    Head Start: Progress and Challenges in Implementing
    Transportation Regulations (27-JUL-06, GAO-06-767R).

    The leading cause of death for children ages 3 to 7 is motor
    vehicle traffic crashes. Head Start, a federal early care and
    education program run by local grantees and targeted at
    low-income children, currently serves approximately 900,000
    children, and transports many of them to and from Head Start
    centers across the country. While not required to do so, many
    Head Start grantees offer transportation as a way to make Head
    Start more widely available to the eligible population,
    especially very poor children. To address concerns about
    transporting children safely, the 1992 Head Start Improvement Act
    directed the Office of Head Start, housed within the U. S.
    Department of Health and Human Services (HHS), to develop
    transportation regulations to ensure the safety and effectiveness
    of transportation services made available to children by Head
    Start grantees. Head Start issued these regulations in 2001. To
    provide Congress with information that it requested on the
    regulations and their implementation, we determined: (1) the
    research and cost information Head Start considered in
    establishing the transportation regulations; (2) the actions Head
    Start grantees have taken to implement the vehicle, restraint,
    and bus monitor requirements of the regulations and the number of
    grantees that have sought waivers and extensions; and (3) the
    associated expenses and effects of implementing the regulations
    on grantees and their transportation partners.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-06-767R
        ACCNO:   A57542
      TITLE:     Head Start: Progress and Challenges in Implementing
    Transportation Regulations
         DATE:   07/27/2006
      SUBJECT:   Children
    	     Cost analysis
    	     Education program evaluation
    	     Financial analysis
    	     Safety regulation
    	     Safety standards
    	     Transportation research
    	     Transportation safety
    	     Waivers
    	     Program implementation
    	     Head Start Program

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO Product.                                                 **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ******************************************************************
    GAO-06-767R

    United States Government Accountability Office

    Washington, DC 20548

    July 27, 2006

    Congressional Requesters

    Subject: Head Start: Progress and Challenges in Implementing
    Transportation Regulations

    The leading cause of death for children ages 3 to 7 is motor vehicle
    traffic crashes. Head Start, a federal early care and education program
    run by local grantees and targeted at low-income children, currently
    serves approximately 900,000 children, and transports many of them to and
    from Head Start centers across the country. While not required to do so,
    many Head Start grantees offer transportation as a way to make Head Start
    more widely available to the eligible population, especially very poor
    children. To address concerns about transporting children safely, the 1992
    Head Start Improvement Act directed the Office of Head Start,1 housed
    within the U. S. Department of Health and Human Services (HHS), to develop
    transportation regulations to ensure the safety and effectiveness of
    transportation services made available to children by Head Start grantees.
    Head Start issued these regulations in 2001.

    Grantees were required to meet most provisions of the transportation
    regulations shortly after their issuance in January 2001; however, the
    compliance date for the provisions regarding passenger restraints and bus
    monitors was 3 years later, and the provision regarding vehicles was 5
    years later. In addition, grantees had two opportunities-in 2004 and in
    2005-to delay or seek a waiver from implementing the restraint and monitor
    provisions by requesting extensions through the Office of Head Start.2
    Further, when grantees annually renew their funding, the transportation
    regulations also permit them to request a waiver3 for good cause from any
    provision of the regulations-which the Office of Head Start may approve or
    deny.4 For purposes of this report, we refer to extensions as
    implementation delays resulting from the 2004 and 2005 provisions and
    waivers as those submitted under the general waiver authority provided for
    in the regulations.

    1At the time of our briefing in May 2006, the Office of Head Start was
    called the Head Start Bureau. Hence, the briefing slides enclosed with
    this report refer to the office by its former name.

    2The effective compliance dates for the restraint and monitor provisions
    were first extended via an interim final rule published in 2004. Then,
    Public Law 109-149, passed in 2005, extended the compliance date for the
    vehicle provision to June 30, 2006, and also allowed the Secretary of HHS
    to waive the restraint and monitor requirements through September 30,
    2006. The vehicle, restraint, and monitor provisions are effective until
    these respective dates or the date of enactment of a statute that
    authorizes appropriations for fiscal year 2006 to carry out the Head Start
    Act, whichever date is earlier. Head Start has issued guidance stating
    that waivers granted for restraints and monitors would cover the remainder
    of a grantee's program year, thus making that date the effective
    compliance date for a grantee. In June 2006, Pub.L. No.109-234 changed the
    compliance date for vehicles to December 30, 2006.

    3 The general waiver authority is outlined under 45 C.F.R. S: 1310.2(c).

    In commenting on the regulations, grantees expressed concern about the
    cost of complying with the regulations and cautioned that, since
    transportation was an optional service, these costs might lead some
    grantees to discontinue offering it at some sites. They also noted that
    the regulations might jeopardize long-standing partnerships with groups,
    such as schools and transit agencies, which some grantees use or contract
    with to provide transportation to their Head Start children. Controversy
    has also surrounded the requirement for child safety restraints, which
    typically are not standard on school buses.5 Restraints reduce seating
    capacity, which could result in fewer school age children being
    transported on school buses in favor of other modes of transportation-such
    as cars-that are less safe. Additionally, given the safety record of
    school buses, some school systems have questioned whether the costs of
    installing restraints outweigh their benefits.6 Currently, most states do
    not require child safety restraints on school buses.

    To provide you with information that you requested on the regulations and
    their implementation, we determined:

               1. The research and cost information Head Start considered in
               establishing the transportation regulations.
               2. The actions Head Start grantees have taken to implement the
               vehicle, restraint, and bus monitor requirements of the
               regulations and the number of grantees that have sought waivers
               and extensions.
               3. The associated expenses and effects of implementing the
               regulations on grantees and their transportation partners.

    To determine the research and cost information Head Start considered, we
    reviewed relevant research and regulations and interviewed officials from
    the Office of Head Start and the Department of Transportation's (DOT)
    National Highway Traffic Safety Administration (NHTSA) and Federal Transit
    Administration (FTA). To describe the actions grantees have taken, we
    surveyed a nationally representative sample of Head Start grantees and
    their delegates, obtaining a response rate of 77 percent. We also analyzed
    requests for extended time to implement the child restraint and monitor
    provisions and interviewed officials from the Office of Head Start and HHS
    Regional Offices about the process for receiving an extension or waiver
    and other aspects of implementing the regulations. Information to describe
    the regulations' effects on grantees was gathered through our survey and
    visits we made to seven grantees and their transportation partners, as
    appropriate. The states and HHS Regions in which the selected grantees
    operated were Indiana (Region 5), Iowa (Region 7), Kentucky (Region 4),
    Massachusetts (Region 1), and Washington (Region 10). Overall, the
    grantees were selected based on geographical diversity; size (e.g., funded
    enrollment); organization type; and to achieve a mix of grantees that
    filed requests in 2004 for more time to implement the restraint and
    monitor requirements and those that did not. We analyzed this information
    in combination with information collected from transportation providers to
    describe the expenses grantees incurred and the operational changes they
    made to implement the regulations. Enclosure I contains more details on
    our scope and methodology. We conducted our review between July 2005 and
    May 2006 in accordance with generally accepted government auditing
    standards.

    4On May 30, 2006, Head Start issued a Notice of Proposed Rulemaking (NPRM)
    that, if finalized, would expand the definition of "good cause" under the
    regulations to allow for a waiver of the restraint and monitor
    requirements if the grantee demonstrates that compliance with these
    requirements would result in a significant disruption to the grantee's
    program and that waiving these requirements would be in the best interest
    of the children involved. This provision differs from the earlier waiver
    process in that the cost of complying could be considered when determining
    whether good cause exists for a waiver.

    5Traditionally, large school buses have relied on compartmentalization-a
    system of closely spaced and padded seats that absorb and cushion riders
    from impact-as opposed to belts or restraints to protect school age
    children during a crash. However, NHTSA is considering requirements for
    lap/shoulder belts in small school buses and standards for voluntarily
    installing lap/shoulder belts in large school buses. See glossary in encl.
    II for additional information on child safety restraints.

    6Some grantee, school district, and transit officials have raised concerns
    about using restraints in the event of a fire or a bus being submerged in
    water. National Highway Traffic Safety Administration (NHTSA) and National
    Transportation Safety Board (NTSB) officials indicated that only two fatal
    accidents have occurred that involved fire or water and that current
    school bus safety standards for fuel tanks and emergency exits are more
    stringent. NHTSA officials also explained that having preschool children
    in restraints would keep them in their seats in the event of an accident,
    resulting in fewer injuries and facilitating the evacuation of the bus as
    the children would be able to walk out unassisted.

    On May 16, 2006, we briefed your staff on the results of our review. This
    report formally conveys the information provided during that briefing.
    (See encl. II for the briefing slides.)

    BACKGROUND

    Head Start issued transportation regulations in 2001 that included
    requirements covering equipment, personnel, and training (e.g., for bus
    drivers) for transporting Head Start children; in particular, the
    regulations mandated that grantees use some type of school bus-or an
    alternative vehicle that is similar to a school bus-and required that
    children be placed in child restraints and accompanied by bus monitors.
    Head Start worked with two agencies within the U.S. DOT-NHTSA and FTA-to
    develop the regulations. NHTSA is responsible for developing
    transportation safety standards that protect children in an accident,
    including those for school buses. These standards include, for example,
    roll over protection and joint strengthening, and require crash testing to
    ensure school buses meet them. FTA provides financial assistance to states
    to develop new transportation services and improve, maintain, and operate
    existing systems that serve multiple populations, including older adults
    and people with disabilities. Transit agencies receiving FTA funding must
    use buses that meet NHTSA standards for buses, pass FTA's performance
    testing, and comply with ADA requirements, among other requirements.
    However, these buses do not meet NHTSA's school bus safety standards and
    most cannot accommodate child safety restraints;7 as such, the Head Start
    transportation regulations do not include public transit buses among the
    vehicles allowed to transport children.

    To ensure that transportation is as widely available as possible, other
    provisions of the Head Start regulations require that grantees coordinate
    transportation with other human services programs, many of which also
    provide transportation services.8 Head Start grantees-particularly those
    in rural areas-have relied on school systems and, to a lesser extent,
    public transit agencies to transport children. Coordinating transportation
    services has also been a priority of Congress and the White House in
    recent years. For example, in 2005, Congress passed the Safe, Accountable,
    Flexible, and Efficient Transportation Equity Act-A Legacy for Users
    (SAFETEA-LU), which requires that human services organizations receiving
    FTA funding targeted to older adults, persons with disabilities, and
    persons with lower incomes provide transportation services derived from a
    locally-developed coordinated public transit human services transportation
    plan.

    7For additional information on transit buses, see the glossary in encl.
    II.

    SUMMARY OF FINDINGS

    Concerning the research and cost information that Head Start considered,
    we found that:

    The Office of Head Start considered safety research and data in developing
    the regulations. Research and safety data from NHTSA, the National
    Transportation Safety Board (NTSB)-an independent federal agency charged
    with investigating transportation accidents and identifying safety
    improvements-and the National Academy of Science's Transportation Research
    Board shows that buses-both school buses and other types, such as transit
    buses-have lower fatality rates than other modes of transportation. For
    example, NHTSA data indicates school buses have 0.2 fatalities per 100
    million vehicle miles traveled as compared to cars carrying children,
    which have 1.5 fatalities per 100 million vehicle miles traveled. NTSB
    also recommended to Head Start that children be transported in vehicles
    meeting NHTSA's school bus standards. NHTSA data also shows that children
    of all ages are safer when wearing height- and age-appropriate restraints
    when traveling on school buses. NHTSA's crash testing of small school
    buses in 1997 and 1999 demonstrated that the severity of head injuries
    exceeded acceptable levels when preschool age children were not restrained
    compared with when they were restrained; this led NHTSA to conclude that
    compartmentalization did not sufficiently protect preschool-age children
    and that they were safer using restraints. The NTSB concurred with NHTSA's
    recommendation. NHTSA's 2002 report to Congress on school bus
    safety9--which addresses large school buses-indicates that lap/shoulder
    belts offer some benefit in reducing the risk of serious injury to older
    children.10 NHTSA's research, however, has been limited to school buses as
    NHTSA has not conducted crash testing to assess the risk for preschool age
    children using restraints on transit buses.

    The requirement for a bus monitor was based on Head Start's conclusion
    that young children on a bus should be supervised. Although the Office of
    Head Start did not research the need for monitors, it based this
    requirement on the belief that preschool-age children and younger who ride
    a bus should be supervised by an adult monitor in case the driver becomes
    disabled.

    8For example, in 2003, GAO reported that 62 federal programs funded
    transportation services and that many of them did not coordinate with each
    other. See GAO, Transportation-Disadvantaged Populations: Some
    Coordination Efforts among Programs Providing Transportation Services, but
    Obstacles Persist, GAO-03-697 (Washington, D.C.: June 30, 2003).

    9National Highway Traffic Safety Administration, Report to Congress:
    School Bus Safety: Crashworthiness Research, (Washington, D.C.: April
    2002).

    10NHTSA has found, however, that lap/shoulder belts are not appropriate
    for preschool-age children. Consequently, these younger children would
    require child safety restraints on large buses to achieve the same
    benefits in reducing serious injuries as older children using lap/shoulder
    belts.

    The Office of Head Start no longer has supporting documentation for its
    cost estimate of $18.9 million for implementing the regulations. Without
    this documentation, we cannot determine the reliability of the data Head
    Start used to develop its estimates. However, Head Start has lacked the
    basic information about transportation services offered by its grantees
    necessary to have calculated a reliable estimate when developing the
    regulations or to answer future questions about the regulations' costs or
    effects. This is because the Office of Head Start has not systematically
    gathered information on the transportation services that grantees provide.
    ACF regional offices were able to provide us with some information about
    the transportation services of their grantees, but the information was
    neither standardized nor in any type of database that could be aggregated
    for purposes of analysis.

    Regarding grantees' actions to implement the regulations and the extent to
    which they sought extensions and waivers, we found that:

    Grantees have made progress in implementing the regulations. Approximately
    64 percent report that they have finished implementing the regulations
    while 18 percent reported being almost finished. The remaining 18 percent
    reported being either half-way or less than half-way finished, or not
    sure.

    Almost all grantees reported primarily using a vehicle type that complies
    with the regulations. Ninety-seven percent of grantees reported primarily
    using either a school bus (93 percent) or the alternative vehicle allowed
    by the regulations (4 percent) to transport Head Start children on a daily
    basis. Bureau officials stated that they purposefully provided a long
    period of time-approximately 5 years-to implement the vehicle provisions
    in order to help ensure that grantees had adequate time to replace their
    old vehicles with ones that would be in compliance with the regulations.

    Grantees reported taking a variety of actions to meet the restraint and
    monitor requirements. Most grantees reported (1) either buying restraints
    and retrofitting their buses with them, or having had vehicles with
    restraints already in them; and (2) adding the bus monitor
    responsibilities to duties of existing staff or having had monitors
    already in place.

    Some transit agencies and other transportation providers who work with
    Head Start are facing difficulties in using the alternative vehicle. This
    is due to a lack of guidance for adapting it to transport other
    populations in addition to Head Start children. While it was developed so
    that grantees' transportation partners could meet the requirements of both
    Head Start and other groups, such as older adults or people with
    disabilities, NHTSA did not define how the vehicle could differ with
    respect to school bus features such as narrow aisle width, high-back
    seats, narrow, high steps, and compartmentalized seating. These features
    make using the vehicle difficult for older adults and people with
    disabilities.

    Fewer grantees requested more time to implement the restraint and monitor
    provisions in 2006 compared to 2004, but the number of waiver requests is
    unknown. In 2006, 19 percent of grantees submitted extension requests,
    dropping from 30 percent in 2004.11 As for waivers requested under the
    general waiver authority provided for in the regulations, the Office of
    Head Start officials stated that they were unaware that any were
    submitted. However, we obtained copies of some waiver requests or the
    Office of Head Start's denials of them from a few regional offices and
    grantees. Additionally, bureau officials confirmed that they have not
    specifically defined criteria for submitting a waiver to guide grantees in
    applying for a waiver or the bureau in approving or denying waiver
    requests.

    With respect to the costs and effects on grantees associated with
    implementing the regulations, we found that:

    Many grantees reported some cost effects from implementing the
    regulations, but noted that they were facing other budgetary pressures.
    Fifty-six percent of grantees reported no more than moderate cost effects
    on their transportation budgets from implementing the vehicle, restraint,
    or monitor requirements while 44 percent reported experiencing large or
    very large increases associated with one or more of these requirements.
    However, grantees that we visited stated that other costs, such as health
    insurance, affected their budgets as much as or more than the regulations.

    Historically, Head Start helped grantees with the cost of purchasing
    vehicles and restraints through supplemental money called Program
    Improvement (PI) funds, providing grantees a total of approximately $76
    million in fiscal years 2001 through 2005.12 However, grantees are now
    expected to pay for replacing vehicles and restraints out of annual
    operating monies or nonfederal sources.

    Grantees are experiencing effects to transportation services or program
    operations as a result of implementing the regulations. Fifty-eight
    percent of grantees reported at least one effect on transportation
    services as a result of the regulations, most often noting that they
    changed transportation routes (83 percent) or reduced transportation
    services (50 percent). Sixty-seven percent of grantees also reported that
    implementing the regulations had at least one effect on their program
    operations, most often reporting that they increased the number of staff
    (58 percent); increased staff hours (54 percent); changed, reduced, or
    eliminated other program services (49 percent); or reduced staff hours in
    the classroom (49 percent).

    Some grantees are facing difficulties sustaining transportation
    partnerships. Thirty-six percent of grantees contracted with or used
    another organization-mostly school systems-for transportation services to
    at least some or all of their program sites. About a quarter of them
    reported that their transportation partners discontinued service for this
    program year while approximately 39 percent of these grantees reported
    that the contractor would discontinue services for the 2006/2007 program
    year. For example, 14 of Iowa's 15 DOT regions provided transportation via
    transit buses to Head Start grantees prior to the regulations; since the
    regulations' issuance, 9 have discontinued or plan to discontinue some or
    all services to Head Start grantees, primarily because transit buses do
    not meet the definition of an allowable vehicle under the regulations.
    Although Iowa's transit buses were built to meet several of NHTSA's school
    bus crashworthiness standards and can accommodate child restraints, they
    do not meet all of them, such as compartmentalization. According to Iowa
    DOT officials, the loss of Head Start funding has resulted in some Iowa
    transit agencies reducing services, raising costs, or both for others they
    serve, such as older adults or people with disabilities. FTA and transit
    officials indicated that other transit agencies that have had a history of
    coordinating human services transportation have encountered similar
    difficulties.

    11We do not have data to determine the reasons for the decline in
    extension requests between 2004 and 2006. However, our survey data shows
    that grantees have taken actions to comply with the regulations either by
    making the required changes or, in some cases, reducing or eliminating
    transportation services.

    12This figure only represents the amount of PI funding that was provided
    to help grantees in implementing some provisions of the transportation
    regulations; it does not represent the total amount of PI funding awarded
    by Head Start for these years.

    CONCLUSIONS

    Many grantees have implemented the transportation regulations, with some
    experiencing adverse program and budgetary effects to do so, including
    reducing transportation services. But the Office of Head Start does not
    track transportation services that grantees provide and thus will not know
    if grantees will be able to continue to comply, or, if over time, other
    budget pressures will lead more grantees to cut transportation. These cuts
    could ultimately affect grantees' ability to meet enrollment and other
    program goals, or reduce transportation safety by children using less safe
    forms of transportation.

    The waiver process will be the key mechanism for grantees to bring
    compliance issues to the Office of Head Start's attention. However, the
    Office of Head Start lacks a management process for tracking and
    considering waivers. Developing such a process would also allow the bureau
    to define the circumstances or issues on which it needs NHTSA's and FTA's
    expertise. Further, the bureau has not specifically defined its criteria
    for "good cause" so that grantees would know the conditions under which
    adhering to the regulations would create a safety hazard appropriate for
    requesting a waiver. The absence of a clear process and criteria may pose
    a barrier for grantees in using this mechanism and reduce grantees'
    assurance that their issues will be weighed appropriately.

    Transit agencies are facing difficulties addressing dual goals: meeting
    the mobility needs of multiple populations including Head Start children,
    people with disabilities, and older adults while addressing federal safety
    requirements. While the federal government has encouraged human service
    and transit agencies to use one type of vehicle to more efficiently
    transport multiple populations, there has been limited federal guidance on
    simultaneously achieving both efficient mobility and safety goals.
    Specifically, few transit agencies use the alternative vehicle because,
    while it meets Head Start safety requirements, it does not comply with ADA
    requirements and consequently is not practical for transporting older
    adults and people with disabilities. Information on how the alternative
    vehicle can be adapted for transit would be useful to both transit
    agencies and Head Start grantees given the program's mandate to provide
    services to children with disabilities.

    Furthermore, some transit agencies-in an effort to maintain long-standing
    coordination efforts-have adapted transit buses to incorporate standards
    that they believe sufficiently protect preschool age children. However,
    NHTSA, FTA, and Head Start have not determined the safety features needed
    for transit buses to sufficiently protect these children. Thus, transit
    agencies are faced with reducing or eliminating service to Head Start,
    resulting in some children being transported in vehicles that are less
    safe or not being able to attend Head Start at all.

    RECOMMENDATIONS FOR EXECUTIVE ACTION

    In order to determine the ability of grantees to provide transportation
    services and to define the waiver process, we make the following three
    recommendations to the Office of Head Start:

               o  Systematically track transportation services provided by
               grantees so that the Bureau can determine changes in the
               availability of these services, especially any reduction in them.
               o  Establish a waiver process that specifies criteria for
               submitting waivers, including more specific guidance on what
               constitutes "good cause," lists the responsible entities for
               review and approval, and documents the receipt, review, and final
               disposition of each waiver. Should any waiver requests submitted
               require Head Start to address issues concerning vehicles, the
               waiver process should include consultation with NHTSA and FTA as
               appropriate.
               o  Once a process has been established, take steps to ensure that
               grantees and regional staff know about it and understand how it
               works.

    In order to enable grantees and transit agencies to better coordinate
    transportation services, we make the following two recommendations to DOT,
    in consultation with Head Start:

               o  Develop guidance on adapting the alternative vehicle to
               incorporate ADA requirements and communicate this guidance to Head
               Start grantees and transit agencies.
               o  Determine if certain safety features could be incorporated into
               transit buses used by Head Start grantees to provide a level of
               safety comparable to school buses or alternative vehicles in
               transporting preschoolers.

                            o  If this determination cannot be made before the
                            remaining deadlines expire, we recommend that Head
                            Start, in consultation with DOT, should determine on
                            a case-by-case basis whether grantees using transit
                            vehicles with child safety restraints can continue to
                            do so until such a determination can be made.
                            o  If DOT determines that transit vehicles with
                            appropriate safety features would afford suitable
                            protections, we recommend that Head Start adopt these
                            features into the final Head Start transportation
                            regulations.

    AGENCY COMMENTS

    We provided a draft of our report for comment to the Administration for
    Children and Families (ACF); and the Department of Transportation (DOT),
    specifically NHTSA and FTA. DOT provided technical comments which we
    incorporated where appropriate. Regarding the lack of guidance on
    achieving mobility and safety goals, FTA noted that it has a research
    project under way aimed at developing a new small bus that would meet both
    of these goals. We encourage FTA to continue these efforts.

    ACF agreed with the two recommendations regarding the waiver process and
    indicated that it would consider our recommendation that it track the
    availability of transportation services. ACF also provided technical
    comments that we included in the report where appropriate. (See encl. III
    for a copy of ACF's comments.)

    As agreed with your office, unless you publicly announce its contents
    earlier, we plan no further distribution of this report until 30 days
    after its issue date. At that time, we will send copies of the report to
    relevant congressional committees and other interested parties and will
    make copies available to others upon request. The report will also be
    available on GAO's Web site at http://www.gao.gov. If you or your staff
    have any questions about this report, please contact either one of us at
    (202) 512-7215 (Marnie Shaul) or (202) 512-6570 (Katherine Siggerud).
    Betty Ward-Zukerman and Cathy Colwell, Glen Trochelman-Assistant
    Directors-Lynn Filla-Clark and Janet Mascia-Analysts-in-Charge-and Sandra
    Tasic, Jeffrey Weinstein, Stuart Kaufman, and Nancy Hess also made key
    contributions to this report.

    Marnie Shaul Katherine Siggerud Director, Education, Workforce, and
    Director, Physical Infrastructure Income Security Issues Issues

    Enclosures

    List of Congressional Requesters

    The Honorable Howard P. "Buck" McKeon Chairman The Honorable George Miller
    Ranking Minority Member Committee on Education and the Workforce House of
    Representatives

    The Honorable Don Young Chairman The Honorable James L. Oberstar Ranking
    Minority Member Committee on Transportation and Infrastructure House of
    Representatives

    The Honorable Michael N. Castle Chairman The Honorable Lynn C. Woolsey
    Ranking Minority Member Subcommittee on Education Reform Committee on
    Education and the Workforce House of Representatives

    The Honorable John A. Boehner House of Representatives

    The Honorable Betty McCollum House of Representatives

    The Honorable Anne Meagher Northup House of Representatives

    ENCLOSURE I

    OBJECTIVES, SCOPE, AND METHODOLOGY

    We designed our study to determine the following: (1) the research and
    cost information Head Start considered in establishing the transportation
    regulations; (2) the actions Head Start grantees have taken to implement
    the vehicle, restraint, and bus monitor requirements of the regulations
    and the number of grantees that have sought waivers and extensions; and
    (3) the associated expenses and effects of implementing the regulations on
    grantees and their transportation partners.

    We obtained information to determine these objectives by interviewing
    cognizant federal and state officials as well as representatives from
    associations, advocacy groups, bus manufacturers and dealers, and
    independent transportation contractors; collecting and analyzing extension
    requests from Head Start grantees submitted to the Office of Head Start
    for 2004 and 2006; conducting site visits with Head Start program
    officials and their transportation partners; and surveying a nationally
    representative sample of Head Start grantees and delegates.

    Interviews

    Office of Head Start and HHS Regional Offices: We interviewed officials
    from the Office of Head Start to discuss, among other things, the
    background and development of the Head Start transportation regulations,
    information on grantees' transportation services, and the extension and
    waiver process. We also interviewed Head Start program staff in the 10 HHS
    Regional offices as well as officials from the American Indian-Alaska
    Native and Migrant and Seasonal Program Branches responsible for Head
    Start grantees and delegates serving migrant, American Indian, and Native
    Alaskan families and children. From the regional offices, we collected
    data on the amount of Program Improvement funds awarded to grantees for
    purchasing buses and child restraints, and discussed their perspective on
    the impact of the regulations on Head Start grantees and delegates in
    their regions.

    Transportation Agencies: We interviewed officials from the U.S. Department
    of Transportation, including the National Highway Traffic Safety
    Administration (NHTSA) and the Federal Transit Administration (FTA). We
    also interviewed officials from the National Transportation Safety Board
    (NTSB), an independent federal agency charged by Congress to investigate
    transportation accidents. Our interviews inquired about the current safety
    research regarding transporting preschool children on school buses or
    alternate vehicles, the agencies' involvement in helping Head Start to
    develop the transportation regulations, issues related to the development
    of the alternative vehicle, and the impact of the regulations on transit
    agencies working with Head Start grantees and other human service
    organizations. 13

    Associations and Advocacy and Trade Organizations: In addition to federal
    officials, we also met with representatives of transportation associations
    including the American Public Transportation Association, Community
    Transportation Association of America, National Association of State
    Directors of Pupil Transportation Services, the National School
    Transportation Association, and

    13The regulations describe this vehicle as an Allowable Alternate Vehicle;
    NHTSA defines it as a Multi Function School Activity Bus. For purposes of
    this report, we will refer to it as the alternative vehicle.

    ENCLOSURE I ENCLOSURE I

    the National Association for Pupil Transportation to discuss the impact of
    the regulations on their members. We also met with representatives of the
    American Academy of Pediatrics to discuss safety issues concerning the
    transportation of preschool age children. We spoke with representatives
    from the National Head Start Association as well as several of their
    members at their annual state directors' meeting to learn more about the
    perspective of Head Start grantees on implementing the regulations.
    Finally, we interviewed representatives from bus manufacturers and
    dealers, as well as independent transportation contractors primarily to
    gather cost information about school buses, alternative vehicles, and
    contracting for transportation services.

    Site Visits

    We visited seven Head Start grantees located in five different states and
    ACF regions in order to learn more about the effects on grantees' budgets
    and program services from implementing the regulations, and to meet with
    their transportation partners, where appropriate, to discuss the impact of
    the regulations on providing transportation to Head Start. The states and
    HHS Regions in which the selected grantees operated were Indiana (Region
    5), Iowa (Region 7), Kentucky (Region 4), Massachusetts (Region 1), and
    Washington (Region 10). Overall, the grantees were selected based on
    geographical diversity; size (e.g., funded enrollment); organization type;
    and to achieve a mix of grantees that filed requests in 2004 for more time
    to implement the restraint and monitor requirements and those that did
    not. (See table 1.) In addition to these criteria, we specifically
    selected Iowa and Washington because of unique partnerships between some
    Head Start grantees in those states and organizations that helped them
    transport Head Start children to and from their centers.

    Table 1: Site Selection Characteristics

                                                     Funded
                           ACF                   enrollment Filed extension
    Grantee location region Organization type (children) request in 2004
    Greencastle,          5 Non-profit               415 No
    Ind.
    Louisville, Ky.       4 School system          1,850 Yes
    Fort Dodge, Iowa      7 Non-profit               194 Yes
    Renton, Wash.        10 Government agency      1,703 Yes
    Pullman, Wash.       10 Non-profit                72 No
    Boston, Mass.         1 Community action       2,000 Yes
                               agency
    Westfield, Mass.      1 School system            205 No

    Documentation

    In conducting our work, we reviewed relevant background information on the
    programs, regulations, legislation, and transportation research studies
    and viewed videotapes of NHTSA's crash testing of small school buses with
    preschool-age dummies. We also collected and analyzed all extension
    requests for more time to implement the restraint and monitor provisions
    from Head Start grantees to the Office of Head Start, as well as some
    waiver request letters that either regional offices or grantees provided
    us. Finally, we collected data on the amount of Program Improvement funds
    awarded to Head Start grantees used to purchase buses or child restraints

    ENCLOSURE I ENCLOSURE I

    from all HHS regional offices. While we asked for this data for fiscal
    years 2001 through 2005, some Regional offices were not able to provide
    this information for all years. Specifically, we did not receive data from
    four regions for fiscal years 2001 and 2002, and from two regions for
    fiscal year 2003. Also some regions could not report the number of buses
    that had been financed, in whole or in part, with Head Start funding, or
    the number sold or taken out of service because such requests were not
    retained.

    Survey Development and Sample Selection

    We developed the survey questionnaire and conducted five pretests of its
    content and format with Head Start grantee directors and others
    knowledgeable about the transportation of children to and from Head Start
    centers. The pretests were conducted either in-person or by telephone.
    During these pretests, we asked Head Start grantees whether the questions
    were clear and unbiased, whether the terms contained in the questionnaire
    were accurate and precise, and whether they would be able to provide us
    with accurate data on various attributes of the vehicles used to transport
    children. We made changes to the questionnaire based on the pretest
    results.

    The surveys were conducted using self-administered electronic
    questionnaires posted on the World Wide Web. We sent e-mail notifications
    to all sampled Head Start grantees on January 5, 2006, to inform them that
    our Web-based survey would soon be activated. On January 10, 2006, we sent
    each potential respondent another e-mail containing a unique username and
    password to ensure that only Head Start grantees included in our sample
    could participate in the survey. To encourage respondents to complete the
    questionnaire, we sent follow-up e-mails to those who had not yet
    responded on January 19, 2006; January 27, 2006; and on February 6, 2006.
    During the week of February 13, 2006, GAO support staff made telephone
    calls to grantees that still had not responded in order to encourage them
    to respond. We closed the survey on February 28, 2006.

    We were interested in obtaining information on transportation services
    provided by Head Start grantees and their progress and challenges in
    implementing the Head Start transportation regulations. To do this, we
    drew a stratified random probability sample of 449 Head Start grantees or
    delegates from a population of 1,928 agencies that operate local Head
    Start programs. Grantees and delegates that operated only Early Head Start
    programs were excluded from the population from which we selected our
    sample. We selected our sample to represent eight strata defined by the
    organization type (community action agencies, government or tribal
    entities, private, non-profit, or school systems) and whether the program
    had filed an extension request in 2004. Ultimately, we received 339
    responses for an adjusted response rate of 77 percent. The division of the
    population, the sample, and the respondents across the eight strata can be
    found in table 2. Each sampled grantee or delegate was subsequently
    weighted in the analysis to represent all the members of the population.

    ENCLOSURE I ENCLOSURE I

    Table 2: Sample Disposition

                                                         Total  Total
    Stratum                                      population sample   Number of
        number Stratum description                        size   size respondents
             1 CAA that filed an extension request         233     44          33
             2 CAA that did not file an extension          405     76          64
               request
             3 School system that filed an                 132     40          36
               extension request
             4 School system that did not file an          235     70          53
               extension request
             5 Private organization that filed an          122     21          18
               extension request
             6 Private organization that did not           560     99          72
               file an extension request
             7 Government entity that filed an              57     24          13
               extension request
             8 Government entity that did not file         184     75          50
               an extension request
         Total                                           1,928    449         339

    All percentage estimates from our sample have margins of error (that is,
    confidence interval widths) of plus or minus 10 percentage points or less,
    at the 95-percent confidence level unless otherwise noted.

    In addition to sampling errors, the practical difficulties of conducting
    any survey may introduce errors, commonly referred to as non-sampling
    errors. For example, difficulties in how a particular question is
    interpreted, in the sources of information that are available to
    respondents, or in how the data are entered into a database or were
    analyzed, can introduce unwanted variability into the survey results. We
    took steps in the development of the questionnaire, the data collection,
    and the data analysis to minimize these non-sampling errors. For example,
    a survey specialist designed the questionnaire in collaboration with GAO
    staff with subject matter expertise. Then, the draft questionnaire was
    pretested with a number of Head Start officials to ensure that the
    questions were relevant, clearly stated, and easy to comprehend. In
    addition, the questionnaire was reviewed by a second survey specialist.
    When the data were analyzed, a second, independent analyst checked all
    computer programs. Since this was a Web-based survey, respondents entered
    their answers directly into the electronic questionnaire. This eliminated
    the need to have the data keyed into a database thus removing an
    additional source of potential error.

    Sample Selection for Analyzing Extension Requests

    To characterize reasons for Head Start agencies filing an extension
    request, we drew a stratified random probability sample from the
    population of 581 agencies that filed an extension request in 2004. We
    selected our sample for two strata defined by the Head Start region
    (Region 3, all other regions). Ultimately, we examined 188 extension
    requests. The division of the population and the division of the sample
    across the two strata can be found in table 3. Each sampled agency that
    filed an extension request was subsequently weighted in the analysis so
    that final results represent all the members of the population of agencies
    that filed extension requests.

    ENCLOSURE I

    Table 3: Sample Disposition

                                           Total agencies that filed Total sample
    Stratum number Stratum description       an extension request         size
             1        Region 3 agency                             68           68
                      requests
             2        All other regions'                         513          117
                      agency requests
           Total                                                 581          185

    All percentage estimates from our sample of the extension requests have
    margins of error (that is, confidence interval widths) of plus or minus 7
    percentage points or less, at the 95-percent confidence level unless
    otherwise noted.

    ENCLOSURE II

    ENCLOSURE III

    (130514)
    *** End of document. ***