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Mel Gravely

Head Start Safety: What is a reportable safety incident, and how do you report it?

A 2022 investigation from the Office of Inspector General (OIG) forced Head Start to take a renewed focus on safety. The OIG report found that one in four Head Start grantees had an adverse safety finding over a five-year period. That was far too many.

Katie Hamm, who was Acting Office of Head Start Director at the time, wrote a letter to all Head Start staff reminding them that keeping children safe is “foundational to Head Start services.”

“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,” Hamm said.

Health and safety incidents are the most common violation to lead to a deficiency for Head Start designees. All programs are required to do everything they can to reduce the number of health and safety incidents through proper procedures and training of staff and volunteers.

What is a reportable safety incident?

So what constitutes a reportable safety incident? Many staff are still confused about what the requirements are.

In order to clear up any confusion, OHS released a 2022 Information Memorandum (IM) called “Reporting Child Health and Safety Incidents,” in which it more clearly defines what needs to be reported.

“A program must report all significant incidents affecting the health and safety of children,” the IM states. “OHS considers a ‘significant incident’ to be any incident that results in serious injury or harm to a child, violates Head Start standards of conduct at 45 CFR §1302.90(c), or results in a child being left alone, unsupervised, or released to an unauthorized adult.”

It goes on to list the following examples:

Child injuries that require either hospitalization or emergency room medical treatment, such as a broken bone; a severe sprain; chipped or cracked teeth; head trauma; deep cuts; contusions or lacerations; or animal bites.

Inappropriate discipline, which is any type of conduct used to instill fear or humiliate rather than to educate a child, such as poking or pinching a child; making fun of or laughing about a child; using/withholding food or an activity as a punishment or reward; or isolating a child.

Potential child abuse and maltreatment, such as grabbing, shoving, shaking, swatting, or dragging a child; spanking or any other type of corporal or physical punishment; binding, tying, or taping a child; terrorizing a child with threats or menacing acts; or any form of sexual contact.

Lack of supervision while in the care or under the supervision of program staff, which includes leaving a child alone anywhere on the grounds of a Head Start facility (e.g., in a classroom, bathroom, on a playground), as well as outside the facility in a parking lot, on a nearby street, or on a bus or another program-approved transportation or excursion.

Unauthorized release where a child is released from a Head Start facility, bus, or other approved program transportation to a person without the permission or authorization of a parent or legal guardian and whose identity had not been verified by photo identification.

How do you report a safety incident?

While reducing the potential for health and safety incidents is the number one priority, it’s also important that designees be honest and report those incidents as soon as possible to the program specialist assigned to your grant or the regional program manager. The Office of Head Start provides a sample reporting form here.

Head Start requires that all designees report any incidents “immediately or as soon as possible.” This is in addition to any local or state reporting requirements. OHS is clear that failure to do so will result in a monitoring finding and may include a deficiency determination.

“OHS reviews publicly available information and reports from the grant period to identify any child health and safety incidents,” the IM states. “If OHS discovers a program failed to report a significant incident within seven calendar days from the time of the incident, the program will receive a monitoring finding, which may include a deficiency determination.”

What about blended classrooms?

One final note about blended classrooms, where some children’s enrollment is funded by Head Start and other children are funded by other means. Even if the incident involved a child that is not funded by Head Start, that incident still needs to be reported to Head Start.

How can The Gravely Group help?

Our training, Active Supervision, Creating and Enhancing a Culture of Safety goes into detail on the who, what, where, and why of accurate and timely safety incident reporting, as well as all of the other pieces that can help a program “create a culture of safety.” Creating a culture of safety means deploying strategies of active supervision continuously throughout the day while children are in our care.

Every child has the right to be safe. Children are safer when we all work together to make that happen.


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