Coronavirus Disease (COVID-19)

Waiver Authority for the Period of Availability for Individuals with Disabilities Education Act (IDEA) Part C Funds for Federal fiscal year (FFY) 2018

Under section 3511(b)(1)(B) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. No. 116-136 (March 27, 2020), the Secretary of Education is authorized to consider waivers to extend the period of availability of certain Federal funds to SEAs responsible for implementing Federal programs. The CARES Act provides substantial relief to children, families, educators, and service providers who have been profoundly affected by the Novel Coronavirus Disease (COVID-19). Funds provided under Part C of IDEA are to assist each State to maintain and implement a statewide, comprehensive, coordinated, multidisciplinary, interagency system to provide early intervention services for infants and toddlers with disabilities and their families. Under the CARES Act, State Lead Agencies that are also SEAs may request a waiver for the period of availability for the use of IDEA Part C funds. The CARES Act does not authorize the Secretary to consider waivers from State Lead Agencies that are not SEAs.

Specifically, as a State Lead Agency that is also an SEA, you may request a waiver on behalf of your State that will permit the IDEA Part C lead agency to use Federal fiscal year (FFY) 2018 IDEA Part C grant award funds for an additional year beyond what is known as the Tydings period. This action is taken as a result of the on-going national emergency declared by the President under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, and to assist in your planning for how to continue the provision of early intervention services to infants, toddlers and children with disabilities and their families.

Your State may now submit a streamlined waiver request for an extension of the period of availability in Section 421(b) of the General Education Provisions Act (GEPA) for FFY 2018 IDEA Part C grant award funds. Upon approval of a waiver, the FFY 2018 IDEA Part C grant award funds will be available for obligation by the State lead agency through September 30, 2021 and may be liquidated through December 30, 2021. OSERS is committed to acting on and responding to complete waiver requests as quickly as possible. To that end, a waiver template is available which, if completed and submitted electronically to IDEAwaiver@ed.gov, will result in an expedited response from the Department. The waiver template in fillable portable document format (PDF) is attached to this memorandum and is also posted at www.ed.gov/coronavirus.

The attached request must be signed by the SEA State lead agency. Your State's SEA representative (Chief State School Officer or other authorized representative) will need to submit the waiver request.

Thank you for your ongoing work in support of educators, families, and infants, toddlers and children with disabilities during these extraordinary circumstances. If you have questions or need additional information regarding submission of your IDEA Part C waiver request, please contact us at IDEAwaiver@ed.gov. If you have general questions regarding COVID-19 and how the U.S. Department of Education can best support you, please contact COVID-19@ed.gov. I encourage you to continue to monitor information regarding COVID-19 from the Centers for Disease Control and Prevention and stay abreast of information and resources for schools and school personnel at http://www.ed.gov/coronavirus.

Attachment

cc: Part C Coordinators of SEA lead agencies

Fact Sheet Regarding Contracted Services Not Performed Due to COVID-19

• Updated August 2020

QUESTION:

Can grant funds be used to cover the cost of approved contracted services that were not performed by a contractor because ofthe COVID-19 pandemic?

ANSWER:

Yes, in some limited circumstances, grant funds may be used to cover the costs of contracted services that were cancelled orotherwise not performed due to the COVID-19 pandemic if the contractor was ready and able to perform such services at the time.In determining whether grant funds may be used, the grantee or subgrantee should follow the steps set forth below.

Check on alternative arrangements first: If the contracted services are necessary to carry out the Federal award, theDepartment encourages grantees and subgrantees to work with their third-party contractors to, first, devise alternative ways toprovide those services (e.g., teleconferencing, training via webinars, and other virtual or remote strategies for servicedelivery) to carry out the intent and purpose of the contracts, to the greatest extent practicable. In so doing, the grantee orsubgrantee should demonstrate its best efforts to ensure continuity of needed services under the Federal award during thepandemic. The provision of services through an alternative means may require modification of the contract in order to enablepayment for the services rendered via alternative or virtual means. Any such modification of the contract should be negotiated sothat the costs paid are reasonable and necessary.

Steps if services cannot be provided in an alternative manner: If the services cannot be provided in an alternativemanner and funds were already paid to the contractor, as we also discussed, in the guidance on travel and conferences,¹ the grantee or subgrantee must first seek to recover refundable and nonrefundable costs from the relevant entity that waspaid (i.e., the contractor). Some entities and businesses are offering flexibility regarding refunds, credits, and other remediesfor losses due to the COVID-19 pandemic. Moreover, many agreements or contracts for conferences, training, or other activitiesrelated to a grant contain emergency or "act of God" or "force majeure" provisions, and the grantee and its subgrantees must seekto enforce such provisions to the maximum extent possible in light of the COVID-19 pandemic.

If a grantee or subgrantee is unable to recover funds paid, and the contractor was prevented from performing under thecontract, but was ready and able to perform such services at the time, due to the grantee's or subgrantee's closure or otherinability to accept the services, caused by the pandemic, the grantee or subgrantee should try to negotiate a reasonablecompromise amount. However, if no compromise can be negotiated, the grantee or subgrantee may charge the appropriate grant forthe costs of cancelling the contract, provided the contract costs were reasonable and incurred in order to carry out an allowableactivity under the grant, consistent with the Federal cost principles described in 2 CFR Part 200 Subpart E of the UniformGuidance (Federal cost principles).

If the grantee or subgrantee was ready and able to accept the contracted services, but the contractor could not provide thecontracted services due to the pandemic, the grantee or subgrantee must not pay for the services because such costs would notsatisfy the requirements of the Federal cost principles.

If there are State or local laws, regulations, or executive orders directly addressing a specific cost item or items duringthis emergency situation as affected by COVID-19, their effect on the grant will be reviewed on a case-by-case basis to determineallowability and allocability under the Federal cost principles.

Grantees and subgrantees should not assume additional funds will be available to cover any shortage in funds that may occur asa result of payments for services that were not provided and/or received. Grantees and subgrantees must maintain appropriaterecords and cost documentation as required by 2 CFR § 200.302 (financial management) and 2 CFR § 200.333 (retention requirementsfor records) to substantiate the charging of any cancellation or other fees related to interruption of operations or services.

• ¹ See the fact sheet on travel and conferences at: https://www2.ed.gov/documents/coronavirus/factsheet-fiscal-questions.pdf.

400 MARYLAND AVE., SW, WASHINGTON, DC 20202

The Department of Education's mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access.

Submission Flexibility for FY 2020 IDEA Grant Applications

• From: Corr, Greg
• Sent: Sunday, April 26, 2020 6:04 PM
• Subject: Submission Flexibility for FY 2020 IDEA Grant Applications

Dear SEA Director and Part C Coordinator,

The Office of Special Education Programs (OSEP) appreciates your work in meeting the needs of infants, toddlers, students, and their families during the challenges imposed on your programs by the Covid-19 pandemic. We know you are operating under extremely stressful circumstances and we are continuously exploring ways in which we can alleviate some of that burden for you.

Many of you have contacted OSEP to share your challenges with submitting your IDEA grant application for FFY 2020. Specifically, you have discussed how the pandemic restrictions that exist within your States have hampered your ability to obtain wet signatures on your IDEA grant applications. In order to address these difficulties, OSEP is providing the following flexibilities for the FFY 2020 Grant Application process:

Submission Instructions:

OSEP will accept a pdf copy of your State's FFY 2020 IDEA grant application with an electronic signature. This "e signature" can be a two-factor authenticated signature or an image file of the signature of the lead agency director or their designee that has the authority to certify the assurances that are contained in the application.

The pdf copy of your State's FFY 2020 grant application must be submitted to one of the following OSEP application email addresses:

• Part B: OSERS.bapp@ed.gov
• Part C: OSERS.capp@ed.gov

Application Deadlines:

The application due dates for the grant applications are:

• Part C: Friday, May 1, 2020
• Part B: Friday, May 15, 2020

If you need additional time to complete your grant application due to the revised submission instructions for 2020, please contact Jennifer Simpson at Jennifer.simpson@ed.gov.

Hard Copy Grant Applications:

States will still be required to submit hard copy FFY 2020 IDEA grant applications to OSEP by mail. However, the due date for submission of those documents to OSEP is no later than August 1, 2020.

We look forward to the receipt of your grant application documents.

Gregg

Additional Instructions -Electronic Grant Submission

• From: Corr, Greg
• Sent: Monday, April 27, 2020 9:39 AM
• Subject: Additional Instructions -Electronic Grant Submission

SEA Directors and Part C Coordinators,

Sunday evening, I sent you an email that explained the flexibilities that are available to you for submission of your State's FFY 2020 IDEA Grant Applications (original message is included below). As you prepare to send your applications to OSEP, please follow these additional instructions:

1. Provide the phone number and email address of the State government official who signed the application so that OSEP can contact them and verify that they signed the document.
   • This information can be provided in the body of the email message that includes your grant application or can be included in a cover letter with your application.
2. Ensure that your submission is sent from an official State government email address.

If you have any questions, please contact Jennifer Simpson at Jennifer.simpson@ed.gov.

Thanks again,

Gregg

State Systemic Improvement Plan

• 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,

Office of Head Start Expectations for Head Start Programs in Program Year 2021–2022 ACF-PI-HS-21-04

• From: ACF Administration for Children and Families, U.S. Department of Health and Human Services
• Log Number: ACF-PI-HS-21-04
• Issuance Date: 05/20/2021
• Originating Office: Office of Head Start
• Key Words: ERSEA; Recruitment; Selection; Enrollment; Virtual and Remote Services; In-person Services

Program Instruction

To: Head Start and Early Head Start Grantees and Delegate Agencies

Subject: Office of Head Start (OHS) Expectations for Head Start Programs in Program Year (PY) 2021–2022

Instruction:

Since the onset of the COVID-19 pandemic, Head Start programs — inclusive of Head Start, Early Head Start, Migrant and Seasonal Head Start, American Indian and Alaska Native Head Start, and Early Head Start-Child Care Partnership programs — have faced unprecedented challenges. Beginning in spring 2020 and throughout PY 2020–2021, all of our directors, staff, and families have demonstrated resiliency, innovation, and perseverance. OHS has provided needed flexibilities and guidance that allowed programs to adapt services based on the changing health conditions in their communities. Now, as programs prepare for PY 2021–2022, OHS is providing updated guidance.

This Program Instruction (PI) outlines OHS’s expectations for Head Start programs to begin working toward full enrollment and providing in-person comprehensive services for all enrolled children, regardless of program option. The PI also addresses whether virtual or remote services are an allowable, long-term, locally designed option (LDO).

By virtual, OHS means services for children provided through technology. Remote refers to services provided via the delivery of supports and resources, such as educational materials or food boxes.

Operating Status and Enrollment

OHS expects Head Start programs to provide comprehensive services in their approved program options beginning in PY 2021–2022, to the extent possible, as local health conditions allow.

OHS acknowledges programs are in different stages of fully returning to in-person services. Many programs continued to provide in-person services for children and families throughout the COVID-19 pandemic. These programs are expected to continue serving children in person, as local health conditions allow.

Other Head Start programs have been alternating between in-person services, virtual or remote services, or some combination of the two, due to community health conditions. These programs are expected to move to in-person services, as local health conditions allow.

OHS expects programs to work toward full enrollment and full comprehensive services, contingent upon U.S. Centers for Disease Control and Prevention (CDC) guidelines and state and local health department guidance and in consideration of local school districts’ decisions.

In September 2021, OHS will begin reviewing monthly enrollment in the Head Start Enterprise System (HSES) and discuss program plans for moving to full enrollment. Programs should build toward full enrollment and provide comprehensive services for all enrolled children as soon as possible. Programs must communicate with their Regional Office and be able to demonstrate why they are unable to be fully enrolled or serve children in person in their approved programs options. All programs must have plans in place that allow for adaptation to changing guidance and to changes in community conditions, which may affect achieving full enrollment or cause programs to temporarily suspend in-person services.

Beginning January 2022, OHS will reinstate pre-pandemic practices for tracking and monitoring enrollment. OHS will also resume evaluating which programs enter into the Full Enrollment Initiative in January 2022. All programs will start fresh, including those participating in the Full Enrollment Initiative prior to the pandemic. Reported enrollment in January 2022 is the first month of enrollment that OHS will evaluate for the under-enrollment process.

Virtual and Remote Services

Virtual and remote services for children are considered an interim strategy in the presence of an emergency or disaster and will not be approved as an LDO.

OHS has supported the implementation of virtual and remote services over the past 13 months. However, they are not an acceptable replacement for in-person comprehensive services. For PY 2021–2022, it is unallowable to have a program option run entirely by technology or delivering educational material, for example. OHS may still support some portion of services to continue remotely, as necessary.

OHS also recognizes that programs have discovered new virtual strategies for engaging families and reinforcing early learning and development at home. Innovations in virtual practice should be used as enhancements rather than substitutes for previously approved program options and service delivery.

Given their increased capacity to conduct virtual and remote services, programs may establish policies and procedures for temporary, weather-related virtual and remote services.

Head Start grantees have significant one-time funds and layered mitigation strategies available to support a return to in-person services. This includes access to the COVID-19 vaccine for adults.

Recruitment and Selection

As grantees look to summer programming and PY 2021–2022, OHS expects programs to prioritize recruiting eligible children and families.

Almost one third of children served in Head Start programs before the pandemic — approximately 250,000 — have not received any services to date.

The pandemic has created and exacerbated long-standing disparities and inequities for families who have been marginalized for decades. The number of children and families in poverty has grown significantly. All grantees should update their community assessments to guide their intensive recruitment efforts and to ensure they are reaching families most in need of services. If a program determines that their pre-pandemic approved program option will not meet the needs of the community, they must submit an updated community assessment and request approval for a change in scope.

Programs should also revisit their established selection criteria based on findings from their updated community assessment. As always, programs must include specific efforts to actively locate and recruit all eligible children and, in particular, those whose families are English language learners, experiencing homelessness, or affected by substance misuse, as well as children with disabilities and children in foster care.

The funds grantees have received from the Coronavirus Aid, Relief, and Economic Security (CARES) and Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Acts, as well from the American Rescue Plan, can and should be used to support enhanced community partnerships and related recruitment efforts. Per OHS guidance in ACF-PI-HS-21-03 FY 2021 American Rescue Plan Funding Increase for Head Start Programs, grantees have flexibility to determine which one-time investments best support the needs of staff, children, and families, while adhering to federal, state, and local guidance. This includes using funds to purchase services, materials, and technology to ramp up recruitment efforts, as well as to provide vaccine outreach and support as one layer of mitigation and protection for staff, children, and families.

Program planning for a full return to in-person services should include new and returning families at every step. Clear communication with families and regular invitations for input ensure Head Start services are most responsive to families, children, and the community.

Additional Information

OHS will support grantees through webinars and guidance as programs continue and return fully to in-person services. Additional resources and information are available on the Early Childhood Learning and Knowledge Center (ECLKC) website.

Please direct any questions regarding this PI to your Regional Office.

Thank you for your work on behalf of children and families.

Dr. Deborah Bergeron

ACF Administration for Children and Families, U.S. Department of Health and Human Services ACF-PI-HS-21-03

• From: ACF Administration for Children and Families, U.S. Department of Health and Human Services
• Log Number: ACF-PI-HS-21-03
• Issuance Date: 05/04/2021
• Originating Office: Office of Head Start
• Key Words: American Rescue Plan (ARP); Appropriations; Fiscal Year (FY) 2021; COVID-19

Program Instruction

To: Head Start and Early Head Start Grantees and Delegate Agencies

Subject: FY 2021 American Rescue Plan Funding Increase for Head Start Programs

Instruction:

President Biden signed Public Law 117-2, the American Rescue Plan Act, 2021 (ARP), into law on March 11, 2021. The $1.9 trillion American Rescue Plan includes $1 billion for Head Start programs. All Head Start, Early Head Start, and Early Head Start-Child Care (EHS-CC) Partnership grantees are eligible to receive additional funds proportionally based on funded enrollment levels.

When combined with the $750 million in the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the $250 million in supplemental funds in the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, the Head Start program has received a total of $2 billion in additional funding to support staff, children, and families during this unprecedented time.

This Program Instruction (PI) provides examples of activities grantees can consider as they continue supporting children and families and investing in safe and high-quality early childhood learning opportunities for children. This PI also describes the application requirements for these funds.

Use of Funding

The Office of Head Start (OHS) strongly encourages grantees to prioritize additional weeks of Head Start and Early Head Start programming with this funding, through summer programs or as extensions of the program year. At this time, Head Start programs are serving one-third fewer children than before the pandemic began. With ARP funding, programs have an opportunity to reach eligible children and families who did not enroll last year, or who did not engage in a full program year, due to the many uncertainties caused by the pandemic. Grantees are encouraged to prioritize programs for rising kindergartners, children with disabilities, children experiencing food or housing insecurity, children that were not able to receive any in-person services this year, or other areas determined by community needs.

Grantees do have flexibility to determine which one-time investments best support the needs of staff, children, and families, while adhering to federal, state, and local guidance. In making these determinations, grantees should consider how the use of the one-time funds could meet both short- and long-term needs and determine whether purchasing, leasing, or contracting for services is more prudent.

Other uses of funding include, but are not limited to, the following:

Reach More Families

• Enrollment and recruitment. Now is the time to focus on re-enrollment and enrolling new families. Programs can use funds to purchase services, materials, and technology to ramp up recruitment and enrollment efforts so that as a program you able to enroll the eligible children and families in your community.
• Additional weeks of Head Start or Early Head Start programming. Extending the program year or offering summer programming to increase the time children and families receive services.
• Family supports. Addressing families’ economic security by partnering with them on employment, education, and career goals. Investing in the development of partnerships with local community colleges, apprenticeship programs, and local employers committed to helping Head Start and Early Head Start families find meaningful employment and career tracks. Assessing families’ nutritional, health, and wellness needs more frequently. Ensuring materials and resources are available in languages families understand.
• Mental health support for children and families. Employing additional family service workers and mental health consultants to assist families with adverse circumstances, including families who may be experiencing homelessness.
• Provision of meals and snacks not reimbursed by the U.S. Department of Agriculture, including purchasing kitchen equipment and supplies to support in-person meal service.
• Transportation. Hiring bus drivers and monitors to allow more trips with fewer children per bus. Purchasing buses and other vehicles that support continuity of program service and reaching families most in need of services, including families experiencing homelessness.
• Partnerships to increase the inclusion of children with disabilities. Providing more training for teachers and families and more support for families. Remodeling classrooms and playgrounds to be accessible.
• Partnerships to increase the enrollment of children experiencing homelessness. Partnering with local shelters and public schools to identify and serve children and families experiencing homelessness.
• Addressing unique needs within their communities, such as providing internet access to support extended learning.

Get Facilities Ready for In-person Comprehensive Services

• Ventilation to reduce risk of indoor transmission and make facilities safer. Installing new heating, ventilation, and air conditioning (HVAC) systems or other improvements, such as windows that can open with safety measures to prevent falls.
• Outdoor learning and play. Purchasing or enhancing outdoor learning spaces, including nature-based learning and outdoor classrooms. Creating play areas and landscape features that promote exploration and discovery in a natural environment, such as plantings, gardens, and “loose parts” (i.e., materials for construction and pretend play), rather than traditional play structures or playgrounds.
• Cleaning supplies and services. Purchasing necessary supplies or contracting services to clean and disinfect facilities and vehicles.
• Renovations or other space modification. Converting available space into classrooms, modifying current classroom designs with room dividers, or adding well-ventilated modular classrooms.
• Additional space. Renting additional classroom space, due to physical distancing, to increase opportunities for more children to return to in-person services. Contracting for slots with child care providers in center-based or family child care settings to deliver comprehensive services.
• Other locally determined facility, staff, and equipment or partnership actions that are necessary to safely resume and maintain full in-person program operations.

Support Head Start Employees

• Planning sessions for staff. Preparing for a return to in-person comprehensive services starts to ensure everyone has the knowledge, skills, and resources necessary to operate effectively. This funding can be used to invest in planning sessions to prepare for providing services now and in the summer and fall.
• Staff wellness and mental health support. Conducting employee wellness surveys or engaging in other data collection to better understand the needs of team members. Increasing access to mental health consultation and therapy services for staff, contracting with an Employee Assistance Program (EAP), and instituting a staff wellness program that includes activities such as mindfulness breaks and opportunity for self reflection.
• Additional staff. Hiring additional classroom staff to meet physical distancing requirements or reduce group size. Bringing in full-time floaters to reduce the need to bring in outside substitutes.
• Professional learning and development for staff. Providing professional learning experiences on key topics such as equity, diversity, inclusion, bias, economic mobility, trauma-skilled practices, and other topics.
• Other personnel costs. Offering fringe benefits and expanding sick leave.
• Vaccine support. Providing transportation assistance to vaccination sites and temporary coverage to allow absence from the workplace for vaccination. Offering paid time off, sick leave, or other paid leave for the time spent receiving vaccination and if staff members experience side effects post-vaccination.

Grantees should carefully plan to engage in activities that are one-time or temporary in nature but have a long-term impact. Additional funding cannot be made available to sustain ongoing, long-term, or permanent expenses. For any ongoing activities, grantees would be responsible for sustaining additional costs either within their existing operations budget or securing outside support to continue activities beyond what is allocated through this opportunity.

Application Requirements

All Head Start, Early Head Start, and EHS-CC Partnership grantees are eligible to receive additional funds. Each grantee may apply for a proportionate amount of the $1 billion based on their total funded enrollment. Funds will be made available through a supplemental application in the Head Start Enterprise System (HSES). The funds will be awarded as supplements to the HE, HA, and HN grants currently used for the $250 million in CRSSA funds. Additional instructions will be forthcoming. Note that grantees will also be asked to report on the ARP funds in HSES, similar to the fall prior data collection.

Waiver of Non-Federal Match

The COVID-19 pandemic is a national emergency seriously affecting economic conditions in communities throughout the U.S. The Head Start Act recognizes that lack of resources in a community adversely impacted by a major disaster may prevent Head Start grantees from providing all or a portion of their required non-federal contribution. OHS has determined that the widespread impact of the COVID-19 pandemic adversely impacts all Head Start grantees. Consequently, OHS will approve requests for waivers of non-federal match for the funds awarded from the ARP. To request a waiver of non-federal match, enter $0 in SF-424A Section C of your application. No additional justification of the waiver is required. The issuance of a notice of award constitutes approval of the requested waiver.

Additional Information

Additional information and materials related to the pandemic are available on the COVID-19 and the Head Start Community webpage on the Early Childhood Learning and Knowledge Center (ECLKC) website. This webpage continues to be updated on a regular basis.

Please direct any questions regarding this PI to your Regional Office.

Thank you for your work on behalf of children and families.

Dr. Deborah Bergeron

Head Start Transportation Services and Vehicles During the COVID-19 Pandemic ACF-IM-HS-20-updated

• From: ACF Administration for Children and Families, U.S. Department of Health and Human Services
• Log Number: ACF-IM-HS-20-04
• Issuance Date: 06/22/2020
• Originating Office: Office of Head Start
• Key Words: Transportation Services; Vehicles; COVID-19 Pandemic

Information Memorandum

To: All Head Start and Early Head Start Agencies and Delegate Agencies

Subject: Head Start Transportation Services and Vehicles During the COVID-19 Pandemic

Information:

School buses and allowable alternate vehicles are generally the safest mode of transportation for children. They are also necessary for many children and families to participate in Head Start programs. Implementing safe practices is essential when providing transportation services during the coronavirus disease 2019 (COVID-19) pandemic.

When making decisions about transporting children, programs should consult local health officials and other state and local authorities, to the extent feasible. These authorities can help assess the current level of mitigation needed based on levels of COVID-19 community transmission and the capacities of local public healthcare systems. Staff should take steps to ensure they mitigate the risk with respect to school buses and allowable alternate vehicles. The steps Head Start programs take to reduce risk should be the same whether the program is providing its own transportation or relying on contracted or school district-provided transportation.

Support Transportation Staff Safety

• Strongly encourage staff members who are sick to stay home, particularly those who have tested positive or are showing COVID-19 symptoms. Sick staff members should not return to work until the criteria to discontinue home isolation are met, in consultation with healthcare providers and state and local health departments. Staff who have recently had close contact with a person with COVID-19 should also stay home and monitor their health. The U.S. Centers for Disease Control and Prevention (CDC) has recommendations sick people should follow.
• Send home staff experiencing symptoms during work hours.
• Assign vulnerable workers alternate duties that minimize their contact with children, families, and other employees, if possible.
• Make available and ensure the use of cloth face coverings per CDC recommendations. Vehicle operators should wear a cloth face covering only if it will not interfere with safe driving. Cloth face coverings should not be placed on children under age 2, anyone who has trouble breathing, or is unconscious, incapacitated, or otherwise unable to remove the mask without assistance.
• Make available and ensure the use of hand hygiene supplies per CDC recommendations. Key times to clean hands:
  • Before and after eating, preparing, or handling food and drinks
  • After using the toilet
  • After coming in contact with bodily fluid
  • After blowing your nose, coughing, or sneezing
  • After handling garbage
  Additional times to clean hands:
  • Before and after work shifts and breaks
  • After touching frequently touched surfaces, such as handrails
  • After putting on, touching, or removing cloth face coverings

Use of Head Start Vehicles During Periods of Service Interruption

Based on public health guidance, programs may temporarily stop regular program operations, including center-based, family child care, and home-based services. During this time, to the extent possible, employees should continue to engage families and deliver critical services remotely. Programs should continue to provide children with supplies they would receive normally through the program, such as diapers, formula, snacks, meals, and learning supplies.

When programs use agency vehicles to transport food and supplies, they should:

• Minimize contact between vehicle operators and other staff, children, and families as they load and deliver supplies.
• Make available and ensure the use of cloth face coverings and hand hygiene supplies, as described above. Ensure staff maintain at least 6 feet (about two adult arms' length) between each other and families receiving supplies.

Use of Head Start Vehicles to Provide Transportation Services for Children

For programs that are currently operating:

• Minimize contact between vehicle operators and other staff. If possible, stay at least 6 feet from other people.
• Make available and ensure the use of cloth face coverings and hand hygiene supplies as described above.
• Conduct a health check of all children and staff before they board the vehicle. Do not transport individuals with a fever of 100.4ºF (38ºC) or above or who show other signs of illness. Do not transport individuals who have been in close contact (within 6 feet) of someone who has tested positive for, or is showing symptoms of, COVID-19. Consider training and equipping bus monitors to use a non-contact thermometer.
• Position children as far apart as possible, preferably 6 feet apart, with one child per bench and no consecutive rows. If children are coming from the same home, they may sit together. If possible, ensure children sit 6 feet away from the vehicle operator.
• Reroute or stagger bus runs, as needed, to keep group size small and minimize potential exposure between children.
• If possible, keep class groups together on bus runs to minimize potential exposure between different groups of children.
• Use visible cues, such as stickers on the floors, to guide children and offer gentle prompts to help them understand the new protocols. Remember that young children do not understand the need for physical distancing. They rely on adults for their safety and care.
• Vehicle operators should avoid touching surfaces often touched by bus passengers, to the extent possible. Staff should use gloves if touching surfaces contaminated by body fluids.

Fluctuating Service

Programs should check state and local health department notices daily about COVID-19 transmission and mitigation levels in the area and adjust operations accordingly. As community conditions continue to change, some programs may need to adjust their program operations and services.

Based on local data and guidance or directives, programs should be prepared to stagger routes, reduce bus runs, or end bus runs temporarily. Programs should engage staff and families when making changes to transportation policies.

Clean Vehicles Between Each Use

Programs should clean and disinfect vehicles between each use pursuant to CDC's recommended process using products that are U.S. Environmental Protection Agency-approved for use against the virus that causes COVID-19. Be sure to thoroughly clean and disinfect commonly touched surfaces. Ensure safe and correct use of cleaning and disinfection products, including storing products securely away from children. Cleaning products should not be used near children. Staff should ensure there is adequate ventilation when using these products to prevent children or themselves from inhaling toxic vapors.

• For hard and non-porous surfaces inside the vehicle (e.g., hard seats, arm rests, door handles, light and air controls, doors, windows), clean with detergent or soap and water if the surfaces are visibly dirty, prior to disinfectant application.
• For seatbelts, and other child safety restraints, programs must employ methods and products that are effective on COVID-19 and safe for use with the restraint system, particularly seatbelt webbing. Chlorine- or ammonia-based solutions may cause deterioration of safety restraint components and cannot be used. For cleaning guidelines, consult the vehicle or restraint system manufacturer.
• For soft or porous surfaces (e.g., fabric seats), remove any visible contamination and clean with appropriate cleaners indicated for use on these surfaces.

Refer to the CDC for additional information, particularly:

• Interim Guidance for Administrators of US K–12 Schools and Child Care Programs
• Guidance for Child Care Programs That Remain Open
• Child Care Decision Tool
• Reopening Guidance for Cleaning and Disinfecting Public Spaces, Workplaces, Businesses, Schools, and Homes
• What Bus Transit Operators Need to Know About COVID-19

Please stay in touch with your program specialist as you plan and provide program services.

Thank you for your work on behalf of children and families.

Dr. Deborah Bergeron