UPDATE: Aug. 19, 2022: On Friday, a U.S. Department of Health and Human Services spokesperson shared in an emailed statement that the Office of Head Start “acknowledges the Centers for Disease Control and Prevention’s (CDC) COVID-19 mitigation recommendations have evolved since the publication of the Interim Final Rule with Comment Period. OHS will take into consideration public comments, the updated CDC recommendations, the recent approval of vaccinations for young children, and the health and safety of Head Start children and families in the ongoing development of program guidance and regulation."
Dive Brief:
- Conflicting guidance, rules and court decisions regarding staff vaccinations and mask wearing are having an adverse impact on Head Start's early education program, said the National Head Start Association. These concerns were shared Tuesday in a letter to Xavier Becerra, secretary of the U.S. Department of Health and Human Services, which oversees the federal program for children from low-income families.
- Head Start preschools are supposed to operate under a Nov. 30, 2021, interim final rule that required staff, contractors and volunteers to have an initial COVID-19 vaccination by the end of January 2022, to conduct weekly testing for the virus, and to mandate mask wearing for everyone 2 years old and over. Guidance released last week by the Centers for Disease Control and Prevention, however, defers safety precaution decision-making to local communities and individuals.
- After pandemic-related disruptions that saw some Head Start centers close or struggle to retain staff and enroll children, NHSA is asking the Health and Human Services Department to restore local autonomy to the programs. Doing so would help the programs rebuild relationships with families and partners, the association said in a July 29 letter.
Dive Insight:
The July letter asked HHS to issue a final rule by Aug. 15 so programs could plan for the new school year, but as of Wednesday, there hadn't been an update. The federal Unified Agenda shows HHS plans to issue a final rule in October.
Tommy Sheridan, NHSA deputy director, said the association has been requesting a final rule since January. "The bottom line on all of this is that with all of this kind of confusion swirling, the easiest thing to do would be to put out a final rule, whatever it says," Sheridan said.
Technically, the association would like the final rule to offer more local flexibility to make decisions about COVID-19 safety measures, Sheridan said.
He added that Head Start programs overall are supportive of immunizations and health practices. A December 2020 CDC report commended Head Start and Early Head Start programs for use of COVID-19 mitigation practices such as cleaning protocols and flexible medical leave policies for staff.
But as the COVID-19 virus has evolved — and as local, state and federal guidance has shifted — it's getting more difficult to create consistency for Head Start programs, especially regarding a stable workforce, Sheridan said.
The interim final rule, which has received about 2,800 public comments, "makes things even more difficult to retain and recruit new staff, and understanding especially in some communities, vaccine hesitancy and things like that are much larger than in other communities," Sheridan said.
A study by NHSA in late 2021 about the interim rule found that vaccine and masking mandates could lead to Head Start programs losing between 46,614 and 72,422 — or 18% to 26% — of all staff and the closing of over 1,300 Head Start classrooms. The survey results are based on 450 responses.
Another NHSA survey of 900 association members released in May shows 90% of respondents said programs closed permanently or temporarily due to lack of staff.
In FY 2019, Head Start served nearly 1 million children from birth to age 5 and pregnant women. Federal funding for the program was $9.7 billion.
Adding to the current chaos are court-issued injunctions against the Head Start vaccine and masking requirements that relieve 25 states from enforcing the interim rule.
For the other states, it's unclear what enforcement or penalties will be levied if those programs don't comply, Sheridan said.
The release of a final rule on vaccines and masking will help to rebuild the program's relationships with partners, such as families and local K-12 programs that provide direct services to children enrolled in Head Start, according to a Feb. 8, letter jointly written by NHSA and AASA, The School Superintendents Association.
That letter, addressed to Becerra and U.S. Education Secretary Miguel Cardona, gave an example of a Minnesota school district that contracts with a company to transport children, including those enrolled in Head Start. The transportation company, however, did not have a vaccinated driver, leaving transportation for those children in doubt.
The interim rule is "such a source of confusion, and it's holding Head Start programs back," Sheridan said.
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