NDHSA Dedicated Webinars
This is a private course developed for the North Dakota Head Start Association (NDHSA). The following webinars are available to NDHSA members. If you are interested in training on Head Start topics, please review our Head Start Practice Area page or Contact Us.
Monitoring Tips for Head Start
Are you new to Head Start or Early Head Start? Have you undergone a review under the Aligned Monitoring System 2.0 (AMS 2.0) yet?
Head Start programs must undergo federal programmatic monitoring at least once every three years. In addition to scheduled reviews under the AMS 2.0, the Head Start Act allows for unannounced reviews in which the monitoring team shows up at your program unexpectedly. Now that the monitoring review process is linked to re-competition under the Designated Renewal System (DRS), avoiding review findings is especially important.
On this webinar, FTLF attorneys will provide:
- An overview of AMS 2.0
- The nuts and bolts of the monitoring process
- Advice on ensuring your monitoring review goes smoothly
- Tips on how to handle an "unannounced" review
Data Management & Privacy Challenges
Collecting and analyzing data about your program can be a critical tool to help you:
- Choose which activities and initiatives to prioritize
- Provide key program information to your Governing Board and Policy Council
- Communicate your achievements and value to the community
However, when collecting data, Head Start programs must be sure to protect the privacy and confidentiality of child records and any personally identifiable information (PII).
All grantees must have a data management policy. The Office of Head Start (OHS) stresses that this policy must comply with the Head Start Program Performance Standards (HSPPS), including the privacy protection requirements in 45 C.F.R. Part 1303, Subpart C. Don’t know where to start? On this webinar, FTLF will discuss:
- What constitutes personally identifiable information (PII)
- Common exceptions to the general rule that you must have parental consent to disclose data with PII
- Important procedures to include in your data management policy
- Best practices for ensuring confidentiality (e.g., using data security agreements)
Although non-compliance or deficiency findings for data management and privacy are not currently as common as findings in other areas, enforcement priorities do shift and it’s important to be prepared.
Head Start Negative Findings
The number of deficiency findings for Head Start programs has been on the rise in recent years. In fact, it's rare for programs to undergo monitoring reviews and come away with no findings.
Unfortunately, in this era of additional scrutiny and consequences, every finding counts. Failure to correct findings of non-compliance will result in deficiencies and failure to correct deficiencies can result in the termination of your program. So, what do you do if you receive a monitoring report with deficiencies or non-compliances?
FTLF has helped many programs respond to monitoring findings over the years. On this webinar, we will share our strategies and best practices for how to:
- Review and analyze the final report
- Draft a proper response
- Develop a plan to address any findings of non-compliance or deficiencies
- Improve internal processes to prevent future findings
GAO Report Findings for Head Start
The Government Accountability Office (GAO) conducted a study to identify problems with Head Start program eligibility screening and instances of potential fraud. On October 2, 2019, they made these results public in a published report.
The GAO submitted fake enrollment information to 15 different programs in major cities across the US: seven correctly determined ineligibility, three encouraged enrollment despite ineligibility, and five altered the forms to make the child appear eligible. These findings will be referred to the inspector general’s office at the Department of Health and Human Services (HHS) for consideration of a criminal inquiry. GAO’s Report also specifically noted that the Office of Head Start (OHS) has not done a comprehensive fraud assessment and does not monitor all grantees in a timely manner.
Déjà vu? It's not just you, we've seen this before. Nine years ago, the GAO went undercover to test Head Start eligibility and enrollment procedures and released a similar report. This report and its findings resulted in Congressional hearings, two sets of revisions to ERSEA regulations, and considerably more required documentation.
What does this mean for Head Start programs? In all likelihood, this means heightened attention to program compliance with eligibility requirements, documentation related to ERSEA, and more frequent and detailed monitoring reviews.
What should you do? It is more important than ever to make sure your staff understands the Head Start Program Performance Standards (HSPPS) applicable to their jobs and daily responsibilities. In light of this report, now is the time to confirm that your program is following the rules and review your existing policies and procedures to see if you need to make any adjustments.
Nicole Bacon, a Partner at FTLF, works in the firm’s Federal Grants, Litigation, and Health Law practice groups. Nicole offers her clients specialized guidance in compliance with federal grant law including specific programmatic requirements as well as the Uniform Administrative Requirements, Cost Principles and Audit Requirements of Federal Awards. Nicole represents a variety of community-based organizations, before State and Federal courts as well as administrative bodies. [Full Bio]
Amanda is in an Associate with the firm’s Health Law and Federal Grant Law practice groups where she represents a variety of community-based organizations and federal grant recipients. She routinely counsels on matters of regulatory compliance and contracting, with a particular focus on guidance related to privacy issues like identifying privacy vulnerabilities and developing data sharing agreements. [Full Bio]
Serving as Managing Partner of the firm since 2003, and a member of the Health Law and Federal Grants practices since 1992, Ted focuses his practice on helping organizations to solve problems. Ted’s expertise in financial, cost reporting, reimbursement, and administrative issues is widely recognized, and illustrated by his selection as a 2014, 2015, 2016, 2018, and 2019 Washington, D.C. Super Lawyer in health care. Ted routinely handles challenging issues for clients such as government audits, internal investigations, and litigation. [Full Bio]
Certificates of Attendance: If you need to document attendance for this webinar, we provide blank Certificates of Attendance for a supervisor to sign and certify that an individual viewed the course.
Group Attendance: Due to the online nature of webinars, we cannot verify participation by more than one person. For groups, we provide an attendance record form and blank Certificates of Attendance to record attendance at a group viewing session and document each individual's participation. We recommend that a supervisor or colleague sign the certificate to certify attendance.
Read more about maintaining an attendance record in our FAQs.
This is a private course for members of the North Dakota Head Start Association. If you are a member, please contact Dawn Williams for the access code. If you are not a member, but are interested in our Head Start training offerings or having FTLF develop a custom training for your organization, please contact us.
Once you have registered, you can re-access the webinar at any time by clicking “My Account” in the upper right hand corner of the page or by clicking the “My Training” tab (found at the top of any page on learning.ftlf.com) and clicking on webinar title.
An unlimited number of participants can experience the recorded webinar by broadcasting it on a projection screen and watching it together. A single login can gain access to the webinar and be issued a certificate. The record of attendance form can be accessed under the certificate link within the activity. For more information on live and recorded webinars, please refer to our FAQ section.
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