This year, we’ve highlighted a few strategies to implement a risk mitigation framework in programs. Through a planned approach, your program can identify, minimize, and eliminate risk. One of the most impactful actions your program can take is to improve its system of ongoing monitoring.
Ongoing monitoring is required in Head Start Program Performance Standard (HSPPS) 1302.102 (b) Monitoring program performance and is part of a comprehensive monitoring system. Per HSPPS, Head Start/Early Head Start programs must implement a system of ongoing oversight, and must:
(i) Collect and use data to inform this process;
(ii) Correct quality and compliance issues immediately, or as quickly as possible;
(iii) Work with the governing body and the policy council to address issues during the ongoing oversight and correction process and during federal oversight; and,
(iv) Implement procedures that prevent recurrence of previous quality and compliance issues, including previously identified deficiencies, safety incidents, and audit findings.
Ongoing monitoring builds on a foundation set with policies and procedures for an effective management system, and it informs self-assessment. Clear and comprehensive ongoing monitoring procedures will support improved program quality and may help to identify concerns before they become program findings (e.g., deficiencies).
To most effectively support ongoing monitoring, consider the following questions.
1. Is your ongoing monitoring system clearly defined? Reflect on whether current procedures set timelines for monitoring (e.g., daily, weekly, monthly, annually), identify the person responsible for conducting a monitoring activity, and whether monitoring tools are specified. If any of these areas are not addressed – for each monitoring activity – update the procedure to include this information.
2. Is it documented? In addition to reviewing your program’s current, documented, monitoring procedures, explore monitoring activities that may be happening but are not yet documented. Ongoing monitoring procedures should all be documented and well defined. This is not only best practice for a comprehensive system of ongoing monitoring; it will also support clear expectations for program staff, building on program policies and procedures. Sometimes, there are only procedures for high-level monitoring activities; make sure monitoring activities take place at all levels of the program.
3. Are you monitoring procedures inclusive of any partnerships? Think broadly about where your program defines monitoring procedures. For example, if your program has partnerships (e.g., Early Head Start – Child Care Partnerships), consider agreements/contracts and how monitoring (e.g., frequency, required reporting) is documented and communicated.
4. Is ongoing monitoring integrated/coordinated across content areas or does it “live” in management? Because ongoing monitoring is central to compliance oversight, it should be integrated across content areas. Monitoring procedures should touch all areas of program operations. If monitoring procedures are well defined and documented, as discussed above, clear responsibilities should be in place for staff across program areas.
5. How does it inform the self-assessment? Data from ongoing monitoring should be used as part of a program’s annual self-assessment. Program data is one of the most important inputs into the self-assessment process. And, as discussed, it should be collected across program areas for the most comprehensive and useful set of information to guide program improvements. Identifying trends on an ongoing basis – areas of strength and need – will make the pre-design phase of the self-assessment more efficient, as your key questions for exploration may already be identified.
As your program considers these five questions, keep in mind that an intentional focus on ongoing monitoring is a way to leverage regular, required, program activities to reduce risk and improve program quality.
Foundations for Families’ Consulting Services include providing assistance for the development or improvement of policies and procedures, monitoring protocols, and data management systems. Our team of consultants is highly skilled at implementing services remotely. If your program is interested to learn more about how we might support your program, please contact us.
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