To determine a child’s living situation, OHS follows the McKinney-Vento Act’s definition of homeless:

• The term “homeless children and youths” —
  • (A) means individuals who lack a fixed, regular, and adequate nighttime residence (within the meaning of section 103(a)(1)); and
  • (B) includes —
    • (i) children and youths who are sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason; are living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations; are living in emergency or transitional shelters; or are abandoned in hospitals;
    • (ii) children and youths who have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings (within the meaning of section 103(a)(2)(C)); 
    • (iii) children and youths who are living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings; and 
    • (iv) migratory children (as such term is defined in section 1309 of the Elementary and Secondary Education Act of 1965) who qualify as homeless for the purposes of this subtitle because the children are living in circumstances described in clauses (i) through (iii).

View the full text of the McKinney-Vento Homeless Assistance Act.

No. These terms are used as part of a program’s administrative procedures. Whenever possible, avoid using “homeless” and “experiencing homelessness” in conversation with families. Many American Indian and Alaska Native families do not recognize the term since families take care of each other to avoid someone being without a home. Other families may not consider themselves homeless even though their living arrangement meets the legal definition.

OHS encourages programs to explore alternative terms for talking with families about their living circumstances. Visit the Family Engagement section below.

The McKinney-Vento Act and other federal laws do not give official definitions of a “fixed, regular, and adequate nighttime residence.” However, the following working definitions from the National Center for Homeless Education may be useful:

• A “fixed nighttime residence” is stationary, permanent, and not subject to change
• A “regular nighttime residence” is used on a predictable, routine, or consistent basis
• An “adequate nighttime residence” sufficiently meets the physical and mental health needs typically met in home environments

Module 3 provides more insights into the McKinney-Vento definition and what it means for Head Start programs.

Potentially. Programs must carefully and sensitively learn from families whether they live with relatives or friends due to a crisis (e.g., loss of income, natural disaster, domestic violence) or another economic-related hardship. If so, that family meets the definition of experiencing homelessness under the McKinney-Vento Act. This would be true whether or not these families pay rent or motel fees.

Potentially. Programs must carefully and sensitively learn from migratory families whether they qualify due to lack of a fixed, regular, and adequate nighttime residence. This includes families who are sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason. If so, that family meets the McKinney-Vento definition of experiencing homelessness.

Potentially. Simply living in a mobile home or trailer park does not mean that a family or child is experiencing homelessness. Programs must carefully and sensitively assess the family’s living situation to determine whether it is due to loss of housing, economic hardship, or a similar reason. If so, that family meets the definition of experiencing homeliness under the McKinney-Vento Act.

Yes. A family living in transitional housing is considered homeless because it is temporary, not fixed.

Potentially. Migrant families often live in temporary housing to follow crops and harvest seasons. This circumstance alone would not be considered homeless under the McKinney-Vento definition. However, migrant families may be considered homeless in certain other circumstances, such as:

• If their housing conditions were unhealthy or unsafe due to overcrowding or lack of sanitation
• If they had a sudden, unplanned loss of income and had to leave their home for other work
• If a family was staying with other families and there was the threat that they could lose their housing at any time

A child is participating in a Head Start program under the McKinney-Vento Act will remain eligible through the end of the succeeding program year (45 CFR §1302.12(j)).

If a child moves from Early Head Start (EHS) to a Head Start program, staff must re-verify the family’s eligibility. If the family is still experiencing homelessness or meets other eligibility criteria, they remain eligible for Head Start services. If a program operates both Head Start options, they must ensure, whenever possible, the eligible child moving out of EHS and into the Head Start program receives services until enrolled in kindergarten.

Yes, families who are displaced by disasters generally will meet the McKinney-Vento definition. However, each family’s situation must be reviewed on a case-by-case basis to determine if a disaster or event caused displacement or loss of fixed or adequate housing. Disasters (e.g., floods, fires, and storms) and other threatening events can devastate communities and the lives of people who live in them. Many children and youth who are displaced by disasters are forced to live in a variety of unstable, temporary arrangements. The McKinney-Vento Act’s definition of homeless includes a broad array of living situations, such as hotels, motels, campgrounds, cars, parks, and sharing the housing of others. Accommodations set up by relief and community agencies may also qualify.

Yes. All Head Start programs — Head Start, Early Head Start, American Indian and Alaska Native, and Migrant and Seasonal Head Start — must prioritize families experiencing homelessness. This requirement is included in the Head Start Act, the Head Start Program Performance Standards (HSPPS), and the McKinney-Vento definition of homelessness (45 CFR §§1302.11(b), 1302.13, 1302.14(a), and 1302.15(c)).

No. Eligible applicants are not guaranteed enrollment in a program. However, programs must use their selection criteria to prioritize families most in need of Head Start services, which includes children experiencing homelessness.

A program may reserve up to 3% of a program’s funded enrollment slots for families experiencing homelessness or children in foster care who could benefit from services (45 CFR §1302.15(c)). However, programs are encouraged to serve and enroll as many children and families experiencing homelessness as possible.

A program can reserve slots for children experiencing homelessness for 30 days. If a reserved enrollment slot is not filled within 30 days, the slot then becomes vacant and the program has an additional 30 days to ensure it is filled with the next eligible child and family most in need of services.

Yes, there are regulatory flexibilities in the HSPPS to support the enrollment of children experiencing homelessness. If a program is able to verify homelessness, a child may attend for up to 90 days, or as long as allowed under state licensing requirements, without immunization and other records to give the family reasonable time to present these documents. A program must work with families to get children immunized as soon as possible in order to comply with state licensing requirements (45 CFR §1302.16(c)).

When determining eligibility for enrollment, a program can have conversations with families to discuss their access to basic needs such as food and safe living circumstances. However, conversations about living circumstances should happen throughout the program year, since families’ living circumstances can change. Be sure to record and track any new information about families’ housing instability.

Yes. There are different ways to look at and understand family living circumstances. OHS recommends using language that is acceptable to their communities and families but still facilitates a determination of whether the child’s living arrangement meets the McKinney-Vento definition of homeless.

Caring and sensitive conversations begin with a simple invitation for the family to share their story. Appropriate language is also needed in program interactions and applications and intake materials. In addition to determining eligibility, questions and conversation starters can lead to concrete supports and referrals programs may be able to provide. For example:

• Consider using terms like “in transition,” “displaced,” or “temporary housing situations” to accurately refer to a family’s living situation
• For a family living in shared housing due to financial hardship, the terminology on the application and enrollment forms could be listed as “Currently sharing housing” or “Living with extended family”
• For a family living in substandard housing, application and enrollment forms may ask if the family’s home is:
  • Without adequate heat, electricity, or water
  • With unsafe heat sources or electrical service
  • With unsafe conditions, such as holes in flooring
  • With a kitchen or plumbing that is inoperable
  • Condemned by housing or other government authorities

It is important that programs document how families meet the McKinney-Vento definition of homelessness when determining eligibility and throughout the year when living circumstances change. Accurate Program Information Report (PIR) reporting must occur so OHS can continue to understand the scope of housing instability in the communities served by Head Start programs.

Module 4 focuses on using respectful and strengths-based strategies in conversations with families experiencing homelessness.

Staff can honor family customs with curiosity and a willingness to learn about what is important to them, including other family members and friends who are part of a child’s life. As an example, programs could consider a conversation starter, such as:

“Even though many families choose to live together for cultural and economic reasons, we do have a law — the McKinney-Vento Act — that is sensitive to the lack of available housing in the U.S. and the need for children to have safe and stable places to live, grow, and thrive. Would it be OK if I asked you a few questions about your living circumstances to see if you would qualify for the Head Start program in this way?”

Chronic absenteeism disproportionately affects vulnerable students, particularly those experiencing homelessness. If a child is unable to attend classes regularly, program staff should work with the family to understand why and which supports may be needed to improve attendance. For example, if the child is often absent because the family does not have transportation to and from a center or socialization, the program must use community resources, including partnerships with local school districts, and where possible, provide transportation for the child (45 CFR §1302.16(c)(2)). Programs can also work with families to ensure they have what they need to be safe and healthy, including shelter or rental assistance, food, clothing, health insurance, employment supports, and health, mental health, and behavioral health services.

Yes, in order for a family to qualify for MSHS, the program must still verify that one family member’s income comes primarily (more than 50%) from agricultural work (45 CFR §1302.12(f)). Section 238 of the Further Consolidated Appropriations Act, 2024, provides that the total amount of a family’s income has no bearing on eligibility for MSHS services. So long as the income of one family member comes primarily from agricultural work and the child is age eligible, the family will qualify for MSHS.

All families in an AIAN Head Start program's service area with age-eligible children, or pregnant people, are now eligible for services. This includes families who are experiencing homelessness. AIAN programs are still required to annually establish selection criteria to enroll children in their service area who would benefit most from Head Start services — which tribes may determine at their discretion to include families experiencing homelessness — and to report data on these families as required in Section C of the PIR form.

The McKinney Vento Act does not specify a timeframe for a family’s living situation in determining whether they are experiencing homelessness. The length of time a family has been in a living situation has no bearing on the factors that determine whether a family is experiencing homelessness under the McKinney Vento Act. If the family’s living situation meets the definition in the McKinney Vento Act — regardless of how long they have lived in the situation — the family is considered homeless.

Once a child is enrolled in a Head Start program, they will remain eligible through the next program year, regardless of how they were deemed eligible, unless there are compelling reasons for the child not to remain (45 CFR §1302.12(j)(1)).

As described in detail in 45 CFR §1302.12(j), barring the prior exception listed, programs are only required to recertify eligibility when a child transitions from Early Head Start to Head Start Preschool.

To verify whether a family is experiencing homelessness and meets the McKinney-Vento definition of homelessness, a program may accept a written statement from a homeless services provider, school personnel, or other service agency attesting that the child is experiencing homelessness or any other documentation that indicates homelessness, including documentation from a public or private agency, a declaration, information gathered on enrollment or application forms, or notes from an interview with staff to establish the child is experiencing homelessness, or any other document that establishes homelessness.

There may be circumstances where a family cannot provide documentation to prove the child is experiencing homelessness. Programs may accept the family’s signed self-declaration to that effect if, in a written statement, staff describe the child’s living situation that meets the definition of experiencing homelessness, (45 CFR §1302.12(i)(3)(ii)). Program staff also may seek information from third parties who have firsthand knowledge about a family’s living situation, but only if the family gives written consent. If the family consents, staff must adhere to program privacy policies and procedures and ensure the eligibility determination record adheres to recordkeeping requirements (45 CFR §1302.12(k)).

Regardless of documentation type, program staff must describe efforts made to verify the accuracy of the information provided and state whether the family is eligible because they are homeless (45 CFR §1302.12(i)(3)(i)).

No. A family’s signed declaration does not need to include the word homeless, as long as the declaration describes a living situation that meets the McKinney-Vento definition of experiencing homelessness. In many instances, OHS recommends that programs avoid using the words “homeless” or “experiencing homelessness” in conversation with families. Many families would not want to be labeled as homeless, and others may not consider themselves experiencing homelessness even though their living arrangement meets the definition.

Yes. There are no OHS requirements that direct programs to request proof of guardianship for children to participate in Head Start programs. OHS also does not require programs to ask for proof of citizenship or immigration status for the child or family. Applying to and participating in a Head Start program will not have a negative impact on an individual or family’s immigration status.

The U.S. Department of Education has mandated that schools may not ask about a parent, guardian, or child’s citizenship or immigration status to establish residency within the district. A school district cannot deny a child experiencing homelessness enrollment because the family cannot provide the required documents to establish residency. OHS follows a similar policy.

Head Start regulations do not require a program to provide transportation. However, if a child experiencing homelessness is unable to attend classes regularly because the family does not have transportation to and from the facility, the program is required to use community resources and provide reasonable assistance (e.g., public transit availability and maps) or, where possible, provide transportation for the child (45 CFR §1302.16(c)).

Programs are also required to support homeless children to transition to other Head Start programs if they move out of the community (45 CFR §1302.72(a)).

Programs that receive operation funds through a local education agency (LEA), or programs where an LEA is the Head Start recipient, may have their own requirements where transportation for all children experiencing homelessness, including Head Start children, is required. The Individuals with Disabilities Education Act (IDEA) requires public schools to provide transportation services to students with disabilities, if it is necessary for them to access their educational program. This includes transportation to and from school, as well as transportation for extracurricular activities.

Head Start programs should consider strategies to strengthen existing partnerships and build new ones to expand enrollment and access to supports and services for families experiencing homelessness. This can mean leveraging state, local, and private initiatives as partners to meet community needs more effectively. Community partners that Head Start programs can work with include, but are not limited to:

• Head Start Collaboration Offices (HSCO)
• State McKinney-Vento coordinators
• LEA McKinney-Vento liaisons
• Program providers who receive Child Care and Development Fund subsidies
• Homeless shelters and transitional housing programs
• Continuums of care
• Mental health or substance abuse support programs
• Domestic violence shelters
• Public housing authorities and Section 8
• Tribal housing authorities
• Food banks
• Low Income Home Energy Assistance Program (LIHEAP)
• Community action, faith-based, culture-sensitive, and other nonprofit organizations

For a fuller list of potential community partners to help support children and families experiencing homelessness, check out Module 8.

Programs can start by reviewing general information about help with rent and housing on the Consumer Financial Protection Bureau website. They can also reach out to their local Public Housing Agency to determine whether families could be eligible for a housing voucher.

Developing and maintaining partnerships with housing agencies and liaisons is one of the best ways to stay up to date on programs, policies, and resources. This means programs can help families quickly connect with meaningful resources they are eligible for, like rental assistance. OHS recommends that programs know and connect with their local Continuum of Care agencies and homeless liaisons.

First, programs can make sure they have information available and on display at the Head Start center so that families have easy access to resources they may need. This may include details about rental assistance, housing vouchers, shelter assistance, and local and national hotlines. These resources should be displayed in languages spoken in the community. Programs can identify and support enrolled families who experience a change in their living situation by building and maintaining relationships with them. Strong relationships are foundational to provide support that is meaningful and targeted to families’ needs.

Program staff may be in a unique position to notice changes in family members that might signify a new living situation. Families may be more likely to share this information if staff have an established relationship and a history of problem-solving together, and if they trust that staff will support them through the stress. Certain unexpected behaviors or patterns may indicate housing instability or homelessness. For example, family members may:

• Be less available and their schedules may be less consistent
• Have trouble providing basic care items such as diapers, changes of clothes, or medications
• Change contact information or addresses frequently or ask not to be contacted at home

Children’s behavior may also seem different. For example, children may:

• Have a harder time separating or be more emotional
• Seem more tired and irritable
• Create new play themes or tell stories that surprise you
• Share information about their living situation

Of course, these behaviors may reflect another change in a child’s or family’s life and not indicate homelessness. Programs can work with families to understand their situation and determine whether additional services would be beneficial. If there is a concern that a family may be experiencing housing instability or homelessness, be prepared to gently ask families if their living situation has changed. For example:

• “You seem more tired lately; is everything okay?”
• “I noticed your child has been crying at drop-off this week.”
• “Your sister seems to be helping out a lot lately.”

Depending on the family member’s answer, consider following this up with, “Has anything changed recently?” If a parent or family member trusts you enough to offer details about their living circumstances, remember to ask their permission before sharing anything with other program staff or community partners.

Learn more about building relationships with families experiencing homelessness in Module 7.

In Sec. 636 of the Head Start Act, the Head Start purpose is defined, in part, as “the provision to low-income children and their families of health, educational, nutritional, social, and other services that are determined, based on family needs assessments, to be necessary.” As such, programs can offer types of extra services to enrolled families experiencing homelessness. However, recipients still need to comply with the cost principles in 45 CFR Part 75 and any costs incurred need to be necessary and reasonable.

Community assessments provide a starting point for understanding and identifying community strengths and gaps in services. Collected data informs selection policies and procedures for prioritized enrollment of children and families who can most benefit from Head Start services, such as those experiencing homelessness. Yearly updates to community assessments can point to emerging trends and changing needs of families in the communities served by a program. It is important for programs to review community assessment and other program data to regularly improve outreach, recruitment, and selection practices for families experiencing homelessness.

Collecting accurate information on a family’s housing status or circumstances ensures programs remain responsive to the needs of the children and families they serve. Identifying families experiencing homelessness is especially important. They may or may not know what services they qualify for or where services are located, or how to find and apply for free or subsidized early childhood and school-age care programs. Some families may be unable to take advantage of parent information and enrollment services because they are without resources or a stable address. Working with families to understand their circumstances ensures that they receive the right help and supports from Head Start programs.

Successful family engagement means that programs must routinely check in with families to understand how their living circumstances and needs evolve over the course of their enrollment. Families experiencing homelessness may require unique approaches to engagement, such as the use of a multidisciplinary team, given the complex nature and challenges of homelessness.

All programs have systems for collecting enrollment data to report in their PIR. Programs should use these systems throughout the enrollment year to count families experiencing homelessness when they are identified. For example, programs can use their regular check-ins with families to understand their living circumstances and ensure this information is recorded in the data collection system for the PIR questions related to:

• How many children and families experienced homelessness during the enrollment year
• How many families the program helped to find housing
• How many families the program helped find emergency shelter and related services

OHS understands that Head Start income eligibility, receipt of public assistance, foster children, and children experiencing homelessness are not mutually exclusive. Families may be eligible for Head Start services in multiple ways. Maintaining accurate data collection on a family’s circumstances beyond their eligibility is critical to ensure the program is serving their families’ needs.

First, in accordance with program policies and procedures, programs must obtain written consent from parents to share their information. Programs and local agencies can use community assessment and program data to coordinate and streamline enrollment for families. Data-sharing with community partners ensures programs remain responsive to the needs of the children and families they serve and can result in referrals for other local services and activities. Programs and partners can develop memoranda of understanding and data sharing agreements to track the number of families enrolled and services received across agencies. Programs can also coordinate with other Head Start programs to support families when they must move for housing-related reasons.

To educate and train staff, recipients can start with the Families Experiencing Homelessness resource collection on the Early Childhood Learning and Knowledge Center (ECLKC) website. In the Supporting Children and Families Experiencing Homelessness interactive learning series, staff can learn about outreach, identification, enrollment, family engagement and support, community partnerships and much more.

OHS encourages programs to reach out to their local school district homelessness liaison to see what kinds of additional training may be available.

Programs can also find relevant resources from these and other organizations:

• National Center for Homeless Education
• SchoolHouse Connection
• National Association for the Education of Homeless Children and Youth

In fiscal year (FY) 2024, monitoring teams will review child files to ensure all necessary documentation to verify eligibility, recruitment, selection, enrollment, and attendance (ERSEA) has been completed and retained. They will also confirm the files are aligned with the program’s ERSEA policies, procedures, and selection criteria for each child served. Monitoring review teams will be trained to accommodate different language choices that may be made with respect to the terms “homeless” or “experiencing homelessness.”

Specifically, during Focus Area (FA) 1 reviews, grant recipients will describe how staff verify eligibility and how the program maintains eligibility requirements. This includes:

• How copies of any documents or statements, including declarations, that are necessary to verify eligibility are collected and maintained (45 CFR §1302.12(k)(2)(i))
• How program staff make reasonable efforts to verify eligibility by conducting either an in-person, virtual, or telephone interview with the family (45 CFR §1302.12(k)(2)(ii))
• How program staff collect statements that identify whether the family or expectant family meets the eligibility requirements (45 CFR §1302.12(1–2),(d)(1),(e)(1)(iii))

During FA2 reviews, grant recipients will demonstrate how the program provides resources that support family well-being, either within the program or through community partnerships. Specifically, programs will show how they provide resources and support for families experiencing homelessness (45 CFR §1302.53(a)(2)(vi)). The monitoring review team will also assess a sample of files for enrolled children and expectant families to understand the program’s eligibility determinations. This includes supporting documentation used to verify eligibility and how programs ensure compliance with children experiencing homelessness.

Read more about FY 2024 Head Start monitoring protocols.