Head Start: New Criteria and Timelines for Re-Competing Grants 

April 10, 2012

The “Improving Head Start for School Readiness Act of 2007” (P.L. 110-134) amended the Head Start Act to require the U.S. Department of Health and Human Services (HHS) to re-compete certain Head Start grants. HHS issued a final rule on how the agency will designate Head Start and Early Head Start outlining the designation renewal system (DRS), which will determine which grantees must re-compete for funding. 

Beginning December 9, 2011, Head Start grantees providing high-quality services, as determined by the DRS, will receive a five year grant to continue running the program without having to recomplete for funding. The Office of Head Start (OHS) developed the DRS, which has seven conditions that would trigger re-competition. If a program triggers re-competition, similar to other federal grants, a request for proposals (RFP) to operate a Head Start program serving that community will be issued. The triggers fall into three categories: quality, licensing and operation, and fiscal and internal controls. 

At this time, OHS anticipates the RFP for redesignated grants to be released in mid-April and they anticipate there will be over 200 RFPs.   High-quality programs do not meet any of the seven triggers. Having to re-compete for funds does not disadvantage the current grant recipient from being awarded the five year grant.  Below outlines the DRS used by OHS to determine which Head Start grantees must re-compete for funding. 

Quality Triggers

  • Head Start programs are comprehensively monitored minimally once every three years by HHS. The monitoring review includes looking at everything from classroom management to services for special populations. If a grantee receives a “deficiency”, which is a finding of serious failure, during one of these monitoring reviews, that grant will be re-competed. OHS defines a deficiency as a “substantial or systemic material failure”. Prior to the new rule, deficiencies must be addressed or the grantee risks losing federal funding. Under the new rule, even if the deficiency was corrected, the grant will be re-competed. In their presentation giving an overview of the new regulations, OHS clarified that deficiencies are found for serious infractions, not for something minor.
  • Each grantee is required to establish and use goals to improve school-readiness. If a grantee has failed to establish and use these goals, this will trigger re-competition.
  • HHS uses an assessment tool to evaluate the effectiveness of services provided in the classroom called CLASS. Head Start grantees have received training and materials so they can effectively use the CLASS system to manage their classrooms. If a grantee has a low performance in one or more of the three areas of CLASS, this will trigger re-competition. The three areas are: instructional support, emotional support and classroom organization.

Licensing and Operation

Current grantees will have to re-compete for funding if their child care license has been revoked by either the state or local licensing agency and/or a grantees’ grant has been suspended by HHS.

Fiscal and Internal Controls

Current grantees will have to re-compete for funding if they have been debarred from receiving any state or federal funds under any program. Debarred is defined as not being able to participate in the program.

If an audit finds a current grantee has the potential to be liquidated in the foreseeable future or finds that there is a “material weakness” in the audit, the grantee will have to re-compete for funding.


The DRS will take approximately 12 months to implement and OHS anticipates the first round of redesignation to start mid-April. Current continuous grants will be converted to the five-year cycle over the next three year transition period. After all the grants are converted to the five-year cycle, in the fourth year of the cycle is when the OHS will determine whether that grantee will have to compete for funding, based on the criteria outlined above. It is important to note that this new rule does not impact current regulations on terminating an existing grant. If a grantee has serious violations of program rules, they can be terminated. Grantees terminated from participating will have to wait five years before they are eligible to compete for funding. 

Some legislators have received calls from concerned constituents about Head Start no longer providing services. HHS staff have explained that grant being re-competed does not mean services will no longer be provided – however, it is possible the service provider may change. If you have questions about providers in your district, please contact the Administration for Children and Families (ACF) regional office responsible for your state. Click here to access the ACF regional contact information: http://www.acf.hhs.gov/programs/oro/regions/regional_contacts.html

To read the final rule, click here: http://www.gpo.gov/fdsys/pkg/FR-2011-11-09/html/2011-28880.htm

NCSL staff in Washington, D.C. track and analyze federal legislation and policy and represent state legislatures on child support issues before Congress and the Administration. In D.C., Joy Johnson Wilson (joy.wilson@ncsl.org) and Rachel Morgan (rachel.morgan@ncsl.org) can be reached at (202) 624-5400.

The child support project and D.C. human services staff receive guidance and support from NCSL's Standing Committee on Health & Human Services.