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HomeMy WebLinkAboutMINUTES - 07161996 - C80 1 I r I C.B0 THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Adopted this Order on July 16, 1996, by the following vote: AYES: Supervisors Rogers, Bishop, DeSaulnier, Torlakson, and Smith NOES: None ABSENT: None ABSTAIN: None SUBJECT: Correspondence C.80 LETTER dated June 26, 1996, from Maria L. Fort, Head Start Program Specialist, U.S. Department of Health & Human Services, Region IX, 50 United Nations Plaza, San Francisco, CA 94102, reporting on results of their review of the County's Head Start Program and of the progress made in correcting deficiencies as identified. ""REFERRED TO FAMILY AND HUMAN SERVICES COMMITTEE, COUNTY ADMINISTRATOR, AND COMMUNITY SERVICES DIRECTOR IT IS BY THE BOARD ORDERED that the above referrals are APPROVED; and DIRECTED that the County Administrator and Affirmative Action Officer report to the Board July 23, 1996, regarding the selection process for hiring Head Start staff. 1h es3rtiy that this Is a trueandeon�ectCopyof an action taken and entered on the minutes of the Board of Su m n the data ATTESTED: PHIL BA HELG .Clerkftf the Board Supervisors and County Administrator g L 0epuy c.c. Correspondents County Administrator Affirmative Action Officer Family and Human Services Committee Director, Community Services N s Region IX a Administration for DEPARTMENT OF HEALTH & HUMAN SERVICES Children and Families Refer to: Head Start [09CH0375] Region IX 50 United Nations Plaza j1jN 2 6 10 San Francisco, CA 94102 Jeff Smith, Chairman t Contra Costa County Board of RECEIVED Supervisors 651 Pine Street Martinez, California 94553 JUL 2 1996 Dear Supervisor Smith: CLERK BOARD OF SUPERVISORS P CONTRA COSTA CO. From May 29 to May 31, 1996, the Administration for Children and Families (ACF) conducted a final follow-up on-site program review (OSPRI) of those areas of your Head Start program which were still deficient during the February, 1996 ;F follow-up review. The purpose of the visit was to assess whether the Contra Costa County Community Services Department has made adequate progress in correcting the identified administrative and program deficiencies, to continue as a Head Start grantee, or whether termination proceedings needed to be instituted. I am pleased to convey to you the good news that due to the extraordinary measures and grantee activities between February 26 and May 20, 1996, especially in April and May, the County Board of Supervisors will remain the Head Start grantee in Contra Costa County. However, a number of systems still need to be properly ' coordinated and fully implemented, and the proposed organization structure put in place. In order to ensure that compliance with Federal laws and regulations;and with the Head Start performance standards has been fully achieved, ACF will conduct a full-scale on-site program review of the Contra Costa County Head Start program during the 1996-97 school year. Ti ri Historically, some of the deficiencies identified during the January, 1995 on-site program review (OSPRI), were also identified in the 1992 OSPRI, especially those pertaining to monitoring and other administrative requirements. Subsequently, in September, 1994, the County lost over $400,000 in Head Start funds because despite three attempts, the agency was unable to submit a Program <} Improvement application that could be funded before the end of the Federal fiscal Q year, September 30, 1994. On May 17, 1995, ACF sent your agency a Letter of Understanding (LOU) which detailed the findings of the January 23 to 27, 1995 on-sight program review, the strengths, the weaknesses, the non-compliances, and the deficiencies for both the grantee and the (then) four delegate agencies. "`i CID T Z� Jeff Smith - Page 2 r You were also advised that you had 90 days from the date of the receipt of the LOU to bring the non-compliances into compliance, and one year from the date �! =k of the receipt of the LOU to correct all the deficiencies, or your agency could face termination proceedings. Subsequently, your agency developed a Quality Improvement Plan (QIP) for the corrective actions needed to eliminate the deficiencies. The identified areas of deficiency were: Grantee: Administration, Mental Health, Parent Involvement, �{ Disabilities. RrtL Bayo Vista Tiny Tots Nursery School: Mental Health, 41 , Parent Involvement, r Eligibility, Recruitment, Enrollment... F First Baptist Church: . Mental Health, Parent Involvement. Since the grantee took over the operation of the Family Stress Center (FSC) and 8 United Council of Spanish Speaking Organizations (UCSSO) delegate agencies' Head Start program, it was the grantee's responsibility to ensure that all the deficiencies, including those identified at UCSSO and FSC, were corrected in a timely manner. From February 23 to February 26, 1996, a follow-up review was conducted of the deficient program components and the administration component, using the applicable sections of the OSPRI. The results of this review were communicated 1 , to you in a letter dated March 29, 1996. While there were some extenuating circumstances (grantee assuming the operations of two delegate agencies), and substantial progress was made, some key areas still remained deficient, especially in Administration, Mental Health and to a lesser degree in Parent Involvement and ; # Disabilities. It was also found that the First Baptist delegate agency had corrected _ all its deficiencies, but Bayo Vista, like the grantee still had several outstanding.. '` Jeff Smith - Page 3 { The final follow-up reviewers (except Ms. Anderson) had been involved in the January, 1995 and February, 1996 reviews: Rif rtL Administration: Maria Fort, Team Leader Norma Johnson "E Mental Health: Mary Soule Parent Involvement: Saovaros Diehl Disabilities: Teresa Anderson kph t �l The team found that all the deficiencies have been corrected, but some only s barely. The actions/activities contributing to the unprecedented progress were: ;a The Board of Supervisors assuming their governance role.- by requiring quarterly program progress/status reports from Head Start management. Change at the Executive Director level. Hiring of the Assistant Head Start Program Manager. ...^til Hiring of a management consultant. Engaging the County's Employee Assistance Program to work with staff on :improving morale and reducing stress. - Utilizing the Regional Technical Assistance Support Center, Development Associates, who helped the grantee develop with the assistance of peer facilitators, the organization structure, systems, policies and procedures; and a training plan. Bayo Vista delegate agency worked with First Baptist and also visited other Head Start programs to come up with necessary corrections to eliminate their deficiencies. iF ' sn .ik �. to Jeff Smith - Page 4 9. I •t ir}. Enclosed with this letter is the detailed report of the findings. Please note the recommendation of developing a unifying vision which is to be translated into goals and objectives, that all staff and parents can identify with and can rally { around. I would be pleased to meet with your Head Start management team and work out a schedule of items to be implemented and completed; identify the items, assign responsibility for its accomplishment, and a time table for completion. I will also be available to work with the management team on future training and technical assistance needs and help identify the most effective resources that are available. I again want to reiterate that we will conduct a full OSPRI during the 1996-97 's school year to ensure that all aspects of the administrative and program at deficiencies have in fact been corrected. We thank the Board, the staff, and the parents for their cooperation and patient assistance to the teams during these difficult on-site follow-up visits., y A. If you have any questions, please contact me at (415) 437-8445. F u: Sincerely, �t/�.►�' jai, Maria L. Fort Head Start Program Specialist Enclosure i cc: Executive Director Head Start Director Y{" Policy Council Chairperson County Administration Officer a[[ . 3' -kilts 40 L 9 "ka ` $,4s FY95 HEAD START FINAL FOLLOW-UP VISIT REPORT i CONTRA COSTA COUNTY COMMUNITY SERVICES DEPARTMENT HEAD START PROGRAM Grant No. 09CH0375 F rYi i? 651 Pine Street $ Martinez, CA 94553 a, i Supervisor Jeff Smith, Board Chairperson Mr. Phillip Batchelor, County Administrator Officer Mr. Scott Tandy, Executive Director Ms. Daneen Cali, Head Start Director Ms. Pam Franklin, Policy Council Chairperson Prepared by the Administration for Children and Families Maria L. !' Fort, Team Leader Fj 5 1"rr ti 06/21/96 HEAD START MONITORING TRACKING SYSTEM PAGE : MEN-1 REPORTING FOR FISCAL YEAR 1996 GRANTEE : 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS DATES OF REVIEW: 05/29/96 TO 05/31/96 MENTAL HEALTH ------------- Number of Parents Interviewed: 2 Number of Staff Interviewed: 9 Component Reviewers : Mary Soule MENTAL HEALTH COMPONENT STRENGTHS : 1 . The grantee has secured a mental health consultant with a strong background in family dynamics who is available 40 hours/week. 2 . Issues of staff alienation have been initially addressed by accessing the Employee Assistance Program, assessing staff needs, and inclusion of staff in the restructuring process .' MENTAL HEALTH COMPONENT RECOMMENDATIONS : 1.. Although all deficiencies in the mental health component have been corrected, the level of quality is extremely minimal . The grantee has secured a highly qualified consultant who has spent her time (employed 3 months) responding to. deficiencies and planning for the future . 2 . In this reviewer' s opinion, it is critical that stability of mental health staff at the grantee level be maintained; and that the full complement of mental health staff as described in the agency' s organizational chart (interns) be put in place as soon as possible . 3 . In addition, because of the multi-disciplinary nature of health issues affecting Head Start families, the position of Health Coordinator should be filled as soon as possible . 4 . The seven major causes of death today are largely "life style" diseases . (Heart decease, cancer, diabetes, drugs, including alcohol, AIDS, etc . ) All contain a critical prevention component . I urge this grantee to meet the challenge of quality, multi-disciplinary health services to improve the lives of staff, Head Start children and families, and of the community at large . PAGE MEN-2 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- ITEM 083 Coordination with the education services component to provide. a program keyed to individual development levels; (3) GENERAL COMMENTS Cross-Component approach to mental health activities is in the beginning stages . Mental health activities are indicated on lesson plans . 06/21/96 HEAD START MONITORING TRACKING SYSTEM PAGE: PAR-1 REPORTING FOR FISCAL YEAR 1996 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS DATES OF REVIEW: 05/29/96 TO 05/31/96 PARENT INVOLVEMENT ------------------ Number of Parents Interviewed: 2 Number of Staff Interviewed: 7 Component Reviewers : Saovaros Diehl PARENT INVOLVEMENT COMPONENT STRENGTHS : The formation of many committees, i .e. Personnel Evaluation; Parent Involvement, Education/Disabilities, etc, and the much improved communication systems greatly contributed to having the shared decision making process in place. The recent Quality Improvement Plan Team Activities to conceptualize the new organization structure, program planning, trainings, and delegate agency relations, exemplify the county leadership' s commitment to shared decision making and to changes for the benefit of the organization. The level of trainings recently given to the Policy Council have greatly enhanced their ability as a body to make informed -decisions and provided for more joint ownership of the program. The contents of materials provided to all PC members at the grantee level and the delegate agency level ensures continuous and on-going communication about the nature and content pf the program. Newsletters are bilingual and very professional in nature. Both the grantee and the delegate agency are to be commended for their ability to readily implement the systems and procedures/policies necessary for achieving full compliance with the Parent Involvement Component . PARENT INVOLVEMENT COMPONENT RECOMMENDATIONS: 1 . In the interest of best practice, the Emergency Fund needs to be reinvestigated to prevent even the appearance of a conflict of interest or personal gain potential. These funds are derived form parent fundraisers and are limited for the use of only PC members for the payment of emergency bills (i .e . shortage of rent/utilities, etc) . Other means of family assistance more consistent with the agency' s goal of self sufficiency should be considered, i .e . money management trainings or resource referrals, rather than direct loans . 2 . To continue the momentum for organizational change, for improved staff morale, and for positive relationship with DAs, the communication lines must remain open and honest . The spirit PAGE PAR-2 GRANTEE : 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- of respect and mutual trust must be fostered on a continuing basis . 3 . Implement the trainer position as outlined in the proposed organization chart . 4 . The parent pantry should be redesigned to make it accessible and benefit all the families, not only the PC members . S . Present to the parents the feasibility of establishing a pantry at all the sites which would be maned by the parents with the assistance of the Family Services and parent Involvement Assistants . 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 I-30-2 "The Parents" (70 . 2) [1304 . 5-2 (b) ] GENERAL COMMENTS An I-30 Plan was developed and approved by the Policy Council on May 9, 1996 and by the Board of Supervisors' pn May 14, 1996 . -'Bayo Vista (Delegate Agency) also developed an I-30 Plan similar to that of the grantee with agency-respective time lines and position designations consistent with their respective organizational structure . ITEM 136 Program activities they have helped to develop . GENERAL COMMENTS The current Fundraising Account Procedures/Policies is pending PC approval . The "Emergency Fund Account" derived solely from the parents' fundraising activities, is reserved for PC members, only. Members who are in dire financial need (i .e. rental shortage, utilities shortage, eviction, etc . ) are permitted to secure a loan from these funds with the stipulation that if there is non repayment, he/she will be dismissed from the PC. This practice of permitting loans to PC members can be construed as a conflict on interest (personal gain) to participate in PC. Furthermore, other means of family education/assistance would be more in line with the agency' s goal of fostering self sufficiency (i .e . Money Management Classes) . ITEM 137 The process of making decisions about .the nature and operation .of the Head Start program. GENERAL COMMENTS Grantee provided agency-wide training on "Shared Decision Making" (a PAGE PAR-3 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- follow up to their 10/95 training) on 4/19/96. Several committees have been established to foster the shared decision making process (i .e . Education/Disabilities; Evaluation; Finance; Personnel; Mental Health; Nutrition; Parent Involvement) . The Bayo Vista delegate agency also deserves to be commended for restructuring their shared decision making policies . All Board of Directors and LPC members receive packets consisting of the agenda, program reports (i .e . Director' s, Education, Fiscal/Finance) , pertinent correspondence, and minutes of various previous meetings to ensure for informed decision making. At both Grantee and DA the financial reports are now a standard item on the PC agenda .and are reflected in the PC minutes . ITEM 146 Parent training/orientation 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 #2011 GENERAL COMMENTS Trainings for parents and staff on Child Abuse Prevention and Positive Discipline. have been provided during the months of. March and April . Staff received a. trai.ning on "Child Abuse The Law" (4-12-96) and on 4-19-96 The ,Child Abuse Prevention Council conducted a training. At GOP Brookside a training was conducted on 4-17-96 . Within the PATHS Newsletter there is a feature article on the Child Abuse Prevention Council to further educate the families about resource within the area. Families also receive a calendar which includes the "Health Care for the Homeless Medical Team Schedule" which. also includes Child Abuse Trainings . 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) GENERAL COMMENTS Monthly newsletters are now distributed agency wide which are in both English and Spanish. The various newsletters are the CCHS Newsletter, GOP West Newsletter and the PATHS (Parent' s Awareness To Head Start) . The flyer regarding Head Start is in Hmong, Lao, Spanish and English. PAGE PAR-4 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- 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 : GENERAL COMMENTS Effective May 9, 1996 , all GOP sites and DAs receive the same ACF information that the Grantee receives . A list of "Handouts" are provided the PC as well as monthly financial reports . DAs have a similar system established. There is now a newly devised timeline for program planning, development and grant submission that is presented to the grantee PC and the delegate agency LPC for approval . 06/21/96 HEAD START MONITORING TRACKING SYSTEM PAGE : DIS-1 REPORTING FOR FISCAL YEAR 1996 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS DATES OF REVIEW: 05/29/96 TO 05/31/96 DISABILITIES SERVICES --------------------- Number of Parents Interviewed: 2 Number of Staff Interviewed: 8 Component Reviewers : Teresa Anderson DISABILITIES SERVICES COMPONENT STRENGTHS : 1 . The agency has worked diligently to comply with all items . The interviews, paperwork, and children' s folders validate that the items are met . 2 . The tracking system used to track children's IEPs and other pertinent information is commendable. DISABILITIES SERVICES COMPONENT RECOMMENDATIONS : Continue to strengthen the Individualization for all children, making sure all children are receiving all benefits from the program. 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) ] GENERAL COMMENTS Good tracking system established by Disabilities Specialists; all agreements are accounted for. ITEM 160 The disabilities coordinator arranges for formal evaluation of children identified as possibly having a disability [1308 . 6 (e) ] GENERAL COMMENTS At Bayo Vista and Brookside the files were all locked and confidentiality maintained. PAGE DIS-2 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE : 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- 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 . 191 GENERAL COMMENTS The 8 IEP' s were accounted for, the Disabilities Specialists had gotten them from the School District . 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) ] GENERAL COMMENTS Files were reviewed and found in compliance . ITEM 163 Head Start IEPs are developed by a multidisciplinary team. [1308 . 19 (f-i) ] GENERAL COMMENTS Files were reviewed and found in compliance . ITEM 164 Vigorous efforts to involve parents in the IEP process were made . [1308 . 19 (j ) ] GENERAL COMMENTS Records were reviewed and notifications were observed. Transportation and translation was provided for parents . 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 .41 GENERAL COMMENTS Interview conducted validated cross-component collaboration. ITEM 166. The program supports the transition process for children with disabilities who are entering and leaving Head Start . [1308 .4 (g) , (1) ] GENERAL COMMENTS Files and interviews validated the process . PAGE DIS-3 GRANTEE : 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- c. go 06/21/96 HEAD START MONITORING TRACKING SYSTEM PAGE: ADM-1 REPORTING FOR FISCAL YEAR 1996 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS DATES OF REVIEW: 05/29/96 TO 05/31/96 ADMINISTRATION -------------- Number of Parents Interviewed: 0 Number .of Staff Interviewed: 9 Component Reviewers : Norman Johnson ADMINISTRATION COMPONENT STRENGTHS : 1 . As a follow-up to ACF On-Site Review of February 23-26, 1996 , all items found out of compliance in the administrative component areas have been addressed and are now in compliance . Specifically OSPRI item numbers reviewed included #188 , 194 , 196, and 200 for the Grantee and items #185 and #187 for Bayo Vista Tiny Tots . 2 . Another major strength included the support and concern expressed by the Contra Costa County Board of Supervisors to correct all ,deficiencies and bring the program into compliance . It appears that the change at the Executive Director level has had a significant impact on the program. The recent hiring of the Assistant Head Start Program Manager has also facilitated a positive impact on the program. The continued involvement of these two positions is viewed as a definite strength in the Administration of the overall program. 3 . Lastly, Bayo Vista Tiny Tots has shown tremendous improvement over previous On-Site Reviews . The collaboration and" coordination with First Baptist and other Northern California grantees has contributed to this agency' s improvement . ADMINISTRATION COMPONENT RECOMMENDATIONS : 1 . Although specific areas reviewed have been addressed and are in the infancy stage of compliance, there still remains much to be done . Areas found to be in compliance were just recently developed and for the most part have yet to be implemented. Once. implementation occurs, there may be a need to revise/amend recently developed systems . 2 . The program continues to need focus and/or clear direction so all employees have a sense of where their respective division PAGE ADM-2 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------ is heading. A vision should be developed and goals, objectives, and plans for achieving the vision. Without this the program will continue to, what appears to be, disjointed, loosely defined and very much in a "reactive to crises" mode . Additionally, the level of mistrust by employees remains high. In general, the program appears to lack a clear understanding of the Head Start philosophy and programmatic systems that need to be in place to reflect that philosophy. 3 . The grantee might also consider doing what the Bayo Vista director and staff did, that is, to visit other grantees (recommended by ACF) and meet with their staff and look at other systems/procedures . This may facilitate a better picture of what could/should be or best practices for administrating a Head Start program. 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, I) GENERAL COMMENTS Bayo Vista has developed a detailed planning and monitoring system. They have mentored and .collaborated with other programs including the First Baptist delegate agency, and have implemented systems/procedures that will greatly enhance their services . ITEM 191 Grantee has an internal monitoring procedure for delegate program operations which: (R, I) GENERAL COMMENTS Full monitoring for component and contract compliance proposed every six (6) months in addition to specific component monitoring. Monitoring process is absent of reference to annual self assessment (which should be a part of the overall monitoring process) . Grantee should review the process to ensure its reasonableness both in the process and in the follow-up. ITEM 194 Head Start agencies shall establish personnel policies and procedures . (R) GENERAL COMMENTS The Head Start Program Manager and the Personnel Office have a written PAGE ADM-3 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS -------------------------------------------------------------------------------- agreement (5-3-96) that will facilitate employment references and performance evaluations (UTA tickler system) . Human Resources Division will ensure that all the required forms are on file prior to staff appointment. The last six, most recently hired staff had reference checks on file. The Human Resources Division will also be responsible for completing the Wage Comparability Study. Performance evaluations have been developed with input from staff and are ready to be utilized by supervisors . Human Resources Division is focusing on collaborating with and expanding services to the Head Start Divisions . 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 . GENERAL COMMENTS See previous remarks under #194 ITEM 200 The Head Start director has designated a staff member who has responsibility for: GENERAL COMMENTS The program has offered "Child Discipline" workshops for parents on April 5, 1996 (Cambridge) , April 17, 1996 (Brookside) and March 8, 1996 . Training has also been provided to staff on April 12 , 1996 . All trainings were supported by sign-in sheets, agendas and evaluations . PAGE ADM-3 GRANTEE: 09CH0375 CONTRA COSTA COUNTY COMMUNITY SERVICES DELEGATE: 005 BOARD OF SUPERVISORS ------------------------------------------------------------------------------- agreement (5-3-96) that will facilitate employment references and performance evaluations (UTA tickler system) . Human Resources Division will ensure that all the required forms are on file prior to staff appointment-. The last six, most recently hired staff had reference checks on file. The Human Resources Division will also be responsible for completing the Wage Comparability Study. Performance evaluations have been developed with input from staff and are ready to be utilized by supervisors . Human Resources Division is focusing on collaborating with and expanding services to the Head Start Divisions. 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 . GENERAL COMMENTS See previous remarks under #194 ITEM 200 The Head Start director has designated a staff member who has responsibility for: GENERAL COMMENTS The program has offered "Child Discipline" workshops for parents on April 5, 1996 (Cambridge) , April 17, 1996 (Brookside) and March 8 , 1996 . Training has also been provided to staff on April 12, 1996 . All trainings were supported by sign-in sheets, agendas and evaluations .