Comments on Head Start Program Performance Standards Notice of Proposed Rule Making

Transcription

1 Comments on Head Start Program Performance Standards Notice of Proposed Rule Making 45 CFR Chapter XIII, Subchapter B RIN AC63 Head Start Performance Standards AGENCY: Office of Head Start (OHS), Administration for Children and Families (ACF), Department of Health and Human Services (HHS). ACTION: Notice of proposed rulemaking. On behalf of the National Association for Family, School, and Community Engagement Policy Council, I submit the following comments: First, we commend the Office of Head Start for continuing the focus on family engagement within the performance standards as a critical element of children s learning and development and a cornerstone of the Head Start program. OHS, with the Parent, Family, and Community Engagement Framework and related tools, shines light on strategies that need to be embedded within programs to achieve meaningful family engagement that drives improved family and child outcomes. We believe strongly that OHS leadership in this area will help to spread family and community engagement principles and practices throughout early learning. We hope that the Department of Education takes full note of the HHS commitment to family engagement and uplifts efforts in that department so that families can engage with teachers and school with equal ease as they do in early learning settings. Second, we appreciate the focus on meeting the needs of children with disabilities and efforts to both support the parents of these children and coordinate care. We also appreciate the focus on dual language learners and the need to support the home language of the child while also building competency in English. It is particularly important that the rule calls for communication with families to be in the home language (via staff or interpreter) and that testing of children is done in the language they most often use so that measurements of ability are not compromised by language barriers. Engaging families in child screenings and assessments and sharing data with parents is mentioned in the proposed rule and reflects best practice from our experience. We are especially pleased that there is a focus on training and professional development for staff about the family and community engagement expectations.

2 Third, we note several places within the standards where it would be appropriate to specifically reference the Head Start Parent, Family, and Community Engagement Framework, to ensure that programs transition from an a theoretical understanding of family and community engagement to a concrete and measurable approach. This Framework and related tools (e.g., Using the Head Start Parent, Family, and Community Engagement Framework in Your Program: Markers of Progress) should be specifically promoted in the performance standards for deepening family engagement practices, just as the Head Start Child Outcomes Framework is promoted for advancing child outcomes. Finally, we suggest a few places where language about transition services can be strengthened. The suggested additions that follow are in bold and all caps. We would be happy to answer any questions or provide further guidance. Please contact Deborah Roderick Stark at drs889@gmail.com or Part 1301: Program Governance Sec Policy Councils and Policy Committees, p 35526, column three Comment: With respect to Policy Councils and Policy Committees, it is not specifically mentioned that a majority of participants must be currently enrolled parents. We know this is in the statute and urge the OHS to include appropriate language in the rule as well. Suggested Wording: Sec (b) Composition. A program must establish a policy council in accordance with section 642(c)(2)(B) of the Act, or a policy committee at the delegate level in accordance with section 642(c)(3) of the Act, as early in the program year as possible. A MAJORITY OF THOSE SERVING ON THE COUNCIL OR COMMITTEE SHOULD BE PARENTS OF CHILDREN CURRENTLY ENROLLED IN THE PROGRAM. Parents of children currently enrolled in a program option must be proportionately represented Part 1302: Program Operations Section Center- based option, p 35532, column two Comment: We support the commitment of Head Start to support continuity of care to minimize teacher changes throughout a child s enrollment in the 2

3 program. This is a practice that is beneficial to parents too as they can build even deeper parent- teacher relationships in support of child outcomes. Suggested Wording: Section (b)(2) A classroom that serves children under 36 months old, wherever possible, and consider mixed age group classrooms to support continuity of care AND STRENTHEN PARENT- TEACHER PARTNERSHIPS. Section Parent involvement, p 35536, column one Comment: We support the long- standing commitment of Head Start to parent involvement and believe it applies to all Early Head Start and Head Start program options, not just center- based and family child care. Further we think that it is important to be more specific about parent involvement and reference the Head Start Parent, Family, and Community Engagement Framework so that programs will use that tool to guide their practices. Suggested Wording: Section (a) In general. Center- based, HOME- BASED, and family child care programs education. PROGRAM PRACTICES SHOULD BE INFORMED BY AND ALIGNED WITH THE HEAD START PARENT, FAMILY, AND COMMUNITY ENGAGEMENT FRAMEWORK. Section Parent involvement, p 35536, column one Comment: We recognize the importance of transitions and believe teachers should offer parents the opportunity for a third meeting to provide additional support to families transitioning out of the program. Teachers should be required to ask parents whether or not they would like to schedule a third parent- teacher meeting during the second in- person parent- teacher meeting. Suggested Wording: Section (b)(2) Teachers hold parent conferences as needed.and activities in the program. IF A CHILD WILL BE TRANSITIONING OUT OF A HEAD START PROGRAM, DURING THE SECOND IN- PERSON PARENT CONFERENCE, TEACHERS WILL ASK THE FAMILY IF THEY WOULD LIKE TO HAVE A THIRD CONFERENCE TO PROVIDE ADDITIONAL SUPPORT FOR A SUCCESSFUL TRANSITION. Section Subpart E. In General, p 35539, column two Comment: This section provides very strong language about family engagement, recognizing that it needs to be integrated into all system and program components, promote shared responsibility, encourage trust and ongoing two- way communication, and include multiple strategies to engage 3

4 parents in their children s learning. Just as the Head Start Child Outcomes Framework is used as a point of reference in the curriculum section, the Head Start Parent, Family and Community Engagement Framework should be referenced in this section as well. Suggested Wording: Section (a) A program must integrate of their children. FAMILY AND COMMUNITY STRATEGIES SHOULD BE INFORMED BY AND ALIGNED WITH THE HEAD START PARENT, FAMILY, AND COMMUNITY ENGAGEMENT FRAMEWORK. Section Transitions from Head Start to kindergarten, p 35541, column three Comment: We suggest that transition be phrased as transition to school rather than a more narrow of transition to kindergarten. In some cases, children may transition from Head Start into state pre- kindergarten that is administered by the public school system or other entities. In this, we hope to underscore the importance of continuous family engagement as a process that can mitigate the fade out effects of the Head Start experience once children enter school. Research shows that continuous family engagement predicts children s literacy gains in fifth grade. (Dearing, Kreider, Weiss) Suggested Wording: Section Transitions from Head Start to SCHOOL (a) Implementing transition strategies and practices. A program that serves children who will enter SCHOOL in the following year must implement transition strategies to support a successful transition to SCHOOL. (b) Family collaborations for transitions. (1) A program must collaborate with parents of enrolled children to implement strategies and activities that will help parents advocate for and promote successful transitions to SCHOOL for their children, including their continued involvement in the education and development of their child. (2) At a minimum, such strategies and activities must: (i) Help parents understand their child s progress during Head Start; (ii) Help parents understand and use parenting practices that will effectively provide academic and social support for their children during their transition to SCHOOL and foster their continued involvement in the education of their child; (iii) Prepare parents to exercise their rights and responsibilities concerning the education of their children in the elementary school setting, including the availability and appropriateness of participation for their child in language instruction educational programs, including those focused on Native language instruction; and, (iv) Assist parents in the ongoing communication with teachers and other school personnel so that parents can participate in decisions related to their children s education. 4

5 (c) Community collaborations for transitions. (1) A program must collaborate with local education agencies to support parental involvement under section 642(b)(13) of the Act and state departments of education, as appropriate, and kindergarten teachers to implement strategies and activities that promote successful transitions to SCHOOL for children, their families, and the elementary school. (2) At a minimum, such strategies and activities must include: (i) Coordination with schools or other appropriate agencies to ensure children s relevant records are transferred to the school or next placement in which a child will enroll, consistent with privacy requirements in part 1303 of this chapter; (ii) Communication between appropriate staff and their counterparts in the schools to facilitate continuity of learning and development, consistent with privacy requirements in subpart C of part 1303 of this chapter; and, (iii) Participation, as possible, for joint training and professional development activities for Head Start and kindergarten teachers and staff. (3) A program that does not operate during the summer must collaborate with school districts to determine the availability of summer school programming for children who will be entering kindergarten and work with parents and school districts to enroll children in such programs, as appropriate. (d) Learning environment activities. A program must implement strategies and activities in the learning environment that promote successful transitions to SCHOOL for enrolled children, and at a minimum, include approaches that familiarize children with the transition to SCHOOL and foster confidence about such transition. (e) Transition services for children with an IEP. A program must provide additional transition services for children with an IEP, at a minimum, as described in subpart F of this part. Section Transitions from Head Start to kindergarten, p 35542, column two Comment: In addition to programs working with parents to enroll children in summer school programs, it is also important that programs work with parents and elementary schools to encourage enrollment in afterschool programs during the school year. Research shows that exposure to structured activities outside the classroom correlates with academic outcomes and successful transition from kindergarten to first grade. We believe this finding could mitigate fade out of the gains children make through their Head Start experience. (Copper & Crosnoe; Powell & Son) Suggested Wording: (c) (4) PROGRAM STAFF SHOULD WORK WITH PARENTS, ELEMENTARY SCHOOL TEACHERS, AND COMMUNITY PROVIDERS TO ENROLL CHILDREN IN AFTERSCHOOL PROGRAMS DURIGN THE SCHOOL YEAR. 5

6 Section Achieving program performance goals, p 35545, column two and three Comment: We appreciate that family engagement is mentioned here but feel it must be recorded as its own issue, not woven with health and nutrition. Just as there is an item on school readiness, there should be a parallel item on family engagement. Suggested Wording: Section (a) (3) FAMILY ENGAGEMENT GOALS THAT ARE ALIGNED WITH THE HEAD START PARENT, FAMILY, AND COMMUNITY ENGAGEMENT FRAMEWORK. Comment: We appreciate the focus on using data for continuous improvement. We urge the inclusion of data on families in addition to child assessment in order to assess how programs are making progress in engaging parents and supporting family outcomes as defined in the Head Start Parent, Family, and Community Engagement Framework. Suggested Wording: Section (c) Using data for continuous improvement complying with program performance standards. THIS INCLUDES DATA RELATED TO BOTH CHILD AND FAMILY OUTCOMES. Part 1305: Definitions Section Definitions Continuity of Care, p 35561, column three Comment: We agree that continuity of care is important for children, but continuity is also beneficial to parents as they are able to develop consistent relationships with teachers over a period of time to solidify the parent- teacher/school partnership. Suggested Wording: Continuity of care means Head Start minimizes the number of transitions in teachers and teacher assistants that children AND PARENTS experience Comment: We encourage the Department to include a definition for family engagement. Suggested Wording: Family engagement is a shared responsibility between home and early learning programs or school. When done well, early learning programs and other community organizations commit to working with families in meaningful and culturally respectful ways, and families commit to supporting their children s learning and development. Family engagement is 6

7 continuous across a child s life, from cradle to career, and carried out everywhere children learn at home, in early childhood programs, in school, in after- school settings, in faith- based institutions, and in community programs. NAFSCE Policy Council Jacki Ball (National PTA) Vito Borrello (NAFSCE) Soncia Coleman (United Way World Wide) Anne T. Henderson (Annenberg Institute for School Reform) Elena Lopez (Harvard Family Research Project) Karen L. Mapp (Harvard Graduate School of Education) Susan Shaffer (Mid- Atlantic Equity Center) Steve Sheldon (Johns Hopkins University) Deborah Roderick Stark (Deborah Roderick Stark and Associates) Heather Weiss (Harvard Family Research Project) Sherri Wilson (Acelero Learning) Helen Westmoreland (Flamboyan Foundation) Lacy Wood (American Institutes for Research) The National Association for Family, School, and Community Engagement (NAFSCE) was launched in September 2014 to advance high impact policy and practice, to promote child development and student learning, and to erase achievement gaps. NAFSCE engages in policy development and advocacy but does not conduct lobbying. For more information and to join the listserv, go to 7