Jane Hanson shares her insights on how the November 2023 Notice of Proposed Rulemaking from OHS could impact your wage study, where to find reliable wage data, and why making hourly wage comparisons is an important part of your analysis. Ms. Hanson is a Consultant with Foundations for Families specializing in wage comparability studies. Read an earlier interview about wage studies here.
We had the pleasure of presenting our current thinking about wage comparability studies to a number of Head Start grantees at the Region IV Head Start Association Annual Training Conference & Expo. While we were in Atlanta, we heard from agencies that are still struggling to recruit and retain staff. Many programs are stuck in a challenging cycle – they don’t have enough teachers to open all their classrooms, and their current wages are making it difficult to recruit and retain qualified staff. If this cycle goes on long enough, the program can become underenrolled and even end up in the Full Enrollment Initiative.
Reducing enrollment numbers through a Change in Scope may allow programs to free up enough money to increase staff compensation. But that requires a wage comparability study to pinpoint competitive wages for staff in your area. With that information, programs can create a realistic budget to help attract and retain qualified staff.
Our wage studies are grounded in the wage comparability guide provided by the Office of Head Start (OHS). Here are a few things to consider as you embark on a wage study to support your agency.
Wages and the Notice of Proposed Rulemaking
Last November the Office of Head Start released a Notice of Proposed Rulemaking (NPRM) as the result of the April 2023 Executive Order (EO) on Increasing Access to High-Quality Care and Supporting Caregivers. The EO directed agencies to make efforts to improve jobs and support for caregivers: “the Secretary of Health and Human Services shall implement strategies to encourage comparability of compensation and benefits between staff employed by Head Start grant recipients and elementary school teachers.” OHS subsequently released an NPRM with new language about wages for Head Start employees.
Here are four key points about wages from the NPRM:
- Programs must make progress toward pay parity for Head Start education staff with kindergarten through third grade teachers in local or neighboring school districts.
- Programs must update or establish a pay scale for all staff.
- Programs must establish a minimum pay floor to ensure all staff receive wages sufficient to cover basic costs of living in the geographic area.
- Programs must promote wage comparability across Head Start Preschool and Early Head Start positions for staff with similar qualifications and experience.
And these are Foundations for Families’ takeaways:
- Making progress towards pay parity means that Head Start programs need to start closing the wage gap for their teachers and education staff. While programs will not be required to pay HS/EHS teachers the same wages as elementary school teachers, programs need to know these salaries in order to set goals. Under the proposed rule, if there is a preschool program in your local school district, your teachers’ wages must be comparable to these wages.
- If your program doesn’t have a pay scale for all staff yet, it’s time to create one. Also called a salary schedule or step chart, a pay scale will differentiate levels among staff members, and each level will have a pay range. Pay scale pages are determined by an employee’s responsibilities, qualifications, and experience. A pay scale will help your organization budget more effectively.
- While the NPRM does not point to a specific dollar amount for the minimum pay floor, you should be familiar with the living wage in your region so you know the basic cost of living for your staff. The living wage is a good basis for establishing minimum pay for your area.
- Promoting wage comparability means that it is time to pay the same wages to Head Start and Early Head Start Teachers with the same qualifications.
With these proposed rules, OHS is sending everyone a clear message about the future of wages for Head Start staff. Right now, it’s up to individual programs to figure out how to make these numbers work. If the proposed rules are finalized as written, then wage requirements go into effect in August 2031 – seven years from now.
Where Can I Find Reliable Wage Data?
In our experience, it can be challenging and time consuming to collect wage data by asking your peers (or competitors) to share salary information through a survey. We often turn to publicly available surveys to find comparable wage estimates. The U. S. Bureau of Labor Statistics Occupational Employment and Wage Statistics (OEWS) is a nationwide survey of more than 800 occupations. Wage data is presented by Metropolitan Statistical Area (MSA). Look up the counties in your service area here to identify your MSA. With that information, you can use the OEWS query system to look up occupations that match your job descriptions.
In addition to this national database, consider the NonProfit Times Salary and Benefits Report for comparable nonprofit wages, or the Center for Community Futures for Head Start and Community Action Agency wages. Although these studies are not free, they are publicly available. You may also be able to participate in a wage survey being conducted by your state Head Start Association, United Way, or other local organization. Usually, in exchange for your organization’s wage data, you will receive the results of the survey.
Why You Should Compare Hourly Wages, not Annual Wages
The OHS wage comparability guide directs agencies to compare hourly wages as part of the study, so that wage comparisons are “apples to apples.” We have found that comparing wage data for public school teachers can be challenging, as they receive an annual salary, not an hourly wage.
As you can see in the example below, even when teachers are paid the same annual amount, that doesn’t mean they earn the same hourly wage. This is why hourly wage comparisons are vital to your study.
| Who? | Hours/ Day | Days/ Year | Annual Hours | Annual Earnings | Hourly Rate |
| Public School Teacher – 9 months | 7 | 194 | 1372 | $40,000 | $29.15 |
| Head Start Teacher – 9 months | 8 | 194 | 1552 | $40,001 | $25.77 |
| Public School Teacher-10 months | 7 | 216 | 1512 | $40,000 | $24.69 |
| Head Start Teacher – 10 months | 8 | 216 | 1728 | $40,000 | $23.15 |
| Early Head Start Teacher – 12 months | 8 | 260 | 2080 | $40,000 | $19.23 |
At $40,000 a year, the public school teacher working for just 9 months is making $29.15 an hour, while the Early Head Start teacher working 12 months a year is making just $19.23 an hour. That is a difference of more than $10 an hour, even though they are making the same amount of money in a year.
The bottom line here is that annual program duration (hours per day X days per year, or hours per week X weeks per year) makes a big difference in hourly pay. If your program keeps losing teachers to the public school system – even after you matched their annual salaries – this could be part of the reason why.
What next?
At the end of the day, wage studies are part of a series of actions included in the continuous improvement process – a community assessment, self-assessment, review of your service delivery model, and more. If you are considering a Change in Scope this year, a recent wage study will be required.
We encourage you to explore Foundations for Families’ Consulting Services. If your program needs assistance conducting a wage and benefits comparability study, please be in touch. Our team of consultants will work with your program to determine a process, timeline, and approach that is the best fit for your needs.
Thank you.
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