With forty-five Head Start and/or Early Head Start grants recently forecasted on grants.gov, it seems like a number of those may be Designation Renewal System (DRS) Round 6. As we discussed earlier this month, there hasn’t been an announcement yet from the Office of Head Start (OHS) telling us that the forecasted grants are DRS. It also looks like some HS/EHS forecasted grants could be replacement grants. We’re digging into data and taking a closer look at the location of forecasted grants to share an analysis with you. In the meantime, let’s take a closer look at DRS in the new Head Start Program Performance Standards (HSPPS).
DRS appears in Section 1304 Subpart B of the new standards. In the previous standards it appeared in 1307. If you’ve checked out DRS in the new standards the first thing you might notice is that the language and format closely mirrors that of the old standards. Even though the information is the same, the refresh is a good reminder to stay current on all areas of the HSPPS. Or, if you’re new to HS/EHS this will be a useful introduction! We hope that you won’t have to face DRS, but if you do, it will be helpful to be grounded in the purpose and triggers.
What is the purpose of DRS? Section 1304.10 Purpose and scope answers this question precisely:
The Designation Renewal System is established in this part to determine whether Head Start and Early Head Start agencies deliver high-quality services to meet the educational, health, nutritional, and social needs of the children and families they serve; meet the program and financial requirements and standards described in section 641A(a)(1) of the Head Start Act; and qualify to be designated for funding for five years without competing for such funding as required under section 641(c) of the Head Start Act with respect to Head Start agencies and pursuant to section 645A(b)(12) and (d) with respect to Early Head Start agencies.
What isn’t DRS? Sometimes OHS terminates HS/EHS grants with cause, and other times HS/EHS grantees voluntarily terminate their grant. In these cases, there is a separate competition to replace the grantee. This is not DRS, as noted in Section 1304.10.
What are the triggers for DRS? If you’re looking for a list of the triggers for DRS you will find them in Section 1301.11 in the new standards. Summarized from Section 1301.11, the seven triggers for DRS include the following (see the standards for additional detail):
- One or more deficiencies on a single program review
- Not establishing school readiness goals or not taking steps to achieve the school readiness goals
- Having an average score across all classrooms observed below established minimum thresholds on any of the three CLASS: Pre-K domains from the most recent observations (minimum threshold for Emotional Support = 4; minimum threshold for Classroom Organization = 3; minimum threshold for Instructional Support = 2), or having an average CLASS score across all classrooms observed that is in the lowest 10 percent
- Revocation of license by state or local licensing agency
- ACF has suspended the program and the suspension has not been overturned or withdrawn
- Agency is debarred from receiving federal or state funds from any federal or state department or agency or has been disqualified from the Child and Adult Care Food Program (CACFP)
- Agency has been determined to be at risk of failing to continue functioning as a going concern
What happens my agency is identified for DRS? If you want to continue to provide HS/EHS services, you will need to recompete for funding. Section 1304.13 states that an agency will need to submit an application that shows it is the “most qualified entity to deliver a high-quality and comprehensive Head Start or Early Head Start program.” The timeline for HS/EHS funding competitions tends to be around 8 weeks, but often these grants are forecasted well in advance as is the case with those we saw posted on July 11, 2017.
What can I do now? Even if the funding opportunity announcement (FOA) for your grant hasn’t been posted yet, there is still much you can do now to prepare. You might consider the following: determine the team who will inform and draft your application, sketch out a timeline for completion of the application, make a list of data and resources you’ll need to gather, and determine if there are partners or stakeholders you will need to engage in your information gathering or application development.
Next week, we’ll provide additional detail about what you can do right now to prepare for a FOA that may be released this fall. You can make your application process easier by using your ‘pre-FOA’ time strategically.