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Early Childhood Education |
Q. Does the McKinney-Vento Act address preschool? |
| A. Yes. The McKinney-Vento Act clearly and specifically includes preschool programs within its definition of free, appropriate public education. 42 U.S.C. §11431(1). |
Q. What must states do to serve preschoolers experiencing homelessness? |
| A. State plans must describe procedures to ensure that preschoolers experiencing homelessness have access to preschool programs administered by the State. 42 U.S.C. §11432(g)(1)(F). States are to use McKinney‑Vento grants in part to provide activities and services for preschoolers in homeless situations, so they can enroll in, attend, and succeed in preschool programs. 42 U.S.C. §11432(d)(2). State coordinators must coordinate with agencies that serve preschoolers, including child development and preschool personnel, to improve the provision of comprehensive services to children. 42 U.S.C. §§11432(f)(4), (f)(5)(A). |
Q. What must school districts do to serve preschoolers experiencing homelessness? |
| A. School district liaisons must ensure that families and children experiencing homelessness can enroll in Head Start and Even Start programs and preschool programs administered by the school district. 42 U.S.C. §11432(g)(6)(A)(iii). Districts can also use their McKinney‑Vento subgrants to provide early childhood education programs for children in homeless situations, if such programs are not otherwise provided through Federal, State, or local funding. 42 U.S.C. §11433(d)(6). |
Q. Does the McKinney-Vento Act require Head Start programs to enroll children without birth certificates or other documents? |
| A. This depends upon what agency operates the Head Start program. The McKinney-Vento Act applies to state and local education agencies. Therefore, a Head Start program administered by a state or local education agency may be covered by the Act and therefore required to enroll families and children immediately, even without birth certificates or other documents. 42 U.S.C. §11432(g)(3)(C). The 2007 reauthorization of the Head Start Act makes homeless children automatically eligible for Head Start and Early Head Start and establishes other policies and procedures to facilitate homeless children's participation in Head Start and Early Head Start. For more information, visit the Statutory Framework section of this site. |
Q. Under HHS Guidance, what documentation is required for proving homelessness? |
| A. According to informal guidance OHS - PC - I - 085 issued by HHS, "Section 640 (m) (1) of the Head Start Act as amended requires that homeless children be prioritized for enrollment. The Office of Head Start (OHS) recognizes that verification and documentation of the circumstances that fall within the federal definition of homeless children can present unique challenges to Head Start agencies. OHS encourages agencies to enroll homeless children based on the families description of their living situation (if that description meets the definition) while required verification of circumstances and collection of documents are obtained within a reasonable time frame. OHS encourages grantees to engage their school district homeless liaisons, private and public shelter providers, HUD Continuums of Care, and other homeless service agencies in their service area to assist in the verification and documentation process. OHS urges agencies to exercise sufficient care to ensure that their verification activities do not increase the risk that families may be evicted or suffer other resulting adverse consequences." |
Q. Under HHS Guidance, what type of living situation typically qualifies a child to be "homeless"? Also, what is the definition of "substandard housing"? |
A: According to HHS Informal Guidance OHS - PC - I - 086, To be categorically eligible for Head Start services as a "homeless child", a child must meet the definition in the McKinney-Vento Homeless Assistance Act of 2001. That Act defines homeless children as "individuals who lack a fixed, regular, and adequate nighttime residence." In addition the definition goes on to specify a number of living situations that homeless children may be found in, such as living in "trailer parks, or camping grounds due to the lack of alternative accommodations". The fact that a child lives in a trailer park does not necessarily cause such child to come within the definition of 'homeless child' unless other factors are present. The examples listed in the definition include many of the more common situations of homelessness but those examples are not meant to be exclusive; there may be some homeless families living in situations not included in the examples in the definition. Head Start staff must gather and analyze information from the family and possibly other sources in order to make the appropriate determination of eligibility. This must be done on a case by case basis because the circumstances of homelessness vary with each family's situation.
In determining whether a child is living in "substandard housing", Head Start staff must evaluate whether the child's housing situation falls short of community standards or is of lower quality than the law prescribes. Staff should consider factors such as whether there are health and safety concerns related to the housing; the number of occupants per square foot; the age(s) of the occupants; and whether the housing meets State or local building codes. Does a comparison of the housing in question with community norms and laws lead staff to conclude that it is lower than what community norms or laws require? |
Q. Under HHS Guidance, are Migrant and Seasonal Head Start programs responsible for prioritizing homeless children? |
| A: According to HHS Informal Guidance OHS - PC - I - 088, Migrant and Seasonal Head Start programs, as is the case for all other Head Start programs, are expected to make every reasonable effort to identify homeless families with Head Start age children and to give every consideration to enrolling those children in their Head Start program. However, all children served in Migrant and Seasonal Head Start programs, including homeless children, must be from families that are eligible for migrant and seasonal Head Start services (i.e. families who are engaged in agricultural labor). Migrant and Seasonal Head Start programs may not enroll homeless families that are not engaged in agricultural labor. Should Migrant and Seasonal programs identify such families, they are urged to contact the Head Start program in their community responsible for serving non-migrant/seasonal families. |
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