Earlier this month the Office of Head Start (OHS) released a request for comment related to the Designation Renewal System (DRS). OHS is interested to hear public comments about changes they are considering making to the CLASS condition of DRS. Per the request for comment the changes include:
- Remove the “lowest 10 percent” provision of the CLASS condition described in 45 CFR 1304.11(c)(2).
- Increase the minimum threshold described in 45 CFR 1304.11(c)(1)(i) for the Emotional Support domain from 4 to 5.
- Increase the minimum threshold described in 45 CFR 1304.11(c)(1)(ii) for Classroom Organization from 3 to 5.
- Remove the minimum threshold for the Instructional Support domain described in 45 CFR 1304.11(c)(1)(iii) and instead provide authority for the Secretary to set an absolute minimum threshold for the Instructional Support domain, considering the most recent CLASS data, by August 1 of each year to be used for CLASS Reviews conducted in the following fiscal year (October 1 through September 30).
As you know, DRS was put in place to ensure the delivery of high-quality Head Start and Early Head Start programs. The programs that are deemed to not be providing high-quality comprehensive services are required to compete for continued funding if they fall into one of the designation categories. Having a score on CLASS in the lowest 10% among agencies monitored (or below CLASS minimum thresholds for any domain) is one of those conditions. OHS shared in the request for comment that there are two main reasons that they’re considering changing the CLASS designation: the 10% threshold “may not be optimally targeting the grantees for competition with the lowest measures of classroom quality” and the delay between CLASS completion and grantees finding out their designation created a great degree of uncertainty for agencies.
OHS describes the lag related to identifying and then notifying grantees in the lowest 10%, and we’ve seen this uncertainty as grantees await the CLASS analysis to take place each year. It seems that by removing the 10% threshold and raising the threshold for Emotional Support and Classroom Organization we may see fewer grantees designated to compete for funds due to CLASS scores. The unknown is the Instructional Support threshold, which as stated in the request for comments would be set by August 1 each year.
What has been your experience with DRS? Has your agency had to enter open competition due to a CLASS score being in the lowest 10%? OHS suggests that their proposed changes will increase transparency and make the process more straightforward for grantees. Do you agree? What concerns do you have?
If you’re interested in submitting comments to OHS make note that they must be submitted by February 6, 2018. Commenters are directed by OHS to www.regulations.gov to submit comments, but regulations.gov isn’t always easily navigable. The easiest way to find this comment opportunity is to search “CLASS Condition of the Head Start Designation Renewal System” on regulations.gov. When you arrive on the announcement page look for the blue “Comment Now!” button.
Check back for more DRS updates. DRS Round 6 open competitions are expected to post to grants.gov next month. We haven’t seen any recent changes to grants.gov related to DRS since we last posted an updated on November 29. After two delays to the DRS Round 6 Funding Opportunity Announcements being released hopefully the January 17th estimated date holds true!