oversight

Head Start: Better Data and Processes Needed to Monitor Underenrollment

Published by the Government Accountability Office on 2003-12-04.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States General Accounting Office

GAO             Report to Congressional Requesters




December 2003
                HEAD START

                Better Data and
                Processes Needed to
                Monitor
                Underenrollment




GAO-04-17
                                                December 2003


                                                HEAD START

                                                Better Data and Processes Needed to
 Highlights of GAO-04-17, a report to           Monitor Underenrollment
 Congressional Requesters




 Head Start, created in 1965, is                The extent to which Head Start programs have enrolled fewer children than
 designed to prepare low-income                 they are funded to serve is unknown because the Administration for
 preschool children for school by               Children and Families (ACF) does not collect accurate national data and
 providing a comprehensive set of               does not monitor underenrollment in a uniform or timely manner. While
 early child development services               some modest fluctuations in enrollment are to be expected, regional offices
 primarily through community-
 based organizations. Over the last
                                                had differing definitions of unacceptable underenrollment, and the
 decade there have been a number                approaches they used to identify it were either not timely or not systematic.
 of changes in Head Start’s                     The regional offices identified a total of about 7 percent of grantees as
 operating environment, including a             unacceptably underenrolled in 2001-02, significantly less than the percentage
 decrease in the number of poor                 of grantees reporting enrollment ratios below 100 and 95 percent on ACF’s
 children; an increase in the                   survey of grantees (see chart below). As a result of differences in regional
 number, size, and scope of other               definitions of what constitutes an unacceptable level of underenrollment,
 federal and state early childhood              grantees with similar levels of underenrollment may be treated differently
 programs; and an expansion in                  across regions.
 Head Start spending and
 enrollment. Given this                         ACF regional officials and officials of underenrolled Head Start grantees
 environment, GAO was asked to
 determine (1) what is known about
                                                often cited a mixture of factors that made it difficult to achieve full
 the extent to which Head Start                 enrollment, including increased parental demand for full-day child care, a
 programs are underenrolled,                    decrease in the number of eligible children, facilities-related problems, and
 (2) ACF regional officials’ and                more parents seeking openings with other sponsors of early education and
 Head Start grantees’ views on what             care.
 factors contribute to
 underenrollment, and (3) what                  ACF national and regional offices and grantees all report taking action to
 actions ACF and grantees have                  address underenrollment through the issuance of guidance, increased
 taken to address underenrollment.              monitoring by regional offices, and more aggressive outreach attempts by
                                                grantees. The ACF national office issued a memo in April 2003 that
                                                instructed regional offices to address underenrollment with a variety of
 GAO recommends that the                        measures depending on its causes. While this guidance was clear on the
 Secretary of HHS direct ACF to                 actions to be taken, it lacked clear criteria for prioritizing grantees for
 (1) ensure the accuracy of national            corrective actions. Also, while many grantees we spoke with had taken steps
 enrollment data, (2) develop a                 to address underenrollment, some told us of their concern to maintain total
 standard criterion for regional                funded enrollment levels, even as they were converting unfilled part-day
 offices to use in identifying                  openings to full-day. While 18 of the 25 grantees we contacted had made
 grantees whose underenrollment                 progress toward full enrollment, others cited continuing problems.
 merits action, (3) develop an
                                                Percentage of Underenrolled Grantees Using Three Different Definitions
 additional enrollment measure that
 takes into consideration the
 different levels of service provided            Less than 100% enrolled                                                                                   57
 by full-day and part-day programs,
 and (4) develop a more systematic
                                                  Less than 95% enrolled                                                                33
 process for regional offices to
 collect reliable enrollment data
 during the program year.                         Regionally identified as
                                                                                                7
                                                         "unacceptable"
www.gao.gov/cgi-bin/getrpt?GAO-04-17.
                                                                                  0                 10           20              30             40    50    60
To view the full product, including the scope
and methodology, click on the link above.                                          Percentage
For more information, contact Marnie S.           Source: GAO analysis of ACF regional office survey responses and Program Information Report data.
Shaul at (202) 512-7215 or shaulm@gao.gov.
Contents


Letter                                                                                          1
                       Results in Brief                                                         2
                       Background                                                               4
                       The Extent to Which Head Start Programs Are Underenrolled is
                         Not Known                                                            11
                       Regional and Grantee Officials Often Cited Combinations of
                         Factors as Responsible for Underenrollment                           18
                       ACF and Grantees Use a Variety of Approaches to Address
                         Underenrollment                                                      22
                       Conclusions                                                            28
                       Recommendations for Executive Action                                   29
                       Agency Comments                                                        30

Appendix I             Scope And Methodology                                                   31



Appendix II            Factors That the ACF Regions and the American
                       Indian-Alaska Native Program Branch Believed
                       Contributed to Underenrollment to a Major or
                       Moderate Extent                                                         33



Appendix III           Factors that Grantees Believed Contributed to
                       Their Head Start Programs’ Underenrollment                              34



Appendix IV            Comments from the U.S. Department of Health
                       and Human Services                                                      35



Appendix V             GAO Contacts and Staff Acknowledgments                                  37

                       GAO Contacts                                                           37
                       Acknowledgments                                                        37

Related GAO Products                                                                           38




                       Page i                                     GAO-04-17 Head Start Enrollment
Tables
          Table 1: ACF Regional Thresholds for Unacceptable Levels of
                   Underenrollment                                                 13
          Table 2: Number of ACF Regions Relying on Various Methods to
                   Oversee Head Start Grantee and Delegate Agency
                   Enrollment Levels                                               14
          Table 3: Percentage of Head Start Grantees, by Region, Reported as
                   Unacceptably Underenrolled by ACF Regions with
                   Unacceptable Underenrollment Thresholds, Compared
                   with PIR Data at the Same Thresholds                            17
          Table 4: Comparison of Region II and III Grantees Identified as
                   Underenrolled                                                   18
          Table 5: April 2003 National Head Start Guidance to ACF Regions          24
          Table 6: Actions by ACF Regions toward Underenrolled Grantees            25
          Table 7: Actions Taken by Interviewed Grantees to Address
                   Underenrollment                                                 27
          Table 8: Factors Cited By ACF Regions as Contributing to
                   Underenrollment to a Major or Moderate Extent, during
                   Program Years 2001-02 and 2002-03                               33
          Table 9: Factors Cited by 25 Grantees as Contributing to Head Start
                   Program Underenrollment, during Program Years 2001-02
                   and 2002-03                                                     34


Figures
          Figure 1: ACF Regions                                                      5
          Figure 2: Distribution of Head Start Services between Full-day and
                   Part-day                                                          6
          Figure 3: Head Start Enrollment Compared with Children Under
                   Age 6 Living in Poverty (1992-2002)                               8
          Figure 4: Growth in Federal Investment in Child Care, Fiscal Years
                   1997 through 2002 in Nominal Dollars                            10
          Figure 5: Comparison of Enrollment Ratios as reported in 2001-02
                   PIR Survey with Unacceptably Underenrolled Grantees as
                   Reported by ACF Regions                                         15




          Page ii                                      GAO-04-17 Head Start Enrollment
Abbreviations

ACF               Administration for Children and Families
CCDF              Child Care Development Fund
HHS               Department of Health and Human Services
PIR               Program Information Report
SSI               Supplemental Security Income
TANF              Temporary Assistance for Needy Families


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Page iii                                               GAO-04-17 Head Start Enrollment
United States General Accounting Office
Washington, DC 20548




                                   December 4, 2003

                                   The Honorable George Miller
                                   Ranking Minority Member
                                   Committee on Education and the Workforce
                                   House of Representatives

                                   The Honorable Dale E. Kildee
                                   House of Representatives

                                   The Honorable Adam Schiff
                                   House of Representatives

                                   Head Start is the largest federal early childhood program, funded at about
                                   $6.7 billion in fiscal year 2003. Created in 1965, Head Start is designed to
                                   prepare poor children for school by providing a comprehensive set of
                                   developmental services. The Administration for Children and Families
                                   (ACF) of the Department of Health and Human Services (HHS)
                                   administers the program. Over the last decade, the Head Start program has
                                   expanded substantially. Between fiscal years 1990 and 2002,
                                   appropriations for Head Start quadrupled from $1.6 billion to over
                                   $6.5 billion, and the number of children served increased by 69 percent
                                   from about 540,000 to over 910,000.

                                   Over the past decade, significant changes to Head Start’s environment may
                                   have created challenges for some Head Start grantees when they tried to
                                   find children to fill funded slots. For example, in the 1990s there was a
                                   decline in welfare caseloads following welfare reform and a decline in the
                                   number of children living in poverty, which may have decreased the
                                   number of children eligible for Head Start. At the same time, the
                                   expansion of other federal and state early childhood programs may have
                                   increased child care options available to Head Start-eligible families.
                                   Consequently, it is possible that federally funded Head Start slots in some
                                   areas remain unfilled even while eligible children elsewhere remain on
                                   waiting lists. Given these potential challenges, and in anticipation of Head
                                   Start’s reauthorization, you asked that we determine the extent to which
                                   Head Start grantees were underenrolled and that we identify potential
                                   causes of underenrollment. As agreed with your offices, our review
                                   addresses: (1) what is known about the extent to which Head Start
                                   programs are underenrolled, (2) what factors may have contributed to



                                   Page 1                                        GAO-04-17 Head Start Enrollment
                   underenrollment, and (3) what actions ACF and grantees have taken to
                   address underenrollment.

                   To determine what is known about the extent to which Head Start
                   programs are underenrolled, we attempted to verify the accuracy of
                   national enrollment data, interviewed ACF headquarters officials, and
                   reviewed federal guidance and regulations on enrollment. Because we
                   determined that national enrollment data were not reliable and because
                   the regional offices have primary responsibility for identifying and
                   addressing underenrollment, we surveyed all 10 ACF regional offices and
                   the American Indian-Alaska Native Program Branch.1 We asked them to
                   identify the threshold below which they consider underenrollment to be
                   unacceptable and to identify grantees with enrollment levels beneath this
                   threshold. To gather further details on the process by which regions
                   identify and address underenrollment, we interviewed regional officials in
                   3 regions—region III (covering Delaware, the District of Columbia,
                   Maryland, Pennsylvania, Virginia, and West Virginia), region V (Illinois,
                   Indiana, Michigan, Minnesota, Ohio, and Wisconsin), and region IX
                   (Arizona, California, Hawaii, Nevada, and the Pacific Insular Areas)—
                   selected on the basis of geographical representation and the number of
                   underenrolled grantees they reported to us. To determine what factors
                   ACF officials and Head Start grantees believed contributed to
                   underenrollment and to identify actions they took to address it, we
                   surveyed all 10 ACF regional offices and the American Indian-Alaska
                   Native Program Branch office, selected and interviewed 25 grantees
                   identified by regional offices as unacceptably underenrolled, and
                   conducted site visits to 3 regional offices listed above. We performed our
                   work between May and October 2003 in accordance with generally
                   accepted government accounting standards. Appendix I further describes
                   our scope and methodology.


                   The extent to which Head Start programs are underenrolled is unknown
Results in Brief   because ACF does not collect accurate national data and its regional
                   offices do not monitor grantee enrollment in a uniform or timely manner.
                   The agency surveys grantees annually to determine national enrollment
                   levels, but we found these data contained many inaccuracies and were



                   1
                    We did not survey the Migrant and Seasonal Program Branch due to the program’s distinct
                   seasonal operating schedule. We generally will refer to the 10 regions and 1 program
                   branch we surveyed as “regional offices” or “regions” throughout the report.




                   Page 2                                                GAO-04-17 Head Start Enrollment
unavailable during the current program year for regional use in monitoring
grantees. Consequently, we could not determine the extent to which Head
Start grantees had enrollments below 100 percent of funded enrollment,
which is how HHS’ regulations define underenrollment. We found that
three regional offices did not set a threshold below which they view
underenrollment as unacceptable, while the other regions use thresholds
ranging from anything below 100 percent to enrollment below 74 percent.
We also found that the approaches regions used to identify unacceptable
levels of underenrollment, such as visits to grantees and reviews of grant
re-funding applications and grantee audits, were either not timely or did
not systematically address underenrollment. Using varying thresholds, the
regional offices identified a total of 170 grantees as unacceptably
underenrolled in program year 2001-02, or about 7 percent of all grantees.
By contrast, using the regulatory definition of underenrollment, survey
data indicated that as many as half or more of the grantees could be
underenrolled. As a result of differences in regional thresholds for what
constitutes an unacceptable level of underenrollment, grantees with
similar levels of underenrollment may be treated differently across
regions.

ACF regional officials and officials of underenrolled Head Start grantees
often cited combinations of factors that made it difficult to achieve
acceptable levels of enrollment, including increasing parental demand for
full-day child care and decreasing numbers of eligible children. Providing
full-day care was said to be more expensive than providing part-day care
because it would require more facility space and staff per child. To make
full-time slots available, many grantees we spoke with were attempting to
expand their facilities or partner with other programs. However, 14 of the
25 grantees we interviewed reported having difficulty acquiring and
developing adequate facilities. Underenrolled grantees and regional
officials also said that underenrollment occurred because parents were
increasingly seeking services from other early education and child care
programs, some of which subsidized care provided by relatives. Other
contributing factors were less frequently cited, such as eligible families
moving from the service area, language and cultural differences between
children’s families and program staff, and weak or inadequate outreach
efforts by grantees to locate eligible families.

ACF national and regional offices and grantees all report taking actions to
address underenrollment, such as issuing guidance, increasing monitoring,
and more aggressively trying to recruit participants. The ACF national
office issued a memorandum in April 2003 that instructed regional offices
to address underenrollment in particular ways depending on its underlying


Page 3                                        GAO-04-17 Head Start Enrollment
             cause. However, the guidance lacked clear criteria for prioritizing which
             grantees should be subject to corrective action based upon their level of
             underenrollment. According to regional officials, the actions they most
             frequently took to address underenrollment were to monitor enrollment
             levels, track improvement efforts, and provide training and technical
             assistance. Many grantees we spoke with have also taken steps to address
             underenrollment, such as increasing their outreach efforts, seeking
             partners to help them provide more full-day service, or increasing the
             availability of full-day slots. Furthermore, some grantees told us of their
             concern to maintain total funded enrollment levels, even as they were
             converting unfilled part-day openings to full day. Consequently, in some
             instances, grantees attempting to convert part-day slots to full-day slots
             said they had to expand facilities or find other child care partners in order
             to serve the same number of children. While 18 of the 25 grantees we
             contacted had made progress toward achieving full enrollment, others
             cited continuing problems.

             To improve ACF’s ability to identify and address underenrollment in a
             more systematic and timely manner, we are making recommendations that
             the agency improve the quality of enrollment data and establish more
             uniform criteria and procedures for identifying and addressing
             underenrollment.


             Head Start was designed to help break the cycle of poverty by providing
Background   comprehensive educational, social, health, nutritional, and psychological
             services to low-income children. Head Start is authorized to serve children
             at any age prior to compulsory school attendance. Originally, the program
             was aimed at 3- to 5-year-olds. A companion program begun in 1994, Early
             Head Start, made these services available to children from birth to 3 years
             of age as well as to pregnant women. Head Start and Early Head Start
             programs are administered by ACF, which funds and monitors more than
             1,500 grantees through its 10 regional and 2 branch offices. (See fig. 1)
             ACF’s national office has responsibility for overseeing and providing
             guidance to the regional offices, as well as for administering and collecting
             annual survey data from grantees.




             Page 4                                         GAO-04-17 Head Start Enrollment
Figure 1: ACF Regions




               X                                                               I

                                  VIII                V                 II


               IX
                                                VII
                                                                                   III


                                                                IV
                                         VI




Source: ACF.



Head Start grantees include community action agencies, school systems,
for-profit and nonprofit organizations, other government agencies, and
tribal governments or associations. Also, many Head Start grantees
provide services by subcontracting with other organizations, known as
delegate agencies. In fiscal year 2002, Head Start grantees served more
than 912,000 children, a 69 percent increase over the number of children
served in 1990. Head Start has traditionally been a part-day, part-year
program, but currently serves more children on a full-day basis, which is
defined as 6 hours or more a day, than on a part-day basis. Approximately
47 percent of children served by Head Start were enrolled in a center-
based full-day program for 6 hours or more a day.2 Less than 20 percent of
children enrolled in Head Start receive 8 hours or more of center-based
services a day. As of 2001-02, about 44 percent of Head Start children were




2
 Center-based programs are those where services are provided to children primarily in
classroom settings.




Page 5                                                 GAO-04-17 Head Start Enrollment
enrolled in a part-day center-based program. Figure 2 shows the
percentages of Head Start services provided on a full-day or part-day basis.

Figure 2: Distribution of Head Start Services between Full-day and Part-day


                                                                   Other
                                 9%



                                            20%                    Center-based full-day greater
          44%                                                      than or equal to 8 hours per day




                                 27%                               Center-based full-day between
                                                                   6 and 8 hours per day



                                                                   Center-based part-day less
                                                                   than 6 hours per day
Source: GAO analysis of 2001-02 Program Information Report Data.



Head Start funds are allotted among the states based on their 1998
allocation and, for funds exceeding that amount, by formula based on the
number of children in each state under the age of 5 from families whose
income is below the federal poverty level.3 Head Start grantees are
required to provide at least 20 percent of annual program funding, which
can include in-kind contributions, such as facilities for holding classes.
During the award process, Head Start grantees receive from ACF regional
officials their level of funded enrollment—the number of children the
grantee is to serve.

Head Start regulations require that at least 90 percent of the children
enrolled in Head Start come from families with incomes at or below the
federal poverty guidelines, from families receiving public assistance, or
from families caring for a foster child. While the poverty guidelines are


3
 For 2003, the federal poverty line for a family of four was $18,400 within the 48 contiguous
states and the District of Columbia. In Alaska and Hawaii, the guidelines were $23,000 and
$21,160, respectively. The poverty guidelines are updated periodically in the Federal
Register, by the U.S. Department of Health and Human Services under the authority of
42 U.S.C. 9902(2).




Page 6                                                                     GAO-04-17 Head Start Enrollment
firm, grantees have some flexibility in determining income eligibility. For
example, grantees can use the 12 months prior to the month the family
applied to Head Start or the previous calendar year as a basis for
determining income eligibility. Also, once a family is determined to be
eligible in 1 program year, it is considered eligible for the subsequent
program year, for a total of 2 years. Additionally, families that participate
in the Temporary Assistance for Needy Families program (TANF) or the
Supplemental Security Income program (SSI)4 or that care for a foster
child are eligible for Head Start services even when family income exceeds
the poverty guidelines. Grantees may fill up to 10 percent of their slots
with children from families that exceed the low-income guidelines.

An enrollment occurs when a Head Start program officially accepts a child
and completes all necessary steps to begin providing services. If a child is
chronically absent and the grantee cannot serve the child in another way,
the child’s slot is considered vacant. Once a slot is vacant, the grantee
generally must fill it within 30 days to be considered fully enrolled.
Consequently, actual enrollments can fluctuate somewhat throughout
funding periods. Head Start regulations require grantees to track program
attendance on a daily basis. However, grantees are asked to annually
report enrollment levels for any 2 months they choose as part of ACF’s
annual Program Information Report (PIR) survey. ACF regions may
require grantees to report enrollment data more frequently.

Head Start regulations require grantees to maintain enrollment at 100
percent of the funded level and regional offices have primary
responsibility for identifying and addressing underenrollment.5 However,
as a practical matter, not all grantees are able to continually sustain
enrollment at the fully funded level. Underenrollment can occur for a
variety of reasons and can vary from month to month in a given program.
Therefore, before deciding that underenrollment is unacceptable and
taking action, the regions take into consideration a variety of factors about
underenrollment, including its level and duration, its causes, and the
actions taken by grantees to address it.


4
 Under TANF, the federal government provides grant funds to states, territories, and tribes
for their programs to assist needy families with children. SSI pays monthly benefits to
people who are age 65 or older or blind or have a disability and who do not own much or
have much income.
5
 Enrollment ratio is the ratio of actual enrollment to funded enrollment; therefore, a
grantee with 100 funded enrollment slots and an actual enrollment of 95 has an enrollment
ratio of 0.95, or 95 percent.




Page 7                                                  GAO-04-17 Head Start Enrollment
The number of children eligible for Head Start services on the basis of
being below the poverty line has decreased over the last decade, falling
from over 6 million children in 1992 to just over 4 million in 2000. By 2002,
the number of children under age 6 living in poverty had increased to
nearly 4.3 million. Over the same period, Head Start enrollment has
increased to over 910,000 children—a level that is significantly below the
number of children living in poverty. (See fig. 3.) However, it should be
noted that Head Start predominately serves children ages 3 and 4, who
make up only a portion of all children under 6 living in poverty.

Figure 3: Head Start Enrollment Compared with Children Under Age 6 Living in
Poverty (1992-2002)
Number of children
7,000,000


6,000,000


5,000,000


4,000,000


3,000,000


2,000,000


1,000,000


         0
          1992       1993       1994        1995       1996       1997       1998       1999       2000        2001          2002
             Years

                       Head Start enrollment
                       Children under age 6 and in poverty
Source: Poverty data are taken from the Census Bureau's Current Population Survey, Annual Social and Economic Supplements.
Enrollment figures are from ACF's PIR data.

Note: Data on number of children under age 6 living in poverty includes only those residing with a
relative.


In addition, during the 1990s, the number of other federal and state
programs offering services to low-income children increased substantially.
For example, welfare reform in 1996 greatly expanded the Child Care
Development Fund (CCDF) and also allowed TANF funds to be used for




Page 8                                                                        GAO-04-17 Head Start Enrollment
child care.6 For fiscal years 1997 through 2002, these programs increased
their investment in children; CCDF spending increased from $2.5 billion to
$6.4 billion and TANF spending on child care increased from $13 million to
$1.6 billion.7 (See fig. 4.) On the state level, one study cited by the
Congressional Research Service (CRS) found that state spending on
prekindergarten programs increased from about $700 million in 1991-92 to
about $1.7 billion in 1998-99.8 Over the same period, the number of
children served by these programs has increased from 290,000 to 725,000.




6
 Other federal programs that support early childhood education for children under 5 years
include Special Education Preschool grants under the Individuals with Disabilities
Education Act, preschool programs under Title I, and Even Start. See Education and Care:
Head Start Key Among Array of Early Childhood Programs, but National Research on
Effectiveness Not Completed, GAO-03-840T (Washington D.C.: July 22, 2003).
7
 CCDF child care funds can be used for families with children up to age 13. In 2000, we
reported that an estimated 70 percent of CCDF funds and 7.5 percent of TANF funds were
used for child care for children under age 5 in fiscal year 1999. See Early Education and
Care: Overlap Indicates Need to Assess Crosscutting Programs. GAO/HEHS-00-78.
Washington D.C.: April 28, 2000.
8
 See Blank, Helen, with Karen Schulman and Danielle Ewin. Seeds of Success, State
Prekindergarten Initiatives, 1998-99. Children’s Defense Fund, September 1999 as cited in
Early Childhood Education: Federal Policy Issues, CRS, (Washington, D.C.: January 27,
2003).




Page 9                                                 GAO-04-17 Head Start Enrollment
Figure 4: Growth in Federal Investment in Child Care, Fiscal Years 1997 through
2002 in Nominal Dollars

Dollars in millions
8,000


7,000


6,000


5,000


4,000


3,000


2,000


1,000


    0
     1997                   1998                   1999                    2000                   2001                     2003
        Years


                  TANF

                  CCDF

Sources: CRS Report, Child Care: Funding and Spending under Federal Block Grants, March 19, 2002 and ACF budget figures.

Note: CCDF amounts include dollars states transferred from their TANF programs to CCDF as
allowed under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. The
amounts shown for TANF include only those TANF funds expended for child care.


Expanding federal and state early childhood programs has increased the
need for coordination to better ensure that services are provided in a
complementary fashion. One way that Head Start encourages coordination
is by requiring all grantees to periodically prepare community assessments
that analyze trends in the number of eligible children in their jurisdictions
and assess the other early childhood services provided in the area. While
grantees are not required to coordinate with other service providers, ACF
has issued guidance encouraging grantees to coordinate with other
providers in order to provide more full-day services. Also, in recent years,
ACF has used some Head Start expansion money to build partnerships
with child care providers to deliver full-day, full-year services. As another
way to increase coordination, HHS has been authorized since 1998 to
provide additional funds to states to encourage such collaboration.




Page 10                                                                      GAO-04-17 Head Start Enrollment
                        The extent to which Head Start programs are underenrolled is unknown
The Extent to Which     because ACF does not collect accurate national data and it does not
Head Start Programs     monitor grantee enrollment in a uniform or timely way. Specifically,
                        national enrollment data contain many inaccuracies and regional offices
Are Underenrolled is    use a variety of thresholds to define “unacceptable” levels of
Not Known               underenrollment.9 Additional approaches used by the regions to identify
                        underenrollment do not systematically address underenrollment or
                        provide timely information. Using varying thresholds, the regional offices
                        identified 170 grantees as unacceptably underenrolled in program year
                        2001-02, or about 7 percent of all grantees. By contrast, the agency’s
                        annual survey data indicated that as many as half or more of the grantees
                        were enrolled at less than 100 percent—the enrollment level grantees are
                        required to maintain under Head Start regulations. Overall, regions’ use of
                        different thresholds for unacceptable underenrollment suggests that
                        regions may treat grantees with similar enrollment ratios differently.


ACF Annual Grantee      ACF’s annual survey of grantees—the only source of nationwide
Surveys Contain         information on grantee enrollment rates—contained many inaccuracies.
Inaccurate Enrollment   The PIR survey, as it is known, requests actual enrollment figures for any
                        2 months that grantees choose to report. When we attempted to verify
Data                    2001-02 PIR enrollment data for 19 of the grantees, we found that 8 had
                        reported erroneously. For 6 underenrolled grantees, we found they
                        underreported their enrollment ratio by an average of 25 percent. We also
                        found that 2 overenrolled grantees had erroneously reported enrollment
                        ratios that were over 200 percent. A similar review by ACF of 75 grantees
                        and delegate agencies10 that had reported particularly high or low
                        enrollment levels found that approximately half had erroneously reported
                        their actual numbers. GAO and ACF found a variety of causes that
                        grantees cited for misreported enrollments, including typographical errors,
                        failure to report children who were enrolled in the home-based or after-



                        9
                         While 100 percent of funded enrollment is required by Head Start regulations, as a
                        practical matter underenrollment can occur as a result of programmatic fluctuations.
                        Consequently, we asked the regional offices to identify the threshold, if any, they used for
                        determining when a grantee’s level of enrollment compared with its total funded
                        enrollment was “unacceptable.” We then asked regional officials to report back to us the
                        grantees they were aware of that fell beneath this threshold.
                        10
                         A delegate agency means a public or private nonprofit organization or agency to which a
                        Head Start grantee has delegated all or part of its responsibility for operating a Head Start
                        program. For the remainder of the report, we will refer to grantees and delegate agencies
                        as grantees only.




                        Page 11                                                   GAO-04-17 Head Start Enrollment
                             school programs, and reporting on 2 months in which enrollment was not
                             their highest.


Regional Monitoring          We found that ACF regional offices employed different criteria and used a
Efforts Employed Varied      variety of data sources and approaches to determine if a grantee is
Criteria and Lacked Timely   underenrolled. Given that regional offices are responsible for identifying
                             and monitoring underenrollment, we asked regional offices to identify
Data                         their operational criterion for an unacceptable level of underenrollment.
                             Of 11 regional offices we surveyed, we found that 3 did not utilize a
                             specific threshold to distinguish between acceptable and unacceptable
                             underenrollment, while the other 8 offices used different thresholds. Each
                             of the 3 regions that did not have a set threshold for “unacceptable”
                             underenrollment indicated that underenrollment was treated on a case-by-
                             case basis that would take into consideration the degree of
                             underenrollment and other factors, including the grantee’s efforts to
                             increase enrollment. For the regions that specified thresholds of
                             “unacceptable” underenrollment, these thresholds ranged from any
                             enrollment ratio below 100 percent in 3 regions to below 74 percent in one
                             region (See table 1.)




                             Page 12                                      GAO-04-17 Head Start Enrollment
Table 1: ACF Regional Thresholds for Unacceptable Levels of Underenrollment

                                                               Thresholds for unacceptable
    ACF region or branch and coverage area                     underenrollment
    Region I                                                   No threshold
    Connecticut, Maine, Massachusetts, New
    Hampshire, Rhode Island, and Vermont
    Region II                                                  No threshold
    New Jersey, New York, Puerto Rico, and U.S.
    Virgin Islands
    Region III                                                 Less than 97 percent
    Delaware, District of Columbia, Maryland,
    Pennsylvania, Virginia, and West Virginia
    Region IV                                                  Less than state averagea
    Alabama, Florida, Georgia, Kentucky, Mississippi,
    North Carolina, South Carolina, and Tennessee
    Region V                                                   Less than 100 percent
    Illinois, Indiana, Michigan, Minnesota, Ohio, and
    Wisconsin
    Region VI                                                  No threshold
    Arkansas, Louisiana, New Mexico, Oklahoma,
    and Texas
    Region VII                                                 Less than 74 percent
    Iowa, Kansas, Missouri, and Nebraska
    Region VIII                                                Less than 95 percent
    Colorado, Montana, North Dakota, South Dakota,
    Utah, and Wyoming
    Region IX                                                  Less than 95 percent
    Arizona, California, Hawaii, Nevada, and Pacific
    Insular Areas
    Region X                                                   Less than 100 percent
    Alaska, Idaho, Oregon, and Washington
    American Indian-Alaska Native Program Branch—              Less than 100 percent
    23 of 50 states
Source: GAO survey of ACF regional offices and ACF.
a
 State average in region IV refers to the average enrollment level of all Head Start grantees for each
state within the region.


ACF regional offices reported that they identify unacceptable
underenrollment primarily by visiting grantees every 3 years and also by
engaging grantees in periodic dialogue. More than half of the regions also
said that they relied heavily on PIR data and on their review of grant-
refunding applications. Finally, 5 regions indicated that they rely to a great



Page 13                                                        GAO-04-17 Head Start Enrollment
extent on their reviews of annual audits of grantees. Table 2 presents the
extent to which regional offices rely on various approaches to identify
underenrollment.

Table 2: Number of ACF Regions Relying on Various Methods to Oversee Head
Start Grantee and Delegate Agency Enrollment Levels

                                                           Extent relied upon
                                                Great or                        Some, little,
                                              very great          Moderate           or no
 On-site monitoring                                  11                   0                  0
 Periodic dialogue with grantees                     10                   1                  0
 Review of grant re-funding
 application                                          8                   2                  1
 Analyze PIR data                                     7                   3                  1
 Review of annual audits                              5                   3                  3
Source: GAO survey of ACF regional offices.


Each of the approaches used by regional offices to monitor enrollment is
lacking in timeliness or accuracy, or is not used systematically to monitor
underenrollment. For example, in 3 regions we visited, ACF officials
commented that while the on-site visits are designed to systematically
assess underenrollment, the visits do not provide timely information
because they are only conducted every 3 years. Conversely, while most
regional officials we surveyed said that they rely on periodic discussions
with grantees to identify underenrolled grantees, regional officials we
visited said that they do not systematically discuss enrollment levels with
grantees during this process. Officials from one region we interviewed also
said that enrollment data included in grant re-funding applications are not
informative because the data are based on forecasts. Also, while surveyed
officials listed the PIR data as a key resource, those we spoke with said it
was not necessarily accurate or timely due to the fact that data arrive after
the subsequent program year has begun. Finally, regarding the use of
annual audits, regional officials we spoke with said they did not always
receive them for all grantees and that the audits they did receive do not
necessarily comment on grantee enrollments.11



11
 Currently, under the Single Audit Act any state or local government or nonprofit
organization that spends $300,000 or more per year ($500,000 for fiscal years ending after
December 31, 2003) in federal funds must have its financial statements, internal controls,
and compliance with federal laws and regulations audited.




Page 14                                                     GAO-04-17 Head Start Enrollment
National Data on the        Applying a range of underenrollment thresholds to national data indicates
Extent of Underenrollment   that a higher percentage of grantees may be underenrolled than what was
Differs from Regionally     reported to us by regional offices. Regional offices, using a range of
                            enrollment thresholds, reported to us that about 7 percent of grantees
Reported Data on Number     were unacceptably underenrolled. Comparatively, PIR survey data
of Unacceptably             indicated that more than 50 percent of Head Start grantees had enrollment
Underenrolled Grantees      ratios below 100 percent—the regulatory definition of fully enrolled. PIR
                            data also showed a significantly higher proportion of grantees—33
                            percent—reported enrollment ratios below 95 percent than the 7 percent
                            of grantees reported as unacceptably underenrolled by the regional
                            offices. Finally, PIR data showed that a similar proportion of grantees—
                            about 9 percent—reported an enrollment ratio below 80 percent as the
                            7 percent of unacceptably underenrolled grantees reported to us by the
                            regions. (See fig. 5.)

                            Figure 5: Comparison of Enrollment Ratios as reported in 2001-02 PIR Survey with
                            Unacceptably Underenrolled Grantees as Reported by ACF Regions

                            Percentage of all grantees
                            60        57


                            50



                            40

                                                  33

                            30



                            20



                            10                                  9
                                                                           7


                             0
                                                  5%
                                    %




                                                               0%




                                                                        nti y
                                                                               d
                                                                     ide nall
                                                                           fie
                                    00



                                              <9




                                                           <8
                                 <1




                                                                       gio
                                            PIR




                                                         PIR
                              PIR




                                                                    Re




                            Source: GAO analysis of ACF regional office survey responses and PIR data.



                            The portion of grantees that regions reported as unacceptably
                            underenrolled differed from what would have been identified by applying
                            the regional threshold to national PIR data. When compared with the
                            percentage of unacceptably underenrolled grantees reported by regions,



                            Page 15                                                                      GAO-04-17 Head Start Enrollment
PIR data show larger percentages of grantees below these thresholds for
each region that specified a threshold. This was true even in regions that
indicated they relied on PIR data to a great or very great extent. (See table
3). For example, region V, using a threshold of 100 percent for
unacceptable underenrollment, reported to us that slightly less than 2
percent of its grantees were unacceptably underenrolled in 2001-02. PIR
data from that same year indicate that about 62 percent of region V
grantees had enrollment ratios less than 100 percent—a difference of 60
percentage points from what was reported to us. In fact, only regions III
and VII, of the 7 regions in table 3 with clearly defined thresholds for
unacceptable underenrollment, reported to us a percentage of
unacceptably underenrolled grantees that was within 10 percentage points
of what PIR data show using the same threshold. While we do not think
that PIR data are reliable for reporting national enrollment figures, the
regional offices based what they reported to us in part on their review of
PIR data.




Page 16                                        GAO-04-17 Head Start Enrollment
Table 3: Percentage of Head Start Grantees, by Region, Reported as Unacceptably Underenrolled by ACF Regions with
Unacceptable Underenrollment Thresholds, Compared with PIR Data at the Same Thresholds

                                                                                                                                 Percentage of grantees
                                                                                                                                    reporting enrollment
                                                                                        Percentage of                                  ratios at less than
                                                                                    grantees reported                                 regionally defined
                                            Regionally defined                      by ACF regions as    Extent to which                    unacceptable
                                            unacceptable                           being unacceptably    regional office                underenrollment
                                            underenrollment                           underenrolled in   reported relying on    threshold using 2001-02
 Region/program branch                      threshold                                         2001-02    PIR data                              PIR survey
 Region V                                   Less than 100 percent                                  1.7   Moderate                                      62
 Illinois, Indiana, Michigan,
 Minnesota, Ohio, and
 Wisconsin
 Region X                                   Less than 100 percent                                 13.6   Great                                       64.8
 Alaska, Idaho, Oregon, and
 Washington
 American Indian-Alaska                     Less than 100 percent                                 44.5   Great                                       59.8
 Native Branch – 23 of 50
 states
 Region III                                 Less than 97 percent                                  14.3   Very great                                  21.4
 Delaware, District of
 Columbia, Maryland,
 Pennsylvania, Virginia, and
 West Virginia
 Region VIII                                Less than 95 percent                                   4.3   Some                                        26.1
 Colorado, Montana, North
 Dakota, South Dakota,
 Utah, and Wyoming
 Region IX                                  Less than 95 percent                                   0.9   Moderate                                    33.8
 Arizona, California, Hawaii,
 Nevada, and Pacific Insular
 Areas
 Region VII                                 Less than 74 percent                                   2.2   Great                                        8.2
 Iowa, Kansas, Missouri,
 and Nebraska
Source: GAO analysis of survey responses from ACF regional offices and PIR data.



Differing Definitions of                                        As a result of differences in regional definitions of what constitutes an
Underenrollment Create                                          unacceptable level of underenrollment, grantees with similar levels of
Potential for Uneven                                            underenrollment may be treated differently across regions, particularly in
                                                                areas without a defined threshold. Regional offices reported to us that
Treatment of Grantees                                           they take a variety of actions to address unacceptable underenrollment,
across Regions                                                  including increased monitoring, technical assistance, and, occasionally,
                                                                enforcement actions, including recouping funds and reducing future grant



                                                                Page 17                                                  GAO-04-17 Head Start Enrollment
                                                                awards. To the extent that differing thresholds affect the identification of
                                                                deficiencies that would lead to these actions, regions may subject grantees
                                                                to different treatment. For example, as shown in table 4, although a higher
                                                                percentage of grantees in region II have enrollment levels below 95
                                                                percent than in region III, according to PIR data (44 percent versus 18
                                                                percent), region II considers only 3 percent of its grantees unacceptably
                                                                underenrolled, while region III considers 14 percent of its grantees
                                                                unacceptably underenrolled. This discrepancy may be attributable to the
                                                                fact that region II lacks a threshold for defining unacceptable enrollment,
                                                                while region III has set a threshold of 97 percent. As a result, more
                                                                grantees in region III have been subject to monitoring and enforcement
                                                                actions.

Table 4: Comparison of Region II and III Grantees Identified as Underenrolled

                                                                                                                    Region III—Delaware, District of
                                                                           Region II—New Jersey, New York,       Columbia, Maryland, Pennsylvania,
                                                                          Puerto Rico, and U.S. Virgin Islands           Virginia, and West Virginia
 Percentage of grantees with enrollment ratio
 below 95% according to PIR                                                                            44.4 %                                17.6 %
 Threshold for unacceptable enrollment                                                            No threshold                        Less than 97%
 Percentage of grantees reported to us by
 region as unacceptably underenrolled                                                                      2.7                                 14.3
Source: GAO analysis of survey responses from ACF regional offices and PIR data.



                                                                ACF regional officials and officials of underenrolled Head Start grantees
Regional and Grantee                                            often cited a mixture of factors that made it difficult to achieve full
Officials Often Cited                                           enrollment, including increased parental demand for full-day child care
                                                                and a decrease in the number of eligible children. Many said welfare
Combinations of                                                 reform has increased the number of working parents, increasing demand
Factors as                                                      for full-day child care and reducing the number of eligible children. Also,
                                                                more than one-half of the grantees we interviewed reported they were
Responsible for                                                 having difficulty acquiring and developing adequate facilities. Meanwhile,
Underenrollment                                                 underenrolled grantees and ACF regional officials also said that
                                                                underenrollment was occurring because more parents were seeking
                                                                services with other early education and child care programs, some of
                                                                which subsidized care with relatives. Other contributing factors, such as
                                                                eligible families moving from the service area, language, and cultural
                                                                differences between children’s families and program staff, and weak or
                                                                inadequate recruiting efforts by the grantees, were less frequently cited.




                                                                Page 18                                            GAO-04-17 Head Start Enrollment
Multiple Factors Often      Many grantees indicated that the combination of multiple factors had
Linked to Underenrollment   fostered underenrollment for their program. Nearly two-thirds of the
                            underenrolled grantees we spoke with cited two or more contributing
                            factors. For example, one northern California grantee believed that
                            underenrollment was caused by a decrease in income-eligible children in
                            its area, because the high cost of living and a shortage of affordable
                            housing in the area, and also by the number of families moving from
                            welfare to work. In addition to citing the decrease in eligible children, this
                            grantee expressed a need for more full-day slots, and reported facing
                            increasing competition from day care programs that reimbursed relatives
                            or friends to provide full-time child care. Similarly, one New Jersey
                            grantee experiencing problems acquiring a new facility was also affected
                            by a state supreme court decision requiring free preschool for poor
                            children. Additionally, this grantee felt that it was losing eligible children
                            as a result of families on welfare finding jobs and needing more full-day
                            slots. A commonly cited combination of factors—cited by 8 of the 25
                            grantees we interviewed—was the simultaneous shortage of full-day slots
                            and the movement of families out of welfare and into the workforce.


Increased Demand for        Regional and grantee officials most frequently cited the increased demand
Full-day Care, Facilities   for full-day child care, construction delays and inadequate facilities, and
Problems, and Increased     the increased availability of early education and child care programs as the
                            factors causing underenrollment. Other factors, such as high turnover
Availability of Other       rates and income eligibility criteria were also cited, but less frequently.
Programs Most Frequently    Each of the factors affecting underenrollment that grantees and regions
Cited as Affecting          cited is described in more detail in the following sections. Appendix II lists
Underenrollment             the factors identified by regions as contributing to grantee
                            underenrollment, and appendix III lists factors identified by grantees.

Grantees and Regions Said   Both regional and grantee officials said that the movement of low-income
Movement of Families from   families from welfare to work had contributed to underenrollment. Seven
Welfare to Work Affected    of 11 regions cited the movement of low-income families from welfare to
Enrollment and Increased    work as either a major or a moderate reason for grantees’
Demand for Full-day Care    underenrollments. Similarly, of the 25 grantees we contacted, 11 cited this
                            factor. Regional officials and grantees suggested the movement from
                            welfare to work affected enrollments in two ways. First, as many parents
                            began to work full-time, they increasingly needed full-day care. When
                            Head Start grantees could not meet this need, some eligible families
                            secured child care elsewhere. Second, some families entered work and
                            earned income that disqualified their children from Head Start programs.
                            A number of grantees related specific examples of how the movement
                            from welfare to work affected enrollments. For example,


                            Page 19                                         GAO-04-17 Head Start Enrollment
                                 •   A large grantee in Illinois said that many former welfare recipients who
                                     need full-day child care services no longer qualify for Head Start because
                                     they earn wages just above the Head Start income guidelines or work
                                     rotating schedules to avoid using formal child care services.
                                 •   A grantee in California said that the cost associated with switching to full-
                                     day care sometimes is a barrier to meeting families’ needs.

Construction Delays and              Of the 25 underenrolled grantees we surveyed, 14 reported that difficulty
Inadequate Facilities Affected       acquiring and developing adequate facilities contributed to
Enrollments                          underenrollment. Similarly, over half of the 11 regions reported that
                                     underenrollment was linked to a major or moderate extent to facilities
                                     being completed more slowly than expected. For example, an Eastern
                                     grantee was unable to serve children in need of full-day care because it
                                     lacked classrooms and found it difficult to acquire more space. In the
                                     Midwest, 2 grantees reported that their inadequate facilities kept them
                                     from filling about 1,800 funded slots—43 percent of their funded slots—
                                     even though many eligible families desired Head Start services for their
                                     children. The grantees said that they had difficulty acquiring alternate
                                     facilities: some potential sites were environmentally unsuitable, while
                                     others faced neighborhood opposition. In another case, an American
                                     Indian grantee that had 25 unfilled Early Head Start slots expects to
                                     achieve 100 percent enrollment in the fall of 2003 when a new facility is
                                     scheduled to open.

Other Early Education and            Regional and grantee officials often indicated that competition from other
Child Care Programs Can              early education or child care centers serving low-income preschool
Affect Enrollments                   children contributed to Head Start underenrollment. Seven of 11 regions
                                     cited this factor as a major or moderate contributor to underenrollment,
                                     and 8 of 25 grantees we interviewed identified this factor. In addition, 5
                                     grantees said that a closely related factor also reduced families’ use of
                                     Head Start—the availability of state subsidies to pay relatives or friends
                                     for child care.

                                     Officials in 2 regions provided specific examples of increased availability
                                     of other programs having a negative impact on Head Start enrollment.
                                     According to region V officials, the availability of other programs had a
                                     major impact on a large grantee in Michigan when the public school
                                     system increased its preschool programming and as a result increased the
                                     options available to Head Start-eligible children. As a result, the grantee
                                     sustained a shortfall of almost 2,000 children.

                                     Grantees also reported specific examples of increased availability of other
                                     programs having a negative impact on Head Start enrollment:



                                     Page 20                                        GAO-04-17 Head Start Enrollment
                              •   A large underenrolled grantee on the East Coast said that availability of
                                  prekindergarten programs at public and charter schools is the most
                                  important reason its delegate agencies are underenrolled.
                              •   A medium-sized grantee in Oklahoma with 454 funded slots indicated that
                                  in the 2001-02 school year, the local public school started a preschool
                                  program for 4-year-old children that resulted in a slight decline in Head
                                  Start enrollments at some of its service centers.
                              •   Officials representing a smaller grantee in Georgia with 161 funded slots
                                  said that their program was affected in 2001-02 when the state funded a
                                  prekindergarten program in public schools. Specifically, the grantee said
                                  that some children who had been pre-enrolled for Head Start switched to
                                  the state-funded program.

                                  Regional and grantee officials also indicated that state subsidies for
                                  unlicensed child care caused some grantees to be underenrolled. Officials
                                  of region IX (Arizona, California, Hawaii, Nevada, and Pacific Insular
                                  Areas) said that increasingly, low-income parents make use of state child
                                  care subsidies to pay for child-care exempt from licensing standards, such
                                  as care provided by friends or nonresident relatives. Region IX officials
                                  believed this had a significant impact on reducing Head Start program
                                  enrollments. In another example, a grantee in Pennsylvania saw its
                                  enrollments drop after the state allowed parents to use state child care
                                  subsidies to pay nonlicensed child care providers such as relatives and
                                  friends. In another instance, a grantee in California said that since its
                                  program primarily offers part-day/part-year services, many families chose
                                  to use subsidized, license-exempt care by relatives or friends who can
                                  provide full-day or part-day care.

Other Factors Affected            Less frequently, regions and grantees also cited other factors as negatively
Enrollments, but Were Cited       influencing Head Start enrollment. Eight grantees indicated that eligible
Less Frequently                   families had moved from their service areas, often because of the high cost
                                  of living, increasing underenrollment. Three regions also reported that
                                  high turnover rates among enrolled children contributed moderately to
                                  underenrollment.

                                  Five grantees indicated that the income-eligibility criterion for Head Start
                                  was too low in their high-cost areas. For example, 4 underenrolled
                                  California grantees said that even relatively poor families were disqualified
                                  from Head Start participation because their incomes, though inadequate to
                                  meet the basic costs in the local area, were above the federal poverty
                                  guidelines. Officials of an underenrolled grantee in Oakland indicated that
                                  during the 2002-03 program year they had denied Head Start services to
                                  over 100 families because their incomes exceeded the current poverty



                                  Page 21                                        GAO-04-17 Head Start Enrollment
                   guidelines. The other three California grantees said that they were also
                   turning families away because they were slightly over the income
                   guidelines. Grantees said that families just over the federal poverty
                   guideline cannot afford to send their children to education and child care
                   programs equivalent in quality to Head Start programs.

                   Four regions cited inadequate program management factors, such as weak
                   recruitment efforts, as a major or moderate contributor to
                   underenrollment. Five grantees also cited such factors as inhibiting Head
                   Start enrollments. Inadequate program management was characterized by
                   weak recruitment efforts, not developing or using waiting lists of Head
                   Start-eligible children, and planning enrollment expansions poorly. For
                   example, a grantee in Pennsylvania agreed to expand enrollment by 144
                   slots, and although the grantee received increased funding in the 2000-2001
                   program year, grantee officials said they had difficulty filling the additional
                   slots because of inadequate planning by the previous management team.

                   Three grantees in California noted that language and cultural differences
                   between eligible Head Start families and program staff complicated
                   outreach and consequently reduced enrollments from some minority
                   groups. One grantee indicated that families in its service area spoke over
                   25 languages at home. Another grantee said it was difficult to find staff
                   that spoke the same languages as the families needing service.


                   ACF national and regional offices and grantees all report taking action to
ACF and Grantees   address underenrollment, such as issuing guidance, increasing monitoring,
Use a Variety of   and attempting to conduct broader outreach efforts. The ACF national
                   office issued a memorandum instructing regional offices to address
Approaches to      underenrollment, and all ACF regions we surveyed said that they have
Address            increased their monitoring efforts. Some ACF regions have also taken
                   action to reduce grantees’ funding and recoup federal funds. Many
Underenrollment    grantees we spoke with have increased outreach efforts, sought partners
                   to help provide more full-day services, and increased the capacity of
                   physical facilities. While 18 of the 25 grantees we contacted had made
                   progress toward achieving full enrollment, others cited continuing
                   challenges.




                   Page 22                                         GAO-04-17 Head Start Enrollment
ACF-Issued Guidance for   In April 2003, ACF headquarters issued policy guidance to its regional
Managing                  offices instructing them to take specific actions with underenrolled
Underenrollment Lacks     grantees, although it provided no particular instructions for the review
                          process or any criteria for prioritizing grantees for corrective action. The
Specific Criteria for     guidance instructs regional officials to address underenrollment
Priority Review and       depending on four possible causes. For example, if the grantee can
Corrective Action         demonstrate that an inappropriate program option is causing
                          underenrollment, the guidance instructs regions to carefully consider
                          grantee requests to make changes to their services, such as converting
                          current part-day slots to full-day slots. The four causes identified in the
                          guidance and the recommended actions are summarized in table 5.




                          Page 23                                        GAO-04-17 Head Start Enrollment
Table 5: April 2003 National Head Start Guidance to ACF Regions

       Category of underenrollment                        Expected regional action
 1     Temporary in nature (e.g., awaiting completion Ask grantee to document in writing when it will return to full enrollment. Periodic
       of a new facility).                            follow-up by assigned regional program specialist. Reevaluate grantee status if it
                                                      remains in this category for more than several months.
 2     Attributable to a nonimplemented expansion         Generally, all grantees must have the additional children enrolled in their
       (i.e., where a grantee that was given              programs within 1 year of receiving their grant expansion. Regions should
       expansion funding to serve an increased            • track grantee expansion,
       number of children failed to enroll these
                                                          • contact grantee and discuss reasons for delays,
       children within a reasonable time period).
                                                          • judge whether grantee is making sufficient progress to warrant extension,
                                                          • require an implementation plan for any extension, which must not exceed
                                                             6 months, and
                                                          • inform the grantee in writing that expansion funds will no longer be available if
                                                             at any time the region determines that the grantee will not be able to
                                                             implement its approved expansion in a reasonable time period.
 3     Attributable to demographic changes that have Determine an appropriate reduction in the grantee’s enrollment and funding
       reduced the number of eligible children in the levels. ACF’s general policy will be to
       grantee’s service area.                        • give the grantee appropriate notice that a funding reduction will be initiated,
                                                      • implement funding reductions at the time a grant is being refunded, based on
                                                         a grantee’s historical underenrollment problems, and
                                                      • reduce funding proportionate to the degree of underenrollment (i.e., on a cost
                                                         per child basis adjusting for those grantee costs that are not directly related to
                                                         enrollment such as the salaries and fringe benefits of management staff.
 4     Not attributable to any of the above causes,       Make an on-site monitoring visit to the grantee to fully assess the reasons for
       but occurring because of grantee management        underenrollment. The assessment could result in the region designating the
       issues. This would include poor community          grantee as deficient. (The region may designate a grantee as being in non-
       outreach, inadequate needs assessments,            compliance rather than deficient if it determines underenrollment is an isolated
       inappropriate program options, inadequate          issue that does not seem to be part of a more systemic problem with the
       transportation services, poor facility planning,   grantee’s ability to provide an appropriate level of Head Start services.)
       lack of coordination with other community          A deficient grantee is required to submit a Quality Improvement Plan (QIP)
       providers, such as prekindergarten programs,       indicating how, within 1 year or less, it will achieve full enrollment. This could be
       or any other management problems causing           accomplished by fixing the problem causing the underenrollment or by agreeing
       underenrollment.                                   to an enrollment reduction that would bring the grantee to its full enrollment level,
                                                          or some combination thereof. The region should monitor the grantee’s progress
                                                          in implementing its QIP and provide any appropriate technical assistance. If the
                                                          underenrollment has not been corrected at the end of the QIP period, the region
                                                          needs to initiate an adverse action against the grantee, which would be
                                                          termination or denial of re-funding.
                                                          If an inappropriate program option is a major factor causing underenrollment,
                                                          regions must consider a grantee’s request to reconfigure its program options.
                                                          Changes such as conversion of part-day slots to full-day or reduction of double
                                                          sessions may include some proposed reduction for enrollment levels. Each such
                                                          proposal should be judged on its own merits, including the extent to which the
                                                          grantee proposes to collaborate with other community providers and the extent
                                                          to which the proposed reconfiguration is supported by data from the grantee’s
                                                          current community assessment.
Source: GAO analysis of ACF memorandum.




                                               Page 24                                                    GAO-04-17 Head Start Enrollment
                                                                The April guidance does not suggest any systematic process for identifying
                                                                underenrolled grantees, nor does it specify criteria for prioritizing when
                                                                grantees should be subject to corrective action based on their level of
                                                                underenrollment. One regional official said that the lack of a threshold
                                                                offered no gauge for establishing priorities and intensifying monitoring
                                                                efforts.


Regional Officials                                              The ACF regions we surveyed reported taking a variety of actions to
Reported Intervening with                                       address underenrollment ranging from providing assistance to recouping
Underenrolled Grantees to                                       federal funds in some cases. Officials in all 11 regions responded that they
                                                                had taken at least one action to ensure that grantees address
Correct Underenrollment                                         underenrollment. The interventions taken most often were to monitor
                                                                enrollment levels (55 grantees), track improvement efforts (43), and
                                                                provide training and technical assistance (30). Notably, 4 regions provided
                                                                additional funds to a total of 18 underenrolled grantees to purchase or
                                                                renovate facilities. Somewhat less often, regions took action to reduce
                                                                funded enrollment levels or recoup funds. Specifically, only 2 regions
                                                                reported that they recouped funds from a total of 6 underenrolled
                                                                grantees. (See table 6.)

Table 6: Actions by ACF Regions toward Underenrolled Grantees


                                                                                                  Count of regions       Number of grantees to
 Regional actions                                                                                 taking the action       which action applied
 Identified deficiency and pursued QIP                                                                           6                          19
 Met with grantees and developed plan to address underenrollment                                                 5                          29
 Required frequent (such as monthly) reporting of enrollment                                                     5                          55
 Provided funds for purchase or renovation of facilities or for more comprehensive
 community assessments                                                                                           4                          18
 Tracked correction efforts for compliance                                                                       3                          43
 Provided training and technical assistance                                                                      3                          30
 Negotiated reductions in funding levels and funded slots                                                        3                           9
 Withheld or recaptured funds for the year of underenrollment                                                    2                           6
 Held meetings with grantee’s board and management                                                               2                           3
 Proposed Head Start grant be relinquished or terminated                                                         2                           2
 Requested audit by the HHS Office of Inspector General                                                          1                           1
 Changed program options                                                                                         1                           1
Source: GAO analysis of ACF regional office survey responses.




                                                                Page 25                                        GAO-04-17 Head Start Enrollment
                         As noted earlier, many regions and grantees said the need for full-day
                         services was a major factor fostering underenrollment. As part of their
                         efforts to assist grantees in providing more full-day services, some ACF
                         regional officials told us they had encouraged grantees to collaborate with
                         other programs or had provided additional funds to purchase or renovate
                         facilities. However, such efforts can be costly. For example, region V
                         officials told us that it costs more to provide full-day care than part-day
                         care because full-day care requires more facility space and staff per child.


Underenrolled Grantees   Grantees we interviewed took a variety of actions to address
Report Taking Some       underenrollment, including more aggressive recruiting efforts,
Remedial Actions         collaborating with other preschool and child care programs, and
                         increasing slots in selected program options such as home-based services.
                         Most grantees we contacted said that they had taken one or more actions.
                         The most frequently mentioned was more aggressive recruiting followed
                         by collaboration with other programs. For example, a large grantee in New
                         York State that faced increased demand for full-day care since welfare
                         reform collaborated increasingly with other child care providers to piece
                         together a package of full-day services. Nine grantees also reported trying
                         to increase physical facilities capacity. (See table 7.) Other actions taken
                         to address underenrollment, which were cited by 3 or fewer grantees,
                         included improving the tracking or monitoring of enrollment
                         opportunities, hiring multilingual staff, reducing the number of funded
                         slots, and providing contractual incentives for delegate agencies to
                         maintain full enrollment.




                         Page 26                                        GAO-04-17 Head Start Enrollment
                             Table 7: Actions Taken by Interviewed Grantees to Address Underenrollment

                                                                                                           Number of grantees
                                                                                                             taking the action
                              Action taken                                                                             (n = 25)
                              Took more aggressive and proactive recruiting approach                                        14
                              Collaborated with other preschool and child care programs                                     12
                              Increased capacity of physical facilities                                                      9
                              Increased slots in selected program options                                                    6
                              Worked on updating community assessment                                                        6
                              Increased marketing of Head Start to the community                                             5
                              Relocated and developed new program centers                                                    5
                              Identified a new unserved low-income population                                                4
                              Trained staff in recruitment and program promotion                                             2
                              Increased home-based program enrollments                                                       1
                             Source: GAO analysis of interviews with underenrolled grantees.



Grantees Cite Obstacles to   Several grantees told us that converting part-day services to full-day was
Providing Additional Full-   often challenging to implement in addition to being more costly.
Day Care                     Additionally, 2 grantees said that ACF did not fully understand all that was
                             involved in transitioning from part-day to full-day services, and that there
                             was no clear national guidance on how to do so. According to these
                             California grantees,

                             The costs of transitioning part-day, double sessions, to full-day services have never been
                             fully understood and no national process has emerged to assist grantees and regional
                             offices to address this problem. The major costs often include facilities and additional
                             staffing (where only two and one-half staff are needed for a double session, four to six are
                             needed to staff a full-day session, depending on the number of hours the option operates).
                             Such fixed costs would require a reduction in the number of slots (children enrolled) or an
                             increase in funding in order to transition from part-day double sessions to two full-day
                             sessions.

                             While these two grantees expressed concern over a lack of guidance, it
                             should be noted that there is national guidance on budgeting for
                             partnerships between child care and Head Start and on financial




                             Page 27                                                           GAO-04-17 Head Start Enrollment
                          management issues in Head Start programs utilizing other funding
                          sources.12

                          Furthermore, grantees told us of their concern to maintain total funded
                          enrollment levels, even as they were converting unfilled part-day openings
                          to full-day. According to region V officials, this concern to maintain
                          enrollment levels may be in keeping with national efforts to serve a greater
                          number of needy children.13 For example, one underenrolled grantee said
                          that ACF suggested several alternatives to address underenrollment,
                          including converting part-day to full-day slots, but would not permit the
                          grantee to reduce funded slots as a way to address underenrollment.
                          Consequently, while converting part-day slots to full-day slots, the grantee
                          would have had to expand its facilities or find other child care partners in
                          order to serve the same number of children.


Grantees Reported Mixed   Some grantees reported success addressing underlying factors
Results Resolving         contributing to underenrollment, while others did not. Of the 25
Underenrollments          underenrolled grantees that we contacted, 18 (72 percent) indicated that
                          their underenrollment had either been corrected (10 grantees) or would be
                          corrected shortly (8 grantees). These 18 grantees overcame a variety of
                          factors that they said affected underenrollment. For example, 6 of these 18
                          grantees overcame a shortage of available full-day slots and 8 managed to
                          fill slots lost due to a decline in eligible children attributed to declining
                          TANF rolls. The 7 grantees that had not made progress addressing
                          underenrollment often cited similar issues. For example, 3 of these
                          7 grantees said they had faced challenges resulting from decreasing TANF
                          caseloads and were unable to respond to the increased demand for full-
                          day services. On the basis of our limited number of interviews, we could
                          not determine why some grantees reported they were able to successfully
                          address problems that other grantees could not.


                          Because ACF has no reliable nationwide data on enrollment, it is not
Conclusions               possible for the agency to identify and track underenrollment trends and
                          to develop strategies to ensure that federally funded Head Start slots are
                          filled. While we could not determine with any precision the extent to


                          12
                           ACF Information Memorandums: IM-HS-01-13, 11/16/2001 and IM-HS-01-06, 3/8/2001.
                          13
                           ACF’s primary performance indicator for the number of children served gives equal
                          weight to part-day and full-day slots.




                          Page 28                                               GAO-04-17 Head Start Enrollment
                      which there is underenrollment, our survey work and analysis indicate it is
                      possible that underenrollment is more widespread than ACF has
                      acknowledged. The complexity of factors buffeting Head Start grantees
                      underscores the need for ACF to accurately identify underenrollment and
                      its causes on a timely basis. Even if ACF corrects national survey data
                      issues, there is no guarantee that its regions will know of underenrollment
                      in a timely manner because the main national data source is not available
                      until the following program year.

                      Furthermore, because ACF regions vary in how they define unacceptable
                      levels of underenrollment and because they rely on approaches to identify
                      grantees that are not timely or consistent, there is some indication that
                      Head Start grantees with similar levels of underenrollment are treated
                      differently across regions. ACF guidance to the regions on how to address
                      different types of underenrollment is a good first step toward a more
                      systematic approach to underenrollment. However, until ACF issues
                      guidance that more clearly explains how to prioritize grantees with
                      varying levels of underenrollment for purposes of corrective action,
                      regions are likely to continue using varied criteria or none at all. Also, until
                      more timely and systematic approaches are developed for regions to
                      identify underenrolled grantees, it is possible that low enrollment will go
                      undetected and federal dollars will not be fully utilized for low-income
                      children who could benefit from Head Start’s program goals.

                      Finally, it appears that there may be a perceived incentive for
                      underenrolled grantees to maintain or increase enrollments due, in part, to
                      ACF’s emphasis on counting the total number of children served
                      irrespective of whether they are enrolled part-day or full-day. Measuring
                      Head Start enrollments without capturing the difference in level of service
                      provided by full-day or part-day programs adds to the difficulty of meeting
                      local needs and adjusting to changes in those needs. Until ACF can get a
                      better grasp of the nature and size of underenrollment and align program
                      incentives with family needs, it may be a challenge for Head Start to best
                      meet the needs of some families it could serve.


                      We recommend that the Secretary of HHS direct ACF to (1) take steps to
Recommendations for   ensure the accuracy of enrollment data reported in its annual nationwide
Executive Action      survey of grantees, (2) develop a standard criterion for regional offices to
                      use in identifying grantees whose underenrollment merits monitoring or
                      corrective actions, (3) develop an additional measure of aggregate services
                      other than total enrollment that takes into consideration the different
                      levels of service provided by full-day and part-day programs, and (4) work


                      Page 29                                          GAO-04-17 Head Start Enrollment
                  with regional offices to develop a more systematic process for them to
                  collect reliable enrollment data during the program year so that they can
                  address underenrollment more quickly.


                  We provided a draft of this report to the Department of Health and Human
Agency Comments   Services for review and comment. In its written response, included as
                  appendix IV of this report, HHS agreed with our recommendations and
                  indicated that it will take action to address each recommendation.


                  We are sending copies of this report to the Secretary of Health and Human
                  Services and other interested parties. In addition, the report will be
                  available at no charge on GAO’s Web site at http://www.gao.gov.

                  If you or your staffs have any further questions about this report, please
                  call me on (202) 512-7215. Other GAO contacts and staff acknowledgments
                  are listed in appendix V.

                  Sincerely yours,




                  Marnie S. Shaul
                  Director, Education, Workforce,
                   and Income Security Issues




                  Page 30                                       GAO-04-17 Head Start Enrollment
                Appendix I: Scope And Methodology
Appendix I: Scope And Methodology


                To determine what is known about the extent to which Head Start
                programs are underenrolled, we assessed the reliability of PIR enrollment
                data, conducted interviews, reviewed program documentation, and
                surveyed ACF regional offices. Specifically, we assessed the reliability of
                the PIR data on grantee enrollment by (1) performing electronic testing of
                key data elements for obvious errors in completeness and accuracy,
                (2) reviewing existing information about the data and the system that
                produces it, and (3) contacting 19 underenrolled and overenrolled
                grantees selected across a range of reported enrollment ratios. We did not
                assess the reliability of other PIR data used in the report. We also
                interviewed ACF headquarters officials, reviewed federal guidance and
                regulations on enrollment, surveyed the regions and a branch office, and
                interviewed regional officials in regions III, V, and IX. The 3 regions were
                selected for site visits on the basis of geographical representation and the
                number of underenrolled grantees they reported to us. Since ACF
                oversight of Head Start grantees is primarily accomplished through its
                regions and program branches, we designed a survey instrument in which
                these entities could provide written responses to our specific requests for
                such information as:

            •   the methods the regions used to oversee grantee and delegate agency
                enrollment levels;

            •   the threshold, if any, they had established for determining the point at
                which a grantee or delegate agency’s level of underenrollment is
                considered to be unacceptable;

            •   a list of all grantees and delegate agencies that they believed had
                unacceptable levels of underenrollment for both the 2001-02 and 2002-03
                program years;

            •   the reasons that they believed unacceptable levels of underenrollment had
                occurred and the extent (major, moderate, minor, or none) that they
                believed each identified reason had contributed to underenrollment;

            •   the actions they had taken to address the unacceptable level of
                underenrollment for their grantees and delegate agencies.

                We surveyed all 10 ACF regional offices and the American Indian-Alaska
                Native Program Branch. The Migrant and Seasonal Program Branch was
                excluded from our review because of its lack of comparability with the
                other branch and regions caused by anticipated enrollment fluctuations
                resulting from the seasonal movement of migrant families.



                Page 31                                        GAO-04-17 Head Start Enrollment
    Appendix I: Scope And Methodology




    To determine ACF officials’ and Head Start grantees’ views on the factors
    that contribute to underenrollment and to identify actions they took to
    address underenrollment, we relied on our survey of the ACF regional
    offices and the American Indian-Alaska Native Program Branch office as
    well as a interviews with 27 grantees (1 of which was actually a delegate
    agency) that had been identified by the regions as underenrolled. Twenty
    grantees were contacted by telephone and 7 were interviewed face-to-face.
    Two of the 27 grantees said that they had not experienced any
    underenrollment; therefore, our grantee survey results were based on the
    responses of 25 grantees that agreed with the regions’ designation of their
    underenrolled status.

    Using a standard set of questions, we interviewed at least 1 identified
    grantee from each region or branch. In selecting grantees to be
    interviewed, we chose 7 from the metropolitan areas of the 3 regions that
    we visited so that we could conduct some of the interviews in person. The
    other 20 grantees we interviewed were primarily selected from each region
    based on having been identified as being underenrolled for 2 program
    years (2001-02 and 2002-03). We also attempted to interview both grantees
    that were funded for more than 500 slots and grantees that were funded
    for fewer.

    The grantee interview requested that grantee officials

•   describe the factors they believed contributed to the grantee’s
    underenrollment,

•   identify the actions the grantee had taken to address underenrollment, and

•   indicate whether they believed that the grantee’s underenrollment had
    been corrected.

    Because of the lack of reliable enrollment data, the information we
    collected regarding underenrollment was primarily testimonial. Apart from
    assessing the basic consistency of interviewees’ responses with known
    program characteristics, we did not independently test the information
    they provided, such as reasons for underenrollment.




    Page 32                                       GAO-04-17 Head Start Enrollment
                                                                Appendix II: Factors That the ACF Regions
Appendix II: Factors That the ACF Regions                       Believed Contributed to Underenrollment to a
                                                                Major or Moderate Extent


Believed Contributed to Underenrollment to
a Major or Moderate Extent
Table 8: Factors Cited By ACF Regions as Contributing to Underenrollment to a Major or Moderate Extent, during Program
Years 2001-02 and 2002-03

                                                                                                                                     Percentage of
                                                                                                               Number of times       regions citing
         Factor cited as contributing to underenrollment                                                                  cited              factor
 1       Fewer eligible families (moving into jobs and off TANF)                                                             7                 63.6
 2       Not enough full-day slots                                                                                           7                 63.6
 3       Other day care or education centers are available in the area                                                       7                 63.6
 4       Completion of facilities was slower than planned                                                                    6                 54.5
 5       Demographic change: decrease in the number of eligible children in service area                                     6                 54.5
 6       Shortage of eligible children below the poverty rate cutoff                                                         5                 45.5
 7       Too many part-day slots                                                                                             5                 45.5
 8       Waiting lists of eligible children not developed or used                                                            4                 36.4
 9       Weak recruitment efforts                                                                                            4                 36.4
 10      High turnover rate (e.g., families move often)                                                                      3                 27.3
 11      Actual enrollments not yet caught up with recent funded program expansion                                           2                 18.2
 12      Not enough part-day slots                                                                                           1                  9.1
 13      Too many full-day slots                                                                                             1                  9.1
Source: GAO analysis of ACF regional office survey responses.




                                                                Page 33                                            GAO-04-17 Head Start Enrollment
                                                                  Appendix III: Factors that Grantees Believed
Appendix III: Factors that Grantees Believed                      Contributed to Their Head Start Programs’
                                                                  Underenrollment


Contributed to Their Head Start Programs’
Underenrollment
Table 9: Factors Cited by 25 Grantees as Contributing to Head Start Program Underenrollment, during Program Years 2001-02
and 2002-03

                                                                                                                                        Percentage of
                                                                                                                                       grantees citing
                                                                                                                 Number of times                factor
         Factors contributing to underenrollment                                                                            cited             (n = 25)
 1       Difficulties in acquiring and developing adequate facilities                                                         14                  56.0
 2       Families moving into jobs and off TANF                                                                               11                  44.0
 3       Not enough full-day slots                                                                                             9                  36.0
 4       Other day care or education centers are in the area                                                                   8                  32.0
 5       Lack of housing for low-income families                                                                               7                  28.0
 6       Income eligibility criterion too low for high-cost area                                                               5                  20.0
 7       Programs paying relatives or friends for child care                                                                   5                  20.0
 8       Lack of income-eligible children in service area                                                                      4                  16.0
 9       High turnover rate (e.g., families move often)                                                                        4                  16.0
 10      High cost of living causes low-income families to move                                                                4                  16.0
 11      Language and cultural barriers among eligible families make selling program difficult                                 3                  12.0
 12      Actual enrollments not yet caught up with expansion                                                                   2                   8.0
 13      Centers in wrong service area location                                                                                2                   8.0
 14      Centers with wrong mix of program service options                                                                     2                   8.0
 15      High cost of transitioning from part-day to full-day care                                                             2                   8.0
 16      Inadequate program management                                                                                         2                   8.0
 17      Poorly planned enrollment expansion                                                                                   2                   8.0
 18      Weak or inadequate recruiting efforts                                                                                 2                   8.0
 19      Completion of facilities was slower than planned                                                                      1                   4.0
 20      Difficulties in finding qualified collaborative care partners                                                         1                   4.0
 21      Head Start income levels too low for collaborating with other low-income programs                                     1                   4.0
 22      Parents do not recognize the benefit of Head Start for their child                                                    1                   4.0
 23      Waiting lists of eligible children not developed or used                                                              1                   4.0
Source: GAO analysis of interviews with underenrolled grantees.




                                                                  Page 34                                             GAO-04-17 Head Start Enrollment
             Appendix IV: Comments from the U.S.
Appendix IV: Comments from the U.S.
             Department of Health and Human Services



Department of Health and Human Services




             Page 35                                   GAO-04-17 Head Start Enrollment
Appendix IV: Comments from the U.S.
Department of Health and Human Services




Page 36                                   GAO-04-17 Head Start Enrollment
                  Appendix V: GAO Contacts and Staff
Appendix V: GAO Contacts and Staff
                  Acknowledgments



Acknowledgments

                  Betty Ward-Zukerman, (202) 512-2732, wardzukermanb@gao.gov
GAO Contacts      Bryon Gordon, (202) 512-9207, gordonb@gao.gov


                  In addition to those named above, Daniel Jacobsen, Lesley Woodburn,
Acknowledgments   Luann Moy, Barbara Johnson, James Rebbe, Susan Bernstein, and
                  Amy Buck made key contributions to the report.




                  Page 37                                    GAO-04-17 Head Start Enrollment
             Related GAO Products
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             Education and Care: Head Start Key Among Array of Early Childhood
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             Head Start and Even Start: Greater Collaboration Needed on Measures of
             Adult Education and Literacy. GAO-02-348. Washington, D.C.: March 29,
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             Early Childhood Programs: The Use of Impact Evaluations to Assess
             Program Effects. GAO-01-542. Washington, D.C.: April 16, 2001.

             Title I Preschool Education: More Children Served, but Gauging Effect
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             Early Education and Care: Overlap Indicates Need to Assess
             Crosscutting Programs. GAO/HEHS-00-78. Washington, D.C.: April 28,
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             Early Childhood Programs: Characteristics Affect the Availability of
             School Readiness Information. GAO/HEHS-00-38. Washington, D.C.:
             February 28, 2000.

             Education and Care: Early Childhood Programs and Services for Low-
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             1999.

             Head Start: Challenges in Monitoring Program Quality and
             Demonstrating Results. GAO/HEHS-98-186. Washington, D.C.: June 30,
             1998.

             Head Start Programs: Participant Characteristics, Services, and
             Funding. GAO/HEHS-98-65. Washington, D.C.: March 31, 1998.




(130221)
             Page 38                                     GAO-04-17 Head Start Enrollment
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