Auditing the Head Start Program as Part of Your Single Audit: Avoid Common Pitfalls

Auditing the Head Start Program as Part of Your Single Audit: Avoid

Common Pitfalls

A Governmental Audit Quality Center Web EventOctober 11, 2012

Governmental Audit Quality Center

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Presenters Ann Linehan, Deputy Director• Office of Head Start

Terry Ramsey, CPA• U.S. Department of Health & Human Services

Belinda Rinker, JD• Senior Advisor to the Office of Head Start

Jim Belanger, CPA• Director, Fiscal Operations, Program Monitoring

Eric Formberg, CPA, CGFM• Plante & Moran PLLC

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What We Will Cover

Overview of the Head Start ProgramCompliance RequirementsCommon Program FindingsAudit Quality IssuesTips for Avoiding Pitfalls

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Overview of the Head Start Program

Ann Linehan, Deputy DirectorOffice of Head Start

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Purpose of Head StartHead Start is a Federal program that promotes the school readiness of children ages birth to five from low-income families by enhancing their cognitive, social, and emotional development.

• Early Head Start provides services to pregnant women and families with children up to age three.

• Head Start serves children age three to five and their families.

Together the two programs are commonly referred to as Head Start.

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Head Start ServicesEach year, Head Start / Early Head Start programs provide comprehensive services to over a million eligible children and families.Comprehensive services include early childhood development and education, health, family engagement, and community partnerships.Community Assessment determines program model/s: center-based, home-based, or family child care.

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Head Start Grants and Eligible Entities

Head Start grants are provided directly to local agencies by the Administration for Children and Families, Office of Head Start, with no intermediary state funding agency.Eligible agencies include local public or private nonprofit agency, including community-based and faith-based organizations, or for-profit agency, within a community. See Head Start Act Sec. 641(a)(1) [42 U.S.C. 9836].Recipients may designate delegate agencies to operate all or part of the Head Start program.

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ACF Office of Head Start Geographic RegionsNote: Region 11 (American Indian/Alaska Native) and

Region 12 (Migrant and Seasonal Head Start) have nationaladministrative offices in Washington, DC.

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Regional Contact Information: http://www.acf.hhs.gov/programs#region

http://www.acf.hhs.gov/programs


Head Start Grants

The current federal funding is nearly $8 billion.

The smallest grant is $190,664 and the largest is $210 million.

With over 1600 grantees, the average funded enrollment per grantee is 595, ranging from 15 to 22,348 children.

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Governmental Audit Quality Center 13


Early Childhood Learning and Knowledge Center (ECLKC)

http://eclkc.ohs.acf.hhs.gov/hslc

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Head Start Performance StandardsHead Start ActMonitoring ProtocolTraining and Technical Assistance Centers

Program InstructionsInformation MemorandumsHead Start Announcements…and more!

http://eclkc.ohs.acf.hhs.gov/hslc


Governance Structure

Head Start agencies must establish and maintain a formal structure for program governance, including a governing body and a policy council. See Head Start Act Sec. 642.

The governing body has fiscal and legal responsibility for the Head Start agency.

The policy council is responsible for supporting program direction. A majority of policy council members must be parents of children who are currently enrolled in the agency’s Head Start program.

Delegate agencies must establish a policy committee.

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http://eclkc.ohs.acf.hhs.gov/hslc/standards/Head%20Start%20Act


Monitoring Reviews

Head Start agencies must be monitored to determine compliance with all applicable requirements. See Head Start Act Sec. 641A. Review Types: Triennial, First Year, Other

Monitoring teams include fiscal reviewers.

Agency receives a written report identifying any areas of deficiency or noncompliance and is given a timeframe to correct all findings

The protocol used to conduct reviews can be found on the ECLKC website under the Monitoring & Reports tab.

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http://eclkc.ohs.acf.hhs.gov/hslc/mr


Regulatory Developments

Limitation of grant period to five (5) years. See Head Start Act Sec. 638. [42 U.S.C. 9833].

Designation Renewal System at 45 CFR Part 1307 identifies seven conditions which, if met, requires a Head Start program to re-compete for a five-year grant.

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Regulatory Developments, cont.

Three of the seven DRS conditions relate to fiscal operations. §1307.3(e): an agency has been suspended from the Head Start/Early Head Start program by ACF during the relevant time period covered under §1307.7.§1307.3(f): an agency has been debarred from receiving Federal or State funds or has been disqualified from the Child and Adult Food program (CACFP) during the relevant time period covered under §1307.7.§1307.3(g): An agency has been determined within the twelve months preceding the responsible HHS official's review under § 1307.7 to be at risk of failing to continue functioning as a going concern.

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http://eclkc.ohs.acf.hhs.gov/hslc/standards/Head%20Start%20Requirements/1307








Compliance RequirementsCommon Head Start Program Findings

Audit Tips

Presented by:Terry RamseyBelinda RinkerJim Belanger

Eric Formberg

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Session Goals

Explain Head Start requirements most likely to be misunderstood by auditors.

Identify common Head Start risk factors and provide audit tips.

Help auditors perform an effective and efficient audit of the Head Start program.

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Materials Highlight RequirementsUnique to Head Start

Basic single audit knowledge is assumed.Audit Standards (GAAS & GAGAS)OMB Circular A-133, Audits of States,

Governments, and Non-Profit OrganizationsA-133 Compliance SupplementOMB Administrative and Cost Principle CircularsFederal Audit Clearinghouse reportingAbility to write proper audit findings

Register for AICPA Web Event titled, Writing Up Government Audit Findings, October 19, 2012, click here.

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http://www.cpa2biz.com/AST/Main/CPA2BIZ_Primary/AuditAttest/IndustryspecificGuidance/Government/PRDOVR~PC-WBC12336I/PC-WBC12336I.jsp


Information Provided is not a Substitute for Compliance Supplement or OMB A-133

Session covers only areas identified as common risks for Head Start programs.An individual entity’s risk may be different

Auditor must still comply with OMB A-133 and consider all requirements identified in the Compliance Supplement.

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Overall Program & Entity RisksHead Start not designed to make money.Only covers costs that are reasonable, allowable

and allocable (RAA) for the accomplishment of program objectives

At best, entity relying on Head Start funding breaks even. Grantee must insure that costs are allowable or

cover unallowable costs from other revenue sources

Entity primarily funded by Federal grants at higher risk for unallowable costs, particularly match. Limited options to cover unallowable costs

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Overall Audit Tips

Combine similar areas if practical.Ensure samples target risk areas.Be alert to:Improperly allocated costs

Both direct and costs claimed as matchCost shifting

Particularly around beginning and end of period

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Activities AllowedProgram Services

Funds must be spent for program services consistent with the Head Start Performance Standards.See list of allowable activities in Compliance

SupplementIf unsure whether a cost is allowable: Check the program regulations (45 CFR 1301 – 1311) at the Policy & Regulation tab on the ECLKC website (provided earlier).

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Activities Allowed Capital Expenditures

Must have ACF prior approval.Necessary for purchase or sale of items of

equipment that meet or exceed the Federal acquisition cost level of $5,000.

Required for all facilities activities funded in whole or in part with Head Start funds as described in 45 CFR Part 1309 including: Construction Initial Purchase or Down Payment Major Renovation Mortgage Principal and/or interest

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Activities AllowedTransportation Costs

Transportation costs to and from Head Start center-based programs and other program activities are only allowable if provided in accordance with Head Start Transportation Regulations (45 CFR 1310). Transportation of center- based children must be in

a compliant vehicle with an age and weight appropriate child restraint system.

Related risk area: time and cost of parent supplied transportation in a non-compliant vehicle is not allowable as match.

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Activities UnallowedNutritional Services

The Head Start Performance Standards at 45 CFR 1304.23 require grantee agencies to use funds from the US Department of Agriculture (USDA), Food and Nutrition Service (FNS), Child Nutrition Programs as the primary source of payment for meal services.The most common USDA program utilized by Head Start programs is the Child and Adult Care Food Program (CACFP).Head Start funds may only be used to cover those allowable costs not reimbursable by USDA. Parents may not be charged for Head Start nutrition program participation.

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http://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/Fiscal/Legislation%20and%20Regulations/Head%20Start%20Program%20Performance%20Standards/fiscal_pps_00244_093005.html


Activities UnallowedNutritional Services Audit Tips

Food costs charged to Head Start present a risk of questioned costs.Ask why costs not charged to USDAValidate that costs are allowableValidate that USDA would not reimburse costsDetermine if grantee has been suspended or

debarred from USDA participation

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Cost AllocationDirect Allocation Method

Many smaller grantees do not have approved negotiated indirect cost rate.Shared costs are allocated as direct costs based on benefit to each program. Occupancy costs of shared facilitiesPersonnel working for multiple programs

Teacher for both Head Start and child care Executive Director for multiple program agency

Busses shared with Head Start and public schoolsCommunication systems and other equipment

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Cost AllocationDirect Allocation Method

Entity should have a written cost allocation plan describing the basis and method for allocating shared costs.ACF does not review or approve direct cost

allocation plansCost allocation plans may be informal, such as

annotated spreadsheetsMethod must provide for an equitable allocation of costs to each program based on benefit received.

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Cost Allocation Risks

Actual allocation of costs not in accordance with cost allocation plan.All costs allocated based on single basis such as level of funding rather than benefit to program.Over-allocating costs to Head Start to cover deficiencies in other funding sources.Failure to include all shared costs in the cost allocation plan.Double charging for same costs by inclusion in a negotiated indirect cost rate agreement and direct charging through allocation.

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Cost Allocation Audit TipsDetermine whether cost allocation plan: Fairly allocates costs based on relative benefits received Uses reasonable allocation bases Is consistently applied to all programs Allocation methods supported by the accounting system

Indirect costs are charged per negotiated indirect cost rate agreement both in terms of rate and base.Test documentation supporting allocations to insure that they are reasonable, allowable and allocable.Be alert to identified cost allocation risks.Listen to an archived “open to the public” GAQC Web event on Understanding Indirect Cost Rates: A Primer for Auditors Performing Single Audits. 33

http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/Pages/UnderstandingIndirectCostRatesWebEvent.aspx




Activities Allowed & Cost Principles Risks

Inadequate source documentation.More common for match and shared costs

Lack of written fiscal procedures.Engaging in procurement activities without free and open competition.Inadequate documentation for shared personnel compensation expenses.Payroll recordsDaily time records for non-exempt employeesPersonnel activity reports

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Activities Allowed & Cost Principles Risks Journal Entries

Journal entries indicate costs moved from other programs to Head Start.Costs entered before or after award period to shift costs between award periods.Multiple adjusting entries needed at end of award period.Audit tips:Test supporting documentation for journal entriesCheck for approval or purchases and sales of

facilities and equipment Be alert to unusual journal entry activity,

particularly at year end

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Activities Allowed & Cost Principles Risks Internal Controls

Basis for allocation of costs is not supported or source documentation is lacking.Small programs may not have sufficient staff to effectively segregate fiscal responsibilities.Credit card use and petty cash access may not be adequately limited.Bank account reconciliation shows unissued checks as outstanding.

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Other Activities Allowed Risks

Extensive use of Head Start funds for professional medical and dental services.Head Start must be payer of last resortDental services often area of highest risk

Compensation to individual employee paid in excess of Executive Level II ($179,700). Not in 2012 Compliance Supplement, will be added to 2013 Compliance Supplement. If paid in excess, Head Start may not pay any part of the

compensation (42 U.S.C. 9498, Sec. 653) May not allocate pro rata part below $179,700 to Head Start May not be included in negotiated indirect cost rate agreement

or allocated direct costs

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Activities Allowed & PropertyReal property, facilities, equipment and related assets purchased in whole or in part with Head Start funds must be used for program purposes.Grantees must adequately protect Head Start assets.Head Start funds more facilities activities than any other ACF program, including 3,632 current facilities.Facilities activities allowed under 45 CFR Part 1309 include: Purchase (initial or through payment of mortgage principal

and/or interest) Construction (applies only to new facilities) Major renovation as defined in 45 CFR 1309.3

Use of Head Start funds for facilities activities results in a Federal interest which must be protected by filing a notice in the public record or posting for modular units.

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http://eclkc.ohs.acf.hhs.gov/hslc/tta-system/ehsnrc/Early%20Head%20Start/supervision/management/fiscal_pps_00022_061405.html


Activities Allowed & Property Risks

Equipment inventory is not updated and reconciled to source documents as required every two years.Equipment or facilities are not properly insured for property damage and liability.Grantee uses Head Start funds for a facilities activity without prior ACF approval.Notice of Federal interest is not filed in the public record or posted on a modular unit.Property subject to a Federal interest is pledged as collateral without ACF approval.

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Activities Allowed & Property Risks

Required ACF rights of notice, cure and substitution are not included in leases, mortgages or subordination agreement.Facilities are sold or transferred without ACF disposition instructions and compensation of Federal share.Rent is charged at full fair market value instead of depreciation or use allowance under capital (material equity) leases and related party leases.Depreciation uses a basis other than acquisition cost or uses accelerated depreciation rather than straight line for facilities.

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Activities Allowed & Property Audit Tips

Identify capital expenditures and determine if ACF consent to purchase was received.Examine leases to identify any that are capital leases or involve related parties. If so, determine if ACF permission was received for

pledge of propertyReview lines of credit to determine if property purchased in whole or in part with Head Start funds was pledged as collateral. If so, determine if ACF permission was received for

pledge of propertyIf Head Start funds were used for facilities activities insure notice of Federal interest was filed or posted.

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Eligibility & EarmarkingChildren must be age-eligible for the Head Start program. Not in 2012 Compliance Supplement, will be added to 2013 Compliance Supplement. At least three years old by the date used to determine eligibility for

public school in the community. Early Head Start serves pregnant women and families with

children under age 3.

Required percentage of income eligible families. 90% of children from low income families below the poverty line,

including homeless families and those eligible for public assistance

May have up to 10% of children from non-low income families Under certain circumstances may have an additional 35% of

children from families up to 130% of the poverty line Indian tribal programs have unique eligibility requirements

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Eligibility & EarmarkingGrantee must examine documents for proof of eligibility, but not required to retain copies. Acceptable documents include tax forms, W-2’s, pay stubs,

statements from employers and proof of receipt of public assistance

Head Start provides a recommended form entitled Head Start Eligibility Verification (OMB 0907-0374).The employee who reviews documents and determines eligibility must provide a signed statement to be retained in the child’s records: Identifying what documents were reviewed Stating the child is eligible to participate

Grantees are strongly encouraged to retain copies of the documentation reviewed.

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http://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2010/Head%20Start%20Eligibiliy%20Verification%20Form,%20expires%2002-28-2013.pdf


Eligibility & EarmarkingHead Start grantee must enroll 100% of funded enrollment.Actual enrollment must be reported monthly, including

reason for any shortfall below funded enrollmentNot less than 10% of enrolled children must be children with disabilities.Funded enrollment less than 10% requires waiver

Risk of failure to enroll sufficient income eligible children.Enrollment of children who are not age eligible.Failure to identify documents relied on to determine eligibility or sign verification.

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Eligibility and Earmarking Audit Tips

Encourage grantees to follow Head Start guidance and use forms provided for eligibility verification.Test regularly at points throughout the program year (end of months).Compare various sources of enrollment and attendance to determine consistency, such as monthly enrollment reports and CACFP meal counts.Highest risks include children enrolled whose families are not income eligible and failure to meet overall required percentages for low income families and children with disabilities.

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Program IncomeNo Participation Fees

Programs may not collect fees for Head Start services or participation, including meals.However, if a parent volunteers to pay all or part

of the child’s costs, it may be accepted Recorded as program income Must be used for allowable program costs

Program may collect co-payment for non-Head Start child care services as part of an extended day (commonly referred to as wrap-around services).Program income may also be received from rental of property purchased with Head Start funds.

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Program Income Audit Tips

Determine if the program is collecting any fees from Head Start parents.If so, examine fees for allowability (not for Head

Start services)Then determine whether allowable fees are used

for program costsBe alert to income from equipment sales such as vehicles purchased with Federal funds but no longer needed for program purposes.Watch for applicable credits mischaracterized as program income.

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Cash Management & Period of AvailabilityRed Flags for Year End Float Risk

Risk conditions at year end:Head Start has funding not drawn down from HHS

Payment Management System (PMS)Other programs have bills without available cash to payEntity is short on cash

Red Flag actions at year end:Pull down all available funding from HHS PMSBooks next year’s expenses in current year

Journal entries with no support Allocating other program costs to Head Start Writing checks with no supporting invoices

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Cash Management & Period of AvailabilityAudit Tips for Year End Float Risk

Understand each program’s cash flow. Possible delays in receipt of state child care funds

Be alert to unusual year end transactions. Understand business reasons

Test supporting documentation for journal entries. Especially charges under agreements for shared services

Review year end direct cost allocations and indirect cost charges. Consider possibility of over-allocating to Head Start Inquire why year end checks do not clear promptly.

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Cash Management Risks & Audit TipsStandard cash management requirements apply to Head Start programs.Risk results from ability of Head Start programs to draw down cash from HHS PMS in advance of expenditures. Availability of cash may lead to: Drawing down excess cash not needed for

disbursementLoaning Head Start funds to another agency program to

cover delayed receipt of fundsEarly drawdown not minimizing time elapsed between drawdown and payment.Drawdown based on accrued expenses not disbursed until later date (or next fiscal period).

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Matching (Non-Federal Share)

The Federal share of the total cost of a Head Start program may not exceed 80% of the total budget.A written waiver from ACF may be provided if grantee

requests waiver and meets specified criteriaWaivers apply for one year, but grantee may reapply

for subsequent yearsGrantees are required to contribute at least 20% of the total costs of the program through cash or in-kind.Grantee notice of award (NOA) reflects amount and proposed sources of grantee match.

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Matching (Non-Federal Share) RisksEconomic conditions have reduced cash donations and historic sources of large in-kind donations, such as free space. Increased risk entity cannot meet required matchMost matching is in-kind, often multiple small amounts

Property and services claimed as matching not meeting cost principles.Valuation is overstatedDonated items are not used for program servicesVolunteer services not benefiting the Head Start programCash claimed when donated, not when used Inadequate documentation of volunteer servicesClaiming Federal source funds as match

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Matching (Non-Federal Share) Audit TipsConsider existence of identified risks.Determine whether documentation supporting amounts claimed as match indicate:Reasonable, allowable, and properly allocatedFairly valued, especially volunteer timeReceived or spent in correct grant periodActually occurredBenefited the Head Start program

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Administrative Cost EarmarkCosts of developing and administering Head Start may not exceed 15% of total program costs, including the required non-Federal match.A written waiver from ACF may be provided for a

period of time not to exceed twelve months if grantee requests waiver and meets specified criteria

Administrative costs include:Salaries and fringe benefits of executive personnelOrganization-wide planning costsAccounting and auditingPurchasing and personnel functionsMaintenance and operation of administrative space

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Administrative Cost Earmark RisksAdministrative costs may be misclassified as programs costs.Dual benefit costs fully allocated to Head Start program.Employees with both administrative and Head Start

responsibilities charged all to Head StartCosts of administrative facility maintenance and

utilities charged completely to Head StartCharging administrative costs through direct allocation which are already include in the approved indirect cost rate.Indirect costs which are categorized as programs costs should be explained.

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Administrative Cost Earmark Audit Tips

Determine whether accounting system properly identifies and classifies costs between program and administrative costs.Ensure all program costs are identified including those provided through matching.Determine cost reasonableness by reviewing annual budget.Test costs for proper allocation between program and administrative cost classifications.Calculate whether administrative costs exceed the 15% limit.

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GAQC Resources

GAQC Web site (www.aicpa.org/GAQC)

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http://www.aicpa.org/GAQC


Just Released!

Auditee Resource Center – Open to the Public• Why quality audit important?• Auditee resources – some existing resources for auditors and

some new (single audit, Yellow Book, other compliance audits, and financial statements audits)o Archived Web eventso Practice aidso Articleso Access to GAQC Alerts

• Links to Publications• Link to Conferences and other training available• Access the Auditee Resource Center

http://www.aicpa.org/INTERESTAREAS/GOVERNMENTALAUDITQUALITY/RESOURCES/AUDITEERESOURCECENTER/Pages/AuditeeResourceCenter.aspx

http://www.aicpa.org/INTERESTAREAS/GOVERNMENTALAUDITQUALITY/RESOURCES/AUDITEERESOURCECENTER/Pages/AuditeeResourceCenter.aspx


GAQC Resources – Tools & Aids

New! Yellow Book Independence Practice AidSingle Audit Practice Aids • SEFA Practice Aids (both for the auditor and auditee)• Internal Control Practice Aids• Illustrative Auditor’s Reports

Peer Review ChecklistsArchived GAQC Alerts and GAQC Web eventsAICPA Audit Guide, Government Auditing Standards and Circular A-133 Audits

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http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/AuditPracticeToolsAids/Pages/YellowBookAuditToolsandAids.aspx

http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/AuditPracticeToolsAids/Pages/YellowBookAuditToolsandAids.aspx

http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/AuditPracticeToolsAids/Pages/Single%20Audit%20Practice%20Aids.aspx

http://www.aicpa.org/INTERESTAREAS/GOVERNMENTALAUDITQUALITY/RESOURCES/ILLUSTRATIVEAUDITORSREPORTS/Pages/default.aspx

http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/AuditPracticeToolsAids/Pages/Peer%20Review%20Checklists.aspx

http://www.aicpa.org/INTERESTAREAS/GOVERNMENTALAUDITQUALITY/NEWSANDPUBLICATIONS/GAQCALERT/Pages/gaqcalertsarchive.aspx

http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/Pages/Archived%20GAQC%20Conference%20Calls.aspx

https://www.cpa2biz.com/AST/Main/CPA2BIZ_Primary/AuditAttest/IndustryspecificGuidance/NotforProfit/PRDOVR~PC-012743/PC-012743.jsp

https://www.cpa2biz.com/AST/Main/CPA2BIZ_Primary/AuditAttest/IndustryspecificGuidance/NotforProfit/PRDOVR~PC-012743/PC-012743.jsp


GAQC Resources – Web EventsChallenges with Fair Value Measurements for NPOs*Understanding Indirect Cost Rates: A Primer for Auditors Performing Single Audits*New 2011 Yellow Book*Understanding the New AICPA Yellow Book Independence Practice Aid*Updated Schedule of Expenditures of Federal Awards (SEFA) Practice Aids (for SAS 119)Subrecipient Monitoring: An Auditee and Auditor Perspective*2012 Compliance Supplement and Related Best PracticesFun and Games with Not-for-Profit Functional ExpensesPreparing for Your Single Audit: An Auditee Perspective *Single Audit Fundamentals On-Demand Series* Open to the Public

http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resources/Pages/Archived%20GAQC%20Conference%20Calls.aspx


Questions ?????

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Closing Remarks

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Auditors play a vital role in assuring that Head Start agencies manage grant funds effectively to support

excellence in services to children and families.


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Auditing the Head Start Program as Part of Your Single Audit: Avoid Common Pitfalls

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