Comment on FR Doc # 2010-23583

West Central Missouri Community Action Agency HEAD START PROGRAM RESPONSE TO ACF’S NOTICE OF PROPOSED RULEMAKING: Attention: Colleen Rathgeb Office of Head Start 1250 Maryland Ave, SW Washington, DC 20024 West Central Missouri Community Action Agency (WCMCAA) Head Start supports the idea of a re-competition system for those programs that have shown a lack of integrity or adherence to the mission of Head Start. We support a re-competition system that is focused on the strengthening programs and one that is accountable and fair to all programs across the board. Some concerns regarding the proposed rules are as follows: • Section 1307.3(a) Requiring that there be a set 25% threshold, sets up a fear based environment that overshadows the needed focus on quality services for our children and families. This broad spectrum will eventually drag quality, high performing programs into re-competition. a. Recommendation: That this not be a set number or percentage, but rather programs that have proven to be in need of re-competition. • Section 1307.3(b) Under the seven conditions outlined there is some concern that there is no appeal process allowed prior to a re-competition. For example, when dealing with state licensing rules there are times when the state rule is in conflict with the federal rule. When state licensing requires that a child be removed from the program due to what they feel is ‘bad behavior’ and the Performance Standards require us not to dismiss children from the program. If this were to rise to the level of deficiency, Head Start would ask for the opportunity to appeal this decision. a. Recommendation: That a program be allowed the appeal process prior to a re-competition being considered. • Section 1307.3(b)(1) One or more deficiencies: there is a lack of consistency in the outcomes from the current review process. Allowing for a group of individuals that see your program for one week out of a year, to make such an important call, is concerning. We agree that poor performance is not acceptable, we just ask for process that is less biased and based on an overall performance view. • Section 1307.3(b)(3) Low CLASS scores: WCMCAA Head Start incorporated this tool into our program in 2010. This is a short time frame to expect field staff to be able to incorporate into their teaching and classroom. The outcome measures of the CLASS tool are subjective and can be affected by the presence of a ‘stranger’ within the classroom. • Section 1307.3(b)(4) License revocation: WCMCAA is a large grantee with several locations. Within this agency there are some centers that perform at a higher rate than others. It would be unfair to punish the entire program, if for some reason, one center was deficient. WCMCAA Head Start supports a process that will strengthen Head Start services for children and families. We only ask that the panel consider the negative effects of some of the statements in the proposal that would hinder quality services.