Head Start: Additional Information on Implementation of 	 
Transportation Regulations (17-NOV-06, GAO-07-194R).		 
                                                                 
The Head Start program, administered by the U. S. Department of  
Health and Human Services (HHS), provides grants to local	 
organizations to offer comprehensive early childhood services to 
approximately 900,000 poor children, ages 5 years or younger.	 
While transportation is not a required service, in order to make 
Head Start more widely available to very poor children, over 70  
percent of Head Start grantees and delegates provide		 
transportation to at least some of the children they enroll. To  
address concerns about transporting children safely, the 1992	 
Head Start Improvement Act directed the Office of Head Start	 
(OHS) to develop transportation regulations to ensure the safety 
and effectiveness of transportation services made available to	 
children by Head Start grantees and delegates. In 2001, citing	 
safety concerns related to vehicles as well as the variation in  
states' standards for pupil transport, Head Start issued	 
regulations governing transportation services. Among other	 
things, the regulations mandated that grantees and delegates use 
school buses or similar alternative vehicles and that children be
placed in restraints and attended by bus monitors. In commenting 
on the 2001 regulations, grantees and delegates expressed	 
concerns about potential unintended effects on Head Start	 
programs of implementing these requirements, such as reducing the
availability of transportation and thereby encouraging enrollees 
to use less safe modes of traveling to and from Head Start. GAO  
was asked to examine these concerns and in July 2006 issued a	 
report, Head Start: Progress and Challenges in Implementing	 
Transportation Regulations (GAO-06-767R), which found in part	 
that many grantees and delegates had implemented the Head Start  
transportation regulations with some experiencing adverse program
and budgetary effects in doing so. Congress subsequently asked us
to provide additional analysis of some information that we	 
obtained through our 2006 study. Specifically, Congress us to 1) 
compare the characteristics of surveyed grantees and delegates	 
that indicated they were facing challenges with implementing the 
regulations to those of grantees and delegates that did not, and 
2) provide information on the numbers of children transported by 
grantees and delegates that submitted requests to OHS in 2006 for
more time to implement the monitor and restraint provisions.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-194R					        
    ACCNO:   A63507						        
  TITLE:     Head Start: Additional Information on Implementation of  
Transportation Regulations					 
     DATE:   11/17/2006 
  SUBJECT:   Children						 
	     Disadvantaged persons				 
	     Education program evaluation			 
	     Grant monitoring					 
	     Motor vehicles					 
	     Reporting requirements				 
	     Safety regulation					 
	     Safety standards					 
	     Transportation					 
	     Transportation research				 
	     Transportation safety				 
	     Program implementation				 
	     Head Start Program 				 

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GAO-07-194R

   

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United States Government Accountability Office

Washington, DC 20548

November 17, 2006

The Honorable George Miller Ranking Minority Member Committee on Education
and the Workforce House of Representatives

Subject: Head Start: Additional Information on Implementation of
Transportation Regulations

The Head Start program, administered by the U. S. Department of Health and
Human Services (HHS), provides grants to local organizations to offer
comprehensive early childhood services to approximately 900,000 poor
children, ages 5 years or younger.^1 While transportation is not a
required service, in order to make Head Start more widely available to
very poor children, over 70 percent of Head Start grantees and delegates
provide transportation to at least some of the children they enroll.

To address concerns about transporting children safely, the 1992 Head
Start Improvement Act directed the Office of Head Start (OHS) to develop
transportation regulations to ensure the safety and effectiveness of
transportation services made available to children by Head Start grantees
and delegates. In 2001, citing safety concerns related to vehicles as well
as the variation in states' standards for pupil transport, Head Start
issued regulations governing transportation services. Among other things,
the regulations mandated that grantees and delegates use school buses or
similar alternative vehicles and that children be placed in restraints and
attended by bus monitors.

Grantees and delegates were required to meet most provisions of the
regulations shortly after issuance, except for the requirements regarding
age-appropriate child restraints, bus monitors, and the use of school
buses or alternative vehicles. Grantees and delegates were expected to
comply with the restraint and monitor requirements in 2004, unless they
requested a time extension, in which case they were expected to comply by
the end of the 2006 program year.^2 Grantees and delegates had two
opportunities --one in January 2004 and one in December 2005--to request
more time from OHS to implement the restraint and bus monitor
requirements. Currently, the compliance date for vehicles is December
2006.

In commenting on the 2001 regulations, grantees and delegates expressed
concerns about potential unintended effects on Head Start programs of
implementing these requirements, such as reducing the availability of
transportation and thereby encouraging enrollees to use less safe modes of
traveling to and from Head Start. GAO was asked to examine these concerns
and in July 2006 issued a report, Head Start: Progress and Challenges in
Implementing Transportation Regulations ( [7]GAO-06-767R ), which found in
part that many grantees and delegates had implemented the Head Start
transportation regulations with some experiencing adverse program and
budgetary effects in doing so. You subsequently asked us to provide
additional analysis of some information that we obtained through our 2006
study. Specifically, you asked us to 1) compare the characteristics of
surveyed grantees and delegates that indicated they were facing challenges
with implementing the regulations to those of grantees and delegates that
did not, and 2) provide information on the numbers of children transported
by grantees and delegates that submitted requests to OHS in 2006 for more
time to implement the monitor and restraint provisions.^3

1 The total enrollment figure is from the Office of Head Start for fiscal
year 2005 and includes enrollment for both Head Start and Early Head Start
programs. Head Start generally serves children ages 3 to 5 years old,
while Early Head Start serves children from birth to age 3 and low-income
pregnant women.

^2 The effective compliance dates for the restraint and monitor provisions
were first extended to January 2006 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. Subsequent to this, Public Law 109-234 changed the
compliance date for vehicles to December 2006. On October 4, 2006, HHS
published a final rule allowing grantees and delegates to annually request
a waiver from the restraint and monitor requirements based on good cause.

For grantees and delegates included in our survey, we defined those
reporting challenges as grantees and delegates that had (1) stopped
providing transportation services at all of their sites wholly or in part
due to implementing the regulations, (2) decreased or stopped
transportation services at a portion of their sites wholly or in part
because of the regulations, (3) filed an extension request in 2004 for
more time to implement the monitor and child restraint requirements, or
(4) not completed implementing the regulations. For grantees and delegates
that reported that they currently provided some level of transportation
services when we surveyed them in early 2006, the survey collected
additional information about the number of children enrolled and
transported, the number of centers operated, use of contractors or other
organizations to transport children, and the number of buses used on a
daily basis. We used these data to determine if those reporting challenges
in implementation had different characteristics than those that did not.
We did not collect similar data on the characteristics of grantees and
delegates that did not provide transportation, beyond asking whether they
considered this a result of the Head Start regulations, a result of both
Head Start regulations and other factors, a result of other reasons, or
were not sure.

The timing for our survey did not allow us to gather data on those
grantees and delegates that applied for the 2006 extensions. Instead, to
determine the number of children that these grantees and delegates
transported, we analyzed additional information extracted from the
requests that grantees and delegates submitted to OHS through March 10,
2006, for more time to implement the monitor and child restraint
requirements. Some additional extension requests may have been submitted
after that date. We did not have data to determine how those applying for
the 2006 extensions compared to those that didn't apply. We also estimated
from our survey the number of children transported by grantees and
delegates who applied for an extension request in 2004. We conducted the
additional analysis for this report between October and November 2006, in
accordance with generally accepted government auditing standards.

Summary

Briefly, we found that among grantees and delegates that offered
transportation, a little less than a third reported challenges in
implementing the regulations. These grantees and delegates did not enroll
or transport larger numbers of children than grantees and delegates that
did not report challenges, but had more centers and used more buses on a
daily basis and were more likely to use another organization, usually a
school system, to provide transportation services. Grantees and delegates
requesting extended time to comply by March 2006 reported transporting
almost 75,000 children, which is about 22 percent of the total number of
Head Start children transported based on estimates derived from our 2006
survey.

^3We base our findings, in part, on our survey of a nationally
representative sample of Head Start grantees and delegates and delegates.
Our analysis resulted in estimates that are generalized to the larger
population of Head Start programs. For other details of our scope and
methodology see [8]GAO-06-767R , encl. I.

Specifically, with regard to grantees and delegates facing challenges in
implementation, we found that

           o Of the approximately 1890 grantees and delegates that GAO
           estimates were directly operating Head Start programs as of
           February 2006, an estimated 29 percent--or 540 grantees and
           delegates--either did not provide transportation services or had
           decreased transportation services at some portion of their program
           sites wholly or party as a result of the regulations. Specifically
           we estimate that 190 grantees and delegates did not provide
           transportation to the centers they were operating as a result of
           the regulations or a combination of the regulations and other
           factors. GAO estimates that an additional 350 grantees and
           delegates had decreased or stopped transportation services at some
           portion of their program sites (but continued to provide it to
           others) and attributed this wholly or partly to the regulations.^4

           o Based on the results of our survey, grantees and delegates that
           had filed extensions in 2004 did not differ in the numbers of
           children enrolled or transported from those that did not file for
           extensions, but had larger numbers of centers and used more buses
           on a daily basis. This same finding held true for grantees and
           delegates that had not finished implementing the regulations at
           the time of our survey compared to those that had. About 29
           percent of the estimated 1,370 grantees and delegates that
           provided some level of transportation filed an extension in 2004
           to delay the effective date of the restraint and monitor
           provisions. We estimate that 36 percent of grantees and delegates
           that were providing some level of transportation services had not
           completely finished implementing the regulations when we surveyed
           them in 2006.

           o Grantees and delegates that contracted with or used another
           organization to transport some or all of their Head Start children
           were more likely to have filed 2004 extension requests than
           grantees and delegates that did not. Specifically, an estimated 48
           percent of grantees and delegates using another organization for
           transportation services filed an extension versus 19 percent of
           grantees and delegates that did not use another organization. Of
           those grantees and delegates that partnered with others to supply
           transportation, we estimate that 60 percent used a school system.

With regard to grantees and delegates that filed an extension request in
2006, we found that

           o A total of 378 grantees and delegates submitted extension
           requests by March 2006, representing 19 percent of all Head Start
           grantees and delegates or approximately 28 percent of grantees and
           delegates that we estimated were providing transportation services
           at the time of our survey. At the time they filed 2006 extensions,
           these grantees and delegates reported transporting almost 75,000
           children, or about 22 percent of the 346,000 Head Start children
           that we estimated were transported at the time of our survey.

           o In contrast, GAO estimates that 2004 extension filers provided
           transportation services to about one-third of the total number of
           Head Start children transported in program year 2005,
           approximately 109,000 children of the estimated total of
           346,000.^5

^4Of the estimated 1890 grantees and delegates operating a Head Start
program, we estimate that approximately 330 grantees and delegates did not
provide any transportation services because of factors other than the
regulations.

^5 Based on our survey, the 95 percent confidence interval for the
estimated number of children transported by those agencies making 2004
extension requests is 77,000 to 140,000 out of an estimated total of
301,000 to 391,000.

Concluding Observations

In most cases, the number of children transported did not seem to predict
which grantees and delegates would report challenges with the regulations.
This would suggest that other variables may be more responsible for the
regulations' posing challenges than the number of children a program is
transporting. These could include the number of routes a Head Start
program has, the amount of geographical dispersion among its centers, and
whether it is a dedicated Head Start transportation system or one that
provides services to other populations.

Close to a third of grantees and delegates decreased or did not provide
transportation services as a result, at least in part, of the regulations.
Information provided in our earlier report suggests that grantees and
delegates face difficult programmatic trade-offs in complying with the new
regulations, and because there are safety advantages in transporting
children by bus, our earlier report recommended that OHS track
transportation services being provided by grantees and delegates so as to
be able to determine the effects that cuts in transportation services may
be having on achieving program goals and maintaining children's safety.

Agency Comments

OHS program officials provided technical comments on our draft report
which we incorporated as appropriate. In commenting on the report, they
emphasized that the October 2006 change to the transportation regulations,
which allows grantees and delegates to apply for annual waivers from the
restraint and monitor requirements, could provide relief from these
requirements for Head Start grantees and delegates who were struggling to
meet these provisions, especially ones working with school systems or
other partners to transport children.

                                   - - - - -

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
the Department of Health and Human Services, relevant congressional
committees, and other interested parties; we will also make copies
available to others upon request. The report can also be obtained through
GAO's Web site at http://www.gao.gov. If you or your staff have any
questions about this report, please contact me at (202) 512-7215. Betty
Ward-Zukerman, Assistant Director; Janet L. Mascia, Analyst-in-Charge; and
Nancy Hess made key contributions to this report.

Sincerely yours,

Cornelia M. Ashby
Director, Education, Workforce, and Income Security
Issues

(130613)

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