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 				 

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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)
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