Removing Barriers to Head Start Programs through Categorical Eligibility

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:

• a copy of notice of approval for,
• other documentation of eligibility or benefits from the SNAP agency,
• or an Electronic Benefit Transfer card with SNAP ID number.

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

1. S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support, Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2019. Alexandria, VA, 2021.
2. Head Start Program Performance Standards, Part 1302—Program Operations and 1302 Subpart A—Eligibility Recruitment Selection, Enrollment, Attendance
3. Subject: Head Start Categorical Eligibility for Families Eligible for the Supplemental Nutrition Assistance Program, ACF-IM-HS-22-03