POLICY:

a) Child records are maintained by NOCAC Head Start staff in a manner that ensures only parents/guardians, and staff within the program or acting on behalf of the program have access. Child records are destroyed seven years after the program year has ended by a contracted shredding business.

b) NOCAC Head Start must maintain, with the child records, for as long as the records are maintained, information on all individuals, agencies, or organizations to whom a disclosure of PII from the child records was made (except for program officials and parents). NOCAC Head Start must maintain the reason why the disclosure was made. NOCAC Head Start must maintain the reason why the disclosure was made. NOCAC Head Start ChildPlus, a web-based data system, to maintain child records, ChildPlus ensures child records are adequately protected and maintained according to current industry security standards.

c) If a parent places a statement in the child record, NOCAC Head Start will maintain the statement with the contested part of the child record for seven years. NOCAC Head Start will disclose the statement whenever it discloses the portion of the child record to which the statement relates.

PROCEDURES:

a) A child record file containing original documents is compiled when a child is enrolled in the NOCAC Head Start program. The child record files containing original documents are kept at the NOCAC Central Office in the NOCAC Head Start program. The child record files containing original documents are kept at the NOCAC Central Office in locked file drawers and do not leave the file area.

b) Child record files containing copies of the original documents are kept in locked filing drawers at the center where the child attends Head Start. The center buildings are locked when staff are not present.

c) Child record files are kept for seven years and then shredded by a contracted shredding business.

d) In the event child records need to be shared with another agency, NOCAC Head Start requires a signed Release of Information form signed by the parents/guardians before any information is shared.

e) NOCAC Head Start uses ChildPlus as the software for children’s information. ChildPlus is a web based program that requires confidential login and strict passwords.

f) Statement given to NOCAC Head Start by a parent/guardian is kept in the child’s file until the entire file is shredded. The statement given to NOCAC Head Start by a parent/guardian is not shared with other agencies unless the parent/guardian signs a Release of Information form.

Forms and Additional Guidance:

POLICY:

NOCAC Head Start will establish written policies and procedures that are approved by the governing body and policy council and available to all staff.

PROCEDURES:

1. When creating a new policy and procedure:
   1. Service Area Manager will create the new policy and procedure using the Policy and Procedure Template. New policies will be created and retained on the Service Area Manager’s (or originator’s) computer so as not to overwrite the policy currently in effect.
   2. A Policy and Procedure Development Plan (PPDP) Policy Draft and Approval form will be completed.
   3. The new policy and the approval sheet are to be placed into the appropriate colored folder based on the categories. The folder will be routed between the appropriate team members for approvals/amendments. The folders can be obtained from the Data Systems Specialist.
   4. Any links to external websites or forms should be detailed within the policy itself and under the “Forms and Additional Guidance” section at the bottom of the policy. Links should be emphasized by using a blue font for ease when created on the website.
   5. If the new policy requires forms, the forms should be included in the routing folder and an electronic version of the forms will be emailed to the Data Systems Specialist in their original format (Word, Excel, etc.) to be saved in a central location for future updates.

ERSEA – Gray

Education – Pink

Safety – Red

Health – Orange

Transportation – Yellow

Nutrition/Dental – Green

FCE – Blue

Mental Health– Baby Blue

Disabilities – Purple

Human Resources, Program Design, Misc.- Black

2. When making modifications to an existing policy:
   1. The Service Area Manager will find the current policy that needs modified on the website. Print and mark the appropriate modifications. The Service Area Manager may also choose to copy the current policy from the website and paste into a Word document, highlight the changes, and then print a copy of the revised policy. Policies being revised will be retained on the Service Area Manager’s (or the originator’s) computer so as not to overwrite the policy currently in effect.
   2. A Policy and Procedure Development Plan (PPDP) Policy Draft and Approval form will be completed.
   3. The updated policy and the PPDP form is to be placed into the appropriate colored folder as shown on the above chart for routing. The new or modified policy and procedure will be routed to the appropriate staff as indicated on the PPDP approval form. The old policy indicating proposed changes will be attached.
   4. Once the final draft has been approved by all relevant service areas, the Director gives final approval and returns the folder to its originator.
3. All new or modified Policy and Procedures will be emailed to the Administrative Coordinator.
   1. No new or revised policies will be amended on the website until Board and/or Policy Council approvals have been obtained if required and noted on the PPDP. Approval dates must be shown on the appropriate section of the Policy and Procedure Template.
   2. The Administrative Coordinator will save the policy on NOCAC’s server and on an external hard drive in an editable document format. Policies will keep the same file name with a revision date added. Associated forms will be saved in an editable document format and a pdf format. Each form will be assigned a form number.
   3. When the Administrative Coordinator has completely prepared the new/revised policy for publication it will be entered into the NOCAC website and published Live.
   4. The Policy and Procedure folder is filed in the designated cabinet where it is available for reference.
   5. Policies and procedures will be reviewed annually for accuracy.
4. Obsolete or Cancelled Policy & Procedures
   1. When a Policy and Procedure is no longer relevant and needs to be removed from circulation the services area manager will get all approvals necessary from the Program Director.
   2. Utilize the PPDP form with instructions to withdraw it.
   3. Forward all relevant documents to the Administrative Coordinator.
   4. 1. 1. Pull the hanging file folder in cabinet and move to the “Old Policy & Procedure” tab.
         2. Move the word documents and related forms to the “Old Policy & Procedures” folder on the NOCAC server.
         3. Remove all the relevant documents and forms on the NOCAC website.

Forms and Additional Guidance:

• Policy and Procedure Template
• Policy and Procedure Development Plan (PPDP) Policy Draft and Approval form

POLICY:

The NOCAC Governing Body has legal and fiscal responsibility to administer and oversee the Head Start program, including the safeguarding of Federal funds.

PROCEDURES:

1. The composition of the NOCAC governing body is in accordance with the requirements of Act 642 c 1 B.
   a) Not less than 1 member shall have a background and expertise in fiscal management or accounting.
   b) Not less than 1 member shall have a background and expertise in early childhood education and development.
   c) Not less than 1 member shall be a licensed attorney familiar with issues that come before the governing body.
   d) Additional members shall:
   i) Reflect the community to be served and include parents of children who are currently, or were formerly, enrolled in Head Start programs; and
   ii) Are selected for their expertise in education, business administration, or community affairs.
2. If a person described above is not available to serve as a member of the governing body, the governing body shall use a consultant or another individual with relevant expertise and the qualifications as described, who shall work directly with the governing body.
3. Exception – If an individual holds a position as a result of public election or political appointment, and such position carries with it a concurrent appointment to serve as a member of the governing body, and such individual has any conflict of interest (Act 642 c 1 C).
   a) such individual shall not be prohibited from serving on such body and the Head Start agency shall report such conflict to the Secretary of HHS; and
   b) if the position held as a result of public election or political appointment provides compensation, such individual shall not be prohibited from receiving such compensation.
4. The NOCAC governing body is comprised of public, private and client sector members from each County plus a Policy Council representative. While some Head Start parents may run for and be elected to seats on the Board the memberships are never identical.
5. The Head Start Policy Council elects one person to serve as a member of the governing body. The member attends and votes at governing body meetings and facilitates communication as part of shared governance.

Training:

1. NOCAC will provide appropriate training and technical assistance or orientation to the governing body that includes training on the Head Start Program Performance Standards (HSPPS) program performance standards and training on eligibility for Head Start children as indicated in §1302.12(m) to ensure the members understand the information they receive and can effectively oversee and participate in the Head Start program.

Duties and Responsibilities of the NOCAC Governing Body:

1. The governing body shall adopt practices that assure active, independent, and informed governance of the Head Start program (including impasse procedures, internal dispute resolution, and facilitation of meaningful consultation and collaboration about policy council and governing body decisions) and fully participate in the development, planning, and evaluation of the Head Start program.
2. The governing body is also responsible for ensuring compliance with Federal laws (including regulations) and applicable State, tribal, and local laws (including regulations).
3. The governing body is also responsible for establishing procedures and criteria for recruitment, selection, and enrollment of children, reviewing all applications for funding and amendments to applications for funding,
4. The Head Start program ensures the sharing of about program planning, policies, and operations, including:
   a)  monthly financial statements, including credit card expenditures;
   b)  monthly program information summaries;
   c)  program enrollment reports, including attendance reports.
   d)  monthly reports of meals and snacks provided through CACFP
   e)  the financial audit;
   f)  the annual self-assessment, including any findings;
   g) the community-wide strategic planning and needs assessment of the Head Start program, including any applicable updates;
   h) communication and guidance from the Office of Head Start; and
   i)  the program information reports.
5. The governing board is also responsible for reviewing and approving all major policies of the agency, including:
   a)  the annual self-assessment and financial audit,
   b)  the agency’s progress in carrying out the programmatic and fiscal provisions in the agency’s grant application, including implementation of corrective actions, and
   c)  personnel policies of the agency regarding the hiring, evaluation, termination, and compensation of agency employees;
6. The governing board is also responsible for developing procedures for how members of the policy council are selected (see Act 642 c 2 B),
7. The governing board is also responsible for approving financial management, accounting, and reporting policies, and compliance with laws and regulations related to financial statements including the approval of all major financial expenditures of the agency, annual approval of the operating budget of the agency, and selection (except when a financial auditor is assigned by the State under State law or is assigned under local law) of independent financial auditors who shall report all critical accounting policies and practices to the governing body, and the monitoring of the agency’s actions to correct any audit findings and of other action necessary to comply with applicable laws (including regulations) governing financial statement and accounting practices.
8. The governing body is responsible for reviewing results from monitoring (see Act 641A c) including appropriate follow-up activities.
9. The governing body is responsible for approving personnel policies and procedures, including policies and procedures regarding the hiring, evaluation, compensation, and termination of the Executive Director, Head Start Director, Director of Human Resources, Chief Fiscal Officer, and any other person in an equivalent position with the agency.
10. The governing body is responsible for establishing, adopting, and periodically updating written standards of conduct that establish standards and formal procedures for disclosing, addressing, and resolving any conflict of interest, and any appearance of a conflict of interest, by members of the governing body, officers and employees of the Head Start program, and consultants and agents who provide services or furnish goods to the Head Start program and complaints, including investigations, when appropriate.
11. The governing body is responsible to the extent practicable and appropriate, at their discretion establishing advisory committees to oversee key responsibilities related to program governance and improvement of the Head Start program.

Governing Body Use of Data:

1. The governing body uses ongoing monitoring results, data on school readiness goals, other information described in §1302.102 (listed below), and information described at section 642(d)(2) of the Act to conduct its responsibilities. This includes:
   a)  Establishing program goals that include:
   i) Strategic long-term goals for ensuring programs are and remain responsive to community needs as identified in the community assessment
   ii) Goals for the provision of educational, health, nutritional, and family and community engagement program services
   iii) School readiness goals
   iv) Effective health and safety practices
   b) Monitoring program performance
   c) Ongoing assessment of program goals
   d) Using data for continuous improvement
   e) Status reports, determined by ongoing oversight data at least semi-annually

Forms and Additional Guidance:

POLICY:

The NOCAC Head Start Policy Council is responsible for the direction of the Head Start program at the agency level.  The program maintains a policy council in accordance with section 642(c)(2) of the Head Start Act.

PROCEDURES:

Regular meetings are held monthly on the first Monday of the month.  Special meetings may be called by the Director and/or Chairperson of the Policy Council during the program year and the summer months.

Policy Council Composition

1. The policy council is elected by the parents of children who are currently enrolled in the Head Start program.
2. The policy council is comprised of current parents of children who are enrolled in the Head Start program and community representatives.
3. Current Head Start parents constitute at least 51% of the members of the policy council.
4. Community representatives are drawn from the local community: businesses; public or private community, civic, and professional organizations; and others who are familiar with resources and services for low-income children and families, including parents of formerly enrolled children.
5. Parents of children currently enrolled in each program option are proportionately represented.
6. The program ensures members of the policy council do not have a conflict of interest with the Head Start program and sign a conflict of interest form at the November meeting.
   a. Members of the policy council do not receive compensation for serving on the policy council or for providing services to the Head Start program.
   b. No employee or their immediate family shall serve on the policy council in a voting capacity.  Staff members may attend the meetings of the policy council or committees in a consultative, reporting non-voting capacity.
7. All parent members of the policy council must be elected or re-elected annually.  All community representatives also must be recommended by the director and elected annually.
8. All parents and community representatives are limited to one-year terms for a combined total of five terms.
9. Policy Council meetings are open to all parents and interested individuals without voting privileges.

Parent Representatives

1. Each county shall be represented by parent representatives of 5% of the total number of children served in that county. The standard form of rounding will be used when a whole number is not available.
   1. Policy Council parent representatives will be elected by the Parent Committee at each site in each County in September and ongoing as necessary.
   2. The total number of parent representatives will be based on the actual enrollment in each option in a given year.  The Family & Community Engagement Manager will calculate the composition based on enrollment and the number of representatives will be made known to each Parent Committee prior to elections.  Only current Head Start parents can be members of the Parent Committees and only those members can vote for the Policy Council parent representatives.
   3. In addition to the regular Policy Council members, each site will elect at least 1 alternate to serve in the event that one of the regular members is unable to serve.

Community Representatives

1. Community representatives can come from the local community; businesses; public or private community, civic and professional organizations; and others who are familiar with resources and services for low income children and families.  Former Head Start parents may also be community representatives.
2. Perspective community representatives are brought to the policy council by a recommendation from the Head Start Director.  The policy council group must vote for the community representatives to be seated.
3. The elected Community Representatives join the Council with equal rights and responsibilities.

Officers

1. Election of the Chairperson, Vice-Chairperson and Corresponding Secretary will be held in October.  They shall hold that position for one year, being available for specially called meetings during the program year and/or the summer.  This is the Executive Committee.
2. Holding an office in the local Parent Committee will not prohibit parents from holding an office on the Policy Council.

Governing Body Representative

1. One person shall be elected to serve as the Head Start Policy Council representative to the Board of Northwestern Ohio Community Action Commission, annually, at the time of Policy Council elections, and may not serve more than two consecutive years (24 months).  If the Policy Council Board representative resigns, a new Board Representative for Policy Council must be elected by Policy Council.  The Policy Council representative is a voting member of the NOCAC Board.
2. One Board Representative will be appointed by the NOCAC Board to serve on Policy Council.  Who is this?

Voting

1. Quorum is established when 30% of Policy Council members are present.  The quorum must consist of at least 51% of the current parents for any business requiring Policy Council approval.  If a quorum is not present and critical business must be taken care of, accomplishment of the critical business shall be done by the Regulatory Committee where minutes will be taken and presented at the next Policy Council meeting.  If no quorum is present, a phone conference will be conducted to verify approval of critical business.
2. All motions will be carried by the simple majority.  A secret ballot will be issued only upon request.

Hiring and Termination of Staff

1. Hiring:  After the NOCAC Head Start Director or their designee have interviewed the applicants being considered for employment the Head Start Director will review the information with the NOCAC Executive Director and indicate the applicant they feel is bet qualified to fill the open position.  The Head Start Director will review the credentials and experience of the applicants that were interviewed at the next full Policy Council meeting.
2. Termination:  The NOCAC Head Start Director will review the documentation with the NOCAC Executive Director.  The NOCAC Executive Director and the NOCAC Head Start Director will make the decision to terminate.  The NOCAC Head Start Director will discuss his/her recommendation to terminate the employee with the full Policy Council.

Committees

1. The following committees are formed from Policy Council members:  Regulatory Committee, Education Committee, Health & Safety Committee, Family & Community Engagement Committee, Mental Health & Disabilities Committee, and Data Outcomes Committee.
2. The Policy Council Chairperson may call for a majority vote on removal of members that do not regularly attend committee meetings.
3. Committees shall have a minimum of fifty-one (51%) percent membership of current Head Start parents.
4. Minutes and attendance are to be taken at all committee meetings.

Removal of Members

1. If The Policy Council feels that a member is not contributing to the Policy Council (e.g., a large number of excused absences or the member is acting in a way that is detrimental to the council), the Policy Council may vote to remove the member.  In cases of removal due to lack of attendance, the Chairperson may call a vote.  If the member is a current parent, the Parent Committee that they represented must be notified of removal and the Parent Committee must elect a new representative.
2. If a Parent Committee feels a representative is not functioning on behalf of their interests, a vote must be taken at a regularly scheduled parent committee meeting to remove the representative.  Policy Council must be notified of removal and the Parent Committee must elect a new representative.
3. Any Policy Council member may resign by submitting a written resignation to the Policy Council Chairperson with a copy to the Director or by missing 2 scheduled meetings without an approved excuse.
4. Any Policy Council member found to have breached confidentiality in any way shall be voted on for removal.

Policy Council Responsibilities

1. The Policy Council is responsible for approving and submitting to the governing body decisions about:
   1. Activities to support the active involvement of parents in supporting program operations, including policies to ensure that the Head Start agency is responsive to community and parent needs.
   2. Program recruitment, selection, and enrollment priorities.
   3. Applications for funding and amendments to applications for funding for programs, prior to submission of applications.
   4. Budget planning for program expenditures, including policies for reimbursement and participation in policy council activities.
   5. Bylaws for the operation of the policy council.
   6. Program personnel policies and decisions regarding the employment of program staff, regarding the hiring, evaluation, compensation, and termination of the Executive Director, Head Start Director, Director of Human Resources, Chief Fiscal Officer, and any other person in an equivalent position with the agency, including standards of conduct for program staff, contractors, and volunteers and criteria for the employment and dismissal of program staff.
   7. Developing procedures for how members of the policy council of the Head Start agency will be elected.

Reporting

1. The program submits the following status reports determined by ongoing oversight data to the policy council:
   1. monthly financial statements, including credit card expenditures;
   2. monthly program information summaries;
   3. program enrollment reports, including attendance reports;
   4. monthly reports of meals and snacks provided through CACFP;
   5. the financial audit;
   6. the annual self-assessment, including any findings related to such assessment;
   7. the community-wide strategic planning and needs assessment of the Head Start agency, including any applicable updates;
   8. communication and guidance from the Office of Head Start; and
   9. the program information reports.

Reimbursement for Reasonable Expenses

1. Policy council members can be reimbursed mileage to and from the meeting at the rate per mile that the agency pays staff.  Childcare is offered on site for children of the policy council members.  Childcare can be reimbursed if the child is in the care of another provider who is not living in the home.

Program Governance Training

1. To ensure the members understand the information they receive and can effectively oversee and participate in the Head Start program, the program provides appropriate training and technical assistance to the Policy Council in November which includes:
2. Training on program performance standards and eligibility to include:
   1. methods on how to collect complete and accurate eligibility information from families and third party sources;
   2. strategies for treating families with dignity and respect and for dealing with possible issues of domestic violence, stigma, and privacy;
   3. program policies and procedures that describe actions taken against staff, families, or participants who attempt to provide or intentionally provide false information.
3. After the initial training, the program provides training as the need arises.  The Policy Council binder is distributed to members at the orientation in November.

Disagreement Resolution

1. If there is a disagreement between the Director, Policy Council, and/or Regulatory Committee, any hiring or termination will be delayed until the issue is settled.  A meeting must be held within seven calendar days of the disputed decision.
2. The meeting will consist of the following people: Regulatory Committee of Policy Council, Director, Executive Director, and Moderator.
3. The Moderator will chair the meeting. All sides of the issue will be presented.  The Moderator will attempt to resolve the issues to the mutual satisfaction of all parties.

Impasse Procedure

1. Head Start grantees must inform the responsible ACF Regional Office as soon as possible after becoming aware that there is a conflict between the grantee agency and the Policy Council, especially those which, if not resolved, could lead to termination, or denial of refunding, of the Head Start grant.  This notification must be made within ten (10) days of the grantee becoming aware of the conflict and in the case of a Policy Council proposing to not approve the grantee’s refunding application, such notification must be made at least 90 days prior to the grantee’s refunding date.  If the situation leading to the Policy Council’s decision to withhold its approval occurs within 90 days of the grantee’s refunding date, the grantee must notify its responsible Regional Office immediately.
2. The Regional Administrator, or a Regional staff member designated by the Regional Administrator, will hold one or more meetings, as appropriate, which the Grantee’s Executive Director, the Grantee’s Head Start Director and the Policy Council Chairperson are required to attend.  The attendance of grantee board members at any meeting is encouraged.  The purpose of these meetings is to attempt to resolve the issues to the mutual satisfaction of all parties and thus avoid the possibility of an adverse action against the grantee.
3. If the meetings are not successful in resolving the issues between the grantee and the Policy Council, the grantee should, within 10 days of the meeting, submit the dispute to the offices of a professional mediator.  The Regional Office will provide assistance to the grantee in selecting a mediator.  The grantee is requested to advise the Regional Office of the time and location of the first scheduled meeting.  The grantee and the Policy Council are expected to attend any meetings requested by the mediator.
4. If the conflict relates to the grantee’s refunding, the mediation process must be completed 15 days prior to the grantee’s refunding date unless the mediator has indicated to the Regional Office, in writing, that additional time for mediation will likely result in a successful resolution of the conflict, in which case the Regional Administrator may extend the current Head Start grant.  The refusal of either party to engage in a mediation process shall be taken into consideration by the AFC Regional Office in determining what course of action is warranted.

Forms and Additional Guidance: 

https://eclkc.ohs.acf.hhs.gov/organizational-leadership/article/what-policy-council

POLICY:

To deliver the full range of services, consistent with §1302.20 b, through visits with the child’s parents, primarily in the child’s home and through group socialization opportunities in a Head Start classroom, community facility, home, or on field trips.

PROCEDURES:

The Head Start Home Based option will only be used to deliver services to a portion of the program’s enrolled children.

The Early Head Start Home Based option will be used to deliver services to all EHS enrolled children.

Head Start:

• The program will maintain an average caseload of 10 to 12 families per Head Start Home Visitor with a maximum of 12 families for any individual Head Start Home Visitor.
• The program will provide one home visit, per week, per family that lasts at least an hour and a half.
• The program will provide a minimum of 32 visits per year per family.
• The program will provide a minimum of 16 group socialization activities distributed over the course of the program year.

Early Head Start:

• The program will maintain an average caseload of 11 families (including one prenatal) per EHS home visitor.
• The program will provide 1 home visit per week per family that lasts at least an hour and a half for enrolled participants.
• The program will provide at least one home visit per month for prenatal moms in accordance with their prenatal plan.
• The program will provide a minimum of 46 visits per year per family.
• The program will provide a minimum 22 group socialization activities distributed over the course of the program year.

HS/EHS home visitors will make up planned home visits or scheduled group socialization activities that were canceled.

HS/EHS home visitors will not replace home visits or scheduled group socialization activities for medical or social service appointments for the purpose of meeting the minimum requirements.

Forms and Additional Guidance:

POLICY:

NOCAC operates program options that meet the needs of children and families based on the community needs assessment.

PROCEDURES:

Options

The program determines after review of the community assessment which options will better meet child and family needs.

Classes are determined when final enrollment is reached considering where the families are located within the service area.

The Head Start program offers, Full Day/Full Year center based, 3 ½ hour Half Day center based, and Home-based options.

The EHS program offers the ome-based option.

After determining the options a staffing chart is developed that displays the county, center, option and staff needed to operate the options.

The staffing chart is shared with the policy council and the NOCAC board annually for approval.

Comprehensive Services

All program options deliver the full range of services as described in subparts C, D, E, F, and

G of the Head Start Performance Standards.

Forms and Additional Guidance: