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MINUTES - 05141996 - D6
To: BOARD OF SUPERVISORS Contra .• .o L = FROM: Phil Batchelor, County Administrator '` 's Costa County DATE: May 10, 1996 s�q•c6UK`� SUBJECT: CERTIFYING CORRECTIVE ACTIONS TO DEFICIENCIES IN THE HEAD START PROGRAM SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: 1. CONSIDER approving a report from the County Administrator and the Community Services Director regarding corrective action for the deficiencies identified by the federal government for the County's Head Start Program. 2. CONSIDER approving in concept proposals to reorganize the Head Start Program, including systems improvements, training programs and relationships with delegate agencies, subject to meeting and conferring with employee organizations on any impacts. 3. Consider approving the 1-30/70.2 Implementation Plan and the Special Education Local Planning Agency (SELPA) Agreement. BACKGROUND: On March 29, 1996 the federal office for the Administration for Children and Families (ACF) notified Contra Costa County in a follow up on-site review (OSPRI) that there are remaining deficiencies that need to be corrected in the Head Start Program by May 20, 1996. Since that time a major effort has been made by the Board of Supervisors, Policy Council, Head Start employees and County staff to address and correct the remaining deficiencies. CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD ON May 14 ,, 1996 APPROVED AS RECOMMENDED X OTHER X _ IT IS BY THE BOARD ORDERED that the above recommendations are APPROVED; and IT IS FURTHER ORDERED BY THE BOARD that subsequent to the final evalutation by the Federal Government of(ithe:IHeadc:Start .Program,;-Rthe.1 D,irectorcofsCommuhtt:y::Services is,-,DIRECTED to provide quarterly status reports on the Head Start Program to the Family and Human Services Committee and the Family and Human Services Committee is REQUESTED to review these quarterly status reports in the capacity of an oversight committee. VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE X UNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN. ATTESTED May 14 , 1996 Contact: PHIL BATCHELOR,CLERK OF THE BOARD OF cc: County Administrator SUPERVISORS AND COUNTY ADMINISTRATOR Community Services .Department-,r; County Counsel ' 0- BY DEPUTY Technical assistance was offered by the ACF through the use of Development Associates, a Walnut Creek consulting firm familiar with the Head Start Program, to assist in the areas that need significant correction. With their assistance four teams were formed to develop proposals to address the following areas: developing a new organizational chart and reporting relationships; structuring effective support systems; creating a comprehensive and coordinated training program and improving relationships with Delegate Agencies. The outcome of this effort are four proposals that have been shared with staff for input and approved in concept by the Head Start Policy Council on May 9. We view these proposals as a foundation for change and believe that there is a combined commitment of all parties for improvement. In addition, the County Administrator and Director of Community Services have engaged a well-respected, former manager as an independent training consultant to provide management training for all Head Start managers. Mental health issues are being addressed through a coordinated effort between the Community Services Department, Human Resources Department and the County's Employee Assistance Program. Finally, as part of the shared decision making process with the Policy Council, it is necessary to approve both the 1-30/70.2 Implementation Plan and Agreement with Contra Costa Special Education for special education services. FISCAL IMPACT: The AFC will schedule a final follow-up review May 29, 30 and 31, 1996. The recommended actions are necessary to preserve Contra Costa County as the grantee for the $6.2 million Head Start Program. We believe that the corrective action taken to date, and comprehensive and cooperative approach to change that has been exhibited by all involved parties will provide the best opportunity for the Head Start Program to be preserved for the children and parents we serve. -2- Request to Speak Form � ( THREE (3) MINUTE LIMIT) Cro nplete this form and place it in the box near the speakers' rostrum before addressing the Board. htan�e: lhor�� 1 am speaking for myself,or inanK of Sul-InfioN Of ONS 1 wish to speak on Agenda hem # - G= My comments will be: general _for..agal t 1 wish to speak on the subject of _ 1 do not wish to speak but leave these Canniummsts for the Board to consider: Request to Speak Form a- ( THREE (3) MINUTE LIMIT) Complete this form and place it in the box new the Weakers' rostrum before addressing the Board. Name: Phone: Addr 1 am !peaking for myself or organization: * nK of orpt�isatioN CHECK ONE 1 wish to k on Agenda Item My comments will be+ general I/..for_,painst . ,I wish to speak on the "Jed of 1 do not wish to speak but leave # e comments for the Board to corssider: Request to Speak Form � ( THREE (3) MINUTE LIMIT) Complete this form and place it In the box near the speakers' rostrum before addressing the Board. -W W MW O S' �ra2d �z CItr. �KY 1 am speaking for myself l' or . mania of or�nEsatiaa CHECK ONE: 1 wish to speak on Agenda Item My comments will be: g+awo _,for rKt . 1 wish to on the of �s Y _ 1 do not wish to speak but leave these comments for the Board to considerz .DRAFT I-30/70.2 IMPLEMENTATION PLAN 1304.5-2(a):Written procedures for Contra_ Costa Community Services Head Start Program implementation of the 1-30170.2 APPROVED BY THE POLICY COUNCIL: Contra Costa Community SerAce`Mead gtart Program will implement the I- 30.70.2 in the following manner: By Defining: The role of the Parent in Shared Decision Making The role of the Staff in Shared Decision Making The role of the Volunteer The I-30/70.2 chart THE ROLE OF THE PARENT The major role of the parent is to get involved with the Head Start Program. There are four major ways that a parent and/or family member can get involved in the Head Start Program. They are: I: Participation in the process of Making Decisions about the nature and operation of the program; II. Participation in the classroom in their home and/or Family Child Care Home as paid employees, Volunteers or Observers; III. Developing activities for all parents that they have helped to develop; IV. Working with their children in cooperation with the staff at center base, home base and/or with Family Child Care provider. The-first of the three maj or ways is: I. PARTICIPATION IN THE PROCESS OF MAKING DECISIONS ABOUT THE NATURE AND OPERATION OF THE PROGRAM. Decision making . in Contra Costa County Community Services Department Grantee Operated Program and Policy Council level occurs on three levels. The levels for Contra Costa County Community Service Head Start are: #L.. The classroom committee is composed of 1.00% of the parents at each classroom.site; 2 f #2. The Site Committee for the Center Based, Family Child Care,and Home-Based option, is composed of three representatives from each classroom committee; #3. The Policy Council, which is composed of a representative from each site, Home Base, and Family Child Care. Also representatives from Grantee's Delegate Agencies and community representatives. Level One: Classroom Committee Level Level One of the Decision Making process for Contra Costa Community Services Head Start Grantee Operated Program is the Classroom Committee. A classroom committee is composed of 100% of parents whose children currently attend and are currently enrolled in that classroom. Decisions at the classroom committee level deals with the nature and operation of the program at that classroom. Tenure on this committee counts toward the three (3) year term limit. A. Nature of the program at the classroom level means the following 1. Assure that the experiences of the child in the Classroom are creative a multicultural 2. Assure that the experiences for parents are designed for parents and will enhance parental skills 3. Assure that the interests of the parents are expressed in activities designed for the enhancement of skills for parents and classroom staff B. Operation of the program at the Classroom Committee level means the following: 1. Assist teachers, area supervisors, component coordinators/managers in ways that enhance program services 2. Work closely as volunteers with classroom teachers and all other component staff to carry out the daily activities in the classroom 3 , Z i 3. Plan, conduct and participate in the informal (social or other) as well as formal programs (training, meeting, etc.) for classroom parents 4. Elect representatives to the Site Committee 5. Provide input into field trips and end of year celebration 6. Participate with staff in raising funds for activities which parents choose to occur and are not included in either the grant or the parent activity funds during the year Level Two: Site Committee Level Level Two of Decision Making Process for parents occurs at the Site Committee Level which consists of representatives from each classroom committee. Decisions at the Site Committee Level deal with the operation of each classroom. Operation at the. Site Committee Level means the following: 1. Assure that parents of children currently enrolled in each classroom will be given preference for positions for which they qualify. All guidelines for the recruiting/selecting/screening of future employees established by the 1-30/70.2 as well as by the Grantee, Board of Supervisors, Policy Council willbefollowed 2. The role of the Site Committee Representative is to represent the common concerns, needs, issues of all the parents from their classroom 3. Oversees that the experience of all of the children at all classrooms are creative and multicultural 4. Assure that all parents interested in leadership skills have the opportunity to have such skills enhanced 5. Assure that the-common interests of all the parents that expressed in activities designed for the enhancement of skills for parents and all appropriate staff 6. Assure that parents interests are surveyed 7. . Elects a parent representative to the Policy Council. Level.Three: Policy Council Level Of Decision Making 4 Level Three (3) of the Decision Making Process for parents is the Policy Council. The Policy Council operates by virtue of the Delegate Agency Policy Committee and the Grantee Operated Program Site Committee and is composed of at least 50%parents of currently enrolled Head Start children and representatives of agencies from the community. All members serving on the Policy council must be elected or appointed. A Policy Council Member has a voting seat and that seat counts toward the three year allowable total term limit. If an alternate serves in a voting capacity for at least 1/2 of the meetings, then that time is considered a full year. The Grantee, BOS and Policy Council Chair have agreed that community representatives and representatives of the BOS may serve in a voting capacity. A Policy Council member represents their site, agency, or the community at large. Therefore, all council members must be in touch with their constituents. A Community Representative is defined as someone representing a major public or private agency, major community civic or professional organization which HAVE CONCERN FOR CHILDREN OF LOW INCOME FAMILIES AND CAN CONTRIBUTE POSITIVELY TO THE PROGRAM. Parents of former Head Start children may serve as community representatives. At no time can any member of the Policy Council, either current parent or community representative serve more than a total of three years in a policy making group. If a parent has served 3 years on the Council, then after that third term that parent can not serve in a voting capacity throughout the program. Also, a parent who becomes employed in any capacity by the county cannot serve in a voting capacity. The one exception to this rule is that of a Parent who is employed by one of the agencies represented on the Council and is appointed to the Council. For Contra Costa County Head Start, a policy making group is defined as a site committee and/or the Policy Council. RESPONSIBILITY OF THE POLICY COUNCIL MEMBERSHIP A. The Policy Council member carries a great deal of responsibility. The major areas of responsibility are listed as follows: 1. Serve as a link between public and private'organizations, the Delegate Agency Policy Committee, the Grantee Operated Program Site Committee, The Grantee BOS and the community it serves. In this linking capacity, the Policy Council will seek 5 information from Delegate Agencies Policy Committee and Grantee Operated Site Committee through reports, engage in periodic parent surveys and community surveys to continuously 'assess the needs of the community that they represent. In addition, Policy Council members must attend community organization meetings to update themselves. 2. Initiate suggestions and ideas for program improvements and to receive a report on action taken with regard to its recommendations, constituents; and public and private organizations, suggestions for program improvement will be based on constituent and community needs. 3. Phan, coordinate and organize in conjunction with the Head Start Program Manager Assistant/Parent Involvement or designee, agency-wide activities for parents. 4. Approve the selection of Delegate Agencies 5. Recruit.volunteer services from parents, community residents and community organizations, to meet identified needs of children and parents. 6. Distribute Parent Activity Funds to Grantee Operated Site Committees. 7. Evaluate the program. DECISION MAKING FUNCTIONS AT POLICY COUNCIL LEVEL (E) MAY BE CONSULTED OR'CALLED UPON before any decision is made or approval granted to.give advice or information BUT NOT 'TO MAKE DECISION OR GRANT APPROVAL in the day to day operation of the program. This input is to be negotiated by Head Start Program Manager and Policy Council Chair person annually in February. The amount of Policy Council involvement in the day to day operation must be clearly defined in the minutes of a Policy Council meeting. "May Be" indicates,that consultation is permissive, not a requirement. (D) MUST BE CONSULTED OR CALLED UPON before any decision is made or approval is granted to give advice or information BUT NOT TO MAKE THE DECISION OR.GRANT APPROVAL in the identification of child development needs in 6 - s the area to be served. ensure that standards for acquiring space, equipment and supplies are metes "Must" indicates that consultation is a requirement. "Identification of child development needs" means contributing to the CNA. "Ensuring the standards for acquiring space, equipment and supplies are met" means ensuring that the standards set in service plans, regulations, performance standards, licensing requirements and other applicable laws are met. (C) MUST APPROVE AND DISAPPROVE before the decision is finalized or the action taken. "Must" indicates a requirement and is mandatory. The Policy Council must have been consulted in the decision making process prior to seeking approval or disapproval for actions and decisions in the following: a. establishing goals of Head Start program and develop ways to meet them within the Performance Standards and/or regulations. b. determine Delegate Agencies C. develop plans to use all available community resources in Head Start d. establish criteria for selection of children and families. e. determining the composition of the appropriate policy group and the method for setting it up within Performance Standards and/or regulations. f. services to be provided to Head Start from the Grantee if there is more than one program within the agency and what services grantee is to offer to Head Start program. g. Head Start personnel policies. h. Participate in the selection of and termination of(hire.and fire) Head Start Program Manager and Grantee staff. i. Prepare request for funds and proposed work program prior to sending to Regional Office. j. make major changes in budget and work program while program is in operation. Major changes in budget is defined as any amount over$50.000 total budget.and major changes in work program is defined as any change which would eliminate or add more the $50.000 cost. The major changes are deemed 7 appropriate if the.County procedures are followed for approvals. k provide information needed for pre-view to Regional Office through the Head Start Program Manager or designee when applicable (B) IS DIRECTLY RESPONSIBLE FOR THE CARRYING OUT OR PERFORMING THE FUNCTION BY PARENTS (Directly Responsible means: The Policy Council tells somebody to do it or they do it themselves.) .consistent with the general guidance and direction of the BOS in the conduct of self-evaluation of Grantee's Head Start Program goals and objectives. component planned services. The:Head Start Program Manager is responsible for assuring that the self-evaluation is conducted or performed by staff. (A) IS GENERALLY RESPONSIBLE AND HAS THE LEGAL AND FISCAL RESPONSIBILITY for guiding and directing the carrying out of the establishment of a method of hearing and resolving community complaints about the Contra Costa County Community.Services.Head Start Program. (Community Complaint is defined as: any complaint from.anyone other then staff) The Head Start.staff will establish the standardized method with parents, give these to the Head Start Program Manager for approval and/or disapproval and provide written procedures to Policy Council for their approval/disapproval prior to implementation. Once the method has been placed.in writing and approved by the Policy Council.and the Head Start Program Manager, the performance of the procedure will be directed by the Head Start Program Manager Assistant/Parent Involvement or designee. II. PARTICIPATIONM THE CLASSROOMAS PAID EMPLOYEE, VOLUNTEERS OR OBSERVERS The second of the four major ways that a parent and/or family member can get involved in the HeadStartProgram is by participation in the-classroom as a paid employees, volunteers or observers. 8 Ti I A. As Paid Employee: Contra Costa County Head Start defines paid employees as currently enrolled parents who have qualified for a position. Encouragement will be provided by appropriate staff through parent meetings and parent trainings and will be guided by parent interest surveys. Preference will be given to parents of children currently enrolled in Head Start. B. As Volunteers: Currently enrolled parents, as well as other qualified persons, can volunteer in the classroom, home base and family child care home. To be considered for volunteering a currently enrolled parent must partake in an orientation designed to talk about the program and the specific aspects of volunteer jobs. If a parent would like to be considered for a long term (more than once a month)volunteering in the classroom, home base, or family child care home, then that volunteer must be willing to partake in a training for volunteers, leading towards obtaining 6-12 Early Childhood Education units, submit to TB testing and be finger printed. C. As Observers: Currently enrolled parents can observe in their child's classroom, family child care home, or home base socialization time at any time that class, family child care home, or home base socialization is in operation Other persons may observe in the classroom by seeking permission from the Head Teacher and by indicating the purpose of the visit and how long they plan to visit. Iff DEVELOPING ACTIVITIES FOR ALL PARENTS The third major way currently enrolled parents and/or family members can get involved in the Head Start Program is to develop activities for all parents. Currently enrolled parents at the classroom and site levels will develop activities for themselves designed to meet their needs. Parent surveys will be taken to determine the interests and needs. Information from these surveys will be analyzed by staff and will be the basis for developing activities. This survey will determine the next program years training needs for parents as well as serve as the basis for some activities for the current year. Because of this,parents will need assistance from staff in how to plan. Parents at the classroom committee level and site committee level will provide survey outcome information to their representative on the Policy Council who will use this information in determining agency wide activities for parents. Site committee representatives need to use 9 , 1 survey outcomes as'their own information for determining what happens at the site. 1 i IV. WITH THEIR CHILDREN IN COOPERATION WITH THE STAFF OF THE CLASSROOM OR FCC HOME . WORKING OR WITH THE H04E BASE WORKER j The fourth major way to become involved is through working with their children in cooperation with the staff ofthe classroom or FCC home or with the home base worker. Parents and/or familymembers are encouraged to be in contact with the classroom personnel. Contact can be through casual meetings, formal meetings, telephone calls, social events, and training events. Staff will encourage parents to be in contact with the appropriate education personnel. 1 THE ROLE OF THE STAFF: Staff have a major role of providing opportunity for parents to become involved.- Every nvolved.Every single.staff, line and management,1 have the responsibility of assuring that currently enrolled parents and/or family members have the opportunity to be involved. Contra Costa County Head Start defines opportunity as staff's willingness to assist families in removing barriers to their involvement. That is: a) Assuring the provision of child care for those parents who'need it to attend.meetings or training; b) Assuring the provision of transportation to and.from meetings and training; c) Securing appropriate space at appropriate times for parents to meet; 10 d) Assuring-the provision of refreshments at meetings and training; e) Assuring the provision of necessary materials; f) Assuring the adherence to the Better Governance Act on behalf of parents; g) Assuring that staff do not burden the parents with staff issues and that all staff will model professionalism. 11 _ r N d V N O V V O o •- M 0 - a w d 0 L rvool " � s ys r•+ C d E - a d V d c N Z% V .0 �M E N E E a 0 0 = ti d o 0 Zwo 00 izo to to 10 0.. N r C? p «•+ •G �. N � •Cy ,o o. o t? 4 CFO d E: c 'G .+ m ,. 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O i 14 3 m `rte w UJ cd M Lp —UN c .c Z in U -' 0 'tn Vii ' 0) a co wa U) CLQ _ LL 14) o % •0 H ' r p� C _ -- N w d C CO > 0. 1!, 0 d .c ea E SN a d `s cis CE LD to r ao .oac c c oa W g X- .m � a v .c E3 EllA � ED oto _ �? .. to 'g t df q H d r+ .S 2 . ; to ea d 7110 > +� _ = U •c 3 N a "C N C �- E v 0 0 � LD a ,CLFE a lu L. a > to r� a D INTERAGENCY AGREEMENT BETWEEN CONTRA COSTA COUNTY COMMUNITY SERVICES DEPARTMENT HEAD START PROGRAM AND CONTRA COSTA SPECIAL EDUCATION LOCAL PLAN AREA (SELPA) 1996 May 10, 1996 INTERAGENCY AGREEMENT BETWEEN CONTRA COSTA COUNTY COMMUNITY SERVICES DEPARTMENT HEAD START PROGRAM AND CONTRA COSTA SPECIAL EDUCATION LOCAL PLAN AREA (SELPA) The purpose of this interagency agreement is to establish a set of working guidelines and procedures between Head Start programs in Contra Costa County and the local education agencies (LEAs) who are members of the Contra.Costa Special Education Local Plan Area (SELPA), to provide services to disabled students in compliance with federal and state laws governing each agency. No part of this Agreement is intended to directly or indirectly extend the responsibilities and obligations of either agency beyond the requirements of law. The agreement is provided to assist in the efficient provision of shared duties and cohesive delivery of individual agency responsibilities. It is the intent of this Agreement to: 1. Define services which will be provided by each agency. 2. Establish a communication system to ensure that collaborative, coordinated services are ,provided. 3. Provide opportunities for service to those children requiring special education and/or services in the least restrictive environment. 4. Establish a system to ensure a smooth transition of disabled children between Head Start and publiclprivate school programs. Each agency shall identify representatives in each of the following areas and provide notification of any staff changes: 1. Administrator responsible for the Interagency Agreement. 2. Liaison for screening,referral and transition. 3. Coordinator of staff development activities May 10, 1996 2 CHILD FIND / SCREENING Education will: Head Start will: Develop a joint developmental screening Develop a joint developmental screening that will assist Head Start teachers in making that will assist Head Start teachers in making appropriate referrals. appropriate referrals. Screen all children enrolled in Head Start within 45 days of enrollment in the program Meet with the LEA liaison about children who are identified by criteria for LEA screening to establish times for LEA screening. Assist Head Start in determining which children will be screened by the LEA screening. Complete screening of children who are Provide LEA with information on Head Start identified by Head Start screening within four Program and adaptations attempted and weeks of Head Start contacting LEA liaison. outcomes for children. Meet regularly with Head Start to discuss Meet regularly with the LEA contact person LEA screening outcomes and identify to discuss LEA screening outcomes and children to be referred to the LEA for special identify children to be referred to the LEA for education assessment to determine special education assessment to determine eligibility. eligibility. May lo, 1996 3 REFERRAL Education will: Head Start will: Provide Head Start with LEA referral form. Shall use LEA referral form when making referrals to LEAs. Make written referrals to LEA for children who are suspected of having a disability, and are believed to meet the CA Ed Code Part 30, Chapter 4.45, Section 56441.11, including the eligibility criteria in Title 5, section 3030, or the family request referral. Develop a joint release of information Develop a joint release of information consent form. consent form. Assist in obtaining parent signature on joint consent for release of information. Jointly develop a standard referral packet Jointly develop a standard referral packet and train appropriate staff in its use. and train appropriate staff in its use and provide the packet of information when a child is referred. Meet regularly with Head Start to discuss Meet regularly with the LEA contact person status of referrals. to discuss referrals. May 1o, 1996 4 ASSESSMENT Education will: Head Start will: Develop and send assessment plan to Head Assist LEA in obtaining parent signature on Start to assist in obtaining parent signature. the LEA assessment plan. Provide LEA with any information relevant to the assessment. Conduct assessments on all children Assist the family and child in attending the referred by Head Start according to assessment. procedures described in California Education Code Part 30. Include Head Start in the evaluation team Participate in the evaluation team when when Head Start is considered as a Head Start is considered as a placement or placement or the child being assessed is the child being assessed is enrolled in Head enrolled in Head Start. Provide interpreters Start. Provide interpreters and translators and translators where required and available where required and available for for assessment and meeting activities. assessment and meeting activities. Provide assessments on all children who appear to meet Head Start eligibility criteria, but do not meet LEA criteria. Meet regularly with. Head Start to discuss Meet regularly with the LEA contact person assessments. to discuss assessments. May 10, 1996 5 IEP Education will: Head Start will: Notify Head Start of IEP meetings for whom Invite, in writing, the LEA liaison to all Head Head Start may be an appropriate Start IEP meetings. placement two weeks prior to the IEP meeting including the initial meeting to determine eligibility for Special Education. The IEP team shall determine eligibility for Special Education in accordance with Federal, State and SELPA guidelines including documentation that the child's difficulties are not due to environmental, cultural or economic factors. Provide Head Start with a copy of each child's IEP. Meet regularly with Head Start to discuss the Meet regularly with LEA contact person to IEP process and.scheduled meetings. discuss the IEP process and schedule meetings. May lo, 1996 6 PLACEMENT Education will: Head Start will: Consider dual enrollment as a placement Consider dual enrollment as a placement option. option Make every effort to maintain placement of Make every effort to accommodate children children in Head Start when Head Start is referred by LEA throughout the course of the the referring agent, as deemed appropriate program year. by the IEP team. Utilize Head Start as a placement option A child with an LEA IEP shall be given when appropriate for preschool children priority for inclusion in Head Start where the identified as needing special services. placement is appropriate, available and upon application. [Head Start Act Section 640(a)(2)(A)] 5% of the Head Start enrollment shall be reserved for LEA IEP priority for the first 45 days of each operation year. Provide or ensure the provision of special Provide LEA staff access to the child to education and related services as specified provide special education services as in the IEP for children the LEA is mandated described in the child's Special to serve. Education/LEA IEP. This may include appropriate work space with individual and/or small group intervention, creation of inclusionary groups, planning time with Head Start Staff and other conveniences provided to Head Start staff being afforded LEA staff. May 10, 1996 7 SPECIAL EDUCATION AND RELATED SERVICES Education will: Head Start will: Provide special education and related Provide the regular education service and all services designated on IEP comprehensive services available to all children enrolled in Head Start. Support families in accessing related services provided by LEA. Provide Special Education and related Provide interpreters and translators for services on local Head Start sites whenever Special Education and related services possible. Provide interpreters and translators where required and available. for Special Education and related services where required and available. Contact LEA regarding child attendance and access to Special Education and related services if the child is absent more than ten (10) days. Reconvene IEP team to make changes in Reconvene IEP team to make changes in special education and related services as special education and related services as necessary. necessary. Provide special education and related service for all children who meet Head Start eligibility criteria only. Attend transition IEP meetings for, Head Contact LEA about children age 4.5 years Start children age 4.9 years on Sept. 1 and transitioning into kindergarten with Head transitioning into kindergarten who are Start IEPs and invite LEA to transition IEP believed to meet LEA criteria or have LEA meetings for children believed to meet LEA I EPs. criteria. May 10, 1996 $ PROCEDURAL SAFEGUARDS Education will: Head Start will: Shall implement all procedural safeguards, Shall ensure that all procedural safeguards, including confidentiality of records including confidentiality of records requirements and placement in the least requirements and placement in the least restrictive environment, for all individuals restrictive environment, are provided for all with exceptional needs placed by the LEA handicapped children and their Head Start, and their parents/guardians, parents/guardians, according to Education according to California Education code Code Sections 56500-56506, effective Sections 56500-56506, effective California California Administrative Code, Title 5, and Administrative Code, Title 5, regulations and Head Start Performance Standards(45 CFR federal law and regulations. 1308.6, 1308.19 and 1308.21) as well as other federal laws and regulations. Shall inform Head Start personnel and Shall inform parent/guardian of individual parents/guardians of individual rights and rights and protections. protections. Shall inform Head Start personnel and Shall inform parent/guardian of due process parents/guardians of due process hearing hearing and complaint procedures, and shall and compliant procedures for all children participate in hearings when requested. placed by the LEA in Head Start, in accordance with California Education Code requirements. May 10, 1996 9 TRAININGNECHNICAL ASSISTANCE Education will: Head Start will: Co-plan, provide and participate in joint Co-plan, provide and participate in joint training on accessing early intervention training on accessing early intervention services from community service providers. services from community service providers. Provide training to Head Start on the use Participate in training on the use and and implementation of the jointly developed implementation of the jointly developed developmental screening. developmental screening. Train appropriate staff in the use of the Train appropriate staff in the use of the jointly developed referral packet. jointly developed referral packet. Participate in other trainings as identified. Participate in other trainings as identified. Provide training to Head Start on possible Participate in LEA provided training on classroom modifications and accommoda- possible classroom modifications and tions. accommoda-tions. Provide training to Head Start on LEA Provide training on Head Start referral referral eligibility criteria, and IEP procedures and eligibility criteria. procedures. Notify Head Start of pertinent training Notify LEA of pertinent training sessions so sessions so that staff and parents can attend that staff and parents can attend when when appropriate. appropriate. Include children placed in Head Start with an Meet the obligation for providing a count of LEA IEP in the Pupil Count consistent with children with IEPs through participation in State and Federal requirements. the IEP process. Co-plan and provide joint training on the Co-plan and provide joint training on the Interagency Agreement. Interagency Agreement. May 10, 1996 10 DISPUTE RESOLUTIONS The administrator responsible for this Agreement, identified by each agency, shall be responsible for the interpretation and implementation of this Agreement. Individuals shall meet and attempt to resolve conflicts at the lowest possible level with personal communication, and written communication, prior to advancing to a higher level of administrative or supervisory involvement. The administrators, responsible for this Agreement, shall be the highest level of involvement. If the designated administrators are unable to agree, a review and consideration of amendment of the Agreement shall be initiated. May 10, 1996 ADMINISTRATIVE/APPROVAL SIGNOFF INTERAGENCY AGREEMENT APPROVAL This agreement is entered into this day of 1996 by and between the undersigned agencies. This agreement is to be reviewed annually and updated every three years or sooner, as necessary. The agreement may be terminated by either agency upon thirty (30) days written notice. Johnny W. Welton, Ed.D. Joan Sparks Director Director Contra Costa Contra Costa County Special Education Local Plan Area Community Services Department Head Start Daneen M. Cali Assistant Head Start Program Manager Acting Head Start Program Manager Contra Costa County Community Services Department Head Start May 10, 1996 12 Contra Costa County / Community Services Department Head Start Division Policy Council 2425 Bisso Lane, Suite 120 . " Concord, CA 94520-4830 (510) 646-5540 ® Fax (510) 646-5551 POLICY COUNCIL PROGRAM DEVELOPMENT COMMITTEE MEETING May 8, 1996 M I N U T E S 1. The meeting was called to order by Brigette Nichols at 10:08 AM. II. Public Comment -The committee agreed to amend the agenda to include review and approval of the Selection Criteria and Blood Protocol 111. 1-30/70.2 Implementation Plan: The document was reviewed and recommended for PC approval with the stipulation that several typographical errors be corrected. IV. Case Management Procedure: The document was reviewed and recommended for PC approval. V. Monitoring Procedure: The document was reviewed and recommended for PC approval with the stipulation that the job title CSD Program Manager be changed to Head Start Program Manager and the job title CSD Program Monitor be changed to Head Start Program Monitor. VI. Parent Emergency fund Plan: The document was reviewed and recommended for PC approval with the stipulation that the acronym ESOP be changed to ECIP. VII. Contra Costa SELPA Interagency Agreement: The document was reviewed and recommended for PC approval. Vlll. Community Complaint Procedure: The document was reviewed and recommended for PC approval with the stipulation that several typographical errors be corrected. A i Page Two PC Prog. Dev. Comm. Minutes 5/8/96 IX. Selection Criteria: The document was reviewed and recommended for PC approval. X. Blood Protocol: The document was reviewed and recommended for PC approval. A. The meeting was adjourned at 10:47 AM. roG d r d z O rd cL N d C? � d DG 0 o � �n 4a D T o •� � 0 tom? o c N La w � N . � N 1 p r N M '7 tf) CO f- GO CF) O r N M d 1f) r tV cn V LO (0 A '. GC! CA r r r r r r r r r r N N N N N N m U � Z c O W m C + 4 N to r r c d v U ca c rn U ami U U c o o O O E o E m o v N N 2 (M �, w v, o U z o c c r E tm c d c J O ., C V Nla c N O M C of =N 0 rn a O 0 C c E to m o oa as '� M o c m . U c a c2 ~ U c r c ! O O m o rn E c o m U c vx uLi ai CL o c a a U a N m o_ '° o o © w O` E o E o c o m �' nmi U N v v� E E N O a 0 O c (D () p� E �., 'c C •Q 0 w r v U `c c v, � E c C3 0 = E rn cm m � g _U E = coi U o $ E > c� i(D 0 � L m O d = 0 0 m co E u. Q 0 Z c o U °> Z c °c? cEo o U = c c W U U W m m m °� o U U :. 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L ' W tocgo 0 L f . w v c U If Is •� � a O C.? � a 0 U n C-1 71 a $� 1 E� A m ti n `� E vd � Y 3� 10 CP ✓ /� b�9 °' S � 7e� N j N o v mc � Jx i Contra Costa County Head Start Quality Improvement Plan April 24, 1996 Team Two P Contra Costa County Head Start Quality Improvement Plan Team Two Team Two was charged with the review and revision of Head Start systems which involve policy making, communication and oversight. To do this we focused on planning, personnel, grant application, general administration and self-evaluation, including some specific sub-systems such as job descriptions, performance evaluation and fiscal reporting. Team Two began with six members from different areas of the Head Start Program Two Parents: Bayo Vista and First Baptist Family Service Assistant Three Program Manager Assistants: Mental Health, Education and Parent Involvement Monitor Facilitator from Development Assoc. The team had a total of seven meeting's to date 4-23-96 Process of Team Two Reviewed the outcomes and the key tasks Re-wrote the outcomes as tasks and numbered them Began charting the processes by task Organized the back up material Conducted interviews of appropriate staff members and invited resource people to our team meetings. Found that the charting was too complex for the model that we were using so changed it to a model that was workable for the team. Documented all meetings and charts with minutes 1 r Contra Costa County Head Start Quality Improvement Plan Team Two EXPLANATION OF CHARTS Stimulus: Need Related Documents: Documents that guide or support the process Stage: In dealing with the need there may be stages with different levels of review and approval Gather Information: From what sources do we need to gather information Actions: Activities that meet the need Person Responsible: Identified the staff position that has primary responsibility for the process, which may be delegated Review and Approval: Positions or groups that have responsibility for reviewing or approving the documents Information To: Who needs to be informed of the final product Information By: Who is responsible for providing the above information about the final product Reference Implementation Plan: Should identify where this process is discussed in the I-30, Implementation Plan. We have not identified this at this time as the I-30 Implementation Plan is still in draft form, but should be identified when it is in its final form. 2 Contra Costa County Head Start Quality Improvement Plan Team Two Recommendations April 24, 1996 Chart 1 ( Personnel Policies) :Our recommendations is that in order to have full participation in decision making around personnel systems we need to include bargaining units and full staff representation at TQM meetings. Chart IA ( Performance Evaluation): Our recommendations are: * Implementation of this system which incorporates accountability for clearly identified performance objectives * Information should be gathered from stakeholders who have observed the employee's performance * That employees are coached regularly throughout the performance period Chart 1B ( Job Descriptions): Our recommendation is to ensure that all employees have copies of their current job descriptions, which are annually updated / reviewed. Chart 2 ( Contract/Grant Oversight): Component managers need to review contracts/ grants and be aware of operations in preparation for quarterly progress reviews with HSPM, PMAs, assistants and monitors. Chart 3 ( Planning): When doing planning all staff need to be aware of Head Start's philosophy and performance standards. Again all appropriate stakeholders need to be involved in the process . Self evaluation criteria needs to be established at the time the goals and objectives are set. Chart 4 ( Self Evaluation): We recommend that the self evaluation criteria created in the planning stage be used as the document which will guide self evaluation. Chart 5 ( Fiscal Reporting): We need to have projections for the program manager so spending is more controlled. When budgets are generated component managers should have input in order to later have more understanding and stake in its supervision. Overall Recommendation: Step by step procedures for each of these systems need to be developed The procedures should clearly define any ambiguous terms used in the systems chart such as "appropriate"and "stakeholders" 3 D Contra Costa County Head Start Quality Improvement Plan Team Two Concernslissues #1 In order to proceed with the development of systems, gaps need to be identified and goals for future work must be defined as clearly as possible. #2 Adequate time needs to be available to adequately respond to goals. #3 In order to complete goals resources need to be readily available. For example, access to individuals and information needs to be smooth and timely. #4 Extra staff support, temporary reassignment or additional prioritization of some job responsibilities is necessary for staff involved in any future process.. We cannot continue our efforts to respond to these complex tasks and provide quality services to our families without this assistance. #5 We would suggest that a Procedures Team be established to create step by step procedures ( details, time lines, lines of authority etc.) for each of these systems. The team should be made up of members who have the skills needed to write procedures and a stake in the process ( ie. personnel staff, management'and line staff). 4 w i c tiG y CT lu C G lu o x C� a o Q <~ >> wl 'u G a Z on Gn to 0 'U c o cz a a a 0 to 03 api ami c. b o p - a� .................. u .� o v) w a N V) � w ^I Cot O U O U h W w wj LA v/ iir.•fl : ::52: H p ., O 'C V O O .y� p, O `� '.+ y i.. 6Ni a�i � pp O .�., • � a+ x V ••:., y .� p, � y U C y y � o > O .0 0 3 3 = .o<< .0 ;`: 0 A >^ > ;a w p ! :::::: .................. .................. .................. o L o L > . Z .................. .................. .................. N L b 'y :' y:. 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H �y U ac y y U CL r- LO) U U V � C.f = x .0 F F .w CL AS N a � LK now a 0 C CL v IL 8 U p u M r� 00 w LL W 0 8a LL� Q. � o 2Ed g at V bN n IE w U. ix sm � .� to C. a u c N o 0 y u8 $ •Vq E_ cP Z tv r" o o rr+ W Cf t w c A . n E b d row d o lot, Zs � $ N rnw ED o m S[� n ` 16 LU it = Q1*4 Ts " Q1 J'p xg � � °� u3 p► E ` V G c +- v p, C W v I , ('.'.ONTRA COSTA (".OlJNTY HEAD START 01JALITY IM1'11OVl?MI:NT 111.21N APRIL 1996 TEAM IV DRAFT DRAFT DRAFT DRAFT OVERVIEW OF ASSIGNED TEAM TASKS Team 4 was task with developing an organizational structure that will include the needs of the Delegate Agencies and meet the Performance Standards requirements in the following areas: 1. SYSTEMS OR PROCESS FOR DEVELOPING DA TRAINING 2. SYSTEMS OR PROCESS FOR CROSS COMPONENT INTEGRATION OF TRAINING FOR THE DA 3. SYSTEMS OR PROCESS FOR DELEGATE AGENCY BUDGET DEVELOPMENT 4. SYSTEM OR PROCESS THAT REFLECTS DA RELATIONSHIP TO GRANTEE TO INCLUDE COMMUNICATION, REPORTING, CONTRACTS AND MONITORING. Team 4 Members: Pam Franklin, Policy Council Chair Daneen Cali,Program Manager Sarah A. Glasper,Education Specialist Annie Stephens, Health Assistant West GOPs Mickey Williams, First Baptist Church Head Start Michale Bishow, Contra Costa Training Institute Ellenor Hodson, Team Facilitator Amelia Scott,Disabilities-Transportation PMA PROCESS USED IN DEVELOPING GOALS: 1. The team members tackled the task by analyzing all rive areas of concerns. We began by discussing What are we doing now/Accomplishments and Barriers to Accomplishments? 2. From the specific questions we came up with 13 Barriers to accomplishments as listed in your packet. 3. From the 13 Barriers we clearly defined those Barriers in-to 8 Barriers which became the GOALS. The process used was, each team member was given eight different colored stickers and was asked to place the stickers where we thought they should be, as we perceivedas Barriers. The members were then asked to vote on those Barriers by voting rive for high priority, three for lesser priority and 1 as the least priority. The 8 Barriers had scores ranging between 20-15.This is how we clearly defined the 8 Barriers. 4. The team developed GOALS for the BARRIERS. By asking what system should be in place to coordinate all the Goals/OBJECTIVES. 5. In developing the GOALS we also developed the process/steps for achieving the goals,which can be viewed as the OBJECTIVES. 6. As resource we asked collaborated with other team members and staff not assigned to teams to provide information that was important to the process. BRIEF DESCRIPTION OF TEAM PRODUCT AND RECOMMENDATION. Review the Goals (GOALS FOR DA GRANT APPLICATION DEVELOPMENT AND BUDGET DEVELOPMENT WERE COMBINED BECAUSE THEY ARE USED AS A CHECK AND BALANCE SYSTEM) Review the Steps TO MAKE THE GOALS HAPPEN/OBJECTIVES RECOMMENDATION: 1. Integrate the new management system into the existing system. 2. Develop flow chart of goals and objectives,with time-lines and names of key personnel Plan-Do-Review ADDITIONAL TECHNICAL ASSISTANCE NEEDED BY THE TEAM IN ORDER TO COMPLETE THE TASK We have yet to develop the time lines and names of key personnel responsible for seeing that the objectives are completed TEAM 4 TASK To have an organizational structure that includes the needs of the delegate agencies, meets the performance Standards including the following: o Systems or process for developing delegate agency training o Systems or process for cross component integration of training for the delegate agency o System or process for delegate agency budget development o Systems or process for delegate agency grant application development o System or process that reflects delegate agency relationship to grantee to include communication, reporting, contracts and monitoring Process Selecting team members Identify barriers Clearly defined barriers Over Arching Mission Development of goals and objectives BARRIERS: 1. Coordinated comprehensive system in place 2. Use of the CNA/FNA's in determining training 3. Turf/Authority Issues lead to training being closed/unknown 4. Annual gathering to coordinate training calendar/areas 5. Schedule to minimize conflicts not ever developed 6. Survey to comprehensively gather information from all constituents 7. Area wide training occurs (GOP-DA's) 8. Training specified in grant not occurring 9. Vision of Head Start is not communicated to new employees 10. Parents need to be involved in over all training planning 11. Cross component integration (currently working on case management procedures) Le. and monthly component management meetings 12. Prework to be prepared with DA information for planning training 13. Identify who is responsible for the coordinated training system DEFINED BARRIERS Coordinated 1. comprehensive 2. arents involved in system overall training planning 3. Cross component 4. Training Master integration Schedule to minimize conflict 5. 6. Identify who is Vision of Head Start Communicated responsible for To all employees including Fed Goals and coordinating training objectives system To all parents 7. Annual gathering to coordinate training-increase access 8. isseminate training information to include all territories/components comprehensive survey to gather all constituent information OVER ARCHING MISSION To unify Contra Costa CSD, Head Start Program both GOP's and DA's into a well articulated, coordinated quality program. GOALS 1. ESTABLISH A CLEARLY DEFINED MANAGEMENT SYSTEM FOR COMPREHENSIVE TRAINING 2. ESTABLISH A SYSTEM FOR INCLUSION OF H.S. PARENTS IN. H.S. TRAINING PROCESS 3. MORE FULLY COORDINATE THE PLANNING OF TRAINING ACROSS ADMINISTRATION AND COMPONENTS 4. DEVELOP, IMPLEMENT AND EVALUATE A "CASE MANAGEMENT SYSTEM WHICH INCLUDE CROSS COMPONENT INTEGRATION" 5. ESTABLISH STABLE AND USER FRIENDLY COMMUNICATION PROTOCOL FOR TECHNICAL ASSISTANCE AND TRAINING REQUIREMENT 6. ESTABLISH EQUAL STANDARD FOR EVALUATION FOR GOP'S AND DA'S 7. TO ESTABLISH A SUCCESSFUL AND CONSISTENT PROCESS FOR GRANT/BUDGET APPLICATIONS FOR ALL GOP/DA'S 8. TO CLARIFY AND STRENGTHEN THE EXISTING FULL AND LIMITED MONITORING PROCESS STEPS TO REACH THE GOALS GOAL 1. * Fully monitored for quality. * Fully communicate the Management system to all H.S. staff and parents. * Fully evaluated and improved annually. * Fully communicated the vision of H.S. to staff, parents and volunteers. * Include all standards and steps in training functions. * Comprehensive survey to gather all constituent information GOAL 2. Llude parents in Policy Council planning committee. lude parents in T 4 T and skill development. engthen the use of the FNA in TNA processes. GOAL 3. * Collaborate on an annual "Master Schedule of all events related to skill building including DA's and GOP's. * Disseminate training information from all components to all sites. * Assign coordinating person to lead training. GOAL 4. * Annual gathering to coordinate/plan to increase access to training for all representative staff of Gop's and DA's. * Develop standard/protocol process for Case Management. * Develop measures to assess the effectiveness of cross component functions within program. * Integrate all monitoring information from(etc. site visits, reports, * Integrate all monitoring information from(etc. site visits, reports, contracts and training into case management process.) GOAL 5. * Include protocols for information access, reporting, assessment and.planning. * Write and distribute a stable schedule of work assignments for Grantee. * Well define, Master Calendar which include all key deadlines for Grantee and reports. GOAL 6. * Bring objectives outside evaluators to equalize performance across all agencies. * Actively request H.S. performance information from community sources (i.e. bipartisan advisory committee). * Provide cooperation, coordination, collaboration across community agencies to insure a QUALITY PROGRAM. GOAL 7. * Strengthen the overarching grant/budget structure which provides for realistic timelines. * Identify a single Coordinator to review and track progress of grant/budget process. The Coordinator must have knowledge of operations, budgeting, licensing, and contract monitoring. * Identify technical needs early and send appropriate assistance to all programs and/or agencies. * Train every agency in the steps and timelines to successfully complete the annual grant/budget application process. * Monitor application for one-time delivery of grant/budget content. * Monitor contract terms to include compliance with the grant/budget process. * Assess grant/budget product and process for quality. Re-design and update training as needed. * Consistently apply standards to GOP and DA's. * Publish enforcement procedures for non-compliance and defunding of an agency or a joint powers of agreement process. * Insure and monitor all linkages between components to avoid duplication and promote coordination within a case management framework. * Grantee provides the technical assistance (one-on -one) to all agencies in a timely and clear form. GOAL 8. * Current system must be better to establish clear responsibilities and accountability (for and to). * Communicates the system to all parties involved( e.g. Grantee staff, Policy Council, Delegate Agencies, and.Grantee Operated Programs). * To clarify, delegate, and empower personnel to carry out the established monitoring processes. CONTRA COSTA COUNTY HEAD START QUALITY IMPROVEMENT TEAM #3 TOPICS Training Needs Assessment Cross Component Training Master Training Calendar System for Monitoring and Evaluation FORMAT What is in place Status Future Product/Action Plan TOPIC TRAINING NEEDS ASSESSMENT (TNA) 1- What is in place? All documentation from previous TNA is on file - 1995 TNA Survey - Delegate Agencies and GOP training needs identified 2- Status - TNA has only been used for County-wide training in October 1995 and April 1996 - QIP took priority over some training; some items on both - TNA requires early updating 3- Future Product/Action Plan - Develop updated survey including TNA action plan including information from all stakeholders. TOPIC II CROSS COMPONENT INTEGRATION 1- What is in place? Cross component integration is conducted at bi-weekly staff meetings. 2- Cross component integration is not understood by staff and occurs minimally. 3- We will institute a cross component training and action plan which will include monthly meetings with Area Coordinators and component managers using a case management concept to facilitate cross component integration. TOPIC III MASTER TRAINING CALENDAR 1- What is in place? A 1994-1995 work activity calendar with very few training activities noted. 2- Status The work activity calendar contains mostly program events such as Award Day,field.trips, etc. 3- Future Product/Action Plan We will create a training activities data base program which will maintain data on all planned and actual training activities. Reports will be produced in various formats to support various requirements. The key product will be a master training calendar which will be used to plan, schedule and record all training activities. TOPIC IV MONITORING AND EVALUATION 1- What is in place? No monitoring of training! 2- Status Evaluations are completed on a random basis. No tabulations, analysis, no feedback. 3- Future Product/Action Plan As part of new training program component managers will monitor training activities; new evaluation forms will be developed; data will be incorporated into the training data base and results will be analyzed. TOPIC V TRAINING BUDGET 1- What is in place? A budget of$45,000,00 of which $3,000.00 is allocated to Delegate Agencies. Grantee is responsible to ensure most of training is accomplished. 2- Status The training budget is managed and monitored by the Program Manager. 3 Future Product/Action Plan Future training budgets will be developed from requirements identified in the TNA and will be funded by priority as developed by the Program Manager and responsible staff. 0 TOPIC VI TRAINING ORGANIZATIONAL STRUCTURE 1- What is in place? No central training structure or program. Each component manager is responsible for providing required training for their component. Little coordination and no analysis or review of results. 2- Status Documentation of completed training does not exist in any kind of organized manner. No planning schedules for various component training have been used. 3- Future Product/Action Plan Establishment of a central Head Start training support unit which will be responsible for accomplishment of the TNA; planning and scheduling all training; maintaining all training data in a computerized data base which will produce training calendars, reports and other products to aid in the planning, conducting and documenting of all training activities. CONTRA COSTA COUNTY HEAD START QUALITY IMPROVEMENT TEAM #3 TOPICS Training Needs Assessment Cross Component Training Master Training Calendar System for Monitoring and Evaluation FORMAT What is in place Status Future Product/Action Plan TOPIC TRAINING NEEDS ASSESSMENT (TNA) 1- What is in place? All documentation from previous TNA is on file - 1995 TNA Survey - Delegate Agencies and GOP training needs identified 2- Status - TNA has only been used for County-wide training in October 1995 and April 1996 - QIP took priority over some training; some items on both - TNA requires early updating 3- Future Product/Action Plan - Develop updated survey including TNA action plan including information from all stakeholders. D- k TOPIC 11 CROSS COMPONENT INTEGRATION 1- What is in place? Cross component integration is conducted at bi-weekly staff meetings. 2- Cross component integration is not understood by staff and occurs minimally. 3- We will institute a cross component training and action plan which will include monthly meetings with Area Coordinators and component managers using a case management concept to facilitate cross component integration. TOPIC III MASTER TRAINING CALENDAR 1 What is in place? A 1994-1995 work activity calendar with very few training activities noted. 2- Status The work activity calendar contains mostly program events such as Award Day,field,trips, etc. 3- Future Product/Action Plan We will create a training activities data base program which will maintain data on all planned and actual training activities. Reports will be produced in various formats to support various requirements. The key product will be a master training calendar which will be used to plan, schedule and record all training activities. TOPIC IV MONITORING AND EVALUATION 1- What is in place? No monitoring of training! 2- Status Evaluations are completed on a random basis. No tabulations, analysis, no feedback. 3- Future Product/Action Plan As part of new training program component managers will monitor training activities; new evaluation forms will be developed; data will be incorporated into the training data base and results will be analysed. TOPIC V TRAINING BUDGET 1- What is in place? A budget of$45,000,00 of which $3,000.00 is allocated to Delegate Agencies. Grantee is responsible to ensure most of training is accomplished. 2- Status The training budget is managed and monitored by the Program Manager. 3- Future Product/Action Plan Future training budgets will be developed from requirements identified in the TNA and will be funded by priority as developed by the Program Manager and responsible staff. TOPIC VI TRAINING ORGANIZATIONAL STRUCTURE 1- What is in place? No central training structure or program. Each component manager is responsible for providing required training for their component. Little coordination and no analysis or review of results. 2- Status Documentation of completed training does not exist in any kind of organized manner. No planning schedules for various component training have been used. 3- Future Product/Action Plan Establishment of a central Head Start training support unit which will be responsible for accomplishment of the TNA; planning and scheduling all training; maintaining all training data in a computerized data base which will produce training calendars, reports and other products to aid in the planning, conducting and documenting of all training activities. Corrective Actions to address the Remaining Deficiencies listed in the March 29, 1996 Letter of Understanding from ACF Administration: Deficiency: Grantee does not have a functional organizational structure..... Action: Four teams provided proposals for restructuring. One team proposed an organizational structure which would reflect internal and external reporting relationships; one team proposed internal systems; one team proposed external systems; and one team proposed training to facilitate cross component integration. These proposals were approved in concept by the Policy Council on 5/9/96 and are before the Board of Supervisors for approval in concept(5/14/96). Deficiency: Monitoring process deficient in relation to the human resources allotted to the process: Action: The monitoring procedures approved by Policy Council on 5/9/96 provide for a team, composed of component managers and program monitors, to perform full monitoring. Deficiency: Lack of clarity of job descriptions, lack of annual evaluations, lack of reference checks and West County personnel files not kept confidential. Action: The proposal presented by Restructuring Team One provides for clarity of functions and will result in new job descriptions for each position. Annual performance evaluations for the "represented class" were presented to CSD personnel support staff on 5/3/96 for "meet and confer" negotiations with employee organizations. In a 5/3/96 memo from CSD personnel support staff, reference checks on all potential Head Start employees will be performed before job offers are made. Personnel files at GOP-West (Brookside) are kept in locked files as of 5/6/96. 1 I 1 Deficiency: Documentation of training in child abuse prevention inadequate Action: The proposals of Restructuring Teams three and four provide for training system that ensures quality documentation . In addition, the Head Start program now uses certificates of training and places these in personnel files. Mental Health Deficiency: Staff anxiety, alienation and distrust are not being addressed Action: Contra Costa County's Employee Assistance Program is providing orientation meetings to Head Start staff. A Meeting held on 5/10/96, and others scheduled for 5/24/96 and 5/31/96. The proposals of Restructuring Teams One through Four provide for clarity of job functions, reporting and supervisorial relationships. Annual performance evaluations will provide clarity. Training for Head Start management is scheduled to occur and a needs assessment of the Head Start managers skills has been conduted. Deficiency: Services continue to be reactive%rises oriented not preventative. Action: Trainings for parents and staff in Mental Health Component services were provided in March, April and May of 1996. The Mental Health consultant is following the Mental Health Component Services Plan and is developing a staff and parent interest survey regarding support groups. Parent Involvement: Deficiency: Written Implementation of I-30 Plan not current Action: Implementation of the I-30 Plan was updated and approved by Policy Council on 5/9/96. 2 Deficiency: No annual review of agency personnel policies Action: Personnel policies were updated and reviewed by Policy Council Personnel Committee in February and March 1996 and approved- by the Policy Council on 5/9/96. Deficiency: No evidence of a written community compliant procedure Action: Community Compliant Procedure approved by Policy Council 5/9/96 Deficiency: No regular means of communication with parents - newsletter Action: A monthly Newsletter started in February 1996 and is translated into Spanish. Three newsletters so far. Deficiency: Written materials not translated into language of parents Action: Newsletter translated into Spanish and recruiting materials translated into Hmong, Chinese and Spanish. Deficiency: Policy Council or Personnel Committee not trained in Agency's personnel policies Action: Personnel Committee of Policy Council trained in personnel policies in February and March 1996. Policy Council provided training in March and April 1996. Bayo Vista Child and Family Center, Inc. Mental Health: Deficiency: No individualization or cross component integration Action: Bayo Vista now uses a Coded Lesson plan system (using a specific code to identify specific children with special needs) and training in cross component integration was provided on 4/19/96 3 Deficiency: Mental Health Activities are still in planning stage Action: Grantee has monitored the mental health activities and have found that the DA now uses the 'Web of Life" curriculum for mental health activities. Parent Involvement: Deficiency: No plan or time table for grant application process Action: Grantee staff is working with Bayo Vista staff in writing plans and plans will be completed and approved by 5/20/96. Deficiency: No evidence of training in child abuse prevention Action: General comments on non-compliance issue states that the Federal Review Team found that there is evidence of child abuse prevention training. Grantee monitoring also has found evidence of training in child abuse prevention. Enrollment, Regruitment, Select}on• Deficiency: Written procedures remain inadequate and do not reflect compliance with current federal regulations and have a condition that a child must be toilet trained as a condition of enrollment. Action: Condition of enrollment removed as of 5/3/96. Grantee staff is working with Bayo Vista staff in a current implementation plan for 45 CFR 1305 (Enrollment, etc.) 4 Contra Costa Community Services Department Head Start Program Corrective Actions For Non-Compliance Items Listed In March 29, 1996 Letter Of Understanding From ACF Item 083 Coordination with the education services component to provide a program keyed to individual development levels; (3) Reason for Non-Compliance: Minimal coordination with education services; service delivery is fragmented Corrective Actions: (Refer to January, 1996 QIP, pp. 9-10,p. 13) 1. Coded system [a coded lesson plan is a lesson plan that uses a specific code to identify children with disabilities]is in use, and reflected on lesson plans. Trainings on individualization held on March 22nd, March 29th,April 12th, and April 19th of 1996. 2. Workshop regarding Individualization held for Head Teachers on May 10, 1996. 3. Disabilities component held two planning meetings with RAP on how to integrate IEPs into lesson plans. Training to occur in October, 1996. 4. Coordinating meeting held weekly to develop a cross-component Case Management Procedure. Case Management Procedure approved May 9, 1996. Item 085 Regular group meetings of parents and program staff; (5) Reason for Non-Compliance: Current service level is reactive in nature rather than preventative. Corrective Actions: (Refer to January, 1996 QIP p. 9,p. 11) County-wide trainings were held April 12, 1996 and April 19, 1996. Policy Council Committees met in February, March; April, and May of 1996. Item 133 There is a written parent involvement plan annually updated and/or revised, [1304.1-4] This includes a detailed plan on implementation of 1-30-2 "The Parents"(70.2) [1304.5-2(b)] Reason for Non-Compliance: Implementation of 1-30-2 "The Parent"plan is not current. 1 - Corrective Actions: Revision complete, and 1-30 Implementation Plan approved by Policy Council on May 9, 1996. Item 137 The process of making decisions about the nature and operation of the Head Start program Reason for Non-Compliance: (E) -No approval of personnel policies;no evidence of approved recruitment plans; (G) - Financial report provided the PC is dated September, 1995; (H) -No evidence of approved written complaint procedure. Corrective Actions: (E) Personnel Policies approved April 18, 1996. (G) "Financial Reports"is now a standard item on Policy Council agenda, and is reflected in Policy Council minutes. (H) Community Complaint Procedure approved by Policy Council on May 9, 1996. (1) On May 9, 1996, Policy Council approved restructuring Teams One through Four proposals in concept. Item 146 Parent traininglodentation is provided on need to prevent child abuse and neglect, and to provide protection for abused and neglected children. [N-30-356-1-30] {See Ad#201] Reason for Non-Compliance: Limited evidence of child abuse training on file. Corrective Actions: (Refer to January, 1996 QIP p. 9) Meetings for parent training on Child Abuse Prevention have been held in March and April, 1996. April, 1996 was Child Abuse Prevention Month,and a GOP sites received Child Abuse Prevention training by the Early.Childhood Mental Health Program. Item 147 There shall be regular two-way communication between staff and parents, which provides information about., the program and its services;program activities for the children; the policy groups;and resources. [1304.5-4(a)] (See Ad#188C](R) Reason for Non-Compliance: (A)-No evidence of regularly scheduled newsletter; (F)-No evidence of written materials in languages(s)other than English. Corrective Actions: 2 A GOP-wide newsletter in English and Spanish was established in February, 1996. Three editions have been published. Flyers and resource materials have been translated into Spanish, Hmong, and Chinese. The "Center for New Americans"has been used as a resource for translation of materials, and for community-based activities.. Item 148 Information is provided to policy groups to enable them to make informed decisions, share professional expertise, and receive staff support. At a minimum, information will include: Reason for Non-Compliance: (B) -No evidence of recent transmittal notices in the PC minutes; (C) - Last financial report to the PC was dated September, 1995; (D) -No evidence or comments that either the Personnel Committee or the Policy Council were trained in the agency's personnel policies. Corrective Actions: (B) Distribution of all ACF information that grantee receives became effective May 9, 1996. Policy Council minutes have been changed to include a section on"Handouts,"and these handouts will be,listed. New system is in effect with May 9, 1996 Policy Council meeting. (C) "Financial Reports" is a standard item on the Policy Council agenda and is reflected in the minutes as of March, 1996. (D) Personnel Committee has been meeting since February of 1996. Personnel Policies have been approved by Personnel Committee as of April 18, 1996. Training is provided by Personnel Technician to Personnel Committee to Personnel Committee members regarding Personnel Policies and interviewing techniques. Item 155 Resources to implement the disabilities services plan are adequate: [1308.4 (n - o)] General Comments: Entrance gate at delegate site (First Baptist Church) is wheelchair a accessible; delegate is looking for new administration offices to comply with the IDEA. Corrective Actions: According to a letter received from the First Baptist Church dated May 3, 1996,the agency is looking for an administrative office which meets ADA. requirements. They plan to be in a new facility by January 1, 1998. 3 Item 156 Efforts to work with LEAs and other agencies within the grantee's service areas serving children with disabilities are accomplished through interagency agreements. [1308.4(1)] Compliance: SELPA agreement about having assessments and therapies in the child's primary language. Corrective Actions: (Refer to January, 1996 QIP p.14) Contra Costa County SELPA Inter-Agency Agreement approved by Policy Council on May 9, 1996. Approved by Contra Costa County Board of Supervisors May 14, 1996. Item 159 The grantee does not deny placement on the basis of a disability or its severity to any Head Start-eligible child when: the parents wish to enroll the child;Head Start is an appropriate placement;and the program has space. [1308.5(c)] Reason for Non-Compliance: Bayo Vista enrollment form states that child must be toilet trained to be enrolled in Head Start. Corrective Actions: • Removal of toilet training as a requirement of Bayo Vista's enrollment was completed May 2, 1996. • Grantee Enrollment Policy approved by Policy Council on May 9, 1996. • Grantee enrollment policy is to be used as a guide by delegate agencies. Item 160 The disabilities coordinator arranges for formal evaluation of children identified as possibly having a disability. [1308.6(e)] Reason for Non-Compliance: (A) -Bayo Vista had a child whose file is tagged as special needs; he has not had an assessment or IEP yet; (C) -Bayo Vista files were not locked; (D)- Head Start needs to request a copy of the parental consent form from the LEA. Corrective Actions: (A) Particular file for Bayo Vista now has referral, assessment and IEP; certified on May 2, 1996. (C) Staff has made at least six visits to Bayo Vista, and found all files locked. To assure that all appropriate files are locked,the grantee has developed and implemented a confidentiality policy which was approved February 15, 1996 by Policy Council. 4 (D) Access Logs will evidence signature of grantee staff monitoring files for completed consent and notification forms Item 161 There is an Individual Education Plan (IEP) for every Head Start child with a disability and in need of special education and/or related services. [1308.19] Reason for Non-Compliance: West GOP was missing eight IEPs, and four IEPs were over a year old. Corrective Actions: (Refer to January, 1996 QIP p. 15) All IEPs current and complete at GOP. Assessment,referral, individual plans, Individual Education Plans, and coded lesson plans are in place to assure confidentiality. A Case Management System was approved May 9, 1996 by Policy Council. This system will assure that needs of children and families are met in a timely manner. Proposals of restructuring Teams One through Four: organizational charts, organizational structures/systems, and training systems will provide an atmosphere for IEPs'to be developed, implemented, and updated appropriately in a cross component integrated system. Item 162 Special education and related services as described in the IEP are provided as soon as possible after the IEP meeting. [1308.19(1)] Reason for Non-Compliance: (A) -No documentation on lesson plan activities individualized for children with disabilities. Corrective Actions: (Refer to January; 1996 QIP p. 16) Coded lesson plan system is in place. All inter-agency agreements with SELPAs reflect agreement by SELPA to begin IEP services immediately. Item 163 Head Start IEPs are developed by a multi-disciplinary team. [1308.19(f- i)] Reason for Non-Compliance: (A) Bayo Vista disabilities coordinator or,representative has not attended the IEP meetings. Corrective Actions: 5 Bayo Vista staff attended a giantee training on April 19, 1996 regarding attendance of Head Start staff at IEP meetings. Review of all Bayo Vista files of children with disabilities indicates documentation of Bayo Vista staff attending IEP meeting. Item 164 Vigorous efforts to involve parents in the IEP process were made. [1308.196[)] General Comments: IEPs are not in parents' primary language. Reason for Non-Compliance: (A) -Not all records had parents' notification in the files. Corrective Actions: Letter on behalf of non-English-speaking parents advocating for IEPs to be in parents' primary language has been sent to all SELPAs on May 3, 1996. Grantee has reviewed and monitored 120 files of children diagnosed as disabled at all GOP sites. Notification, document, and signed consent forms are in appropriate files. On April 19, 1996, parents and staff participated in training on their roles in the IEP process. Item 165 The disabilities coordinator works closely with other Head Start staff to ensure that the-special needs of each child with disabilities are met [1308.18, 1308.20, 1308.4] Reason for Non-Compliance: Little.collaboration between components and within. components; no documentation that there is any inter-component coordination. Corrective Actions: Cross-component integration is conducted as evidenced in the coded lesson plans (a Coded Lesson Plan is a lesson plan that uses a specific code to identify children with disabilities] and Case Management Procedures as approved by Policy Council on May 9, 1996. The proposals of restructuring Team Four(to implement management system which will assure cross-component integration)were approved May 9, 1996 by the Policy Council and May 14, 1996 Contra Costa County Board of Supervisors. Training on the outcomes of restructuring Teams One through Four began April 24, 1996. Item 166 The program supports the transition process for children with disabilities who are entering and leaving Head Start [1308.4(8), (I)] General Comments: Very comprehensive document for transition to and from Head Start. 6 General Comment praised grantee. Item 181 The grantee has conducted a community needs assessment(CNA) within its service area at least once every three years, and updated it in each of the two intervening years by considering whether there have been significant changes in the information'contained in the CNA. The CNA includes the following information about the grantee's Head Start service area: General Comments: CNA should identify local community agencies/resources that address the three goals. The grantee will follow the CNA recommendation of the Federal Review Team when updating document. The resources which support(or are lacking in)the community regarding program goals and objectives will be listed. Item 182 Information from the community needs assessment has been used to: General Comments: To support the agency's goal of assisting families to gain employment/training toward self-sufficiency, full-day opportunities should be seriously considered. General Comments were provided by Federal Review Team. Grantee will update Parent Survey by June 13, 1996. Head Start shall cooperate with Child Development Division to accommodate needs of Head Start parents for child care. Item 184 The program option chosen meets the needs of the children and families as indicated by the grantee's community needs assessment [1306.31(b)] General Comments: Full-day services. General Comments provided by Federal.Review Team. An update of Parent Survey,to determine parent.needs regarding full-day option,will be conducted by June 13, 1996. Item 187 The grantee has, and implements, a written procedure which describes an on-going monitoring process that assures specific program objectives and activities are completed in a timely manner. (R, 1) 7 General Comments: A team approach to monitoring would promote greater cross component integration. ?. General Comments provided by Federal Review Team. Current monitoring process has been reviewed to reflect recommendations of Review Team. Monitoring procedures were approved by Policy Council May 9, 1996. Item 988 Each program should establish and maintain an internal communication system, including the following: Reason for Non-Compliance and General Comments: No evidence that PC is provided information it needs for informed decision-making; financial status reports. Corrective Actions: (Refer to January, 1996 QIP pp. 12-13) Policy Council minutes and agendas are posted on bulletin boards at all sites and Division office. The information is provided to Policy Council via Policy Council agenda packets(mailed out to all Policy Council members six days prior to meeting),handouts,and correspondence. The County operates by virtue of its Better Governance Ordinance, which dictates that all documents except Personnel, are open and available for public comment. Therefore, 96 hours prior to any meeting, agenda and other materials to be discussed at that meeting M=be.made available to Council members and public. The GOP-wide newsletter, started in February, 1996, provides information. Item 191 Grantee has an internal monitoring procedure for delegate program operations which (R, 1) General Comments: Monitoring procedure does not foster cross component integration of services from grantee/central office. Corrective Actions: (Refer to January, 1996 QIP p. 2,p. 6) Monitoring procedures have been updated to include Federal Review Team recommendations. A team of component managers and monitors will perform full monitoring. Limited monitoring will be conducted by Program Monitors and Program Monitor Assistants. Monitoring procedures update approved by Policy Council May 9, 1996. -Item.194 Head Start agencies shall establish personnel policies and procedures. (R) 8 Reason for Non-Compliance: Policy Council minutes do not reflect approval of personnel policies; sample indicated no evidence of reference checks or regular performance evaluations. Recent wage comparability conducted by grantee management staff, more prudent to have study done by an outside consultant. Corrective Actions: (Refer to January, 1996 QIP p.4) • Policy Council Personnel Committee reviewed written personnel policies and updated Personnel Policies were approved by Policy Council April 18, 1996. • Use of Temporary Appointment(can hire Head Start staff on an emergency basis for thirty days prior to approval of Policy Council)has been removed from updated Personnel Policies approved by Policy Council April 18, 1996. • Wage comparability study will be performed by an outside consultant or Human Resource Department. • Blood-borne pathogen procedures approved by Policy Council May 9, 1996. • CSD Personnel staff will perform reference checks prior to making any job offer, effective May 3, 1996. • Job evaluation instrument used for"represented class employees" given to CSD personnel support staff on May 3, 1996 for"meet-and-confer"negotiations with employee organizations. Item 196 A file and records system shall be maintained to include official documents for each staff member, related to: qualifications for appointment or promotion;periodic pay increases;records of continued training or education; official recognition;performance evaluation; and adverse action. The system must protect the confidentiality of personnel records. Reason for Non-Compliance: Reference checks and training recap forms - files reviewed show no evidence of their uniform use. At West GOP, cabinet housing personnel records was not locked. Corrective Actions: (Refer to January, 1996 QIP p.4, #3) • Proposal of restructuring of Team Three provides a system for reference checks,training and tracking of all staff. System to track training recommended by restructuring Team Three. • Personnel files at GOP West at Brookside are now in locked cabinet, effective May 6, 1996. Only personnel files will be kept in the locked cabinet. Item 200 The Head Start Director has designated a staff member who has responsibility for. Reason for Non-Compliance: Inadequate documentation of child abuse training. Corrective Actions: 9 Child Abuse Prevention trainings held March and April, 1996. Certificates of completion received by participants were sent to personnel files for documentation. Two events regarding Child Abuse Prevention training for staff were held on April 12, 1996. Two training events regarding Child Abuse Prevention for staff and delegate agencies were held April 19,1996. Fourteen parent training events were held in April, 1996. Training was provided by Early Childhood Mental Health Program. FIRST BAPTIST CHURCH HEAD START Item 072 A mental health professional shall be available, at least on a consultation basis, to the Head Start Program and to the children. (9) [1304.3-8(a)1-8] General Comments: Delegate has access to grantee's consultant for T I TA; identify monies to support a five-hour per week consultant for Mental Health support services. Corrective Actions: First Baptist Church Head Start submitted budget change request for permission to contract Mental Health Consultant; this request was granted. Administration: administration recommendations of the Federal Review Team for First Baptist Church Head Start are to reexamine program options and to make reference checks more consistent. k • Grantee will update Parent Survey regarding program options by June 13, 1996, and provide First Baptist Church Head Start with outcomes by July 1, 1996 • In the May 10, 1996 First Baptist Church Head Start letter,the agency agrees to be consistent in completing reference checks. BAYO VISTA CHILD AND FAMILY CENTER, INC. Item 083 Coordination with the education services component to provide a program keyed to individual development levels; (3) 10 ID, 1� Reason for Non-Compliance: Staff has begun training process to implement"Web of Life" curriculum in future. Corrective Actions: "Web of Life"curriculum is used as of May 3, 1996. Bayo Vista is using the coded lesson plan system to assure individualization. Item 085 Regular group meetings of parents and program staff; (5) Reason for Non-Compliance: Mental health activities are still in planning stage. Corrective Actions: Mental Health activities are now implemented as of May 3, 1996, as evidenced by summaries of parent meetings, parent support groups, and trainings. Also evident in lesson plans, coding system, and"Web of Life"curriculum. Grantee staff have monitored Bayo Vista Mental Health activities. Item 134 Working with their children in their own home in connection with the staff of the center. General Comments: Evidence in children's files:that home visits have occurred. Corrective Actions: Grantee monitoring found evidence that home visits occurred by October 31, 1995, and the second home visit was completed by April 30, 1996. Item 137 The process of making decisions about the nature and operation of the Head Start program. General Comments: DA has evidence of LPC receiving financial reports monthly and giving prior approval to hirings. Grantee monitoring has found that, as of May 3, 1996, all hiring is for single position and has received prior approval of LPC. Item 138 Participation of Head Start parents is voluntary, and not required as ..a condition of the child's enrollment. [1304.5-2(b)] General Comments: DA's parent involvement is voluntary,not a condition of enrollment. Grantee agrees with Review Team's position that participation of Head Start parents is voluntary, and not required as a condition of the child's enrollment. Grantee has monitored Bayo Vista parent involvement activities. Item 146 Parent traininglodentation is provided on need to prevent child abuse and neglect, and to provide protection for abused and neglected children. [N--30-356-1-30] [See Ad#201] General Comments: Evidence of child abuse prevention training. Grantee agrees with Review Team's position that there is evidence of child abuse prevention training. Item 148 Information is provided to policy groups to enable them to make informed decisions, share professional expertise, and receive staff support. At a minimum, information will include. Reason for Non-Compliance: No evidence of plan or timetable for submission of grant application. Corrective Actions: I-30 Implementation Plan will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting plans. Item 169 The family income is verified and documented with a signed statement by Head Start employee before determining that a child is eligible to participate in the program. [1305.4(c)] [1305.4(d)] [1305.4(e)] [See SS #126A] General Comments: Written procedures need to be updated to address current federal regulations. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting plans. 12 Item 173 The program has a formal process for establishing selection criteria and for selecting children and families that considers all eligible applicants. [13O5.6(a)] The program considers [13O5.6(b)] [See SS #119] General Comments: Written procedures need to be updated to comply with current federal regulations. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting plans. Item 174 The program maintains a waiting list that ranks children according to the program's selection criteria to assure that eligible children enter the program as vacancies occur. [13O5.6(d)] [See SS #.119] General Comments: Written procedures need to be updated to comply with current federal regulations. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting 45 CFR 1305 Implementation Plan Item 175 Each enrolled child, except those enrolled in a migrant program, is allowed to remain in Head Start until kindergarten or first grade is available in the child's community, unless there are compelling reasons for a child not to remain in Head Start [13O5J(a)] General Comments: Written procedures need to be updated to comply with current federal regulations. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting 45 CFR 1305 Implementation Plan 13 Item 176 If a child has been found income-eligible, and is participating in the program, he or she remains income-eligible through that year and the immediately succeeding enrollment year, [1305.7(c)] General Comments: Written procedures need to be updated to comply with current federal regulations. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting 45 CFR 1305 Implementation Plan Item 177 Funded enrollment levels are maintained Vacancies are filled as they occur, unless sixty calendar days or less remain in the program's enrollment year. [1305.7(b)] General Comments:. DAs enrollment in 142; 7 short of the funded 149. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting 45 CFR 1305 Implementation Plan Item 179 When the reasons for a child's absence are unexcused for four or more consecutive days, the program has initiated appropriate family support procedures, including home visits or other direct contact with the child's parents, that emphasize the benefits of regular attendance, while at the same time remaining sensitive to any special family circumstances. [1305.8(b)] [See SS#125] General Comments: Written procedures need to be updated to comply with current federal regulations. Corrective Actions: Updated written procedures will be in place by May 20, 1996. Grantee staff are working with Bayo Vista staff in rewriting 45 CFR 1305 Implementation Plan Item 185 The grantee should have and should implement a written procedure for program planning which is approved by the Board and the Policy Council, and which includes a process for formulation of component 14 objectives with adequate time for review of final objectives, including timetables and budgets. (R, 1) Reason for Non-Compliance: No written procedure for program planning that includes program goals and objectives. Corrective Actions: Written procedures will be in place by May 20, 1996. Grantee staff is working with Bayo Vista staff in rewriting grant application process plan and budget development plan. Item 187 The grantee has and implements a written procedure which describes an ongoing monitoring process that assures specific program objectives and activities are completed in a timely manner. (R, 1) Reason for Non-Compliance: No written procedure for monitoring. Corrective Actions: Written procedures will be in place by May 20, 1996. Grantee staff is working.with Bayo Vista staff in rewriting monitoring plans. 15