Coronavirus Disease (COVID-19)

A1. As of March 24, the vast majority of Head Start centers are closed due to coronavirus disease 2019 (COVID-19). OHS is advising grantees to continue to coordinate with local health authorities and implement their existing policies and procedures related to closure of Head Start and Early Head Start centers during infectious disease outbreaks. Closure of centers in areas impacted by COVID-19 is an important element of containing and limiting its spread.

Many Head Start and Early Head Start programs are following the lead of school systems and local health authorities and closing centers.

If program operations are impacted by the coronavirus, please reach out to your Regional Office to inform them of any programmatic changes.

A2. Yes. Grantees with closed centers should continue to pay their staff, even while staff are not physically at their offices or centers. A pre-existing policy or procedure is not required prior to paying staff under these unusual employment circumstances. Programs do not have the discretion to deny staff their regular wages and health benefits. Regardless of what staff can do remotely, all staff should be paid for hours they normally worked before the closure.

To the extent possible, staff are expected to support ongoing services to enrolled Head Start children and families. We understand that some staff are able to be more engaged than others when centers are closed.

Supporting your Head Start staff by continuing to pay them is a critical factor in mitigating the fiscal crisis, recognizing their valuable work and ensuring that staff are in place when services resume. While we understand some staff may need to come into their office or center for essential and critical work, it is irresponsible for any grantee to require most staff to report to work during program closures as it heightens the risk of spreading the COVID-19.

A3. No. OHS is directing programs to continue to pay wages and provide benefits for staff during center closures necessary to address COVID-19.

This flexibility is particularly important for Head Start programs to ensure staff are ready and able to return to work as soon as it is possible to resume operations. This flexibility remains in effect through April 30, 2020 unless further extended by OHS.

To the extent possible, employees should continue to engage families and to deliver critical services remotely during center closures. However, continuing payment of wages and benefits are not contingent on the ability to work during this crisis.

A4. Local health and government authorities as well as school systems are recommending closure of centers in communities where community spread of COVID-19 is a concern. Social distancing helps to minimize exposure and limit the spread of COVID-19. We do not recommend home visitors continue to visit family homes under these circumstances. We do encourage program staff to maintain contact and continue support to children and families via virtual communications and other creative outreach that limits exposure and risk.

A5. If your Head Start program has chosen to remain open during this time, the health and safety of staff, families, and children is the highest priority. Programs choosing to remain open must adhere to guidance from the CDC and your local health officials. You can access all CDC recommendations at the following link: Guidance for School and Child Care.

A6. Many grantees have asked about flexibilities and funding for U.S. Department of Agriculture (USDA) programs such as the Child and Adult Food Care Program (CACFP) and the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC).

Last week, Congress passed and the president signed the Families First Coronavirus Response Act, which included nationwide flexibility for the USDA to waive congregate meal requirements for food and nutrition programs (CN COVID-19 Non-congregate Feeding Nationwide Waiver). Note that the USDA has granted waivers for all states that elect to use the waiver; therefore, programs must check their specific state guidelines. More information can be found at the Food and Nutrition Program Guidance on Human Pandemic Response.

USDA guidance about reimbursement in light of the new flexibility is forthcoming. While we await USDA guidance on reimbursement, Head Start programs can and should use Head Start funds to provide meals and snacks. To the extent programs current budgets are insufficient to cover these costs, programs will be able to request supplemental Head Start funds later this year.

A7. The guidance from ACF-HS-IM-19-01 General Disaster Recovery Flexibilities applies to programs impacted by COVID-19. While we often think of disasters as natural events such as hurricanes and earthquakes, health emergencies such as the COVID-19 outbreak can also form the basis of a disaster declaration. In addition, the following waivers are available as provided in the Head Start Act:

1. Programs may request a waiver of all or part of their 20% non-federal share based on emergency or disaster because other organizations may not be able to provide the usual contributions to Head Start grantees during this time.
2. Programs may request a waiver of the 15% administrative cost limitation if additional program management attention is needed to respond to the COVID-19 outbreak.

Although there are no formal waivers for the number of days of service provided via center-based programs, or number of home visits and socializations provided via home-based programs, programs will not be expected to make up the days missed due to COVID-19.

Finally, the Administration for Children and Families (ACF) has granted fiscal flexibilities related to COVID-19:

1. Grantees can shift up to $250,000 between budget categories without prior ACF approval.
2. ACF has issued an Information Memorandum with guidance related to fiscal flexibilities and waivers affecting grant applications, no-cost extensions, allowable costs, extension of certain deadlines, procurement, prior approvals, indirect cost rates, and single audit submissions.

Programs should maintain documentation to address any variations in their normal fiscal practices made to respond to the COVID-19 outbreak.

A8. The Office of Head Start is carefully monitoring the closures related to the COVID-19 outbreak. We have postponed FY 2020 Focus Area Two (FA2) and Classroom Assessment Scoring System (CLASS): Pre-K® onsite monitoring reviews scheduled to occur in March and April. These reviews will be rescheduled when programs return to a steady operating status. We will make ongoing decisions about postponing monitoring reviews scheduled beyond April. We have instructed DLH DANYA, the contractor responsible for contacting grantees about monitoring events, to notify grantees immediately who are scheduled in April of postponements and they will contact grantees if decisions are made to postpone grantees scheduled for reviews beyond April in the coming weeks. All FA1 reviews will continue as scheduled.

A9. There are a number of things Head Start programs can do to support children and families:

• Remember staff well-being is very important. No one can pour from an empty cup. Family services staff, home visitors, and teachers may need extra support from each other, from mental health consultants and other experts at this time. Consider using online video platforms to share program information and plan for meeting Head Start child and family needs. Using video platforms allows staff to spend time together and support one another.
• Support families by staying in touch. Families have told us continued outreach from their Head Start staff was what helped them the most in other large-scale emergencies, such as hurricanes. Head Start programs can ensure that every family receives outreach and communication through phone calls, video chats, texts, emails, or other mediums. Offer support, ask parents how they are doing, take delight in connecting with children, and tell them you miss them. Offer a listening ear for caregivers who want to talk about parenting challenges, behavioral health issues, and other challenges that may emerge or be exacerbated by current conditions.
• Provide Food, Diapers, and Formula. Many programs are meeting critical needs by delivering food, diapers, and formula, while following guidelines for social distancing, to enrolled children and families. Some programs have partnered with food pantries to distribute food to adults as well as children. Head Start programs can partner with local diaper banks to distribute diapers for siblings of enrolled children.
• Provide information on community supports as adversity can increase during this time. Assisting families with navigating community supports can greatly contribute to relieving some of their stress and burden. Provide parents and caregivers with any needed resources, such as food or online resources for family health information. When social distancing is encouraged, families who feel unsafe in their home environment may be particularly vulnerable. Provide families with telephone numbers to local domestic violence shelters, child protective services, and local community mental health centers that have moved to telehealth appointments. If a family needs immediate behavioral health services, consider using the Substance Abuse and Mental Health Services Administration's (SAMHSA) National Helpline and the National Suicide Prevention Lifeline.
• Help families stay connected virtually. Social distancing should not mean social isolation for Head Start and Early Head Start families. Help families stay connected virtually. There are a number of vendors offering free Wi-Fi at this time. Help families take advantage of free video platforms so they can stay in touch with family, friends, trusted providers, and, possibly, other Head Start families.
• Encourage parents to establish routines at home. Provide some examples of what a daily schedule might look like. Routines help children feel safe and know what is expected. Routines can include times for eating, washing up, playing, learning, and sleeping. Teachers and home visitors can help parents make a visual, daily schedule for children. Cut pictures from magazines or make simple drawings. This looks different for different families and can be done individually.
• Support parent-child relationships. Remind parents that their main job is to take care of themselves and to keep children as safe and secure as possible during this time. Point families to child-family activities by offering easy, low stress activities to do with children. Consider conducting parent cafes or parenting curricula groups with video platforms so parents can connect with each other.
• Push out positive messages to parents on social media and texting platforms. Show families you believe in them during this time. Resources on Using Social Media to Engage Families and Social Media Essentials for Getting Head Start Programs Connected are available on the Early Childhood Learning and Knowledge (ECLKC) website. The ECLKC has many other resources staff can use to connect with parents.
• Support child development virtually. If Head Start teachers and families have access to technology, teachers can post videos of themselves online or use direct video messaging. Teachers and home visitors can reassure children of all ages with simple and consistent messages. Use children's names, and do a familiar greeting, song, or finger play. There are many examples to draw from online. Remember that many families are under enormous stress. They do not need to duplicate all the educational experiences that happen at a center. They should focus on keeping themselves and children safe and healthy.
• Take advantage of the OHS MyPeers Community. Connect with staff from around the country to exchange ideas and share resources on the OHS MyPeers virtual learning network community. Grantee agencies may set up a grantee staff workgroup to support internal communication and work functions during telework. There are regularly scheduled orientations for new users.

• From: VanderPloeg, Laurie
• Sent: Tuesday, March 24, 2020 4:20 PM
• Subject: State Systemic Improvement Plan

Dear State Directors and Part C Coordinators:

In response to inquiries from multiple stakeholders and following deliberative conversations within the Department, OSEP would like to provide updates on upcoming timelines specific to the FFY 2018 SPP/APR, including the submission due date for the State Systemic Improvement Plan (SSIP). We have recently received questions regarding a possible extension of the due date for the SSIP (Indicators B-17 and C-11) and implications of the COVID-19 pandemic on the SPP/APR clarification period and OSEP's issuance of States' annual determinations.

Although OSEP recognizes the unique and challenging circumstances state offices are experiencing, we have decided to adhere to the April 1, 2020 due date for the SSIP. We acknowledge that there may be circumstances related to the COVID-19 crisis that impact a State's ability to meet the April 1st deadline and OSEP is prepared to address State-specific needs as they arise. If you are unable to submit the SSIP by April 1st, please contact OSEP at SPPAPR@ed.gov, and cc Leslie.Fox@ed.gov, prior to April 1st.

As States continue to weather the impact of COVID-19 on schools and early intervention programs, OSEP recognizes that timely information and clear expectations are critical for your planning and decision-making. As you know, the SPP/APR clarification period is scheduled from April 14 - April 28 for Part C, and April 16 - April 30 for Part B. If necessary, OSEP may adjust these dates based on emerging issues. However, at this time we continue to be committed to completing our reviews of States' SPP/APRs and issuing determinations in a timely manner.

Thank you for your on-going work to support infants, toddlers, children and youth with disabilities and their families under such challenging circumstances.

Sincerely,

In general, no. Videoconferencing or any other similar form of technology between the child and caseworker does not serve as a monthly caseworker visit for the purposes of meeting the requirements of section 422(b)(17) of the Social Security Act (the Act). Rather, a monthly caseworker visit must be conducted face-to-face and held in person. Furthermore, the Act requires State and Tribal title IV-B agencies to describe standards for monthly caseworker visits with children in foster care that are well-planned and focused on issues pertinent to case planning and service delivery to ensure the safety, permanency, and well-being of the child.

However, there are limited circumstances in which a title IV-B agency could waive the in-person aspect of the requirement and permit the monthly caseworker visit to be accomplished through a videoconferencing. Such circumstances are limited to those that are beyond the control of the caseworker, child, or foster family, such as a declaration of an emergency that prohibits or strongly discourages person-to-person contact for public health reasons; a child or caseworker whose severe health condition warrants limiting person-to-person contact; and other similar public or individual health challenges. Even in the face of such challenges, agencies must continue to comply with the monthly caseworker visit requirement.

If an agency uses videoconferencing under these limited, specified circumstances, caseworkers must conduct the videoconference in accordance with the timeframe established in the Act, and must closely assess the child's safety at each conference. Also, we encourage agencies to consider plans of action should a caseworker not be able to reach a child via videoconference, or should the videoconference raise a concern about the child's safety or well-being. The waiver of the requirement would be narrowly limited to the timeframe during which the public or individual health challenge or issue renders it impossible or ill advised to meet the in-person requirement and should be well documented in the child's case plan. Scheduling conflicts and the like are insufficient grounds for waiving the in-person requirement.