Head Start
Progress and Challenges in Implementing Transportation Regulations Gao ID: GAO-06-767R July 27, 2006The leading cause of death for children ages 3 to 7 is motor vehicle traffic crashes. Head Start, a federal early care and education program run by local grantees and targeted at low-income children, currently serves approximately 900,000 children, and transports many of them to and from Head Start centers across the country. While not required to do so, many Head Start grantees offer transportation as a way to make Head Start more widely available to the eligible population, especially very poor children. To address concerns about transporting children safely, the 1992 Head Start Improvement Act directed the Office of Head Start, housed within the U. S. Department of Health and Human Services (HHS), to develop transportation regulations to ensure the safety and effectiveness of transportation services made available to children by Head Start grantees. Head Start issued these regulations in 2001. To provide Congress with information that it requested on the regulations and their implementation, we determined: (1) the research and cost information Head Start considered in establishing the transportation regulations; (2) the actions Head Start grantees have taken to implement the vehicle, restraint, and bus monitor requirements of the regulations and the number of grantees that have sought waivers and extensions; and (3) the associated expenses and effects of implementing the regulations on grantees and their transportation partners.
Concerning the research and cost information that Head Start considered, we found that the Office of Head Start considered safety research and data in developing the regulations. Research and safety data from the National Highway Traffic Safety Administration (NHTSA), the National Transportation Safety Board (NTSB)--an independent federal agency charged with investigating transportation accidents and identifying safety improvements--and the National Academy of Science's Transportation Research Board shows that buses--both school buses and other types, such as transit buses--have lower fatality rates than other modes of transportation. The requirement for a bus monitor was based on Head Start's conclusion that young children on a bus should be supervised. Although the Office of Head Start did not research the need for monitors, it based this requirement on the belief that preschool- age children and younger who ride a bus should be supervised by an adult monitor in case the driver becomes disabled. The Office of Head Start no longer has supporting documentation for its cost estimate of $18.9 million for implementing the regulations. Without this documentation, we cannot determine the reliability of the data Head Start used to develop its estimates. Regarding grantees' actions to implement the regulations and the extent to which they sought extensions and waivers, we found that grantees have made progress in implementing the regulations. Approximately 64 percent report that they have finished implementing the regulations while 18 percent reported being almost finished. Almost all grantees reported primarily using a vehicle type that complies with the regulations. Ninety-seven percent of grantees reported primarily using either a school bus (93 percent) or the alternative vehicle allowed by the regulations (4 percent) to transport Head Start children on a daily basis. Grantees reported taking a variety of actions to meet the restraint and monitor requirements. Most grantees reported (1) either buying restraints and retrofitting their buses with them, or having had vehicles with restraints already in them; and (2) adding the bus monitor responsibilities to duties of existing staff or having had monitors already in place. Some transit agencies and other transportation providers who work with Head Start are facing difficulties in using the alternative vehicle. This is due to a lack of guidance for adapting it to transport other populations in addition to Head Start children. Fewer grantees requested more time to implement the restraint and monitor provisions in 2006 compared to 2004, but the number of waiver requests is unknown. In 2006, 19 percent of grantees submitted extension requests, dropping from 30 percent in 2004. As for waivers requested under the general waiver authority provided for in the regulations, the Office of Head Start officials stated that they were unaware that any were submitted. With respect to the costs and effects on grantees associated with implementing the regulations, we found that many grantees reported some cost effects from implementing the regulations, but noted that they were facing other budgetary pressures. Fifty-six percent of grantees reported no more than moderate cost effects on their transportation budgets from implementing the vehicle, restraint, or monitor requirements while 44 percent reported experiencing large or very large increases associated with one or more of these requirements. Grantees are experiencing effects to transportation services or program operations as a result of implementing the regulations. Fifty-eight percent of grantees reported at least one effect on transportation services as a result of the regulations, most often noting that they changed transportation routes (83 percent) or reduced transportation services (50 percent). Finally, some grantees are facing difficulties sustaining transportation partnerships.
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United States Government Accountability Office: Washington, DC 20548:
July 27, 2006:
Congressional Requesters:
Subject: Head Start: Progress and Challenges in Implementing
Transportation Regulations:
The leading cause of death for children ages 3 to 7 is motor vehicle
traffic crashes. Head Start, a federal early care and education program
run by local grantees and targeted at low-income children, currently
serves approximately 900,000 children, and transports many of them to
and from Head Start centers across the country. While not required to
do so, many Head Start grantees offer transportation as a way to make
Head Start more widely available to the eligible population, especially
very poor children. To address concerns about transporting children
safely, the 1992 Head Start Improvement Act directed the Office of Head
Start,[Footnote 1] housed within the U. S. Department of Health and
Human Services (HHS), to develop transportation regulations to ensure
the safety and effectiveness of transportation services made available
to children by Head Start grantees. Head Start issued these regulations
in 2001.
Grantees were required to meet most provisions of the transportation
regulations shortly after their issuance in January 2001; however, the
compliance date for the provisions regarding passenger restraints and
bus monitors was 3 years later, and the provision regarding vehicles
was 5 years later. In addition, grantees had two opportunities--in 2004
and in 2005--to delay or seek a waiver from implementing the restraint
and monitor provisions by requesting extensions through the Office of
Head Start.[Footnote 2] Further, when grantees annually renew their
funding, the transportation regulations also permit them to request a
waiver[Footnote 3] for good cause from any provision of the
regulations--which the Office of Head Start may approve or
deny.[Footnote 4] For purposes of this report, we refer to extensions
as implementation delays resulting from the 2004 and 2005 provisions
and waivers as those submitted under the general waiver authority
provided for in the regulations.
In commenting on the regulations, grantees expressed concern about the
cost of complying with the regulations and cautioned that, since
transportation was an optional service, these costs might lead some
grantees to discontinue offering it at some sites. They also noted that
the regulations might jeopardize long-standing partnerships with
groups, such as schools and transit agencies, which some grantees use
or contract with to provide transportation to their Head Start
children. Controversy has also surrounded the requirement for child
safety restraints, which typically are not standard on school
buses.[Footnote 5] Restraints reduce seating capacity, which could
result in fewer school age children being transported on school buses
in favor of other modes of transportation--such as cars-that are less
safe. Additionally, given the safety record of school buses, some
school systems have questioned whether the costs of installing
restraints outweigh their benefits.[Footnote 6] Currently, most states
do not require child safety restraints on school buses.
To provide you with information that you requested on the regulations
and their implementation, we determined:
1. The research and cost information Head Start considered in
establishing the transportation regulations.
2. The actions Head Start grantees have taken to implement the vehicle,
restraint, and bus monitor requirements of the regulations and the
number of grantees that have sought waivers and extensions.
3. The associated expenses and effects of implementing the regulations
on grantees and their transportation partners.
To determine the research and cost information Head Start considered,
we reviewed relevant research and regulations and interviewed officials
from the Office of Head Start and the Department of Transportation's
(DOT) National Highway Traffic Safety Administration (NHTSA) and
Federal Transit Administration (FTA). To describe the actions grantees
have taken, we surveyed a nationally representative sample of Head
Start grantees and their delegates, obtaining a response rate of 77
percent. We also analyzed requests for extended time to implement the
child restraint and monitor provisions and interviewed officials from
the Office of Head Start and HHS Regional Offices about the process for
receiving an extension or waiver and other aspects of implementing the
regulations. Information to describe the regulations' effects on
grantees was gathered through our survey and visits we made to seven
grantees and their transportation partners, as appropriate. The states
and HHS Regions in which the selected grantees operated were Indiana
(Region 5), Iowa (Region 7), Kentucky (Region 4), Massachusetts (Region
1), and Washington (Region 10). Overall, the grantees were selected
based on geographical diversity; size (e.g., funded enrollment);
organization type; and to achieve a mix of grantees that filed requests
in 2004 for more time to implement the restraint and monitor
requirements and those that did not. We analyzed this information in
combination with information collected from transportation providers to
describe the expenses grantees incurred and the operational changes
they made to implement the regulations. Enclosure I contains more
details on our scope and methodology. We conducted our review between
July 2005 and May 2006 in accordance with generally accepted government
auditing standards.
On May 16, 2006, we briefed your staff on the results of our review.
This report formally conveys the information provided during that
briefing. (See encl. II for the briefing slides.)
Background:
Head Start issued transportation regulations in 2001 that included
requirements covering equipment, personnel, and training (e.g., for bus
drivers) for transporting Head Start children; in particular, the
regulations mandated that grantees use some type of school bus--or an
alternative vehicle that is similar to a school bus--and required that
children be placed in child restraints and accompanied by bus monitors.
Head Start worked with two agencies within the U.S. DOT--NHTSA and FTA-
-to develop the regulations. NHTSA is responsible for developing
transportation safety standards that protect children in an accident,
including those for school buses. These standards include, for example,
roll over protection and joint strengthening, and require crash testing
to ensure school buses meet them. FTA provides financial assistance to
states to develop new transportation services and improve, maintain,
and operate existing systems that serve multiple populations, including
older adults and people with disabilities. Transit agencies receiving
FTA funding must use buses that meet NHTSA standards for buses, pass
FTA's performance testing, and comply with ADA requirements, among
other requirements. However, these buses do not meet NHTSA's school bus
safety standards and most cannot accommodate child safety
restraints;[Footnote 7] as such, the Head Start transportation
regulations do not include public transit buses among the vehicles
allowed to transport children.
To ensure that transportation is as widely available as possible, other
provisions of the Head Start regulations require that grantees
coordinate transportation with other human services programs, many of
which also provide transportation services.[Footnote 8] Head Start
grantees--particularly those in rural areas--have relied on school
systems and, to a lesser extent, public transit agencies to transport
children. Coordinating transportation services has also been a priority
of Congress and the White House in recent years. For example, in 2005,
Congress passed the Safe, Accountable, Flexible, and Efficient
Transportation Equity Act-A Legacy for Users (SAFETEA-LU), which
requires that human services organizations receiving FTA funding
targeted to older adults, persons with disabilities, and persons with
lower incomes provide transportation services derived from a locally-
developed coordinated public transit human services transportation
plan.
Summary Of Findings:
Concerning the research and cost information that Head Start
considered, we found that:
The Office of Head Start considered safety research and data in
developing the regulations. Research and safety data from NHTSA, the
National Transportation Safety Board (NTSB)--an independent federal
agency charged with investigating transportation accidents and
identifying safety improvements--and the National Academy of Science's
Transportation Research Board shows that buses--both school buses and
other types, such as transit buses-have lower fatality rates than other
modes of transportation. For example, NHTSA data indicates school buses
have 0.2 fatalities per 100 million vehicle miles traveled as compared
to cars carrying children, which have 1.5 fatalities per 100 million
vehicle miles traveled. NTSB also recommended to Head Start that
children be transported in vehicles meeting NHTSA's school bus
standards. NHTSA data also shows that children of all ages are safer
when wearing height-and age-appropriate restraints when traveling on
school buses. NHTSA's crash testing of small school buses in 1997 and
1999 demonstrated that the severity of head injuries exceeded
acceptable levels when preschool age children were not restrained
compared with when they were restrained; this led NHTSA to conclude
that compartmentalization did not sufficiently protect preschool-age
children and that they were safer using restraints. The NTSB concurred
with NHTSA's recommendation. NHTSA's 2002 report to Congress on school
bus safety[Footnote 9]--which addresses large school buses--indicates
that lap/shoulder belts offer some benefit in reducing the risk of
serious injury to older children.[Footnote 10] NHTSA's research,
however, has been limited to school buses as NHTSA has not conducted
crash testing to assess the risk for preschool age children using
restraints on transit buses.
The requirement for a bus monitor was based on Head Start's conclusion
that young children on a bus should be supervised. Although the Office
of Head Start did not research the need for monitors, it based this
requirement on the belief that preschool-age children and younger who
ride a bus should be supervised by an adult monitor in case the driver
becomes disabled.
The Office of Head Start no longer has supporting documentation for its
cost estimate of $18.9 million for implementing the regulations.
Without this documentation, we cannot determine the reliability of the
data Head Start used to develop its estimates. However, Head Start has
lacked the basic information about transportation services offered by
its grantees necessary to have calculated a reliable estimate when
developing the regulations or to answer future questions about the
regulations' costs or effects. This is because the Office of Head Start
has not systematically gathered information on the transportation
services that grantees provide. ACF regional offices were able to
provide us with some information about the transportation services of
their grantees, but the information was neither standardized nor in any
type of database that could be aggregated for purposes of analysis.
Regarding grantees' actions to implement the regulations and the extent
to which they sought extensions and waivers, we found that:
Grantees have made progress in implementing the regulations.
Approximately 64 percent report that they have finished implementing
the regulations while 18 percent reported being almost finished. The
remaining 18 percent reported being either half-way or less than half-
way finished, or not sure.
Almost all grantees reported primarily using a vehicle type that
complies with the regulations. Ninety-seven percent of grantees
reported primarily using either a school bus (93 percent) or the
alternative vehicle allowed by the regulations (4 percent) to transport
Head Start children on a daily basis. Bureau officials stated that they
purposefully provided a long period of time--approximately 5 years--to
implement the vehicle provisions in order to help ensure that grantees
had adequate time to replace their old vehicles with ones that would be
in compliance with the regulations.
Grantees reported taking a variety of actions to meet the restraint and
monitor requirements. Most grantees reported (1) either buying
restraints and retrofitting their buses with them, or having had
vehicles with restraints already in them; and (2) adding the bus
monitor responsibilities to duties of existing staff or having had
monitors already in place.
Some transit agencies and other transportation providers who work with
Head Start are facing difficulties in using the alternative vehicle.
This is due to a lack of guidance for adapting it to transport other
populations in addition to Head Start children. While it was developed
so that grantees' transportation partners could meet the requirements
of both Head Start and other groups, such as older adults or people
with disabilities, NHTSA did not define how the vehicle could differ
with respect to school bus features such as narrow aisle width, high-
back seats, narrow, high steps, and compartmentalized seating. These
features make using the vehicle difficult for older adults and people
with disabilities.
Fewer grantees requested more time to implement the restraint and
monitor provisions in 2006 compared to 2004, but the number of waiver
requests is unknown. In 2006, 19 percent of grantees submitted
extension requests, dropping from 30 percent in 2004.[Footnote 11] As
for waivers requested under the general waiver authority provided for
in the regulations, the Office of Head Start officials stated that they
were unaware that any were submitted. However, we obtained copies of
some waiver requests or the Office of Head Start's denials of them from
a few regional offices and grantees. Additionally, bureau officials
confirmed that they have not specifically defined criteria for
submitting a waiver to guide grantees in applying for a waiver or the
bureau in approving or denying waiver requests.
With respect to the costs and effects on grantees associated with
implementing the regulations, we found that:
Many grantees reported some cost effects from implementing the
regulations, but noted that they were facing other budgetary pressures.
Fifty-six percent of grantees reported no more than moderate cost
effects on their transportation budgets from implementing the vehicle,
restraint, or monitor requirements while 44 percent reported
experiencing large or very large increases associated with one or more
of these requirements. However, grantees that we visited stated that
other costs, such as health insurance, affected their budgets as much
as or more than the regulations.
Historically, Head Start helped grantees with the cost of purchasing
vehicles and restraints through supplemental money called Program
Improvement (PI) funds, providing grantees a total of approximately $76
million in fiscal years 2001 through 2005.[Footnote 12] However,
grantees are now expected to pay for replacing vehicles and restraints
out of annual operating monies or nonfederal sources.
Grantees are experiencing effects to transportation services or program
operations as a result of implementing the regulations. Fifty-eight
percent of grantees reported at least one effect on transportation
services as a result of the regulations, most often noting that they
changed transportation routes (83 percent) or reduced transportation
services (50 percent). Sixty-seven percent of grantees also reported
that implementing the regulations had at least one effect on their
program operations, most often reporting that they increased the number
of staff (58 percent); increased staff hours (54 percent); changed,
reduced, or eliminated other program services (49 percent); or reduced
staff hours in the classroom (49 percent).
Some grantees are facing difficulties sustaining transportation
partnerships. Thirty-six percent of grantees contracted with or used
another organization--mostly school systems--for transportation
services to at least some or all of their program sites. About a
quarter of them reported that their transportation partners
discontinued service for this program year while approximately 39
percent of these grantees reported that the contractor would
discontinue services for the 2006/2007 program year. For example, 14 of
Iowa's 15 DOT regions provided transportation via transit buses to Head
Start grantees prior to the regulations; since the regulations'
issuance, 9 have discontinued or plan to discontinue some or all
services to Head Start grantees, primarily because transit buses do not
meet the definition of an allowable vehicle under the regulations.
Although Iowa's transit buses were built to meet several of NHTSA's
school bus crashworthiness standards and can accommodate child
restraints, they do not meet all of them, such as compartmentalization.
According to Iowa DOT officials, the loss of Head Start funding has
resulted in some Iowa transit agencies reducing services, raising
costs, or both for others they serve, such as older adults or people
with disabilities. FTA and transit officials indicated that other
transit agencies that have had a history of coordinating human services
transportation have encountered similar difficulties.
Conclusions:
Many grantees have implemented the transportation regulations, with
some experiencing adverse program and budgetary effects to do so,
including reducing transportation services. But the Office of Head
Start does not track transportation services that grantees provide and
thus will not know if grantees will be able to continue to comply, or,
if over time, other budget pressures will lead more grantees to cut
transportation. These cuts could ultimately affect grantees' ability to
meet enrollment and other program goals, or reduce transportation
safety by children using less safe forms of transportation.
The waiver process will be the key mechanism for grantees to bring
compliance issues to the Office of Head Start's attention. However, the
Office of Head Start lacks a management process for tracking and
considering waivers. Developing such a process would also allow the
bureau to define the circumstances or issues on which it needs NHTSA's
and FTA's expertise. Further, the bureau has not specifically defined
its criteria for "good cause" so that grantees would know the
conditions under which adhering to the regulations would create a
safety hazard appropriate for requesting a waiver. The absence of a
clear process and criteria may pose a barrier for grantees in using
this mechanism and reduce grantees' assurance that their issues will be
weighed appropriately.
Transit agencies are facing difficulties addressing dual goals: meeting
the mobility needs of multiple populations including Head Start
children, people with disabilities, and older adults while addressing
federal safety requirements. While the federal government has
encouraged human service and transit agencies to use one type of
vehicle to more efficiently transport multiple populations, there has
been limited federal guidance on simultaneously achieving both
efficient mobility and safety goals. Specifically, few transit agencies
use the alternative vehicle because, while it meets Head Start safety
requirements, it does not comply with ADA requirements and consequently
is not practical for transporting older adults and people with
disabilities. Information on how the alternative vehicle can be adapted
for transit would be useful to both transit agencies and Head Start
grantees given the program's mandate to provide services to children
with disabilities.
Furthermore, some transit agencies--in an effort to maintain long-
standing coordination efforts--have adapted transit buses to
incorporate standards that they believe sufficiently protect preschool
age children. However, NHTSA, FTA, and Head Start have not determined
the safety features needed for transit buses to sufficiently protect
these children. Thus, transit agencies are faced with reducing or
eliminating service to Head Start, resulting in some children being
transported in vehicles that are less safe or not being able to attend
Head Start at all.
Recommendations For Executive Action:
In order to determine the ability of grantees to provide transportation
services and to define the waiver process, we make the following three
recommendations to the Office of Head Start:
* Systematically track transportation services provided by grantees so
that the Bureau can determine changes in the availability of these
services, especially any reduction in them.
* Establish a waiver process that specifies criteria for submitting
waivers, including more specific guidance on what constitutes "good
cause," lists the responsible entities for review and approval, and
documents the receipt, review, and final disposition of each waiver.
Should any waiver requests submitted require Head Start to address
issues concerning vehicles, the waiver process should include
consultation with NHTSA and FTA as appropriate.
* Once a process has been established, take steps to ensure that
grantees and regional staff know about it and understand how it works.
In order to enable grantees and transit agencies to better coordinate
transportation services, we make the following two recommendations to
DOT, in consultation with Head Start:
* Develop guidance on adapting the alternative vehicle to incorporate
ADA requirements and communicate this guidance to Head Start grantees
and transit agencies.
* Determine if certain safety features could be incorporated into
transit buses used by Head Start grantees to provide a level of safety
comparable to school buses or alternative vehicles in transporting
preschoolers.
* If this determination cannot be made before the remaining deadlines
expire, we recommend that Head Start, in consultation with DOT, should
determine on a case-by-case basis whether grantees using transit
vehicles with child safety restraints can continue to do so until such
a determination can be made.
* If DOT determines that transit vehicles with appropriate safety
features would afford suitable protections, we recommend that Head
Start adopt these features into the final Head Start transportation
regulations.
Agency Comments:
We provided a draft of our report for comment to the Administration for
Children and Families (ACF); and the Department of Transportation
(DOT), specifically NHTSA and FTA. DOT provided technical comments
which we incorporated where appropriate. Regarding the lack of guidance
on achieving mobility and safety goals, FTA noted that it has a
research project under way aimed at developing a new small bus that
would meet both of these goals. We encourage FTA to continue these
efforts.
ACF agreed with the two recommendations regarding the waiver process
and indicated that it would consider our recommendation that it track
the availability of transportation services. ACF also provided
technical comments that we included in the report where appropriate.
(See encl. III for a copy of ACF's comments.)
As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after its issue date. At that time, we will send copies of the report
to relevant congressional committees and other interested parties and
will make copies available to others upon request. The report will also
be available on GAO's Web site at http://www.gao.gov. If you or your
staff have any questions about this report, please contact either one
of us at (202) 512-7215 (Marnie Shaul) or (202) 512-6570 (Katherine
Siggerud). Betty Ward-Zukerman and Cathy Colwell, Glen Trochelman-
Assistant Directors--Lynn Filla-Clark and Janet Mascia--Analysts-in-
Charge--and Sandra Tasic, Jeffrey Weinstein, Stuart Kaufman, and Nancy
Hess also made key contributions to this report.
Signed by:
Marnie Shaul:
Director, Education, Workforce, and Income Security Issues:
Katherine Siggerud:
Director, Physical Infrastructure Issues:
Enclosures:
List of Congressional Requesters:
The Honorable Howard P. "Buck" McKeon:
Chairman:
The Honorable George Miller:
Ranking Minority Member:
Committee on Education and the Workforce:
House of Representatives:
The Honorable Don Young:
Chairman:
The Honorable James L. Oberstar:
Ranking Minority Member:
Committee on Transportation and Infrastructure:
House of Representatives:
The Honorable Michael N. Castle:
Chairman:
The Honorable Lynn C. Woolsey:
Ranking Minority Member:
Subcommittee on Education Reform:
Committee on Education and the Workforce:
House of Representatives:
The Honorable John A. Boehner:
House of Representatives:
The Honorable Betty McCollum:
House of Representatives:
The Honorable Anne Meagher Northup:
House of Representatives:
Enclosure I:
Objectives, Scope, And Methodology:
We designed our study to determine the following: (1) the research and
cost information Head Start considered in establishing the
transportation regulations; (2) the actions Head Start grantees have
taken to implement the vehicle, restraint, and bus monitor requirements
of the regulations and the number of grantees that have sought waivers
and extensions; and (3) the associated expenses and effects of
implementing the regulations on grantees and their transportation
partners.
We obtained information to determine these objectives by interviewing
cognizant federal and state officials as well as representatives from
associations, advocacy groups, bus manufacturers and dealers, and
independent transportation contractors; collecting and analyzing
extension requests from Head Start grantees submitted to the Office of
Head Start for 2004 and 2006; conducting site visits with Head Start
program officials and their transportation partners; and surveying a
nationally representative sample of Head Start grantees and delegates.
Interviews:
Office of Head Start and HHS Regional Offices: We interviewed officials
from the Office of Head Start to discuss, among other things, the
background and development of the Head Start transportation
regulations, information on grantees' transportation services, and the
extension and waiver process. We also interviewed Head Start program
staff in the 10 HHS Regional offices as well as officials from the
American Indian-Alaska Native and Migrant and Seasonal Program Branches
responsible for Head Start grantees and delegates serving migrant,
American Indian, and Native Alaskan families and children. From the
regional offices, we collected data on the amount of Program
Improvement funds awarded to grantees for purchasing buses and child
restraints, and discussed their perspective on the impact of the
regulations on Head Start grantees and delegates in their regions.
Transportation Agencies: We interviewed officials from the U.S.
Department of Transportation, including the National Highway Traffic
Safety Administration (NHTSA) and the Federal Transit Administration
(FTA). We also interviewed officials from the National Transportation
Safety Board (NTSB), an independent federal agency charged by Congress
to investigate transportation accidents. Our interviews inquired about
the current safety research regarding transporting preschool children
on school buses or alternate vehicles, the agencies' involvement in
helping Head Start to develop the transportation regulations, issues
related to the development of the alternative vehicle, and the impact
of the regulations on transit agencies working with Head Start grantees
and other human service organizations. [Footnote 13]
Associations and Advocacy and Trade Organizations: In addition to
federal officials, we also met with representatives of transportation
associations including the American Public Transportation Association,
Community Transportation Association of America, National Association
of State Directors of Pupil Transportation Services, the National
School Transportation Association, and the National Association for
Pupil Transportation to discuss the impact of the regulations on their
members. We also met with representatives of the American Academy of
Pediatrics to discuss safety issues concerning the transportation of
preschool age children. We spoke with representatives from the National
Head Start Association as well as several of their members at their
annual state directors' meeting to learn more about the perspective of
Head Start grantees on implementing the regulations. Finally, we
interviewed representatives from bus manufacturers and dealers, as well
as independent transportation contractors primarily to gather cost
information about school buses, alternative vehicles, and contracting
for transportation services.
Site Visits:
We visited seven Head Start grantees located in five different states
and ACF regions in order to learn more about the effects on grantees'
budgets and program services from implementing the regulations, and to
meet with their transportation partners, where appropriate, to discuss
the impact of the regulations on providing transportation to Head
Start. The states and HHS Regions in which the selected grantees
operated were Indiana (Region 5), Iowa (Region 7), Kentucky (Region 4),
Massachusetts (Region 1), and Washington (Region 10). Overall, the
grantees were selected based on geographical diversity; size (e.g.,
funded enrollment); organization type; and to achieve a mix of grantees
that filed requests in 2004 for more time to implement the restraint
and monitor requirements and those that did not. (See table 1.) In
addition to these criteria, we specifically selected Iowa and
Washington because of unique partnerships between some Head Start
grantees in those states and organizations that helped them transport
Head Start children to and from their centers.
Table 1: Site Selection Characteristics:
Grantee location: Greencastle, Ind;
ACF region: 5;
Organization type: Non-profit;
Funded enrollment (children): 415;
Filed extension request in 2004: No.
Grantee location: Louisville, Ky;
ACF region: 4;
Organization type: School system;
Funded enrollment (children): 1,850;
Filed extension request in 2004: Yes.
Grantee location: Fort Dodge, Iowa;
ACF region: 7;
Organization type: Non-profit;
Funded enrollment (children): 194;
Filed extension request in 2004: Yes.
Grantee location: Renton, Wash;
ACF region: 10;
Organization type: Government agency;
Funded enrollment (children): 1,703;
Filed extension request in 2004: Yes.
Grantee location: Pullman, Wash;
ACF region: 10;
Organization type: Non-profit;
Funded enrollment (children): 72;
Filed extension request in 2004: No.
Grantee location: Boston, Mass;
ACF region: 1;
Organization type: Community action agency;
Funded enrollment (children): 2,000;
Filed extension request in 2004: Yes.
Grantee location: Westfield, Mass;
ACF region: 1;
Organization type: School system;
Funded enrollment (children): 205;
Filed extension request in 2004: No.
[End of table]
Documentation:
In conducting our work, we reviewed relevant background information on
the programs, regulations, legislation, and transportation research
studies and viewed videotapes of NHTSA's crash testing of small school
buses with preschool-age dummies. We also collected and analyzed all
extension requests for more time to implement the restraint and monitor
provisions from Head Start grantees to the Office of Head Start, as
well as some waiver request letters that either regional offices or
grantees provided us. Finally, we collected data on the amount of
Program Improvement funds awarded to Head Start grantees used to
purchase buses or child restraints from all HHS regional offices. While
we asked for this data for fiscal years 2001 through 2005, some
Regional offices were not able to provide this information for all
years. Specifically, we did not receive data from four regions for
fiscal years 2001 and 2002, and from two regions for fiscal year 2003.
Also some regions could not report the number of buses that had been
financed, in whole or in part, with Head Start funding, or the number
sold or taken out of service because such requests were not retained.
Survey Development and Sample Selection:
We developed the survey questionnaire and conducted five pretests of
its content and format with Head Start grantee directors and others
knowledgeable about the transportation of children to and from Head
Start centers. The pretests were conducted either in-person or by
telephone. During these pretests, we asked Head Start grantees whether
the questions were clear and unbiased, whether the terms contained in
the questionnaire were accurate and precise, and whether they would be
able to provide us with accurate data on various attributes of the
vehicles used to transport children. We made changes to the
questionnaire based on the pretest results.
The surveys were conducted using self-administered electronic
questionnaires posted on the World Wide Web. We sent e-mail
notifications to all sampled Head Start grantees on January 5, 2006, to
inform them that our Web-based survey would soon be activated. On
January 10, 2006, we sent each potential respondent another e-mail
containing a unique username and password to ensure that only Head
Start grantees included in our sample could participate in the survey.
To encourage respondents to complete the questionnaire, we sent follow-
up e-mails to those who had not yet responded on January 19, 2006;
January 27, 2006; and on February 6, 2006. During the week of February
13, 2006, GAO support staff made telephone calls to grantees that still
had not responded in order to encourage them to respond. We closed the
survey on February 28, 2006.
We were interested in obtaining information on transportation services
provided by Head Start grantees and their progress and challenges in
implementing the Head Start transportation regulations. To do this, we
drew a stratified random probability sample of 449 Head Start grantees
or delegates from a population of 1,928 agencies that operate local
Head Start programs. Grantees and delegates that operated only Early
Head Start programs were excluded from the population from which we
selected our sample. We selected our sample to represent eight strata
defined by the organization type (community action agencies, government
or tribal entities, private, non-profit, or school systems) and whether
the program had filed an extension request in 2004. Ultimately, we
received 339 responses for an adjusted response rate of 77 percent. The
division of the population, the sample, and the respondents across the
eight strata can be found in table 2. Each sampled grantee or delegate
was subsequently weighted in the analysis to represent all the members
of the population.
Table 2: Sample Disposition:
Stratum number: 1;
Stratum description: CAA that filed an extension request;
Total population size: 233;
Total sample size: 44;
Number of respondents: 33.
Stratum number: 2;
Stratum description: CAA that did not file an extension request;
Total population size: 405;
Total sample size: 76;
Number of respondents: 64.
Stratum number: 3;
Stratum description: School system that filed an extension request;
Total population size: 132;
Total sample size: 40;
Number of respondents: 36.
Stratum number: 4;
Stratum description: School system that did not file an extension
request;
Total population size: 235;
Total sample size: 70;
Number of respondents: 53.
Stratum number: 5;
Stratum description: Private organization that filed an extension
request;
Total population size: 122;
Total sample size: 21;
Number of respondents: 18.
Stratum number: 6;
Stratum description: Private organization that did not file an
extension request;
Total population size: 560;
Total sample size: 99;
Number of respondents: 72.
Stratum number: 7;
Stratum description: Government entity that filed an extension request;
Total population size: 57;
Total sample size: 24;
Number of respondents: 13.
Stratum number: 8;
Stratum description: Government entity that did not file an extension
request;
Total population size: 184;
Total sample size: 75;
Number of respondents: 50.
Stratum number: Total;
Stratum description: [Empty];
Total population size: 1,928;
Total sample size: 449;
Number of respondents: 339.
[End of table]
All percentage estimates from our sample have margins of error (that
is, confidence interval widths) of plus or minus 10 percentage points
or less, at the 95-percent confidence level unless otherwise noted.
In addition to sampling errors, the practical difficulties of
conducting any survey may introduce errors, commonly referred to as non-
sampling errors. For example, difficulties in how a particular question
is interpreted, in the sources of information that are available to
respondents, or in how the data are entered into a database or were
analyzed, can introduce unwanted variability into the survey results.
We took steps in the development of the questionnaire, the data
collection, and the data analysis to minimize these non- sampling
errors. For example, a survey specialist designed the questionnaire in
collaboration with GAO staff with subject matter expertise. Then, the
draft questionnaire was pretested with a number of Head Start officials
to ensure that the questions were relevant, clearly stated, and easy to
comprehend. In addition, the questionnaire was reviewed by a second
survey specialist. When the data were analyzed, a second, independent
analyst checked all computer programs. Since this was a Web-based
survey, respondents entered their answers directly into the electronic
questionnaire. This eliminated the need to have the data keyed into a
database thus removing an additional source of potential error.
Sample Selection for Analyzing Extension Requests:
To characterize reasons for Head Start agencies filing an extension
request, we drew a stratified random probability sample from the
population of 581 agencies that filed an extension request in 2004. We
selected our sample for two strata defined by the Head Start region
(Region 3, all other regions). Ultimately, we examined 188 extension
requests. The division of the population and the division of the sample
across the two strata can be found in table 3. Each sampled agency that
filed an extension request was subsequently weighted in the analysis so
that final results represent all the members of the population of
agencies that filed extension requests.
Table 3: Sample Disposition:
Stratum number: 1;
Stratum description: Region 3 agency requests;
Total agencies that filed an extension request: 68;
Total sample size: 68.
Stratum number: 2;
Stratum description: All other regions' agency requests;
Total agencies that filed an extension request: 513;
Total sample size: 117.
Stratum number: Total;
Stratum description: [Empty];
Total agencies that filed an extension request: 581;
Total sample size: 185.
[End of table]
All percentage estimates from our sample of the extension requests have
margins of error (that is, confidence interval widths) of plus or minus
7 percentage points or less, at the 95-percent confidence level unless
otherwise noted.
[End of section]
Enclosure II:
Head Start: Progress and Challenges in Implementing Transportation
Regulations:
Briefing to Staff of the House Committees on Education and the
Workforce, Transportation and Infrastructure, Subcommittee on Education
Reform and Representatives McCollum and Northup:
May 16, 2006:
Introduction:
Young children are some of our most vulnerable citizens, especially
when being transported in vehicles. The Head Start program serves over
900,000 children, ages birth to 5, and provides most of them with
transportation services, sometimes in partnership with other agencies,
to and from Head Start programs each day.
As required by provisions in the 1992 Head Start Improvement Act, the
Head Start Bureau developed transportation regulations to assure that
safe and effective transportation services were available.
* Issued regulations in January 2001:
* Pursuant to statutory changes, the compliance date for meeting the
vehicle type requirement is June 30, 2006, by which time programs are
to use school buses or specific alternate vehicles that incorporate
school bus safety features:
* Compliance dates for equipping vehicles with restraints and assuring
the presence of bus monitor was June 2004 for those who did not request
more time, or the end of grantees' 2006 program year for those who
received time extensions:
* To increase transportation safety in Head Start, the regulations
required grantees to meet vehicle, equipment, training, and personnel
provisions.
* Additionally, Head Start regulations required that grantees
coordinate transportation services with other human services programs
to ensure that transportation is as widely available as possible. Many
of these programs provide transportation services-a 2003 GAO report
found that 62 federal programs funded transportation services and that
many of them did not coordinate with each other.[Footnote 14]
* The regulations were developed in consultation with two Department of
Transportation (DOT) agencies-the National Highway Traffic Safety
Administration (NHTSA) and the Federal Transit Administration (FTA).
* In commenting on the proposed regulations, some Head Start programs
expressed concern about implementing the regulations without adversely
affecting their budget, transportation services, and other program
services provided.
* In response, Head Start allowed grantees to request extensions for
more time to implement the child restraint and bus monitor provisions.
Objectives:
To provide information on the regulations and their implementation, GAO
determined:
1. The research and cost information Head Start considered in
establishing the transportation regulations:
2. The actions Head Start grantees have taken to implement the vehicle,
restraint, and bus monitor requirements of the regulations, and the
number of grantees that have sought waivers and extensions:
3. The associated expenses and effects of implementing the regulations
on grantees and their transportation partners:
See Glossary on slides 50-55 for definitions of terms used throughout
these slides and pictures of vehicles used by Head Start grantees and
child safety restraints:
Scope and Methodology:
Surveyed a nationally representative sample of 449 Head Start grantees
out of a total of 1,928 that deliver Head Start services[Footnote 15]
* Overall response rate was 77 percent:
* Responses from this survey were used to project to approximately
1,370 grantees and delegates that provide transportation
services[Footnote 16], with a 95-percent confidence interval of +/-10
percent:
Interviewed federal and state officials; representatives from
transportation association and advocacy groups; Head Start program
providers; bus us manufacturers; and transportation providers:
Conducted site visits with 7 grantees in 5 states, selected for
geographic diversity, size, and organization sponsorship to learn about
the steps and choices grantees made to meet the regulations:
Reviewed transportation research, agency regulations and guidance and
other documentation:
Analyzed the Head Start Bureau's extension and waiver request
documentation:
This work was conducted in accordance with generally accepted
government auditing standards.
Results in Brief - Objective 1:
Head Start used NHTSA and the National Transportation Safety Board
(NTSB) research in formulating its vehicle and restraint requirements.
* NHTSA and NTSB research shows that preschoolers are safer on school
buses than passenger vehicles.
* NHTSA research shows preschoolers on small school buses are even
safer when in child safety restraints. Similarly, data from a 2002
NHTSA report indicates that older children on large school buses are
safer when using lap/shoulder belts. Because lap/shoulder belts are not
appropriate for preschool age children they would need child safety
restraints when riding on large school buses to achieve the same
benefit.
The requirement for a bus monitor was based on the Head Start Bureau's
conclusion that young children should be supervised by an adult while
riding on the bus, in the event that the driver became disabled.
The Head Start Bureau no longer has the documentation supporting its
$18.9 million estimate for the cost of implementing the regulations nor
does it systematically track grantees' transportation services. Thus,
it lacks basic information to develop a reliable estimate.
Results in Brief-Objective 2:
Based on our survey, about two-thirds of the approximately 1,370 Head
Start grantees that offer transportation reported having completely
finished implementing the regulations as of February 28, 2006. An
additional 18 percent reported having almost finished.
Others are still having problems in meeting the requirements. GAO's
analysis of Head Start's 2006 extension request documentation shows
that 19 percent of grantees asked for more time to implement the
restraint and monitor requirements. The number of waivers-requests for
exemptions from the regulations submitted by grantees with their annual
refunding application--is unknown.
Of the approximately 1,370 grantees providing transportation, 97
percent report using vehicles that meet the Head Start requirements for
vehicle type, mostly school buses.
The small percentage of grantees that work with transit and other
transportation partners using an alternative vehicle allowed by the
regulations are challenged by the lack of guidance on how to adapt
these vehicles to meet the transportation and safety needs of Head
Start as well as other populations that they serve.
The waiver process exists as a mechanism for grantees to raise issues
with the Bureau regarding compliance, but the Bureau does not have a
clearly defined process for tracking and considering waiver requests.
This may pose a barrier for grantee use.
Results in Brief-Objective 3:
Approximately 56 percent of grantees who provided transportation
reported having, at most, moderate cost effects associated with
implementing the vehicle, restraint, and/or the monitor requirements
while 44 percent reported large to very large cost effects for at least
one or more of these provisions.
Grantees reported effects on their transportation services and
operations as a result of implementing the regulations:
* An estimated 58 percent of the 1,370 grantees providing
transportation reported at least one effect on their transportation
services such as changing routes or reducing transportation services.
* An estimated 67 percent of grantees reported at least one effect on
program operations, including increasing the number of staff needed or
increasing staff hours.
* A third of grantees reported increased parental satisfaction with
transportation services.
Background: Head Start:
Head Start was created in 1965 to provide comprehensive child
development services primarily to poor children.
In FY 2005, Congress appropriated $6.84 billion to almost 2,000 Head
Start grantees that provide services to over 900,000 children
nationwide.
Grantees are not required to provide transportation services, but many
do so to assist children's access to the program, especially those from
very poor families.
Fiscal year: 2001;
Appropriated budget(billions): $6.20;
Percentage change in budget from previous year: +17.7%.
Fiscal year: 2002;
Appropriated budget(billions): $6.54;
Percentage change in budget from previous year: +5.5%.
Fiscal year: 2003;
Appropriated budget(billions): $6.67;
Percentage change in budget from previous year: +2.0%.
Fiscal year: 2004;
Appropriated budget(billions): $6.77;
Percentage change in budget from previous year: +1.6%.
Fiscal year: 2005;
Appropriated budget(billions): $6.84;
Percentage change in budget from previous year: +1.0%.
Source: Head Start Bureau.
[End of table]
Background: Head Start Transportation Regulations Modified After
Issuance:
In January 2001, Head Start issued transportation regulations
requiring, among other things, that:
* By January 20, 2004, vehicles transporting Head Start children have a
bus monitor on board and all children be transported in age-height
appropriate child safety restraints.
* By January 18, 2006, vehicles transporting Head Start children be
school buses or allowable alternate vehicles[Footnote 17] that meet
safety standards required of school buses.
Section 1310.2(c) of the regulations also allowed grantees to apply for
waivers to any transportation requirement for "good cause" (i.e., where
implementation may cause a safety hazard to children); cost cannot be
cited as a reason for a waiver.
In January 2004, the Head Start Bureau issued interim final regulations
allowing grantees to apply for a time extension to meet the monitor or
restraint requirements.
* For grantees with approved extension requests, time to comply was
extended to January 2006.
In December 2005, the Labor-HHS-Education appropriations act extended
the time allowed to meet:
* the vehicle requirement to June 30, 2006[Footnote 18]
* the monitor and restraint requirements until September 30, 2006, (by
authorizing HHS to grant a waiver of these requirements) or the date of
the enactment of a statute that authorizes appropriations for FY 2006
to carry out the Head Start Act, whichever date is earlier [Footnotes
19, 20]
Background: US DOT and NTSB:
Two DOT agencies whose missions are to ensure safe transportation
services and provide human service transportation have worked with Head
Start to help develop the Head Start transportation regulations.
* NHTSA helps ensure highway and motor vehicle safety and establishes
standards intended to protect occupants during accidents, as well as to
prevent accidents:
* FTA provides financial assistance to develop new transportation
services and improve, maintain, and operate existing systems that serve
the general population as well as older adults and people with
disabilities:
- Transit agencies receiving FTA funding must have vehicles that comply
with Americans with Disabilities Act (AD) requirements, including being
wheel-chair accessible:
- FTA participates in the United We Ride program established pursuant
to an executive order in 2004 that required coordinating transportation
for human services programs, including Head Start:
NTSB is an independent federal agency charged by Congress to
investigate a variety of transportation accidents and make
recommendations about preventing future ones, and provided input to HHS
regarding the safety of vehicles used for Head tart:
Background: Vehicles Used to Transport Children to Head Start:
Head Start grantees or their transportation partners use a variety of
vehicles to transport children, including:
* Large and small school buses, which are built to safety standards
issued by NHTSA, and include various safety features to protect
children in the event of an accident, such as compartmentalization, a
system of closely spaced and padded seats:
* An alternate vehicle that is similar to a school bus, with the
exception that it does not have stop arms or flashing lights:
* Public transit buses, which are used by public transit agencies that
also transport members of the general population as well as older
adults and people with disabilities:
Definitions and more detailed explanations of these vehicles, as well
as pictures, are included in the glossary on slides 51-53:
Background: Child Safety Restraints:
Child safety restraints include:
* Restraints that are added to the vehicle after it is purchased:
* Restraints that are built into the seat, also known as integrated
child safety restraints.
Additional information describing the various types of child safety
restraints, as well as pictures, can be found in the glossary on slides
54 and 55:
Objective 1: Head Start Considered Safety Of School Buses and NTSB
Recommendations:
The Head Start Bureau considered school bus safety data in deciding to
require their use or the use of alternative vehicles.
* In the 1990s, some Head Start grantees used 15-passenger vans_ (see-
picture at right) that do not meet NHTSA school bus standards such as
joint strength and rollover protection, high backed padded seats, and
minimum seat spacing:
* In 1998 and 1999, 4 accidents occurred involving children in vehicles
not meeting these standards, including 15-passenger vans, resulting in
fatalities and serious injuries, including a fatally injured Head Start
child:
Figure: 15-Passenger van:
[See PDF for image]
Source: GAO.
[End of figure]
* As a result, in 1999 NTSB recommended to Head Start that children
should be transported in vehicles meeting NHTSA school bus standards.
Objective 1: School Buses Have Lower Fatality Rates Than Other Modes of
Transportation:
NHTSA data indicates school buses have much lower student fatality
rates than passenger vehicles.
* School buses: 0.2 fatalities per 100 million vehicle miles traveled:
* Cars: 1.5 fatalities per 100 million vehicle miles traveled:
2002 Transportation Research Board report, The Relative Risks of School
Travel, indicates school buses and other buses account for far fewer
fatalities among school age children during normal school hours than
other modes of school transportation. (See figure to the right.)
[See PDF for image]
Source: Transportation Research Board.
[A] On average this represents about 20 fatalities per year; of these,
5 are passengers and 15 are pedestrians.
[End of Figure]
Objective 1: NHTSA Testing Shows Need For Restraints On School Buses,
but Gaps in Testing Exist For Transit Buses:
Head Start relied on NHTSA research and recommendations to require
child safety restraints:
* NHTSA crash testing in 1997 and 1999 demonstrated that
compartmentalization did not provide preschool age children on small
school buses sufficient protection and that they are safer using child
safety restraints:
* In 1999, NHTSA recommended that preschool age children transported in
school buses use child safety restraints:
Although NHTSA's research did not address preschool age children on
large school buses, data in NHTSA's 2002 report to Congress on school
bus safety indicates that older children are safer when wearing lap/
shoulder belts. However, NHTSA has found that lap/shoulder belts are
not appropriate for preschool age children. Consequently, these younger
children require child safety restraints on large buses to achieve the
same level of protection:
NHTSA has not conducted crash testing to assess the risk for preschool
age children using child safety restraints on transit buses:
Objective 1: Head Start Based Monitor Requirement on Safety
Considerations:
The Head Start Bureau based the decision to require monitors on the
belief that preschool children riding a bus, and infants and toddlers
also transported by some grantees, should be supervised by an adult
monitor in case the driver became disabled.
More recently, the American Academy of Pediatrics standards for child
care also identifies bus monitors as necessary for child care
facilities, which also transport preschool age children.
Objective 1: Head Start Lacks Cost Documentation and Data on
Transportation Services to Develop Cost Estimates:
In the final regulations issued in 2001, Head Start estimated the cost
of implementing the regulations to be $18.9 million, most of which
reflects the cost of restraints but the Bureau no longer has the
supporting documentation for its estimate.
Without documentation, we cannot determine the reliability of the data
Head Start used to develop its estimates. However, Head Start does not
systematically track transportation services and thus lacks basic
information on which to develop a reliable estimate.
Objective 2: Most Grantees Report Having Completed Implementation:
An estimated 1,370 grantees--approximately 70 percent of Head Start
grantees--provide transportation services:
Of these, 64 percent of grantees reported having completely finished
implementing the regulations:
Of the 36 percent reporting that they were not finished, about half
were almost done while the remaining were either half-way done, less
than half-way done, or not sure.
[See PDF for image]
Source: GAO survey.
Percentages do not add to 100 due to rounding.
[End of figure]
Objective 2: Reasons Why Some Grantees Are Not Finished with
Implementation Are Unknown:
Of the 36 percent that reported they were not finished with
implementing the regulations, approximately 30 percent reported
operating under a waiver or extension for the restraint or monitor
requirement, or both.
We cannot fully determine from our survey data the circumstances under
which the remaining grantees those reporting that they were not
finished implementing the regulations but did not report obtaining an
extension or waiver are operating.
Objective 2: Most Grantees Primarily Use Vehicles That Meet Head Start
Regulations:
About 97 percent of grantees reported primarily using vehicles that
meet the Head Start regulations-93 percent reported using school buses
and 4 percent reported using the alternative vehicles:
Others primarily used transit buses (less than 1 percent), vans (1
percent), or other (2 percent):
[See PDF for image]
Source: GAO survey.
Percentages do not add to 100 due to rounding.
[End of figure]
Objective 2: Challenges in Using Alternative Vehicles:
While only 4 percent of grantees reported using an alternative vehicle,
this option was offered so that grantees and their transportation
partners-especially transit agencies--could meet both the Head Start
requirements and other requirements governing the transport of other
populations such as older adults or people with disabilities.
The alternative vehicle resents challenges for transit agencies and
other providers because the focus of NHTSA's standards is safety in
general and they do not specifically address other features, such as
ADA requirements, that would facilitate transporting other populations:
Transit industry officials indicated that the alternative vehicle
would be difficult for other populations, such as older adults or
people with disabilities, to use because they were very similar to a
school bus in terms of aisle width, high-back seats, and high steps:
* DOT officials in a state that has made extensive efforts in the past
to coordinate human services transportation indicated that the
requirement that the alternative vehicle have compartmentalized seating
made it difficult for older adults and people with disabilities to
comfortably use the seats:
* Transit officials have also indicated that other features of the bus,
such as the narrow, hi h steps in the alternative vehicle made it
difficult for older adults and people wit disabilities to use:
No guidance exists to identify allowable charges to the alternative
vehicle to accommodate populations such as older adults and people with
disabilities:
* Officials at one school bus manufacturer that makes the alternative
vehicle saw the Head Start population and the transit population as two
very distinct populations and did not see how the alternative vehicle
could be used for transit:
* A transit provider and school bus manufacturer indicated that
manufacturers are reluctant to modify the alternative vehicle for
transit use without guidelines from DOT because of concerns about
liability if they alter a bus considered to be a category of school
bus:
FTA identified one transit provider that was using the alternative
vehicle for transit:
* This provider independently researched how to incorporate ADA
requirements such as overhead handrails and supports:
* Although the manufacturer was initially reluctant to modify the
vehicle to incorporate these features the transit provider's research
ultimately convinced the manufacturer that they were acceptable:
Objective 2: Steps Reported by Grantees to Implement the Restraint
Requirement:
Grantees took a variety of actions to implement the restraint
requirements, most often through buying restraints and retrofitting
vehicles with them.
Table:
Actions taken: Bought and retrofitted restraints;
Percent of grantees: 52.
Actions taken: Already had vehicles with restraints;
Percent of grantees: 31.
Actions taken: Other;
Percent of grantees: 12.
Actions taken: Bought, leased, or contracted for vehicles with
restraints;
Percent of grantees: 7.
Actions taken: Operating under an extension or waiver;
Percent of grantees: 9.
Source: GAO survey.
Note: Grantees could report more than one action; thus numbers do not
add to 100 percent.
[End of Table]
Objective 2: Steps Reported by Grantees to Implement the Monitor
Requirement:
While grantees reported taking various steps to implement the monitor
requirement, over half reported already having monitors in place.
Table:
Actions taken: Already had monitors in place;
Percent of grantees: 58.
Actions taken: Changed or added monitor responsibilities to existing
staff;
Percent of grantees: 22.
Actions taken: Hired additional staff;
Percent of grantees: 21.
Actions taken: Recruited volunteers;
Percent of grantees: 9.
Actions taken: Other;
Percent of grantees: 4.
Actions taken: Operating under a waiver or extension;
Percent of grantees: 8.
Source: GAO survey.
Note: Grantees could report more than one action; thus, numbers do not
add to 100 percent.
[End of Table]
Objective 2: Fewer Grantees in 2006 Than 2004 Are Requesting
Extensions:
Based on GAO's analysis of extension request documentation submitted to
the Head Start Bureau (shown on next page),
* the percent of grantees requesting more time to implement the
restraint and monitor requirements dropped from 30 percent in 2004 to
19 percent in 2006.
* Numbers may be understated because extension requests had to be
calculated against the total number of Head Start grantees, not just
those offering transportation.
* In 2004 and 2006, requests for time extensions to implement the
restraint requirement have outnumbered the monitor requirement;
however, about one-third of those seeking extensions sought more time
to implement both in 2004, while around half did so in 2006.
The 2004 interim final rule and 2005 appropriations act provision
authorized Head Start to waive the requirements for restraints and
monitors for those grantees who requested more time to implement these
provisions, but did not specifically authorize similar actions for the
vehicle requirement.[Footnote 21]
Objective 2: Fewer Grantees Are Requesting Extensions:
Year[A]: 2004;
Total number of Head Start Programs[B]: 1,969;
Percentage of Head Start programs that applied for an extension: 30;
Of All Head Start Programs: Percentage that filed only for child
restraint requirement: 13;
Of all Head Start programs: Percentage that filed only for bus monitor
requirement: 4;
Of all Head Start programs: Percentage that filed for both
requirements: 10;
Of all Head Start programs: Percentage other: 3;
Of all Head Start programs: Percentage total[C]: 30.
Year[A]: 2006;
Total number of Head Start Programs[B]: 1,954;
Percentage of Head Start programs that applied for an extension: 19;
Of All Head Start Programs: Percentage that filed only for child
restraint requirement: 9;
Of all Head Start programs: Percentage that filed only for bus monitor
requirement: 3;
Of all Head Start programs: Percentage that filed for both
requirements: 8;
Of all Head Start programs: Percentage other: 0;
Of all Head Start programs: Percentage total[C]: 19.
Source: GAO analysis of the Head Start Bureau's extension request
documentation from grantees and delegates.
Note: Percentages in this table will differ from information on waivers
or extensions in other slides that are from GAO's survey of grantees
and delegates. This is because GAO's survey results are reported based
on the population of grantees and delegates providing transportation.
The analysis of Head Start's data is based on the entire population of
Head Start grantees and delegates, including those that don't provide
transportation, because Head Start does not track transportation
services provided by grantees.
[A] Analysis of the fiscal year 2004 extension requests was done for a
representative sample of 185 requests out of a total of 581, with a
margin of error of +/-2 percent. Analysis of the fiscal year 2006
extension requests was done for all requests received by the Bureau as
of March 10, 2006, which totaled 378.
[B] Programs include both grantees and delegates providing
transportation and those that don't.
[C] Percentages may not add to the total because of rounding.
[End of table]
Objective 2: Cost of Implementing the Requirements Was Major Reason for
Extension Requests:
In both 2004 and 2006, the cost of implementing the restraint or
monitor requirements was the reason most often given by grantees for
requesting extensions, but non-cost reasons have become almost as
common in requests for extensions to implement the restraint
requirement.
Table:
Year[A]: 2004;
Factors cited by programs requesting extensions: Child restraints:
Cost: 51%;
Factors cited by programs requesting extensions: Child restraints: Non-
cost: 37%;
Factors cited by programs requesting extensions: Child restraints: Dod
not specify: 4%;
Factors cited by programs requesting extensions: Bus monitors: Cost:
41%;
Factors cited by programs requesting extensions: Bus monitors: Non-
cost: 17%;
Factors cited by programs requesting extensions: Bus monitors: Did not
specify: 2%;
Factors cited by programs requesting extensions: Other: 9%.
Year[A]: 2006;
Factors cited by programs requesting extensions: Child restraints:
Cost: 62%;
Factors cited by programs requesting extensions: Child restraints: Non-
cost: 60%;
Factors cited by programs requesting extensions: Child restraints: Dod
not specify: 5%;
Factors cited by programs requesting extensions: Bus monitors: Cost:
45%;
Factors cited by programs requesting extensions: Bus monitors: Non-
cost: 24%;
Factors cited by programs requesting extensions: Bus monitors: Did not
specify: 4%;
Factors cited by programs requesting extensions: Other: 1%.
Source: GAO analysis of the Head Start Bureau's extension request
documentation from grantees and delegates.
[A] Analysis of the 2004 extension request documentation has a margin
of error of +/-7 percent.
Notes: (1) Categories are not mutually exclusive; reasons under each
can add up to over 100%. (2) Some grantees requested an extension for
the child restraint or bus monitor provisions, but did not specify cost
or non-cost factors. These were counted as relating to the specific
provision(s), but cited as "Did not specify." (3) "Other" includes
extensions that either did not specify which provision their request
pertained to, cited a factor that did not relate to the regulations, or
gave no reason for the request.
[End of Table]
Objective 2: Head Start Approved Extension Requests with Few
Exceptions:
In 2004, the Bureau approved all extension requests, including those
that were submitted up to a month or two after the March 2004 deadline;
denied only those requests that came in a few months or a year after
the deadline, and could no longer be processed:
In 2006, the Bureau approved all extension requests made by school
systems and all others except extension requests in meeting the:
* child safety restraint requirement for children who were not being
transported on school buses:
* child safety restraint requirement for Early Head Start children:
* bus monitor requirement for children being transported on public
vehicles where they are sharing rides with non-Head Start populations:
Objective 2: Head Start Lacks System for Considering Waiver Requests:
The waiver process provided in 45 C.F.R 1210.2(c) is intended to be
available for grantees to present special circumstances for the
Bureau's consideration, but the Bureau does not have a clearly defined
process for tracking or reviewing them. Specifically,
* Bureau officials stated that they have not outlined a process or
specific criteria defining "good cause" for when adherence to a
requirement would create a safety hazard and thus demonstrate cause to
grant a waiver:
* We found 12 waivers submitted to the Bureau for review-some of which
were denied--but Bureau officials stated that they were unaware of any
waivers that were submitted; one grantee reported submitting a waiver
but never receiving a response:
Three grantees and staff in 4 regional offices whom we interviewed were
not sure about what the waiver process was, how it differed from the
extension process, and when and by whom requests were approved or
denied:
Objective 3: Grantees Must Plan for Vehicle and Restraint Costs in the
Future:
Bureau and Regional officials stated that grantees are now expected to
pay for replacing vehicles out of annual operating monies or nonfederal
sources.
Head Start historically funded such costs, in addition to other
priorities, with supplemental money called Program Improvement (PI)
funds[Footnote 22]:
* Grantees received approximately $76 million in PI funding for
vehicles and restraints between FY01-05,[Footnote 23] with about 85
percent awarded for vehicles[Footnote 24]:
* Staff from some Regional offices stated that they only partially
funded the cost of buses prior to 2005 and required grantees to finance
the remainder:
Grantees are allowed to receive PI funding for restraints, but Head
Start guidance states that fiscal year 2006 will be the last year this
funding will be awarded in the foreseeable future:
Objective 3: Vehicle Costs Driven by Size, Options, and Purchase
Method:
Costs of vehicles vary depending on factors such as passenger capacity,
weight, types of seats, wheel chair lifts, air-conditioning and other
items specified by the buyer, as well as how they are purchased:
* Price discounts---which could amount to $3,000-$6,000 per vehicle--
are offered by some manufacturers when a certain number of buses is
purchased:
* Some grantees were able to purchase vehicles at reduced cost through
collaboration with school systems or other transportation partners:
Table:
Manufacturers' cost ranges for different size vehicles: Vehicle type:
Small ( 10,000 lbs.);
Manufacturers' cost ranges for different size vehicles: Capacity:
Greater than 24-passenger;
Manufacturers' cost ranges for different size vehicles: Cost range:
$35,000-$100,000;
Manufacturers' cost ranges for different size vehicles: Percentage of
vehicles bought: 63%.
Source: GAO analysis of vendor and GAO survey data.
Note: Child restraints typically reduce passenger capacity by one-
third. Price ranges for buses include one with different types of
restraints and buses with no restraints.
[End of table]
Objective 3: Types and Costs of Restraints Vary:
Grantees have a variety of restraints from which to choose
Cost of restraints vary by type[Footnote 25]:
Integrated restraints (e.g., those built into the seat) tend to be more
expensive than those added to the bus later:
Information gathered by GAO shows price ranges for
* Integrated restraints cost approximately $350-$773 (per seat):
* Add-ons cost approximately $55-200 (per restraint):
Objective 3: Some Grantees Found Ways to Pay Less for Vehicles:
Pullman, WA: Head Start grantee paid less for a bus by partnering with
local Area Office on Aging (AoA):
* AOA secured 80 percent of the cost through FTA funding:
* Grantee's share was only $11,000:
* Vehicle was built to meet Head Start requirements and ADA
requirements for other populations, such as older adults and people
with disabilities:
Westfield, MA: Head Start grantee used nonfederal funds to buy buses:
* Received funding from the Community Partnership for Children grants
awarded by the Massachusetts Department of Education:
* Community Partnership grants can be used for a variety of purposes
including transportation:
Renton, WA: The Head Start grantee partners with school systems that
own and operate school buses to transport 1,200 Head Start children:
* Grantee "piggy-backs" on the school systems' specifications for
school bus orders, modifying them to reflect the grantee's needs:
* School systems receive state funding to buy school buses:
* Cost to grantee for buses is any amount that exceeds basic state
funding for a school bus:
Objective 3: Regulations Have Some Cost Effects on Grantees, but Report
Other Budgetary Pressures:
A majority of grantees who provided transportation reported having, at
most, moderate cost effects associated with implementing the vehicle,
restraint, and/or monitor requirements.[Footnote 26]
However, a significant portion of grantees-approximately 44 percent-
reported large to very large cost effects for at least one or more of
these provisions:
Grantees we visited and some Regional officials stated that other
costs, such as health insurance, are affecting their budgets as much or
more than costs incurred from the transportation regulations:
Table:
Cost effects of vehicle, restraints, or monitor requirement: Moderate
or less;
Grantees reporting: 56%.
Cost effects of vehicle, restraints, or monitor requirement: Large or
very large;
Grantees reporting: 44%.
Source: GAO survey.
[End of Table]
Objective 3: Regulations Have Some Cost Effects on Grantees:
In looking at the cost effects reported by grantees on their
transportation budgets for the vehicle, restraint, and monitor
provisions separately, we found that:
* Monitors were cited more often as having the smallest or no cost
effect:
* Restraints and vehicles were cited more often as having a large or
very large cost effect:
None or small cost effect;
Vehicles: 42%;
Restraints: 26%;
Monitors: 52%.
Moderate cost effect;
Vehicles: 23%;
Restraints: 33%;
Monitors: 22%.
Large or very large cost effect;
Vehicles: 28%;
Restraints: 31%;
Monitors: 16%.
No basis to judge;
Vehicles: 5%;
Restraints: 2%;
Monitors: 3%.
Operating under a waiver/extension;
Vehicles: NA;
Restraints: 8%;
Monitors: 7%.
Source: GAO survey.
Note: Survey respondents could check only one answer to this question.
Thus, those marking "waiver/extensions" would not have provided cost
information.
[End of table]
Objective 3: Examples of Effects on Grantee Costs:
Jefferson County, Kentucky: The grantee stated that the public school
system transports around 5,000 preschool children a day-approximately
1,900 are Head Start children-on large buses. They estimated that
retrofitting integrated restraints into 402 buses that transport the
preschoolers will cost the school system approximately $6 million
(parts and labor), and indicated that this cost would force them to
stop providing transportation services to Head Start.
Renton, Washington: The grantee noted that adding bus monitors to
transport approximately 1,800 Head Start children cost the grantee
around $420,000 in program year 2005. The grantee absorbed these costs
by closing classrooms and cutting staff classroom hours, among other
things, but also noted benefits in having monitors on buses in the
event of problems:
Greencastle, Indiana: The grantee reported using volunteers to meet the
bus monitor requirement and "paid" them with $10 gift cards from Wal-
Mart. According to the grantee, the cards cost approximately $34,000 in
program year 2003; these costs were absorbed by cutting an
administrative staff position from the budget. The gift cards helped
maintain an adequate number of volunteers.
Objective 3: Regulations Led Many Grantees to Change Transportation
Services:
Overall, 58 percent of the estimated 1,370 grantees providing
transportation reported at least one of the following effects on their
transportation services as a result of implementing the regulations:
* changing routes:
* reducing transportation previously provided:
* changing how transportation is provided, such as using a new
contractor:
* discontinuing services altogether:
The top two effects on transportation services that grantees reported
as a result of implementing the regulations were changes to
transportation routes and reduction in transportation services.
Table: Percent of grantees with transportation services effects:
Changed routes;
Yes: 83;
No: 16;
Not sure: 1.
Reduced transportation services previously provided;
Yes: 50;
No: 50;
Not sure: 0.
Changed how transportation was provided;
Yes: 27;
No: 73;
Not sure: 0.
Discontinued transportation services;
Yes: 13;
No: 85;
Not sure: 2.
Source: GAO survey.
Note: Responses for grantees operating under a waiver or extension were
excluded from the analysis for this question.
[End of table]
Objective 3: Regulations Led Many Grantees To Change Program
Operations:
An estimated 67 percent of the 1,370 Head Start grantees who provide
transportation noted at least one effect on program operations as a
result of implementing the regulations:
Looking at each specific effect, over one-half of grantees cited having
to increase the number of staff and staff hours while approximately
half also reported changing or eliminating other services and reducing
staff hours in the classroom:
About one-third also reported that the regulations increased parents'
satisfaction with transportation:
Table: Percent of grantees with program operations effects:
Increased number of staff;
Yes: 58;
No: 42;
Not sure: 0.
Increased staff hours;
Yes: 54;
No: 44;
Not sure: 1.
Changed, reduced, or eliminated services;
Yes: 49;
No: 47;
Not sure: 4.
Reduced staff hours in classroom;
Yes: 49;
No: 49;
Not sure: 3.
Increased parents' satisfaction with transportation services;
Yes: 34;
No: 50;
Not sure: 16.
Reduced staff hours;
Yes: 26;
No: 72;
Not sure: 3.
Merged or consolidated sites;
Yes: 14;
No: 85;
Not sure: 1.
Offered another option of care;
Yes: 10;
No: 89;
Not sure: 2.
Reduced enrollment;
Yes: 5;
No: 91;
Not sure: 4.
Closed centers;
Yes: 4;
No: 95;
Not sure: 1.
Source: GAO survey.
[End of table]
Objective 3: Some Grantees Contracting for Transportation Services
Reported Problems with Continuing Transportation:
36 percent of the grantees providing transportation reported that at
least some of their program sites contract or use another organization
to transport their children.
For the 36 percent who contract:
* About a quarter reported the contractor could not currently continue
the partnership (8 percent of all grantees providing transportation);
* 39 percent reported the contractor will not continue providing
transportation in program year 2006/2007 (14 percent of all grantees
providing transportation):
Objective 3: Some Transit Agencies Report Difficulties Sustaining Head
Start Partnerships:
Iowa: State law requires coordination among human services programs:
Iowa requires that transit buses used to transport children must meet
some but not all of NHTSA crashworthiness standards that apply to
school buses; thus these buses don't comply with the Head Start
transportation regulations:
Before the regulations, 14 of 15 state DOT regions provided
transportation to grantees; 9 of these have since discontinued or plan
to discontinue some or all services to grantees:
The regulations led Head Start grantees in Iowa to either:
* Purchase school buses or alternative vehicles; some transit agencies
operate these buses for grantees
* Reduce or eliminate transportation services, or:
* Rely on school districts:
Iowa DOT officials stated that the loss of funding from Head Start
grantees had resulted in some regional transit agencies reducing
services, raising costs, or both for other groups they serve, such as
older adults or people with disabilities:
FTA officials confirmed that this loss of funding has similarly
affected the cost and level of services other transit agencies provide:
Objective 3: Some Transit Agencies Report Difficulties Sustaining
Partnerships:
Michigan and Pennsylvania:
Transit agencies were using transit buses that met FTA's standards and
had restraints. However, officials were not certain whether the buses
met NHTSA's school bus standards:
The restraint requirement has affected the number of children transit
agencies can transport:
Transit officials also said that seats with restraints are
uncomfortable and impractical for the adults and people with
disabilities that they serve, requiring different uses to transport
them:
* Officials in charge of these agencies told us that older adults have
difficulty exiting seats because of additional padding:
* One of these officials also told us that the buses used for Head
Start have impacted the cost and quality of service provided to other
customers, and that the seats have been difficult to maintain and keep
clean:
Objective 3: Examples of Grantees Having Difficulties Sustaining or
Developing Transportation Partnerships:
Michigan: One grantee that serves 21 counties (13,000 sq. miles) and
transports about 700 children had partnered with the public schools to
transport around a quarter of the children. The grantee stated that the
schools can no longer do it because of the restraint requirement. As a
result, the grantee plans to discontinue some transportation services
if it cannot find another partner.
Independent Transportation Contractors: For some Head Start grantees,
contracting with an independent transportation provider may not be an
option. Contractors reported that they need a critical mass of children
to make a contract economically feasible for both parties. Typically
contractors work best with very large grantees or those connected with
school systems.
Glossary:
Head Start requirements: requirements outlined in the Head Start
transportation regulations:
NHTSA school bus standards - safety standards NHTSA issues to protect
children on and around a school bus.
* "Crash-worthiness" standards offer protection in the event of an
accident and include rollover and fuel tank protection, joint
strengthening, and a system of closely spaced and padded seats,
commonly referred to as compartmentalization.
* Traffic control standards are intended to help prevent accidents, and
include requirements that the bus have stop arms and flashing lights.
Large School Buses: exceed 10,000 pounds, seat between 24 - 84
children:
* Often used for school age children, but also transport preschool
children.
* Bus size and design absorbs the force of a crash, thus NHTSA does not
require restraints in these buses for older children:
* Compartmentalized design is intended to offer protection in the event
of a crash.
Small School Buses: less than 10,000 pounds; seat no more than 24
children:
* Often used for preschool children.
* NHTSA requires lap belts because the smaller size does not absorb the
force of a crash as well as a large bus and lap belts reduce the chance
of a child being ejected.
Allowable Alternate Vehicle sub-category of school bus that meets all
crash worthiness standards but not traffic control standards.
* Created for use by public transit agencies that transport children to
Head Start so they could still serve the needs of others who use public
transit.
* Sizes vary, but similar to school buses.
* Lap belts required on small vehicles but not on large vehicles.
Public Transit Buses: used by public transit agencies in cities, small
communities, and rural areas. Size and design varies, depending on
needs of the population served, which can include the general public,
older adults, and people with disabilities.
* Buses must meet NHTSA standards for buses, pass FTA's performance
testing at Altoona, PA testing facility, and comply with Americans with
Disabities Act.
* Buses are not required to meet NHTSA school bus standards or undergo
crash testing and most cannot accommodate child safety restraints.
Glossary: Pictures of Buses:
Figure: Small school bus:
[See PDF for image]
[End of figure]
Figure: Allowable alternate vehicle:
[See PDF for image]
[End of figure]
Figure: Large school bus:
[See PDF for image]
[End of figure]
Figure: Public transit bus:
[See PDF for image]
[End of figure]
Source: Thomas Built Buses, GAO.
Glossary:
Child safety restraints - Designed to keep children in their seats and
protect from injury in the event of a crash. They can take various
forms and offer a range of protection:
* Harnesses and vests - Worn over child's shoulder and torso. Restraint
is attached to bus seat and seat back to keep child in place in the
event of a crash:
* Convertible seat - Placed on bus seat and attached using seat belt.
Child is restrained in seat:
* Booster seat - Placed on bus seat and secured with a lap/shoulder
belt. Built-in harnesses are used to secure child:
* Integrated child safety seat - Restraint is built into bus seat and
folds out for use. It is folded back up when older child or adult uses
the seat.
Glossary: Pictures Of Restraints:
Figure: Add-on restraints:
[See PDF for image]
[End of figure]
Figure: Integrated restraints:
[See PDF for image]
[End of figure]
Source: GAO, Q'Straint.
[End of section]
Enclosure III:
Department Of Health & Human Services:
Administration For Children And Families:
Office of the Assistant Secretary, Suite 600:
370 L'Enfant Promenade, S.W.
Washington, D.C. 20447:
JUL 25 2006:
Ms. Marnie S. Shaul:
Director, Education, Workforce, and Income Security Issues:
Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Dear Ms. Shaul:
Attached are comments of the Administration for Children and Families
on the Government Accountability Office draft report entitled, "Head
Start: Progress and Challenges in Implementing Transportation
Regulations" (GAO-06-767R).
Should you have questions or need additional information, please
contact Channell Wilkins, Director, Office of Head Start, at 202-205-
8573.
Sincerely,
Signed by:
Wade F. Horn, Ph.D.
Assistant Secretary for Children and Families:
Enclosure:
Comments Of The Administration For Children And Families On The
Government Accountability Office Draft Report Entitled, "Head Start:
Progress And Challenges In Implementing Transportation Regulations (GAO-
06-767R):
The Administration for Children and Families (ACF) appreciates the
opportunity to comment on this Government Accountability Office (GAO)
draft report.
GAO Recommendations:
In order to determine the ability of grantees to provide transportation
services and to define the waiver process, we make the following three
recommendations to the Head Start Bureau:
* Systematically track transportation services provided by grantees so
that the Bureau can determine changes in the availability of these
services, especially any reduction in them.
* Establish a waiver process that specifies criteria for submitting
waivers, including more specific guidance on what constitutes "good
cause," and lists the responsible entities for review and approval.
Should any waiver requests submitted require Head Start to address
issues concerning vehicles, the waiver process should include
consultation with NHTSA and FTA as appropriate.
* Once a process has been established, take steps to ensure that
grantees and regional staff know about it and understand how it works.
ACF Comment:
The Office of Head Start supports the second and third recommendations
made by GAO. We will consider the first recommendation, but there are
information collection implications in this recommendation that need to
be fully considered before any final decision can be made.
[End of Section]
FOOTNOTES
[1] At the time of our briefing in May 2006, the Office of Head Start
was called the Head Start Bureau. Hence, the briefing slides enclosed
with this report refer to the office by its former name.
[2] The effective compliance dates for the restraint and monitor
provisions were first extended via an interim final rule published in
2004. Then, Public Law 109-149, passed in 2005, extended the compliance
date for the vehicle provision to June 30, 2006, and also allowed the
Secretary of HHS to waive the restraint and monitor requirements
through September 30, 2006. The vehicle, restraint, and monitor
provisions are effective until these respective dates or the date of
enactment of a statute that authorizes appropriations for fiscal year
2006 to carry out the Head Start Act, whichever date is earlier. Head
Start has issued guidance stating that waivers granted for restraints
and monitors would cover the remainder of a grantee's program year,
thus making that date the effective compliance date for a grantee. In
June 2006, Pub.L. No.109-234 changed the compliance date for vehicles
to December 30, 2006.
[3] The general waiver authority is outlined under 45 C.F.R. §
1310.2(c).
[4] On May 30, 2006, Head Start issued a Notice of Proposed Rulemaking
(NPRM) that, if finalized, would expand the definition of "good cause"
under the regulations to allow for a waiver of the restraint and
monitor requirements if the grantee demonstrates that compliance with
these requirements would result in a significant disruption to the
grantee's program and that waiving these requirements would be in the
best interest of the children involved. This provision differs from the
earlier waiver process in that the cost of complying could be
considered when determining whether good cause exists for a waiver.
[5] Traditionally, large school buses have relied on
compartmentalization--a system of closely spaced and padded seats that
absorb and cushion riders from impact--as opposed to belts or
restraints to protect school age children during a crash. However,
NHTSA is considering requirements for lap/shoulder belts in small
school buses and standards for voluntarily installing lap/shoulder
belts in large school buses. See glossary in encl. II for additional
information on child safety restraints.
[6] Some grantee, school district, and transit officials have raised
concerns about using restraints in the event of a fire or a bus being
submerged in water. National Highway Traffic Safety Administration
(NHTSA) and National Transportation Safety Board (NTSB) officials
indicated that only two fatal accidents have occurred that involved
fire or water and that current school bus safety standards for fuel
tanks and emergency exits are more stringent. NHTSA officials also
explained that having preschool children in restraints would keep them
in their seats in the event of an accident, resulting in fewer injuries
and facilitating the evacuation of the bus as the children would be
able to walk out unassisted.
[7] For additional information on transit buses, see the glossary in
encl. II.
[8] For example, in 2003, GAO reported that 62 federal programs funded
transportation services and that many of them did not coordinate with
each other. See GAO, Transportation-Disadvantaged Populations: Some
Coordination Efforts among Programs Providing Transportation Services,
but Obstacles Persist, GAO-03-697 (Washington, D.C.: June 30, 2003).
[9] National Highway Traffic Safety Administration, Report to Congress:
School Bus Safety: Crashworthiness Research, (Washington, D.C.: April
2002).
[10] NHTSA has found, however, that lap/shoulder belts are not
appropriate for preschool-age children. Consequently, these younger
children would require child safety restraints on large buses to
achieve the same benefits in reducing serious injuries as older
children using lap/shoulder belts.
[11] We do not have data to determine the reasons for the decline in
extension requests between 2004 and 2006. However, our survey data
shows that grantees have taken actions to comply with the regulations
either by making the required changes or, in some cases, reducing or
eliminating transportation services.
[12] This figure only represents the amount of PI funding that was
provided to help grantees in implementing some provisions of the
transportation regulations; it does not represent the total amount of
PI funding awarded by Head Start for these years.
[13] The regulations describe this vehicle as an Allowable Alternate
Vehicle; NHTSA defines it as a Multi Function School Activity Bus. For
purposes of this report, we will refer to it as the alternative vehicle.
[14] GA0 Transportation-Disadvantaged ed Populations: Some Coordination
Efforts Among Programs Providing Transportation Services, but Obstacles
Persist, GAO-03-697 Washington, D.C.: June 30, 2003).
[15] For the purposes of these slides, we refer to all Head Start
grantees and their delegate agencies-entities that help grantees
deliver services--as grantees. Our survey excluded grantees that
provided only Early Head Start services.
[16] This number is an estimate with a range from 1,290 to 1,460.
[17] NHTSA has also defined this vehicle as a Multi Function School
Activity Bus. However, for purposes of these slides, we will refer to
it as the alternative vehicle.
[18] In June 2006, P.L. 109-234 extended the compliance date for the
vehicle provisions to December 2006.
[19] The Head Start Bureau's guidance to grantees in 2006 states that
the agency will consider waiver requests that would cover the remainder
of a grantee's program year, thus making that date the effective
compliance date for the grantee.
[20] On May 30, 2006, Head Start issued a Notice of Proposed Rulemaking
(NPRM) that, if finalized, would expand the definition of "good cause"
under the regulations to allow for a waiver of the restraints and
monitors requirements if the grantee demonstrates that compliance with
these requirements would result in a significant disruption to the
grantee's program and that waiving these requirements would be in the
best interest of the children involved. This provision differs from t
re earlier waiver process in that the cost of complying could be
considered when determining whether good cause exists for a waiver.
[21] See page 29 for information on recently enacted changes to
compliance dates for vehicles, restraints, and monitors.
[22] PI funds are monies reallocated from grantees who have not used
all of their funding to other grantees who are requesting additional
funds that meet the Bureau's priorities established for these monies.
[23] The Head Start Bureau did not award fiscal year 2005 PI funds.
[24] This figure only represents the amount of PI funding that was
provided to help grantees to implement some provisions of the
transportation regulations; it does not represent the total amount of
PI funding awarded by Head Start for these years.
[25] Our data only reflects the costs of the restraints and not the
additional costs of retrofitting the bus in cases where that would be
necessary.
[26] We note that it is difficult to separate the effect of the
transportation regulations on grantees' overall costs from changes in
other factors that affect grantee costs, such as changes in capital
funds provided, labor or health costs.
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