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Mel Gravely

Getting Back to Full Enrollment

So your Head Start Agency has received an Underenrollment Letter. Now what?

The Office of Head Start (OHS) first announced its Full Enrollment Initiative in June 2018. In its announcement, OHS emphasized that full enrollment is the law.

Section 642(g) of the Head Start Act states that “each Head Start agency shall enroll 100 percent of its funded enrollment and maintain and active waiting list at all times with ongoing outreach to the community and activities to identify underserved populations.” As far as legislative language goes, it’s very brief. But it’s also unambiguous. Full enrollment is not optional.

While the Full Enrollment Initiative was first launched in mid-2018, the COVID-19 pandemic put a pause on enforcement. Along with many other institutions, Head Start programs shuttered their doors to protect public health. Some moved to virtual instruction, while others moved to part-time models. OHS gave grant recipients lots of leeway during that first year so that they could respond to risks in real time.

But by the 2021-2022 school year, OHS announced that it expected designees to start moving back to full enrollment. OHS knew that it would take time to get there. In our blog, “Is your ERSEA strategy ready for post-COVID?,” we wrote that some child care providers were finding recruitment difficult in the post-pandemic landscape.

“[M]any Head Start programs have fully re-opened. However, they are finding that picking up where they left off is not so simple,” we wrote. “They’ve found that many parents have already made other arrangements, or, as we’ve seen, one parent is now at home full-time after job loss or voluntary resignation. As a result, some programs are facing low enrollment and are struggling to fill open slots.”

OHS continued to give some flexibility in getting back to full enrollment through the end of the 2021-2022 school year. They released a variety of resources to help programs get there. In addition, new funding from the American Rescue Plan was approved by Congress, which gave programs flexibility to purchase equipment, upgrade facilities, or boost staff compensation.

The pandemic forced Head Start to put full enrollment on the back burner for a couple years. It wasn’t until early 2023 that Head Start grantees began receiving under-enrollment letters, with the first batch of letters sent out in February of last year.

It’s now been more than a year from those first letters, and some grantees may now be deemed “chronically underenrolled” if they failed to meet enrollment targets over a 12-month period.

Programs are worried. OHS Director, Khari M. Garvin, recently released a video addressing their concerns.

“Throughout the last year, the Office of Head Start (OHS) received feedback from grant recipients about the Full Enrollment Initiative,” Mr. Garvin says. “We have heard from many of you about how it feels like an unfair burden. It can feel as though OHS is unaware of staffing challenges and other factors that make it difficult for Head Start programs to maintain full enrollment.”

The Director again stressed that Full Enrollment is the law according to the Head Start Act, and that OHS has to abide by what it says. But he also said that they are looking for areas of flexibility wherever they can. They are also striving to improve their customer service while helping designees navigate through Full Enrollment.

“I want you to know that we are evaluating all aspects of the Full Enrollment Initiative to more fully support each grant recipient that is under-enrolled,” he said.

So what should a designee agency do if they have received an Underenrollment Letter?

First, before they even receive a letter, Head Start grantees should already know that they’re under-enrolled based on the enrollment and attendance records that they are required to submit every month. The Head Start Act requires that grantees with four or more consecutive months of underenrollment receive an Underenrollment Letter. However, before it comes to that, grantees should already be taking steps to correct their under-enrollment when it first appears. The hope is that they can get ahead of the problem early.

If an agency does receive a letter, here are some of our recommended next steps:

1. Document all current efforts to get back to full enrollment.
2. Revisit the Community Assessment.
3. Invest in a solid ERSEA strategy.
4. Address staff shortages.
5. Reach out to your community partners.
6. Consider an enrollment conversion/reduction.

If your agency has received an Underenrollment Letter, The Gravely Group is your go-to resource. Over the years, our ERSEA training has consistently been one of our most-requested trainings.  In it, we review each aspect of ERSEA, and give real-life examples that you can implement immediately to boost enrollment and attendance. Let The Gravely Group help you navigate your path back to full enrollment. Contact us today!

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