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Mel Gravely

Enhancing Safe Practices in Your Head Start Program

In September 2022, the U.S. Department of Health and Human Services, Office of Inspector General (OIG), released the following report: ACF Should Improve Oversight of Head Start to Better Protect Children’s Safety. In this 40-page report, the Inspector General found that nearly one in four Head Start grantees received an adverse finding from the Administration for Children and Families (ACF) for child abuse, lack of supervision, or unauthorized release between October 2015 and May 2020. And the OIG fears that there are many more incidents that may be falling through the cracks.

“Using data from 2 States for 2017 through 2019, OIG identified 130 additional incidents that occurred in Head Start centers but of which ACF was not aware,” the report states.

The Office of Head Start (OHS) is looking deeper into the safe practices of Head Start programs nationwide. In August 2022, in anticipation of the Inspector General’s report, the Acting Director of OHS at the time, Katie Hamm, released a letter titled “Child Safety in Head Start Programs.” In it, she reiterated the importance of a continuous review of safety practices in Head Start programs.

“The vigilance and commitment of grant recipients to keep all children safe and secure is foundational to Head Start services,” Hamm wrote. “However, every year we see several serious incidents that violate our Head Start Program Performance Standards (HSPPS), staff standards of conduct, and put children at risk.”

It is important that program leaders understand the Office of Head Start’s requirements for creating and maintaining safe, quality environments, as well as know strategies to address gaps that may lead to an unsafe environment. OHS has made clear that they are taking a renewed focus on safety in the post-pandemic era, and it will be a major focus of this year’s monitoring protocol.

“OHS has a zero tolerance policy for any situation that harms or endangers a child and for lack of reporting those incidents to OHS,” Hamm stated in her letter. “Grant recipients who do not report to OHS situations which endanger the health or safety of children will have monitoring findings as a result.”

After the OIG report, the Office of Head Start added Health & Safety as one of its top priorities in its Head Start is Heart Work initiative, which is meant as a guide to help lead programs out of the pandemic.

“OHS expects that each child served in Head Start and Early Head Start programs is properly safeguarded,” the initiative says. “As a major part of many communities where vulnerable children and families live, Head Start programs will be a safe space for them to thrive.”

First, programs need to detail their system of health and safety in writing, and as you might expect, it can be far-reaching. It must address a variety of safety areas, including child abuse and neglect, child injuries, and emergency preparedness. Section 1302.47 of The Head Start Program Performance Standards (HSPPS) generalizes the requirements, breaking them down into nine categories: Facilities, equipment and materials, background checks, safety training, safety practices, hygiene practices, administrative safety procedures, disaster preparedness plan, and COVID-19 mitigation policy.

For more detailed information on what these policies should look like, the HSPPS cites Caring for Our Children Basics, which lays out some of the finer details of safety requirements for Head Start grantees and other federally-funded child care providers. It details rules on everything from whether you need a parent’s permission to apply sunscreen (spoiler alert: you do, in writing) to the eight-step procedure for diaper changes.  If you haven’t reviewed these documents for a while, we highly recommend it.

Second, staff training on safety protocols is imperative. The HSPPS mandates it, both within 90 days for new hires, but also for all staff on an ongoing basis.

Last, is reporting. Programs must know what constitutes a reportable incident as well as the proper procedures to report those incidents. Without accurate data, OHS can’t know for sure that efforts to decrease safety incidents are working and that we are all protecting children in the best possible ways.

If your agency needs help with its safety plan, or is experiencing a monitoring event with a focus on safety, The Gravely Group is here to help. We have recently started offering a training called Enhancing Safe Practices, in which we aim to help programs understand the Office of Head Start’s requirements for creating and maintaining safe, quality environments, as well as helping programs prepare for any monitoring events when it comes to safety. In our training, we encourage programs to “create a culture of safety” that guides every interaction with children in the center, in the home, or in the community.

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