Preparing for the New School Year
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In April 2022, the Administration for Children and Families (ACF) issued new guidance and an Information Memoranda (IM) announcing the long-awaited, family-friendly policy of permitting families and guardians to use proof of Supplemental Nutrition Assistance Program (SNAP) receipt or eligibility as a pathway to enroll in Head Start. This policy shift is based upon the interpretation of the phrase “public assistance” in Sec. 645 of the Head Start Act.
The COVID pandemic precipitated a decline in the availability of both, public and private child care programs. The inability of families to secure child care forced a significant amount of parents and an overwhelming amount of women to leave the workplace. The pandemic also created a different type of paradox within Head Start programs. Some child care programs were forced to close completely or reduce classrooms due to the inability to stay financially afloat as a result of parents leaving the workforce. In contrast, the child care programs funded by the Office of Head Start (OHS) did not experience the same type of financial uncertainty. Head Start staff were financially able to operate and pay their Head Start funded employees throughout the pandemic. However, Head Start programs struggled to maintain full-enrollment and to retain teachers during the heightened public health emergency.
A fully enrolled Head Start program must have families that are willing to enroll their children in a Head Start program and also the ability of those families to prove that they, in fact, are eligible for Head Start services. Consequently, the decision to allow categorical eligibility for SNAP recipients produces a positive outcome for the families and a parallel positive outcome for Head Start programs. Adopting this interpretation will make it easier for eligible families to enroll children in Head Start services by allowing families to demonstrate proof of SNAP receipt or eligibility to enroll in Head Start thereby simplifying the process of determining program eligibility for grantees.
It must be acknowledged, that establishing and announcing SNAP benefit recipients as “categorically eligible” for Head Start enrollment is not a complete solution for families seeking Head Start enrollment. The policy is only permissive. Meaning, programs can decide to apply SNAP categorical eligibility or they can also choose to not use SNAP categorical eligibility. Head Start programs must adhere to their recruitment and selection criteria to ensure they prioritize enrollment for those who may benefit most from Head Start services. This permissive element of the SNAP policy interpretation does create an unintended but possible consequence of discouraging families that attempt to access Head Start services using their SNAP benefits but are denied services because the Head Start program has not adapted their Eligibility, Retention, Selection, Enrollment, and Attendance (ERSEA) practices in favor or support of SNAP categorical eligibility.
Most young children in SNAP households are in families with incomes below 100% of poverty. However, historically, a family would be required to provide a large number of pay stubs, an official statement of unemployment from an official source, or other proof of income to establish eligibility. In comparison, SNAP eligibility can be determined by a single document or even, just the SNAP benefit card used to purchase food. Since programs can now use the receipt of SNAP benefits as establishing categorical eligibility, the family will not be subjected to the time and anxiety burden caused by having to produce paystubs in order to construct an income history. Permitting Head Start enrollment eligibility on the basis of SNAP eligibility, effectively, knocks down a barrier for families determined to access early childhood education services. SNAP categorical eligibility serves as a balance of inequities when applied to the ERSEA process. Categorical eligibility is a lever of social change and economic justice. It is important to note that Head Start programs must continue to use their ERSEA established selection criteria to prioritize the enrollment of families most in need of services.
To verify SNAP receipt or potential eligibility, a program would need to examine and maintain a copy of documentation from the state, local, or tribal public assistance. Families can use:
The Council for Professional Recognition supports Head Start programs and the early childhood education community as they move forward in increasing access to families by removing barriers to Head Start enrollment. We are eager to highlight community partnerships and outreach efforts for ways to encourage SNAP recipients to apply for Head Start services on behalf of children and families.
SOURCES
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Chief Operations Officer
Andrew Davis serves as Chief Operating Officer at the Council. In this role, Andrew oversees the Programs Division, which includes the following operational functions: credentialing, growth and business development, marketing and communications, public policy and advocacy, research, innovation, and customer relations.
Andrew has over 20 years of experience in the early care and education field. Most recently, Andrew served as Senior Vice President of Partnership and Engagement with Acelero Learning and Shine Early Learning, where he led the expansion of state and community-based partnerships to produce more equitable systems of service delivery, improved programmatic quality, and greater outcomes for communities, children and families. Prior to that, he served as Director of Early Learning at Follett School Solutions.
Andrew earned his MBA from the University of Baltimore and Towson University and his bachelor’s degree from the University of Maryland – University College.
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Jan Bigelow serves as Chief Financial Officer at the Council and has been with the organization since February of 2022.
Jan has more than 30 years in accounting and finance experience, including public accounting, for-profit and not-for-profit organizations. She has held management-level positions with BDO Seidman, Kiplinger Washington Editors, Pew Center for Global Climate Change, Communities In Schools, B’nai B’rith Youth Organization and American Humane. Since 2003, Jan has worked exclusively in the non-profit sector where she has been a passionate advocate in improving business operations in order to further the mission of her employers.
Jan holds a CPA from the State of Virginia and a Bachelor of Arts degree from Lycoming College. She resides in Alexandria VA with her husband and dog.
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