South Dakota Head Start Association

Response to NHSA Comments on the Proposed Federal Performance Standards

The South Dakota Head Start Association (SDHSA) is providing these comments as direction to the NHSA as that organization prepares to make comments regarding the Proposed Federal Performance Standards.

SDHSA appreciates the opportunity to provide comment. In general, the revisions suggested in the performance standards will support improved quality for Head Start children across the nation. SDHSA appreciates the strengths-based approach and the elimination and reduction of number of standards for compliance – keeping the focus on quality.

Revised Head Start Models:

SDHSA supports NHSA concerns/comments regarding the revised Head Start models.

Additional Comments from SDHSA:

• Advocate for the Head Start home-base program option to be considered as a standard program option (not locally designed) with no waiver process required, and keep 32 week implementation. 1302.24

• Concern if no financial support is provided for implementation of the revised Head Start models - potential is great for reduced enrollment. 1302.21(c)(3)

• Concern if financial support is provided of Grantee’s ability to meet local non-federal share match – consider a quick and easy waiver process

Full-Year Dosage:

SDHSA supports NHSA concerns/comments regarding Full-Year Dosage:

Additional Comments from SDHSA:

• Provide opportunity for Head Start programs to align number of days of service with local school districts (instead of mandating 180 days) – this would support partnerships already established and may alleviate some facility concerns. 1302.21(c)(1)

• If 180 days continues to be mandated – clarification needed if the 180 days includes any professional development days for staff.

• Advocate options for part-day programming based on community needs.

Changing Ages Served:

South Dakota does not have any publicly funded pre-kindergarten programming available at this time. This is a concern as a possible reduction in Head Start program slots (if funding is not received for implementation of the performance standards) will negatively affect thousands of children if they cannot be served by local Head Start programs – there are limited other options for them.

Shifting Family Focus: 1304.40

SDHSA supports NHSA concerns/comments regarding Shifting Family Focus and would advocate that the Early Head Start and Head Start home-base models support family engagement.

Parent Committees:

SDHSA support NHSA concerns/comments regarding Parent Committees

Additional Comments from SDHSA:

• Supports the change in Policy Council representatives being allowed to serve for 5 years if local bylaws allow. 1301.4 (d)(3)

• No concerns with elimination of Parent Committees – gives program alternate ways to provide family/parent engagement opportunities.

QRIS: 1302.53(e)

South Dakota does not have a state or local Quality Rating and Improvement System in place. While we would be supportive of such QRIS, there is no indication that any funding at the state level now or in the near future to implement one.

Attendance Systems: 1302.16(a)(1-2)

SDHSA supports NHSA concerns/comments regarding Attendance Systems. Would advocate for elimination of specific time period in which program needs to contact family of child absent.

Credentials: 1302.90(b)(4)

SDHSA supports NHSA concerns/comments regarding Credentials. We would advocate that the Early Head Start center-based teaching qualifications remain as they currently are.

Supporting Children Without IEPs

SDHSA feels this is an unnecessary provision in that Head Start programs are required to individualize services for all children.

Curricula: 1302.32

SDHSA supports NHSA concerns/comments.

Health and Safety: 1304.22

SDHSA supports NHSA concerns/comments.

Criminal Background Checks:

SDHSA supports NHSA concerns/comments. No suggestions for timelines.

Data Governance: 1302.101(4)(iii)

SDHSA supports NHSA concerns/comments. Guidelines will not be restrictive to programs in implementing high quality services – may support more state-wide data work in South Dakota.

Distinct Service Areas:

SDHSA supports NHSA concerns/comments and is supportive of this option.

Additional Comments:

SDHSA would like advocacy for additional funding to support the mentor-coaching – current workloads in programs will not support this implementation. Suggestion was to advocate for how training funding could be used to support the implementation of this standard. 1302.92 (b)(4)

SDHSA supports the community assessment moving to align with the 5-year grant cycle.

SDHSA is comfortable with impasse procedures as they are written. 1301.5(b)

These comments were written, approved, and are respectfully submitted by the Board of Directors of the South Dakota Head Start Association:

Jane Leite, President Rick Thaler, Vice President Tom Hopper, Treasurer Brenda Knouse, Secretary Carmen Stewart, Past President Sue Glodt, Director Representative Steph Lebeda, Director Representative Marcus Bevier, Director Representative Vicki Lowry, Director Representative Anne Reddy, Director Representative Carmelita Bear Ribs, Director Representative Tammy McDaniel, Staff Representative Sharon Roberts, Staff Representative Joyce Harmon, Staff Representative Jodi Berscheid, Staff Representative Dayle Blasius, Staff Representative Melissa Johnson, Staff Representative Becky Anglin, Staff Representative Jill Winter, Staff Representative Nicole Glines, Friend Representative Renee Olson, Friend Representative Shontell Mason, Friend Representative Shalyn Torpey, Friend Representative Nikita DeVoll, Parent Representative Rachel VanderLey, Parent Representative Diana Hendricks, Parent Representative Sheila Hanson, Parent Representative Michelle Klingbile, Parent Representative Kathy Cruse, SD Head Start Association Executive Director