By Patti Greenstein, Consultant and Trainer
This year, the Office of Head Start (OHS) revised the FY2020 Focus Area 2 (FA2) Monitoring Protocol to include an increased focus on the area of ERSEA (eligibility, recruitment, selection, enrollment, and attendance). As OHS explained during the FY2020 Monitoring Kickoff Webinar, the idea was to identify an area for grantees to think about and “do better.”
As grantees receiving monitoring reviews over the last several months have been preparing for and participating in reviews, we have been thinking about the lessons learned through that preparation and experience that are relevant to all grantees working to ensure compliance at the highest level and mitigate the risk of any potential ERSEA related findings or challenges. Below are responses to some of the questions we often get asked about monitoring and ERSEA systems.
I think our ERSEA systems are pretty strong. Do I need to do anything?
Yes. We recommend that all programs, even those with robust systems in place, review their systems, policies, and procedures to ensure they are comprehensive and that they reflect all of your current day-to-day practices. For example, have you made modifications over time to how you document homelessness when determining eligibility but forgotten to update your policies and procedures to reflect those changes? Ensuring all policies and procedures are up to date is a proactive way to continue to ensure compliance while supporting staff (and especially new staff!) and ensuring you have the necessary supports in place for monitoring job performance.
We think our ERSEA systems are comprehensive but worry we might be missing something. What are some specific areas that we should be focusing on?
Based on our work with programs, we have found the following areas to be the most challenging and/or overlooked:
- Developing effective systems for documenting homelessness and self-declarations of no income
- Developing, implementing, and tracking a system for validating the accuracy of the initial eligibility determinations. How do you monitor the work of frontline staff who determine eligibility to ensure it is done correctly?
- Establishing policies and procedures for actions to be taken if/when staff are found to be violating eligibility determination regulations
- Developing a waiting list that ranks children according to selection criteria and, if applicable, can be sorted by criteria such as location and/or program option
- Developing and implementing policies and procedures for working with over-income families to ensure slots are available for the most vulnerable children and families
- Developing, implementing, and monitoring policies and procedures to guide a transition from a paper-based data collection and management system to data management software or utilization of a combination of both (e.g., which data is entered and stored where? What is scanned into the software? What are the systems for quality control? How often is all of this monitored?)
Is there anything that really stood out in the modifications to the FY2020 FA2 Monitoring Protocols that we should be aware of as it relates to ERSEA?
The revisions to the protocol in the area of ERSEA provide valuable insight into what OHS is focusing on in this important area. Three items worth highlighting are the inclusion of questions related to processes for working with over-income families (to ensure spaces are available to the children and families who need them most), the focus on tracking and filling vacancies (not only to maintain funded enrollment but the processes behind that outcome), and the embedding of ongoing monitoring in this area specifically as it relates to a system for validating the accuracy of eligibility determinations.
We suggest everyone review the protocol, the Head Start Program Performance Standards (HSPPS), and the advance copy of the 2020-2021 PIR form together to ensure your ERSEA systems are fully compliant and that you are collecting and tracking all required data.
Foundations for Families’ consulting services include management system review, particularly ERSEA, and technical assistance as well as federal review preparation, in addition to a wide variety of customizable services for Head Start/Early Head Start programs. If we can be of assistance to your program, please contact us to learn more.