sufficient
for the purpose of this report. However, we identified concerns about
the overall reliability of data from ACF's annual PIR survey of
grantees, which we discuss more fully in this report. To further
address objective 1, we reviewed a recent ACF study on the validity of
PIR survey data. To further address objective 2, we met with the
contractor responsible for coordinating the on-site review process and
tracking on-site review results, and representatives from the National
Head Start Association. We also examined patterns of on-site review
results in areas related to program governance, record-keeping and
reporting, and fiscal management for all programs reviewed in both
fiscal years 2003 and 2006 to assess the extent of repeat findings, and
obtained the results of a study conducted by ACF to evaluate its on-
site review process. For additional details about our scope and
methodology, see appendix I. Our work was conducted from February 2007
through December 2007 in accordance with generally accepted government
auditing standards.
Results in Brief:
ACF has not undertaken a comprehensive assessment of risks that may
limit Head Start's ability to meet federal program objectives, despite
our 2005 recommendation, and little progress has been made in ensuring
that the data from its annual PIR survey of grantees, which could
facilitate such an assessment, are reliable. Risk assessment is a key
component of internal control that can provide the basis for
determining what actions need to be taken to address problems that may
limit an agency's progress toward meeting federal program objectives.
For the Head Start program, this would include a formal, ongoing
process of identifying external and internal risks, estimating their
significance, and deciding how to best manage them. While ACF has two
systems in development to address programwide risk, our analysis
suggests that these two systems fall short of that goal. First, ACF has
a new system for assessing individual grantees each year before
deciding whether to refund, or renew, their grants. This system partly
addresses our 2005 recommendation that ACF produce a comprehensive risk
assessment of the Head Start program. However, this refunding analysis
system only assesses risk posed to the program by poorly performing
grantees; it does not allow for a broader assessment of other sources
of risk, such as those we previously identified, including limited
efforts to assess regional office staff adherence to ACF policies and
procedures and improper payments to contractors. Improper payments
continue to be an issue for ACF. For example, in April 2007, the HHS
Inspector General reported that 5 percent of Head Start slots that were
paid for in 2006 had not been filled. Although ACF collects data on
improper payments to grantees that enrolled too many children from
families that did not meet the program's income eligibility
requirement, ACF officials stated that they do not have plans to track
other types of improper payments. The second process that ACF is
developing is a new, integrated management information system, known as
the Head Start Enterprise System (HSES). However, HSES has been in
development for over 4 years and it is not clear when or how it will
facilitate a more comprehensive risk assessment for the Head Start
program. Furthermore, both the refunding analysis system and the HSES
depend, in part, on data from the annual PIR survey of grantees, which
several studies have found to be unreliable. These studies suggest that
PIR data are unreliable, partly, because of the length and complexity
of the survey, which includes over 130 questions that are sometimes
difficult for grantees to answer. ACF does not independently verify the
accuracy of data submitted by grantees. Despite its widespread use in
providing the public with information on the national Head Start
program and in overseeing grantees, our analysis also raises
significant concerns about the reliability of the data from this
survey.
ACF has taken steps to improve its oversight of Head Start grantees by
implementing a more rigorous process for certifying reviewers who
conduct on-site monitoring visits, implementing new processes to
improve the consistency of reviews, and working to establish a system
for evaluating reviews on an ongoing basis. Now, ACF verifies all
potential reviewers' qualifications and requires them to pass online
tests in writing and computer literacy. Reviewers must also complete
ongoing training and are evaluated by their peers at the end of each
review. ACF has also taken a number of steps to improve the consistency
and objectivity of reviews. For example, ACF has developed a Web-based
data collection tool that provides a more structured way of gathering
evidence on grantee performance. To help ensure objectivity of review
teams, they are now led by program specialists from outside the
grantees' home regions who are directly accountable to the central
Office of Head Start. Also, to improve on-site monitoring reports,
review findings are now reviewed by central office staff for
consistency. Based on the results of our survey of Head Start and Early
Head Start program directors, grantees have mixed views about the
revised on-site monitoring procedures. For example, although most
grantees who were reviewed under the revised procedures were very or
somewhat satisfied with how their most recent on-site review was
conducted, they were almost evenly split over whether having a program
specialist from outside their home region lead their review had a
positive or negative effect on the review process. In 2005, we found
evidence that some reviewers may not have followed on-site review
guidelines and, as a result, some grantees were not reviewed as
rigorously as others. In 2006, ACF evaluated its on-site reviews to
determine whether it was followed consistently by different teams of
reviewers and the extent to which the review process helped reviewers
identify serious program problems. ACF found that, although review
teams did not consistently identify the same program problems for the
same grantees, none of the teams failed to identify serious program
problems. ACF is working to establish an ongoing system for evaluating
its on-site review process.
ACF uses data to track grantee performance and to target assistance to
underperforming grantees, but weaknesses in the extent to which
performance data are used to guide oversight may have hindered this
effort to improve grantee performance. ACF uses the results of its data
analysis to target resources from its training and technical assistance
network to help underperforming grantees address program weaknesses
through workshops, on-site assistance, or other specialized training.
However, there are limits on ACF's use of data to improve grantee
performance. Although ACF uses data during its annual refunding process
to assess grantee performance, it lacks clear criteria for determining
which grantees need additional oversight. Currently, ACF makes such
decisions on an ad-hoc basis, which may result in grantees with similar
problems receiving different levels of oversight. In addition, prior to
the December 2007 reauthorization of Head Start, ACF had limits to its
ability to recompete grants in order to replace severely
underperforming grantees. Competing grants has been shown to facilitate
grant accountability. The Improving Head Start for School Readiness Act
of 2007 (Improving Head Start Act),[Footnote 3] which revises and
reauthorizes the Head Start program, imposes time limits on Head Start
grants and gives ACF more flexibility to open competition for Head
Start grants to other prospective grantees on a regular basis[Footnote
4].
We are making a number of recommendations to the Assistant Secretary
for Children and Families aimed at further improving management and
oversight of the Head Start program. We recommend that ACF continue to
address our previous recommendation by developing a more strategic and
comprehensive approach to assessing Head Start programwide risks. We
also recommend that ACF expand efforts to look for cost-effective ways
to collect data on and estimate the extent of improper payments. In
addition, we recommend that ACF determine which elements of the PIR are
essential for program management and focus resources on a streamlined
version of the PIR that would be required of all grantees and
periodically verified for accuracy. Finally, we recommend that ACF
develop clear criteria for determining which grantees require more
thorough reviews--such as special, on-site reviews--as a result of its
refunding analysis system. In its comments on a draft of this report,
ACF agreed with the latter two recommendations, and emphasized the
progress it has already made toward developing a comprehensive risk
assessment process and toward reducing improper payments. With respect
to risk assessment, we found that ACF will rely on two key systems--the
refunding analysis system, which is limited in how it could be used for
risk assessment, and the Head Start Enterprise System, which has not
been fully developed. However, it is unclear how these systems will be
used to proactively manage program risk nationally. Additionally, ACF
noted its efforts to implement the Improper Payments Information Act of
2002 and commented that improvements in monitoring and increased risk
management may identify further areas for study related to improper
payments. We believe our recommendations in these two areas remain
valid to help ACF expand and focus its continuing efforts.
Background:
The Head Start program was established in 1965 to promote the school
readiness of low-income children by enhancing their cognitive, social,
and emotional development by providing a range of individualized
services to pre-school aged children and their families. The program is
overseen by ACF, which awards grants directly to a network of about
1,600 public and private nonprofit and for-profit agencies to help pay
for health, educational, nutritional, social, and other services to
primarily low-income children from birth to age 5, and their
families.[Footnote 5]
ACF monitors the success of local agencies that receive Head Start
grants in meeting Head Start program goals and complying with program
requirements by conducting on-site monitoring reviews of grantee
programs every 3 years; administering an extensive, annual PIR survey
of grantees; and reviewing required financial reports and annual audit
reports. Reviewers assess Head Start grantee compliance with all
program requirements, including those specified in the Improving Head
Start Act, the Head Start Program Performance Standards, and other
relevant federal, state, and local regulations. These requirements
consist of administrative, financial management, and other standards,
such as using age-appropriate materials to help children learn to
recognize letters and numbers, and providing safe play areas.
By law, each Head Start grantee must receive a full review at least
once every 3 years. New grantees must receive a full review after
completion of their first year of providing Head Start services and at
least once every 3 years thereafter.[Footnote 6] ACF's policy is to
conduct these reviews on-site. Except for new grantees, Head Start
grantees are reviewed on a rotating basis, and approximately one-third
of all grantees are monitored each year. Reviews are conducted by a
team of reviewers led by a federal Head Start program specialist from
one of ACF's 10 regional offices.
In our February 2005 report, we identified a number of weaknesses in
ACF's oversight of Head Start grantees. Specifically, we found that ACF
did not have a strategy for bringing information from its various
monitoring processes together in order to comprehensively assess Head
Start program risks, and identified problems with each of its
strategies for monitoring grantees. We found that ACF did not have
procedures to ensure that on-site reviewers performed their
responsibilities in accordance with established guidelines or to ensure
that managers and staff in ACF regional offices were held accountable
for the quality of the on-site reviews. We also found that ACF did not
have procedures for independently verifying data submitted by grantees
in its annual PIR survey, which, in addition to providing information
about grantee performance, is used to provide information to Congress
and the public about important program characteristics, such as program
design and staffing, and numbers and characteristics of children
enrolled and attending Head Start programs nationwide. Finally, we
found that ACF made limited use of financial reports and audits to
ensure that all grantees effectively resolved financial management
problems and had made little use of its authority to terminate grantees
that did not meet program, financial management, and other
requirements, and fund new grantees to replace them. We made a number
of recommendations to address the problems that we identified,
including:
1. producing a comprehensive risk assessment of the Head Start program;
2. strengthening on-site reviewer training and certification
procedures;
3. developing a more consistent approach to conducting on-site reviews
and analyzing findings;
4. implementing a quality assurance process that ensures on-site
reviews are conducted within established guidelines and ACF managers
are held accountable for the quality of on-site reviews;
5. ensuring the accuracy of PIR survey data by independently verifying
key data submitted by grantees, or ensuring that grantees have systems
in place to collect and report accurate, verifiable data;
6. making greater use of available information on the status and use of
federal funds; and:
7. taking steps to obtain competition for grants that are being
refunded if it is determined that current grantees have failed to meet
program, financial management, or other requirements.
In 2006, ACF reorganized its regional offices in order to streamline
program operations. (See fig. 1.) Currently, ACF regional program staff
report directly to its central program offices, rather than to regional
office administrators. The regional administrators no longer have
direct authority to manage individual program activities. As a result,
Head Start program specialists are directly accountable to central
office management. Also, financial management specialists, who monitor
financial management of all ACF grants, including Head Start grants,
are now directly accountable to the central Office of Grants
Management, which is located within the ACF Office of Administration.
The Office of Administration provides support to ACF's program offices
on a range of administrative issues, such as managing personnel,
information resources, procurement, and grants. The Office of Grants
Management carries out the Office of Administration's grants
administration duties and provides leadership and technical guidance to
ACF program and regional offices on grant operations and grants
management issues.
Figure 1: Changes to Reporting Structure for ACF Staff Working on Head
Start:
This figure is a flowchart showing changes to reporting structure for
ACF staff working on Head Start.
[See PDF for image]
Source: GAO analysis if ACF information.
[End of figure]
The Head Start program was revised and reauthorized in the December
2007 Improving Head Start Act. Prior to this, the program was last
reauthorized in 1998, for fiscal years 1999 through 2003. In the years
between the 1998 and 2007 reauthorizations, the program remained funded
through the annual appropriations process.
ACF Has Not Undertaken a Comprehensive Risk Assessment, and Data
Reliability and Other Challenges Remain:
ACF has not undertaken a comprehensive assessment of risks to the
federal Head Start program, despite our 2005 recommendation, and little
progress has been made in ensuring that the data from its annual PIR
survey of grantees, which could facilitate such an assessment, are
reliable. Although ACF has two systems in development to address risk
assessment, neither system provides for a comprehensive, programwide
risk assessment for the Head Start program. Further, both systems
depend to some extent on unreliable data from the annual PIR survey of
grantees. Although ACF has known about the problems with PIR survey
data, it has done little to address them.
ACF Has Not Undertaken a Comprehensive Risk Assessment:
ACF has not undertaken a comprehensive assessment of risks to the
federal Head Start program. Risk assessment is one of five internal
control standards that together provide the foundation for effective
program management and help government program managers achieve desired
results through effective stewardship of public resources.[Footnote 7]
To carry out a comprehensive risk assessment, program managers need to
identify program risks from both external and internal sources,
estimate the significance of these risks, and decide what steps should
be taken to best manage them. Although such an assessment would not
assure that program risks are completely eliminated, it would provide
reasonable assurance that such risks are being minimized. For the Head
Start program, this might include anticipating and developing
strategies to minimize the impact of changes in resources available to
oversee and assist local grantees, or to develop initiatives to address
social and demographic changes that may result in changing service
needs for families with young children.
In 2005, we reported a similar finding, noting that despite efforts to
collect information and assess risks, ACF did not have a strategy for
bringing this information together in order to comprehensively assess
program risks, and recommended that ACF produce a comprehensive risk
assessment of the Head Start program. To address our 2005 finding, ACF
has attempted to bring together information about local programs and to
assess risk on a grantee-by-grantee basis; however, it has yet to
develop a systematic approach to assessing risks that may arise from
other sources and, if undetected, could hinder ACF's ability to achieve
Head Start program objectives, or for developing strategies to
prioritize and address risks proactively.
New Systems Could Facilitate Comprehensive Risk Assessment but
Limitations Exist:
ACF is in the process of developing two systems that may help it assess
programwide risks; however, significant limitations or uncertainty
exist with respect to each that could constrain ACF's ability to use
them to conduct a meaningful risk assessment. The first system, the
refunding analysis system, is a process whereby ACF evaluates the
performance of individual grantees each year before it refunds, or
renews, their grants. The second system, the Head Start Enterprise
System (HSES), is still under development. As envisioned by ACF, the
HSES may one day integrate all available Head Start program data into a
single, interactive database that may one day facilitate analysis
across many program areas. The first system is limited in how it could
be used for risk assessment, and the completion of the second system is
uncertain. The refunding analysis system is limited because it assesses
risk from only one source--grantee performance--and does not assess
other types of risk, such as inadequate procedures for ensuring that
staff follow policies for monitoring grantee activities or for
minimizing payments that are not in accordance with program
requirements. Although the planned HSES has the potential for assessing
a wider range of potential program risks, it has been in development
for at least 4 years, and it is unclear when or how it will actually be
used.[Footnote 8]
The refunding analysis system is an evolving system for evaluating
grantee financial management and performance annually and determining
which grantees require additional assistance. Each month, regional
program staff who are responsible for overseeing Head Start grantees
bring together and assess all available information about grantees that
are scheduled to re-apply for their grants. The information is reviewed
by grants management staff and Head Start central office staff.
Although the refunding analysis system is intended to provide analysis
of grantee performance prior to refunding, it serves primarily as a
means of identifying grantees that need assistance and not as a means
of discontinuing grants for underperforming grantees.
Although the refunding analysis system allows grantees that are
considered high risk to be brought to the attention of Head Start
program managers, it does not allow for a broader assessment of other
sources of risk, such as those we previously identified. For example,
in 2005, we identified improper payments to contractors as a source of
potential risk for the Head Start program. Under the Improper Payments
Information Act of 2002,[Footnote 9] agencies are required to annually
identify programs and activities that may be susceptible to significant
improper payments;[Footnote 10] provide Congress with the annual
estimated amount of improper payments; and, for programs and activities
with estimated improper payments that exceed $10 million, report on
actions taken to reduce improper payments. In addition, the Improving
Head Start Act requires the Secretary of HHS to submit a report to the
appropriate congressional committees certifying that HHS has completed
a risk assessment to determine which ACF programs are at significant
risk of making improper payments, and describing the actions HHS will
take to reduce these improper payments.[Footnote 11] Since fiscal year
2004, ACF has taken limited action to minimize improper payments by
collecting data on payments to grantees that do not meet the
requirement that at least 90 percent of the children who are enrolled
in Head Start programs must be from low-income families.[Footnote 12]
However, ACF officials stated that, due to resource constraints, they
do not have plans to track other types of improper payments, such as
overpayments to grantees that serve fewer children than are reported to
be enrolled in their local Head Start programs and excessive
compensation paid to Head Start program staff. Overpayments to grantees
with programs that have enrollment below their funded levels are not
uncommon. In April 2007, the HHS Inspector General reported that in the
2006 program year, fewer than half (40 percent) of Head Start grantees
were fully enrolled and that enrollment levels by grantee ranged from
full enrollment to as low as 68 percent of funded enrollment.[Footnote
13] Overall, this translated into 5 percent of Head Start slots that
were funded but not filled. The HHS Inspector General also found that
only 11 percent of grantees had reported enrollment levels to ACF that
matched their actual enrollment levels, and questioned the ability of
26 percent of grantees to maintain accurate attendance records and to
determine enrollment accurately. The HHS Inspector General has also
conducted a series of audits of Head Start programs that identified
unreasonable levels of compensation to Head Start program
executives.[Footnote 14] Although ACF requires grantees to provide
information about Head Start program staff salaries and compensation as
part of their annual refunding applications, ACF has not estimated the
extent to which excessive compensation may be a problem, or verified
the extent to which information provided by grantees is accurate.
ACF Has Made Little Progress toward Ensuring Accuracy of Key Data:
In developing its new systems, ACF plans to use data from its annual
PIR survey of grantees, which several studies over the past 12 years
have determined to be unreliable. Specifically, the refunding analysis
system uses PIR data on grantees' enrollment of children with
disabilities and provision of medical and dental treatments as factors
when determining the risk that an individual grantee will fail to meet
program standards. In addition, ACF plans to use the PIR database in
the HSES. Our February 2005 report found discrepancies in the 2003 PIR
database. During our current review, we conducted similar tests to
check for data consistency in the 2006 PIR database and found that it
continues to provide some inconsistent data. Our findings are
consistent with a more recent study funded by ACF that was undertaken
in response to our 2005 recommendation to address the accuracy of PIR
data. Specifically, ACF's 2007 study found that the PIR data reported
by individual Head Start grantees are frequently inaccurate and may be
unreliable for grantee monitoring or risk assessment purposes.
The 2007 study found that data submitted by grantees for the PIR survey
may be unreliable due to the length and complexity of the survey. The
survey includes over 130 questions and provides data on program
operations, enrollment, staff and their qualifications, services for
children and families, and other information used for policymaking and
accountability. All Head Start grantees are required to submit PIR data
every year. ACF's 1995 study on PIR data validity also suggested that
the length of the survey reduced the accuracy of PIR data submitted by
grantees, and its 2007 study further suggested that instructions
provided to grantees for completing the PIR may be unclear and could
lead to grantees submitting incorrect data. Based on our survey of
program directors, we estimate that over half of all Head Start
grantees spend more than 24 hours to complete the PIR. In our survey,
we solicited comments from program directors about potential obstacles
to completing the PIR and they cited various obstacles, such as unclear
instructions and questions that may change from one year to the next.
In addition to using the PIR data to assess progress of individual
grantees, ACF aggregates the PIR data to provide national, regional,
and state-level statistics on Head Start. ACF uses the aggregate data
to report to Congress and the public on the performance of the Head
Start program. Head Start grantees report using the PIR survey to help
manage their programs. A majority of grantees report using the PIR
survey to help ensure compliance with federal laws and regulations,
compare the performance of their program to national or regional
benchmarks, and observe trends in their own performance over time.
Moreover, the Improving Head Start Act requires ACF to use the PIR as
one determinant of whether grantees meet program and financial
management requirements and standards, as part of a new system for
renewing Head Start grants.[Footnote 15] Reliance on systems that
contain inaccurate data can mislead policymakers and program managers
and result in inappropriate decisions.
In its 2007 study, ACF asserted that the national statistics produced
by the PIR present a reasonable estimate of the services provided by
the Head Start program even though the data collected from individual
grantees are unreliable. However, if there are actual errors in grantee-
reported data, the nationally-reported PIR statistics might present a
false picture of the services provided by the Head Start program. For
example, the study estimated that grantees over-reported the number of
children that received medical exams by 3.6 percentage points and noted
that problematic record-keeping on the part of grantees or physicians
might account for some of the discrepancy between the PIR statistics
and the study's estimates. [Footnote 16] Given that the Head Start
program provides services to more than 900,000 children, over-reporting
in the number of children that received medical exams by 3.6 percentage
points could mean that as many as 32,000 fewer children may be
receiving medical exams than the nationally-reported PIR statistics
indicate.
The 2007 study found that ACF lacked procedures to independently verify
the accuracy of the data. Although ACF has built internal consistency
checks into the PIR database, these checks will not detect inaccurate
data as long as the grantee reports data consistently throughout its
PIR report. In our 2005 report, we also found that ACF lacked a data
verification process and recommended that ACF either (1) independently
verify key data submitted through the survey or (2) ensure that
grantees have systems in place to collect and report accurate,
verifiable data.
The 2007 study offered several recommendations for enhancing the
reliability of PIR data. Most of the study's recommendations would
address the accuracy of data reported by individual grantees, to allow
ACF to better assess grantee performance. For example, the study
recommends that ACF perform regular validation of the PIR data
submitted by grantees, possibly during the triennial on-site monitoring
reviews. Alternatively, one recommendation focuses on ACF's use of the
PIR as a tool for generating national statistics, and suggests
accomplishing this through a more limited survey to a random sample of
grantees, thereby reducing the overall burden on grantees. ACF
officials told us that they have not yet developed any plans to
implement the specific recommendations from its 2007 study.
ACF Improved On-site Monitoring by Strengthening Review Processes and
Is Working to Establish a System to Evaluate Reviews:
ACF has implemented several changes aimed at improving the quality and
consistency of its on-site reviews of Head Start grantees, in response
to our 2005 recommendations. These changes directly address our
previous findings regarding the lack of procedures for ensuring that
review teams were following on-site review protocols or for ensuring
that managers and staff in ACF regional offices are held accountable
for the quality of the reviews. Specifically, ACF has implemented a
more rigorous process for certifying reviewers and new processes to
improve the consistency of reviews, and is working to establish a
system for evaluating reviews on an ongoing basis.
ACF Has Implemented More Rigorous Certification Procedures for
Reviewers:
ACF has implemented more rigorous procedures for ensuring that a
sufficient number of qualified reviewers are available to help conduct
required on-site reviews of Head Start programs. Danya International,
Inc. (Danya) manages the on-site review process under a contract with
ACF and monitors whether reviewers meet all of the necessary
qualifications, such as having a Bachelor's degree and at least 3 years
of work experience in a field related to early childhood development or
public program management, and whether they comply with ongoing
training and performance requirements. Danya's polices require that
reviewers who do not satisfactorily meet the necessary qualifications
or who fail to comply with ongoing requirements for reviewers cannot
participate in an on-site review. According to Danya, 174 reviewers
were placed on hold or removed from the reviewer pool in fiscal years
2006 and 2007 because they did not meet the necessary qualifications.
Procedures for recruitment of on-site reviewers are more systematic
than in the past. Previously, ACF relied on informal networking among
individuals affiliated with the Head Start program to recruit new
reviewers. Now, Danya procedures provide for an ongoing assessment of
the composition of the current reviewer pool and the numbers of
reviewers needed to carry out reviews in a given year, and a targeted
recruitment strategy to address any shortfalls in the numbers or types
of reviewers needed. For example, to address a shortfall of reviewers
who speak Spanish or have experience in Native American issues, Danya
representatives may attend conferences to recruit new reviewers with
needed special skills and experience, such as conferences sponsored by
the National Hispanic Head Start Association or the National Indian
Education Association. Each month, a three-person panel of qualified
reviewers screens all new applications to determine which applicants
appear to have the required skills and experience. Applicants who meet
the initial screening requirements are asked to provide more detailed
employment and education information, which is then verified by
Danya.[Footnote 17]
In addition to meeting the basic requirements for qualifying to become
an on-site reviewer, Danya procedures require that new and current
reviewers alike must meet minimum training and performance requirements
before they are assigned to a review team. New reviewers are required
to complete a basic training course and must successfully complete a
Head Start monitoring review as a trainee under the supervision of an
experienced coach. All reviewers are required to complete any new
training that may be specified during a given fiscal year, stay
informed about changes to the review process, and successfully complete
online tests in writing and computer literacy. Also, members of the
reviewer pool who are employees of Head Start programs, known as peer
reviewers, who work for programs that are in serious noncompliance with
program requirements are not eligible to participate in on-site
reviews.[Footnote 18] ACF also requires the review team leader and
report coordinator to complete evaluations for all members of the
review team; in addition, each team member must assess the performance
of several colleagues on the team. If a reviewer's performance is rated
as unsatisfactory by two or more raters on a single review, Danya will
follow up to verify the raters' assessments, if necessary, and consult
with ACF to decide whether the reviewer should be placed on probation
and allowed to participate in an additional review for further
assessment, or whether the reviewer should be dropped from the reviewer
pool.
New Processes Increase Consistency of Reviews:
In fiscal year 2006, ACF implemented new procedures to improve the
quality and consistency of on-site reviews. Concerns about the lack of
independence of on-site review team leaders prompted changes in how
team leaders are assigned. As a result, each review team is now led by
ACF program staff from a region other than the grantee's home region.
Concerns regarding inconsistencies in the findings cited by different
teams of reviewers for the same grantees led to changes in how findings
are developed and reported. The review teams collect only data and
facts during their review: they do not draw conclusions from the
information they gather or prepare the final report. Instead, reviewers
record their observations in a centralized, Web-based system, noting
any potential areas of noncompliance. The reviewers' notes are then
submitted for centralized review by ACF. The draft review report is
prepared centrally and includes findings of noncompliance with program
requirements or deficiency--a more serious form of noncompliance that
can lead to termination of the grant. The draft report is then
forwarded to the grantee's home region and to the review team leader's
region for review and comment. Any comments received are incorporated
into the report as necessary to clarify the reviewers' observations,
and the final report is signed by the Director of the Office of Head
Start and then issued to the grantee.
ACF has also revised its on-site review protocols to encourage a more
efficient and uniform approach to conducting on-site reviews. In fiscal
year 2007, ACF implemented a more uniform set of on-site review
protocols, under which every grantee is asked the same questions
relating to 10 distinct program areas, such as health services, fiscal
management and education and early childhood development services. The
protocols encourage a more targeted assessment of whether or not
grantees are in compliance with program regulations, and no longer
provide for reporting about program strengths, such as the provision of
services that extend beyond what is required by regulation. Prior to
the on-site review team's visit, grantees receive a 30-day notification
and are asked to prepare a uniform set of documents for reviewers to
examine before meeting with the grantee. During the review, reviewers
are required to enter the information they gather into a central, Web-
based system, which facilitates sharing evidence among reviewers and
tracking whether reviewers have completed all necessary tasks.
ACF has also implemented uniform corrective action periods and
mandatory follow-up visits when grantees are found to be either
noncompliant or deficient. At the time of our previous review, ACF
relied on grantees to self-certify that they had corrected any problems
identified during audits or on-site reviews and only made follow-up
visits to grantees that had been found deficient. Now, when grantees
are found to be noncompliant with Head Start program regulations, ACF
allows them 90 days to resolve the underlying problems and bring their
programs into compliance. If found deficient, grantees are given 6
months to fully resolve deficiencies before ACF will take action to
terminate their grants, though ACF will allow additional time if a
grantee can justify its request for an extension.[Footnote 19] At the
end of the relevant corrective action period, ACF conducts follow-up
reviews in order to verify that grantees have resolved the problems
identified during the initial on-site review.
ACF officials said that most grantees have adjusted well to the new on-
site review process, although there were some initial negative
reactions from the grantees when the new procedures were first
introduced. ACF officials told us that they encourage grantees to
provide feedback on the review process and on the conduct of on-site
reviewers. They have also established formal procedures for review team
leaders to report violations of the on-site code of conduct by
reviewers and to replace reviewers while the team is on-site, if
necessary. Based on our survey results, we estimate that 9 percent of
grantees encountered problems with reviewers during their most recent
review that required outside intervention. For example, one respondent
reported several problems, including trouble scheduling the review, a
reviewer with a conflict of interest, and overly aggressive reviewers.
Our survey results suggest that grantees have mixed views about the
revised on-site monitoring procedures. Generally, directors of programs
reviewed under the revised procedures had positive views of the
reviewers but had less positive views of specific changes in the
procedures and the extent to which their most recent on-site review had
led to improvements in their Head Start programs. Specifically, most
directors of programs that were reviewed under the revised procedures
were very or somewhat satisfied with how their most recent on-site
reviews were conducted. Most directors also found that the review teams
had adhered to the new protocols and that the review teams demonstrated
an understanding of program requirements. They were almost evenly split
over whether having program specialists from outside their home region
lead their review had a positive or negative effect on the review
process,[Footnote 20] but about three-quarters thought that the focus
on reporting only noncompliance had a negative or very negative effect
on the on-site review process. When asked the extent to which their
most recent reviews led to program improvements in each of the 10
program component areas, directors generally reported that the review
led to few or no improvements in most program areas, with the exception
of health services and program design and management, which directors
generally thought had improved to a greater extent than other program
areas as a result of their most recent reviews.
Although we cannot directly attribute any improvements in Head Start
program management to these changes, our analysis of on-site review
data does suggest that there may have been some improvements in Head
Start program management since our last review. In 2005, we reported
that about 76 percent of all grantees that had on-site reviews in 2000
had been found to be out of compliance with one or more standards in
the areas of fiscal management, program governance, or record-keeping
and reporting. We also reported that, in subsequent reviews, 53 percent
of those same grantees had been cited again for problems in these same
program areas. Our more recent analysis of on-site review data shows
that, for grantees reviewed in 2003, about 71 percent were found to be
out of compliance with standards in the same three areas of program
management. In 2006, 29 percent of grantees reviewed were cited again
for problems in these three areas.
In response to our 2005 recommendation, ACF has begun to implement
procedures for assessing the quality of on-site reviews. In 2006, ACF
conducted a one-time study of the consistency of on-site reviews. This
study revealed some differences in the findings identified by different
teams of reviewers that visited the same grantees. However, ACF
determined none of the non-duplicated preliminary findings identified
by re-review teams were serious enough to meet the regulatory
definition of a program deficiency. The Improving Head Start Act
further requires that on-site reviews are to be conducted in a manner
that includes periodic assessments of the reliability of the
process.[Footnote 21] ACF is currently working to establish an ongoing
system for evaluating its on-site review process that would address
this new requirement.
ACF Uses Data to Identify Grantees in Need of Assistance, but
Weaknesses Have Hindered Efforts to Improve Grantee Performance:
To improve Head Start grantee performance, ACF uses data from multiple
sources to identify underperforming Head Start grantees. For example,
it uses data to direct resources to grantees in need of training and
technical assistance. It also uses data to identify high-risk grantees
that may need additional oversight. However, ACF's use of data to
improve grantee performance has faced limitations. For example, ACF
does not have clear criteria for determining which grantees need
additional oversight. In addition, ACF had limits on its ability to
obtain competition for grants prior to the recent reauthorization of
Head Start.
ACF Uses Data to Track Grantee Activities and Performance and to Target
Resources to Underperforming Grantees:
ACF uses data from multiple sources to track Head Start grantee
performance and to identify grantees with program weaknesses. In
addition to findings from on-site monitoring reviews, ACF also assesses
grantees' performance through analysis of their audit reports,
financial reports, and other sources of information. One of the ways
that ACF uses data to assess grantee performance is by calculating risk
levels for each grantee, through its refunding analysis system. ACF
determines grantee risk levels by using various indicators, such as
findings from on-site monitoring reviews, turnover of key program
staff, PIR survey data, and negative media coverage.[Footnote 22]
After ACF identifies underperforming grantees, it targets resources
from its training and technical assistance (T/TA) network to help these
grantees address their program weaknesses. ACF gives grantees with
deficiencies priority for receiving services from the T/TA network.
Priority for receiving services is then given, in order, to other
grantees in non-compliance or at risk for deficiencies, grantees new to
providing Head Start services, and grantees with new directors or key
staff. Grantees with deficiencies are sometimes offered on-site
assistance to address their program weaknesses. The T/TA network also
assists grantees through workshops, cluster training for groups of
grantee program staff and management, presentations at local and
national conferences, and other activities. For example, T/TA network
staff members affiliated with ACF's regional office in Atlanta have
provided clustered training to grantees covering topics like literacy,
domestic violence, and guidance related to ACF's on-site monitoring
review process. In addition, all grantees are required to submit an
annual T/TA plan to ACF, identifying their T/TA needs for the coming
year. Grantees can use multiple data sources to identify their T/TA
needs, including on-site monitoring review reports and community
assessments.
Lack of Criteria for Initiating Additional On-site Reviews Undermines
ACF's Ability to Address Severely Underperforming Grantees:
ACF uses the refunding analysis system as an opportunity to identify
program weaknesses before it reviews grantees' annual grant
applications. If the process identifies an underperforming grantee--
those designated as "high risk"--ACF may decide to initiate a special
on-site review to determine whether the grantee is deficient and
whether the grantee should ultimately be terminated. If the grantee is
deemed deficient, ACF can require the grantee to correct the
deficiencies within specified time frames,[Footnote 23] or to begin a
quality improvement process, after which ACF will assess whether the
grantee has corrected all deficiencies. In all cases, grantees that do
not correct identified deficiencies are subject to termination
proceedings. However, ACF's criteria for deciding which grantees are
subject to the special on-site review are unclear. These decisions are
typically made on an ad-hoc basis, which may result in grantees with
similar problems receiving inconsistent levels of oversight. We have
reported that consistency is an essential component to ensuring
performance accountability in federal grants.[Footnote 24]
Prior to enactment of the Improving Head Start Act, statutory
provisions limited ACF's ability to terminate underperforming grantees
at the time an on-site review or the annual refunding analysis showed
inadequate performance. ACF was required to grant priority to existing
grantees[Footnote 25] when making funding decisions, unless ACF
determined that the grantee failed to meet program, financial
management, or other requirements established by ACF. However, before
ACF could terminate a failing grantee and open the grant to competition
from other prospective grantees, ACF was required to provide the
grantee with official notice and an opportunity for a hearing on its
termination--or convince the grantee to relinquish its grant. Moreover,
if a grantee appealed ACF's termination decision, ACF was required to
pay the grantee's legal fees until the hearing process was completed.
Recent work related to grants management has pointed to competition for
grants as a way to facilitate grant accountability. For example, the
Domestic Working Group, chaired by the Comptroller General of the
United States, cited grant competition as a key area of opportunity for
improving grant accountability.[Footnote 26] It noted that grant
competition promotes fairness and openness in the selection of
grantees, and that agencies can better ensure that grantees have the
capability to efficiently and effectively meet grant goals by
incorporating evaluation criteria focused on factors indicative of
success into the competition process.[Footnote 27]
The recent reauthorization of Head Start amends some of the
requirements and procedures for refunding Head Start grantees,
including the introduction of time limits for Head Start
grants.[Footnote 28] This will give ACF the ability to open competition
for Head Start grants to additional grantees, thereby enhancing ACF's
ability to remove severely underperforming grantees from the program,
on a regular basis.
Conclusions:
In light of federal budget limitations and increasing expectations for
program accountability, ACF's ability to demonstrate effective
stewardship over billions of dollars in Head Start grants has never
been more critical. Since our 2005 review, ACF has made significant
improvements in its procedures for monitoring local Head Start
programs. In particular, the agency has taken steps to bring together
information about individual grantees from various sources in order to
identify those that are struggling to meet Head Start performance
standards, and to target assistance to help these grantees strengthen
their programs. This risk-based approach is promising and provides a
foundation for a more strategic, comprehensive approach to managing the
Head Start program. Nevertheless, ACF's current initiatives do not yet
constitute a comprehensive plan for managing program risks. Without a
more comprehensive approach to identifying risks, threats to ACF's
ability to achieve Head Start program objectives will likely go
undetected until a problem arises. For example, undetected improper
payments could result in a severe reduction in the funds available to
pay for services for children.
Although ACF has made progress since we last reported in 2005 toward
strengthening its oversight of the approximately 1,600 local agencies
that receive Head Start program grants, its systems for doing so depend
in part on data that are unreliable. If ACF does not act to address the
weaknesses in its data, it cannot depend on its new systems to provide
it with reliable information on grantee performance. The lack of
reliable information about local program activities further compromises
ACF's ability to manage risks by limiting its ability to understand
whether problems are isolated or national in scope, as well as whether
they arise from individual grantee failures or from weaknesses in the
broader structure of the program itself. A lack of sound information
also calls into question the credibility of ACF's reporting to Congress
and the American public on the services provided by the Head Start
program.
Even if ACF conducts a comprehensive risk assessment of the Head Start
program and works to improve the accuracy of its data, it will still
face challenges addressing risks posed by the most severely
underperforming grantees. The annual refunding process could be used to
link funding opportunities to performance. For example, if ACF develops
clear and objective criteria for deciding which grantees are subject to
a special on-site review, it could ensure that all grantees with
similar problems receive similar levels of oversight. Without such
criteria, special on-site reviews will continue to be conducted on an
ad-hoc basis and, as a result, ACF may continue to fund poorly
performing grantees that do not receive special on-site reviews without
providing them the additional oversight they need.
Recommendations for Executive Action:
To improve its management and oversight of the Head Start program, we
are making the following four recommendations to HHS's Assistant
Secretary for Children and Families:
* More fully implement our 2005 recommendation by developing a
strategic and comprehensive approach to assessing Head Start
programwide risks. A comprehensive, programwide risk assessment should
take all program risks into account. Specifically, a comprehensive risk
assessment should include an assessment of risks arising from external
sources, such as social and demographic changes that may affect the
availability or demand for Head Start program services, as well as from
internal sources, such as underperforming grantees, differences in how
regional offices implement program policies and procedures, or the
availability of sound data to help manage the program. A comprehensive
risk assessment should also include strategies for minimizing risks
that could significantly limit the ability of ACF and grantees to help
grantees deliver high-quality programs.
* Look for cost-effective ways to expand ACF's efforts to comply with
the Improper Payments Information Act of 2002 and to address our 2005
recommendation by collecting data on and estimating the extent of
improper payments made for unallowable activities and other
unauthorized purposes. These should take into account various aspects
of the program and should not be limited to improper payments to
grantees that enroll too many children from families that do not meet
the program's income eligibility requirement.
* Take additional steps to ensure the accuracy of PIR data by
determining which elements of the PIR are essential for program
management and focus resources on a streamlined version of the PIR that
would be required annually of all grantees, with the responses verified
periodically. If additional information is needed to produce national
estimates of a wider range of Head Start program services, ACF should
include the relevant, additional data items in an expanded version of
the PIR, which could be administered to a random, representative sample
of grantees each year.
* Develop clear criteria for determining which grantees require more
thorough reviews--such as special, on-site reviews--as a result of its
refunding analysis system.
Agency Comments and Our Evaluation:
We provided a draft of this report to ACF for comment. The full text of
these comments appears in appendix II. ACF agreed with two of our
recommendations, and emphasized progress already made toward developing
a comprehensive risk assessment process and toward reducing improper
payments. Specifically, ACF noted that it plans to implement a
programwide risk management process in early 2008. ACF also said that
it has developed a new integrated data management system. While we
agree that ACF's planned programwide risk management process and
integrated data management system are important initiatives that may
facilitate programwide risk assessment, both systems have yet to be
fully implemented and it remains to be seen how these systems will
actually be used to proactively manage the Head Start program
nationally. ACF also emphasized the progress it has made to reduce the
frequency and amount of improper payments arising from participants'
ineligibility, and that its focus on eligibility is consistent with how
ACF has implemented the Improper Payments Information Act of 2002 for
other programs, and was approved by HHS and OMB management. We agree
that ACF's progress toward reducing the improper payment error rate due
to Head Start program ineligibility from 3.6 percent in 2003 to 1.3
percent in 2006 is commendable, and acknowledge ACF's commitment to
reducing improper payments for the Head Start program. However, as
noted in ACF's comments, the agency's improved monitoring efforts and
planned risk management initiatives may help ACF to identify further
areas for study related to improper payments, and we encourage ACF to
pursue these areas, as practical. ACF agreed with our recommendation to
review and streamline its annual PIR survey of grantees, noting that it
will continue to use the results of its own PIR validation study to
inform the design of future surveys, take steps to periodically verify
grantee responses, and leverage technological improvements to capture
program data more frequently and consistently. Finally, ACF said it
will soon have the ability to define realistic criteria for determining
which grantees require more thorough or special reviews, and noted that
improvements in monitoring, and changes to the process for designating
grantees resulting from reauthorization, should help enable it to do
so. We're encouraged that ACF said it should have both its risk
management process and its integrated data management systems
operational this year. Both systems will play an important role in its
efforts to better target its oversight efforts.
List of Congressional Requesters:
The Honorable Edward M. Kennedy:
Chairman:
The Honorable Michael B. Enzi:
Ranking Member:
Committee on Health, Education, Labor and Pensions:
United States Senate:
The Honorable Christopher J. Dodd:
Chairman:
The Honorable Lamar Alexander:
Ranking Member:
Subcommittee on Children and Families:
Committee on Health, Education, Labor and Pensions:
United States Senate:
The Honorable George Miller:
Chairman:
The Honorable (Howard) P. "Buck" McKeon:
Ranking Member:
Committee on Education and Labor:
House of Representatives:
The Honorable Dale E. Kildee:
Chairman:
The Honorable Michael N. Castle:
Ranking Member:
Subcommittee on Early Childhood, Elementary and Secondary Education:
Committee on Education and Labor:
House of Representatives:
The Honorable Lynn C. Woolsey:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To answer our research objectives, we interviewed Administration for
Children and Families (ACF) and Office of Head Start officials and
their staff in Washington, D.C., and in the ACF regional offices in
Philadelphia and Atlanta. We conducted interviews with staff from all
of ACF's 10 regional offices, and reviewed relevant documentation from
each of these offices. We visited two regional offices--Philadelphia
and Atlanta--to help us develop interview and data collection protocols
and conducted telephone interviews with the remaining eight regional
offices.
To obtain grantees' opinions on ACF's oversight of the Head Start
program, we administered a Web-based survey to a nationally-
representative sample of Head Start and Early Head Start program
directors. Our target population consisted of directors whose programs
were the subject of on-site reviews from October 2005 through March
2007, and were reviewed under ACF's newly revised on-site review
process. Based on data supplied by ACF and the contractor responsible
for coordinating the on-site reviews, we identified a total population
of 598 Head Start grantees. From this population, we selected a
stratified random probability sample of 329 grantees. We stratified the
population based on whether or not the grantee has any delegate
agencies and the ACF region in which the grantee operates.[Footnote 29]
We also included in our sample all grantees that participated in ACF's
2006 one-time study of the consistency of its on-site reviews. With
this probability sample, each grantee had a nonzero probability of
being selected, and that probability could be computed for any grantee.
Each grantee selected in the sample was subsequently weighted in the
analysis to account statistically for all the grantees in the
population.
Because we followed a probability procedure based on random selections,
our sample is only one of a large number of samples that we might have
drawn. Since each sample could have provided different estimates, we
express our confidence in the precision of our particular sample's
results as a 95 percent confidence interval. This is the interval that
would contain the actual population value for 95 percent of the samples
we could have drawn. As a result, we are 95 percent confident that each
of the confidence intervals in this report will include the true values
in the study population. All percentage estimates from this survey have
margins of error of plus or minus 10 percent or less, unless otherwise
noted.
We developed our survey questions based on feedback that we received
during three focus group sessions that we conducted with Head Start
program directors whose programs were reviewed under the revised on-
site review process. After we drafted the survey questionnaire, we
conducted a series of six pretests by telephone to check that (1) the
questions were clear and unambiguous, (2) terminology was used
correctly, and (3) the information could feasibly be obtained. We made
changes to the content and format of the questionnaire as necessary
during the pretesting process.
The survey was fielded between July 12, 2007, and August 20, 2007. Of
the 329 program directors in our sample, 261 responded--for a response
rate of 79 percent.
To assess the changes ACF made to its on-site monitoring review
process, we met with the contractor responsible for coordinating the
reviews, as well as with representatives from the National Head Start
Association, and reviewed the results of a study conducted by ACF to
evaluate its on-site review process.
We also analyzed the extent to which ACF's on-site monitoring reviews
identified repeat noncompliance by Head Start grantees, using 2003 and
2006 data from the on-site review database that is currently maintained
by Danya International, Inc. (Danya). We used four data elements from
this database for our analysis: Grantee ID, Fiscal Year, Review Type,
and Core Area. We further limited our analysis to three core areas:
program governance, record-keeping and reporting, and fiscal
management. To assess the reliability of these data, we relied on both
our 2005 assessment of the reliability of 2003 data, and performed
additional tests. Specifically, we conducted electronic testing of both
the 2003 and 2006 data and found no missing or out-of-range entries for
any of the four elements that we used, and obtained additional
information about the 2006 data from Danya. Based on our previous and
updated assessments, we find the 2003 and 2006 data sufficient for the
purpose of this engagement.
We analyzed the on-site review data for 2003 and 2006 to obtain, for
each year, the numbers of (1) all grantees reviewed, (2) grantees
receiving triennial or first-year reviews only, and (3) grantees cited
for deficiency or noncompliance in one, two, or all three of the core
areas of interest (program governance, record-keeping and reporting,
and fiscal management). To obtain the number of grantees with repeat
noncompliance, we computed the number of grantees cited for
noncompliance or deficiency in both 2003 and 2006, in each of the same
core areas. The computer code used to derive these numbers was
subjected to independent review within GAO and was found to be
accurate.
We reviewed ACF studies from 1995 and 2007 on the validity and accuracy
of PIR data, the results of which are discussed in this report. We also
conducted consistency tests on PIR data from the 2006 PIR database,
similar to the tests that we conducted on the 2003 PIR database for our
2005 report on Head Start oversight. Overall we conducted 29 tests,
across all three sections of the PIR database: Enrollment and Program
Operations, Program Staff and Qualifications, and Child and Family
Services. In 9 of our 29 tests, PIR data contained inconsistent data
that did not sum to the expected totals. In each of the nine tests that
failed, less than 1 percent of the 2,696 data items failed. Our
findings indicate that the PIR database contains some inconsistent
data.
Table 1: Summary of Results for PIR Data Consistency Tests, 2006 PIR
Database:
Section of PIR Database: Enrollment and Program Operations;
Number of PIR data elements tested: 8;
Number of tests that passed: 8;
Number of tests that failed: 0.
Section of PIR Database: Program Staff and Qualifications;
Number of PIR data elements tested: 7;
Number of tests that passed: 5;
Number of tests that failed: 2.
Section of PIR Database: Child and Family Services;
Number of PIR data elements tested: 14;
Number of tests that passed: 7;
Number of tests that failed: 7.
Section of PIR Database: Total;
Number of PIR data elements tested: 29;
Number of tests that passed: 20;
Number of tests that failed: 9.
Source: GAO analysis.
[End of table]
Our work was conducted from February 2007 through December 2007 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Comments from the Department of Health and Human Services:
Department Of Health & Human Services:
Office of the Assistant Secretary for Legislation:
Washington, D.C. 20201:
January, 10, 2008:
Cornelia M. Ashby, Director:
Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Ms. Ashby:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO) draft report entitled: "Head Start: A
More Comprehensive Risk Management Strategy and Data Improvements Could
Further Strengthen Program Oversight".
The Department appreciates the opportunity to review and comment on
this report before its publication.
Sincerely,
Signed by:
Rebecca Hemard for:
Vincent J. Ventimiglia:
Assistant Secretary for Legislation:
Comments Of The Department Of Health And Human Services (HHS) On The
Government Accountability Office Draft Report Titled, "Head Start: A
More Comprehensive Risk Management Strategy And Data Improvements Could
Further Strengthen Program Oversight" (GAO-08-221):
GAO Recommendations:
To improve its management and oversight of the Head Start program, we
are making the following four recommendations to HHS's Assistant
Secretary for Children and Families:
* More fully implement our 2005 recommendation by developing a
strategic and comprehensive approach to assessing Head Start program-
wide risks. A comprehensive, program-wide risk assessment should take
all program risks into account. Specifically, a comprehensive risk
assessment should include an assessment of risks arising from external
sources, such as social and demographic changes that may affect the
availability or demand for Head Start program services, as well as from
internal sources, such as underperforming grantees, differences in how
regional offices implement program policies and procedures, or the
availability of sound data to help manage the program. A comprehensive
risk assessment should also include strategies for minimizing risks
that could significantly limit the ability of ACF's [sic] and grantees
to help grantees' [sic] deliver high-quality programs.
* Look for cost-effective ways to expand ACF's efforts to comply with
the Improper Payments Information Act of 2002 and to address our 2005
recommendation by collecting data on and estimating the extent of
improper payments made for unallowable activities and other
unauthorized purposes. These should take into account various aspects
of the program and should not be limited to improper payments to
grantees that enroll too many children from families that do not meet
the program's income eligibility requirement.
* Take additional steps to ensure the accuracy of PIR data by
determining which elements of the PIR are essential for program
management and focus resources on a streamlined version of the PIR that
would be required annually of all grantees, with the responses verified
periodically. If additional information is needed to produce national
estimates of a wider range of Head Start program services, ACF should
include the relevant, additional data items in an expanded version of
the PIR, which could be administered to a random, representative sample
of grantees each year.
* Develop clear criteria for determining which grantees require more
thorough reviews”such as special, on-site reviews”as a result of its
refunding analysis system.
HHS Comments:
Since GAO's last report on this topic, ACF has made progress in
implementing the recommendations outlined in order to provide high-
quality services to our nation's children, families, and communities.
Improvements to results-oriented oversight and management, including
reconciliations in Federal funds and changes to the monitoring process,
have been made. The Office of Head Start (OHS) was reorganized and
policies and procedures are being standardized. Inconsistencies in
policy and policy implementation have been identified and largely
addressed. Further action will continue. The Head Start program
performance standards and other regulations are under review and
redesign to address changes required in the law, in the field of early
childhood, and in the social and demographic landscape.
With regard to specific recommendations:
* A national refunding analysis process for central office
communication with regional office program and grants staff was
instituted to analyze available data and information prior to issuance
of each grantee's annual refunding notice. Simultaneously, a more
comprehensive grantee risk assessment was developed and implemented in
two regions. These activities evolved into a program-wide risk
management process that is on track for national implementation in
early 2008. This process involves internal program, grants, and
technical assistance staff and managers, grantee staff and board
members, and representatives of other funding sources for the grantee.
Through this process, Head Start will better identify risks,
challenges, and opportunities that Head Start programs may be
experiencing, and proactively provide targeted technical assistance to
minimize risks and foster innovations. An integrated data management
system has been developed to provide operational oversight and to
improve the quality, availability, and consistency of grantee and
management data. In addition to greater knowledge of grantee operations
to inform of decision making, the process offers increased ability to
identify internal risks based on staff performance and to target staff
development opportunities. Aggregate data will be utilized to determine
program-wide risks, strengths, and trends. It should be noted that this
system is in full compliance with the Office of Management and Budget's
(OMB) requirements for technical investment reporting.
* OHS has made regular and successful efforts since passage of the
Improper Payments Information Act of 2002 (IPIA) to identify and
eliminate improper payments. OHS has fully complied with the
requirements of the Act and the directives of OMB in this area. In
2002, before passage of the Act, OHS worked with OMB and Health and
Human Services (HHS) and ACF management to arrive at an appropriate and
effective approach to identify and eliminate improper payments in the
Head Start program. This approach has indeed focused on eligibility, as
the GAO report notes. This was done primarily because eligibility was
considered an area where the most frequent improper payments could be
found and such payments most closely fit the definition of improper
payment in the Act. Examining eligibility of recipients in the context
of possible improper payments is consistent with the manner in which
ACF has implemented the Act for other programs designated at risk of
improper payments, and has been approved by both HHS and OMB
management.
The report implies that OHS does not focus on other possible improper
payments than those related to eligibility. While ACF's IPIA efforts do
in fact focus on eligibility, OHS uses other efforts to identify and
eliminate improper payments as well, including but not limited to OMB's
A-133 annual audit process.
Finally, the report fails to credit OHS for not only meeting the spirit
of the IPIA but its intent. OHS has a proven track record of reducing
the frequency and amount of improper payments. Since 2002, the Improper
Payment Error Rate for Head Start, as reported in the annual HHS
Performance and Accountability Report, has declined from 3.6 percent in
2003 to 1.3 percent in 2006.
Further areas for study related to improper payments may be identified
through monitoring improvements and increased risk management. Head
Start will determine whether formal study on other types of improper
payments is warranted, based on, for example, analysis of disallowance
issues and rates. Where necessary, OMB approval will be pursued.
* OHS agrees with GAO's recommendation to review and streamline the
Program Information Report (PIR). The PIR validation study results will
continue to inform the design, and OHS will periodically verify the
responses. Increases in technological capacity at the national and
program levels provide the ability to capture and use data with greater
frequency and consistency.
* OHS will soon have the ability to define realistically the criteria
for determining which grantees require more thorough or special
reviews, based on continued improvements to the OHS monitoring process,
the redesignation process required through reauthorization, and
implementation of the national risk management process.
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contact:
Cornelia Ashby (202) 512-7215 or asbyc@gao.gov:
Acknowledgments:
The following individuals made important contributions to this report:
Bill J. Keller, Regina Santucci, Christopher W. Backley, Susannah
Compton, James Ashley, Cindy Gilbert, Alison Martin, George Quinn,
Jerry Sandau, Elizabeth Wood, Kimberly Brooks, Jacqueline Nowicki,
Doreen Feldman, Alexander Galuten, and James Rebbe.
[End of section]
Appendix IV: Related GAO Products:
Improper Payments: Incomplete Reporting under the Improper Payments
Information Act Masks the Extent of the Problem. GAO-07-254T.
Washington, D.C.: December 5, 2006.
Grants Management: Enhancing Performance Accountability Provisions
Could Lead to Better Results. GAO-06-1046. Washington, D.C.: September
29, 2006.
Head Start: Progress and Challenges in Implementing Transportation
Regulations. GAO-06-767R. Washington, D.C.: July 27, 2006.
Head Start: Comprehensive Approach to Identifying and Addressing Risks
Could Help Prevent Grantee Financial Management Weaknesses. GAO-05-176.
Washington, D.C.: February 28, 2005.
Head Start: Better Data and Processes Needed to Monitor
Underenrollment. GAO-04-17. Washington, D.C.: December 4, 2003.
Head Start: Increased Percentage of Teachers Nationwide Have Required
Degrees, but Better Information on Classroom Teachers' Qualifications
Needed. GAO-04-5. Washington: D.C.: October 1, 2003.
Managing for Results: Efforts to Strengthen the Link between Resources
and Results at the Administration for Children and Families. GAO-03-9.
Washington, D.C.: December 10, 2002.
Strategies to Manage Improper Payments: Learning from Public and
Private Sector Organizations. GAO-02-69G. Washington, D.C.: October
2001.
Standards for Internal Control in the Federal Government. GAO/AIMD-00-
21.3.1. Washington, D.C.: November 1999.
[End of section]
Footnotes:
[1] GAO, Head Start: Comprehensive Approach to Identifying and
Addressing Risks Could Help Prevent Grantee Financial Management
Weaknesses, GAO-05-176 (Washington, D.C.: Feb. 28, 2005).
[2] Head Start is authorized to serve children at any age prior to
compulsory school attendance. The program was originally aimed at 3-to
5-year-olds. Early Head Start, begun in 1994, focuses on serving
children from birth to 3 years of age and pregnant women. For the
purposes of this report on program oversight, when we discuss the Head
Start program, we are referring to both Head Start and Early Head
Start.
[3] Pub. L. No. 110-134 (2007).
[4] Under the Improving Head Start Act, a grantee that is determined to
be delivering a "high-quality and comprehensive Head Start program" is
designated as a "Head Start agency" for 5 years. Grantees that do not
deliver a high-quality, comprehensive Head Start program are subject to
an open competition for grant funding.
[5] Although Head Start is intended to serve primarily children whose
family income is at or below the federal poverty line, its regulations
permit up to 10 percent of children to be from families that are not
low-income, and up to 49 percent in American Indian-Alaska Native
programs. See 45 C.F.R. § 1305.4(b)(2)-(3).
[6] 42 U.S.C. § 9836a.
[7] For a complete discussion of the principles of internal control and
their importance to federal program management, see GAO, Standards for
Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
(Washington, D.C.: November 1999) and Office of Management and Budget
(OMB) Circular A-123, Management's Responsibility for Internal Control
(Dec. 21, 2004).
[8] As of early November 2007, OMB had yet to approve funding for this
project. According to OMB Circular A-11 Part 7, Planning, Budgeting,
Acquisition, and Management of Capital Assets (July 2007), agencies are
required to submit an attachment to their yearly budget request
justifications, known as an OMB Exhibit 300, outlining any new spending
for information technology initiatives, such as the HSES. OMB uses this
to help allocate budgetary resources according to the Administration's
priorities and to assess whether agencies' programming processes are
consistent with OMB policy and guidance. According to OMB, ACF has not
submitted an OMB 300 for the HSES.
[9] Pub. L. No. 107-300 (2002).
[10] Improper payments include any payments that should not have been
made under applicable requirements, including payments in an incorrect
amount or to an ineligible recipient.
[11] Pub. L. No. 110-134, § 28.
[12] Under 45 C.F.R. § 1305.4(b)(1), at least 90 percent of the
children who are enrolled in each Head Start program must be from
families with incomes below the official poverty line. Children from
families that are receiving public assistance or who are in foster care
are eligible to receive Head Start services, regardless of income.
[13] U.S. Department of Health and Human Services Office of Inspector
General, Enrollment Levels in Head Start, OEI-05-06-00250 (April 2007).
[14] See OIG reports A-01-04-02501, A-05-04-00023, and A-07-04-02016,
available at [hyperlink, http://oig.hhs.gov].
[15] Pub. L. No. 110-134, §7, 42 U.S.C. § 9836(c)(1)(E).
[16] This difference was found to be statistically significant at the
95 percent confidence level.
[17] Danya policy also requires that, beginning in fiscal year 2007,
all educational degrees and work experience of current reviewers must
also be verified before they may conduct further monitoring reviews.
[18] The reviewer pool includes both peer reviewers, who are employees
of Head Start grantees and may participate in a limited number of
reviews each year, and consultant reviewers, who are full-time
consultants. As of October 2007, 482 of the 1,285 available on-site
reviewers (38 percent) were peer reviewers.
[19] ACF requires that violations of health and safety regulations must
be resolved within 30 days.
[20] An estimated 36 percent thought that selecting review team leaders
from outside of their region had a very or somewhat positive effect and
37 percent thought that this change had a very or somewhat negative
effect. About 24 percent thought that the change had neither a positive
nor negative effect.
[21] Pub. L. No. 110-134, § 8, 42 U.S.C. § 9836a(c)(2)(G).
[22] As previously indicated, the PIR data reported by individual Head
Start grantees are frequently inaccurate and may be unreliable for
grantee monitoring or risk assessment purposes.
[23] Under 42 U.S.C. § 9836a(e)(1)(B), ACF shall require the grantee to
correct the deficiency immediately if the deficiency threatens the
health or safety of staff or program participants or poses a threat to
the integrity of federal funds. If ACF determines, in light of the
nature and magnitude of the deficiency, that a 90-day period is
reasonable, ACF may require that the grantee correct the deficiency
within that time frame.
[24] GAO, Grants Management: Enhancing Performance Accountability
Provisions Could Lead to Better Results, GAO-06-1046 (Washington, D.C.:
Sept. 29, 2006).
[25] Priority was required to be granted to grantees that were
receiving Head Start funds on August 13, 1981.
[26] The Domestic Working Group consists of 19 federal, state, and
local audit organizations. The purpose of the group is to identify
current and emerging challenges of mutual interest and explore
opportunities for greater collaboration within the intergovernmental
audit community.
[27] Domestic Working Group: Grant Accountability Project, Guide to
Opportunities for Improving Grant Accountability (Washington, D.C.:
October 2005).
[28] As previously stated, under the Improving Head Start Act, a
grantee that is determined to be delivering a high-quality and
comprehensive program is designated as a Head Start agency for a 5-year
period. A grantee that does not deliver a high-quality and
comprehensive program is subject to an open competition.
[29] A Head Start grantee may subcontract with other public, or private
nonprofit organizations to provide part or all of the grantee's Head
Start services. The subcontractors providing the Head Start services
are referred to as delegate agencies.
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