Adding SNAP Benefits to Head Start Categorical Eligibility

Adding SNAP Benefits to Head Start Categorical Eligibility

Glenna Davis: Hello, everyone, and welcome to Adding SNAP Benefits to Head Start Categorical Eligibility. It is now my pleasure to turn the floor over to Catherine Hildum. Catherine, the floor is yours.

Catherine Hildum: Hello. Thank you, everyone, for joining today on this exciting webinar. I'm just going to tell you today, we will be hearing from Dr. Bernadine Futrell, the director of the Office of Head Start, as well as myself. I'm a senior policy analyst at the Office of Head Start, and Heather Wanderski, who is the program operations director in the Office of Head Start. And that is the program for today. There are three speakers, and I am going to now turn it over to our OHS director, Dr. Futrell.

Dr. Bernadine Futrell: Thank you so much, Catherine! Hello, Head Start. Hello, hello. It's so exciting. We've got exciting news to share, and we're very honored and proud to be working –hopefully with all of you. And it's great to see so many of you on the line. I want to give a big, huge kudos to Catherine and the entire team for really doing the work and getting this IM together so that we can come together to say, to share this great news. And also, Heather, who –we're going to kind of co-pilot this today, so super excited, and we welcome you to our SNAP and Head Start eligibility webinar. Our goal today is to talk about the IM that was released last week regarding Head Start eligibility determination and using SNAP.

But before we do that, I do want to say thank you to the Head Start community. Your heart work – as we've been calling it – has really been something that we watch and we admire and we thank you for. Because we know what you are doing is on behalf of children and families and what is working best in your communities. And we pride ourselves in being able to work closely, federal to local, with our Head Start community and our program. We're in the midst of this “Head Start is Heart Work” conversations that we're having because it's so important as we're building out of this pandemic, important as we continue to leverage different resources or policy options, that we anchor ourselves in the hard work that is Head Start. And a part of that is acknowledging and recognizing the opportunities that are in front of us and the work that we have to do.

I want to thank you, the Head Start community, for raising your hand and helping to share with the Office of Head Start not only your experiences during this pandemic, but also your ideas and innovations on how to move forward as we continue to move Head Start forward, prioritizing reaching our children and families, advancing equity, supporting our workforce, and recovering and responding during this pandemic. I want to thank you and welcome you. This IM is one of the ways that we see a way for the Office of Head Start to really lean into supporting our Head Start grant recipients as we're in this recovery phase.

Without further ado, the next slide, thank you. This is the right slide. We're going to start with talking about this IM. This IM really helps to highlight and add SNAP eligibility to our definition for public assistance that can be used to determine Head Start eligibility. What that means is that now if families who have already gone through the process to demonstrate eligibility for SNAP, they can now have a seamless way to demonstrate their eligibility for Head Start. We are energized by this opportunity to do this but also see it as a way to move forward and really supporting you all, programs in prioritizing children and families who can benefit the most or the most need in your communities. This we see is a way to really move forward in that cycle.

We can go to the next slide now, thank you. Right. Who's impacted by adding SNAP? What we know … And we're going to go through a Q&A here, some questions that we already received, and if we have time, we'll answer some questions that you have. But what we know from looking at SNAP and then pausing and recognizing where we are in this pandemic, and how to really ensure that families have no hurdles, no barriers. When I say we're prioritizing equity, what we mean by that is anything that is blocking anyone from their fullest potential of impact that we can address, we want to remove it. One of the barriers did seem to be kind of this multiple-level process to demonstrate eligibility. What this means though for Head Start is majority of the children and families who are already income eligible for Head Start are the same children and families who are income eligible and enrolled in SNAP. It's about 80% of those families who would already be eligible for Head Start via income guidelines.

And if you really look at the numbers, we know there are about 500,000 families who are receiving SNAP that are above poverty, and most of those families, they're still within –  depending on the different flexibilities – within our Head Start poverty guidelines between 100 and 130%. And we also know that most families receiving SNAP, they're already eligible, and this is making it easier for them to demonstrate their eligibility and for youth programs as you're working families and communities. We know that with anything with Head Start, we always want to prioritize children and families based on our needs assessment. We want to encourage you to do that, but what this does is, it says to a SNAP-eligible family, that if you – if that community needs assessment, identify the priority there, then you have an enrollment in Head Start. Again, it doesn't guarantee, I'm talking to our Head Start community, and we all know this, but we want to just make the point that this is one of many tools that you can use to really target your enrollment and your recruitment to meet the needs in your particular community.

What's in this IM? This gets through a little bit of the legal speak there. Thank you. What it does is it addresses barriers. President Biden issued an Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government. What that means simply is, how do we look at everything that we have, and for Head Start, looking at enrollment and looking at the enrollment process, and how do we identify ways to reduce any challenges for families that may have to navigate multiple program eligibility processes or criteria. This IM aligns with this executive order, and it allows the Head Start programs, for all of you be able to reach your families who are already eligible in new ways, in ways that you can reach and different ways to open up the conversation as to why Head Start, why a family should be enrolled in Head Start. It helps to address that. It also minimizes the burden of families seeking public assistance. You all hear me say all the time that I'm a Head Start baby, but I can also tell you when my sister, who raised me, started working, we lost access to a lot of resources because things were changing in our family even though our primary caretaker was a high school student.

The challenge is that what we don't want to do is create a burden for families that are seeking public assistance. If the opportunities are there and they're qualified, we want to make it easy as possible there. And then really want to coordinate the federal benefit programs with families. You can enroll in SNAP, and you can enroll in Head Start. And also for Head Start families, ensure that they are enrolled in SNAP and other eligibilities that they may qualify for. Excuse me. All right.

The next slide and then I'm going to kick it over to Heather here soon, and we're going to go through some Q&A. The next slide, thank you, what this means in the black-and-white print, our Head Start eligibility criteria remains – that income is equal to or below the federal poverty level. That's one criteria. The SNAP criteria is connected to public assistance. It's income eligible for public assistance, meaning TANF, SSI, and now SNAP. That's where this new criteria – eligibility criteria will be, and then as always children experiencing homelessness or in foster care. We do want to just lift up and remind that there are additional eligibility criteria within Head Start. 10% of slots can be used for children who do not meet any kind of income eligibility requirements, and programs can use this for over income children who might benefit. In particular areas, children with disabilities. And then also 35% of slots can be used for children under 130% of the poverty. As I said earlier, a lot of the children already in SNAP kind of fit here, but just a reminder of who's eligible for Head Start. If you want to go ahead and screenshot that, text that to any eligible family and let them know so that we can get families connected to our Head Start programs and services.

OK, the next one, we just wanted to just list out the eligibility for programs just so that you know where this goes when you do your PIR and your data reporting. It goes with public assistance. Yes, a lot of the families will be income eligible as well but if you're using SNAP to determine eligibility, that's where it will go. OK. Now with that, I'm going to invite Heather to take it from here, and we're going to get talk through – I'm sorry, Catherine, we're going to turn it over to Catherine to talk through some additional points within this IM. Thank you.

Catherine: Thank you, Dr. Futrell. I want to go to the next slide there, please, Gretchen. As Dr. Futrell pointed out, this really – this new policy is very consistent with the core priorities of Head Start that we've been discussing, in particular advancing equity for Head Start enrollment. Head Start's longstanding mission is to serve communities that have suffered from inequity, bias, racism, institutional barriers, and other systemic issues that have caused them not to be able to participate in Head Start. This guidance aligns with that mission very well to serve those who are most in need of Head Start services. And it also is very aligned with the ACF Strategic Plan to advance equity by reducing any structural barriers, anything that's preventing families from participating in programs and also really promoting innovation and collaboration within ACF and between federal agencies.

As always, we will continue to reference this. Grant recipients will continue to follow all of their eligibility recruitment selection enrollment, all of their ERSEA requirements and their – as well as their program policies and procedures to ensure that they are serving those who most will benefit from comprehensive early childhood development services that Head Start provides and prioritizing those most in need of services for enrollment. And now I'm going to turn it back to Heather, who's going to talk to us about the implementation of this SNAP IM. Heather?

Heather Wanderski: Thanks, Catherine. And thank you, Dr. Futrell. I think when programs are thinking about implementation of SNAP, I think it's important to reinforce that all of the regulations, both the Head Start Act and the Head Start Performance Standards, all remain the same. It's just now that we have in the actual performance standards there's a regulation, 1302.12(c)(1)(2), which indicates that the families eligible for or in the absence of child care would be potentially eligible for public assistance. Now that includes SNAP as part of that definition. It's still going to be really important that programs continue to ensure that they develop and implement a recruitment process that prioritizes children and families most in need of services within the community.

And I've been seeing a lot of questions around this next piece here. When it comes to the eligibility verification process, the staff involved should be examining and maintaining documentation either from the state, local, or tribal public assistance agency that shows the family receives public assistance. And we've talked about a little bit in the spaces that it could come in the form of a copy of the SNAP notice of approval. It could be other documentation of eligibility or benefits from a SNAP agency, or it could be an electronic benefits card that contains a SNAP identification number. And I see some questions being asked about, “What about the date? How do we verify that?” Certainly, that's all something that you're going to need to be thinking about and making sure that you are addressing that in your policies and procedures around the eligibility verification piece.

I also saw some questions about coming in through the Q&A piece around, “Do I have to now verify a family's income?” The answer to that is no. As part of this process, this is now considered categorical eligibility determination. Again making sure that you're looking at that regulation, 1302.12(c)(1)(2), and that's that the family is eligible for public assistance. That's the regulation we're referencing. When we're talking about documentation, you're going to want to be focused in on that piece. When thinking about your existing policies and procedures, as I just referenced, they may need to be updated to ensure that your eligibility determinations that are being made, that they meet all the requirements of 1302 subpart A, which addresses eligibility, recruitment, selection, enrollment, and attendance. For example, 1302.12(a)(1) in the performance standards addresses selection criteria. And as you annually review your program selection criteria that weighs the prioritization of all your participants, that's an area you're going to want to make sure that you address as part of this process.

You may also consider that during the completion of your community assessment, or if you're planning to complete an update to your community assessment, that you would review data on SNAP eligibility in your community and how that aligns with the strengths, needs, and resources within your service area. This would be another opportunity to really determine whether your policies and procedures need to be updated in these areas. And I think in addition to policies and procedures, you're going to want to also consider examining your community partnerships and your existing outreach efforts to see if there's any adjustments that may be needed to help encourage – as Dr. Futrell was saying – encourage our SNAP recipients to apply for Head Start services. I think that those are primarily the points I wanted to hit on, and I'll be continuing to monitor Q&A, but I think actually we have some Q&A already queued up, right, Catherine, for us, as part of this?

Catherine: We sure do, Heather. We have some Q&A that we've already received and that we're going to run through now. I'll be asking the questions, and I'll ask Dr. Futrell and Heather to respond. Our first question is, “Why is the Administration for Children and Families, why is ACF including SNAP benefits in Head Start eligibility now?” And I'll turn to Dr. Futrell to answer that, please.

Dr. Futrell: Sure. Thank you, Heather, for your comments, and thanks, Catherine, for the question. President Biden's Executive Order on Transforming Federal Customers' Experience and Service Delivery to Rebuild Trust in Government requires that federal agencies – requires all the federal agencies to reduce this challenge of navigating multiple eligibility pathways and processes and also to better support alignment and coordination across federal public benefit programs. For ACF, for Head Start, that means that we are expanding our interpretation of public assistance because the current narrow interpretation, well, previously, did not capture many families who were already eligible for Head Start programs. The majority of households, as I mentioned before, with young children who have SNAP benefits, they have incomes below 100 % poverty, so they're already income eligible for Head Start. And also, we know that many of these families, if they were to apply for Head Start, they would then have to demonstrate their income eligibility for both SNAP and the Head Start program, which really creates an unnecessary burden to both the families and the Head Start grant recipients. Reducing this administrative burden to qualify for multiple federal services also allows programs to really reach families in need without any slowing down. Thanks.

Catherine: Thank you, Dr. Futrell. I have another question now for Heather. Will this SNAP inclusion, will this make higher income children eligible for Head Start programs? Heather?

Heather: Yeah, that's a great question. We'd say generally, no. Though SNAP has – as we kind of alluded to – has a higher income threshold for eligibility than our Head Start program, I think as Dr. Futrell had discussed earlier when she was sharing some of the data, the majority of SNAP recipients are already eligible for Head Start services based on their income level. And some data indicates that there are SNAP recipients with incomes higher than 130% of the federal poverty level, but the numbers are relatively small. The inclusion of SNAP benefits as public assistance, excuse me, will expand the pool of eligible participants in Head Start programs for those particular households.

And I think the really important piece here that I want to, as I mentioned earlier is, it's going to be critically important for programs to recruit and enroll children and families that are most in need of services based on your established selection criteria. Going back and making sure that if you have a family that is both income eligible and categorically eligible to take a look at that selection criteria and see if any adjustments need to be made on that priority. And I think, and again just reinforcing what I mentioned earlier, is that if a family falls into both, it's going to be a lot easier for them to be able to provide you with documentation to support being categorically eligible. That would probably be the easier option, as Dr. Futrell had mentioned, to get them into receiving services and get them connected in a lot sooner based on that categoric eligibility determination.

Catherine: Thank you, Heather. And the next question we have, which is one we have heard several times. Why does the IM, is Head Start choosing now to add SNAP for categorical eligibility but not including WIC, or the Special Supplemental Nutrition Program for Women, Infants, and Children? Dr. Futrell, would you answer that one, please?

Dr. Futrell: Sure thing. Thank you. This IM around SNAP, it's really specifically aligning SNAP for public assistance for purposes of determining Head Start eligibility. We know that the SNAP income-based eligibility threshold is 130% of the federal poverty guideline. We know that's slightly higher than the income for Head Start eligibility, but it also really, it's so close and then the number of families impacted is not substantial. Excuse me. When we want to include SNAP as public assistance, we're looking at also making sure we stay true to the Head Start –kind of what Head Start – is designed to do with the target children and families on that income threshold. WIC on the other hand has income eligibility that's up to 185% of the federal poverty guideline, which is significantly higher than the income-based eligibility for the Head Start program and for SNAP. And we also know the number of households receiving SNAP with both children under 5 that are above the 130% federal poverty guideline is much smaller than that of those who would be above the federal poverty guideline for WIC.

Looking at the data available, we think it's about 150,000 new households that may be receiving SNAP that have Head Start eligible children. We would be able to capture them in then this process, whereas WIC, that's an estimated 900,000 children under 5 participating in WIC with household incomes above 130%. We want to make sure that the change is really addressing the burden from families who are already eligible for Head Start and not expanding significantly the pool of children who would be eligible.

Catherine: Thank you, Dr. Futrell. The next question I'll defer to Heather, who is in charge of program options. Do programs need Regional Office approval to consider SNAP benefits as public assistance?

Heather: No, programs do not need Regional Office approval to include SNAP benefits in their interpretation or definition of public assistance. Programs are going to need to make sure that their policies and procedures, along with their selection criteria, are updated to include SNAP as part of the definition of public assistance and that these updates incorporate what a program knows from the latest community assessment data. Really ultimately, programs need to make sure that they are prioritizing services for those most in need based on their community assessment data, but they do not need to secure separate approval from the Regional Office in order to start this process.

Catherine: Thank you, Heather. And the next question for Dr. Futrell. When does the IM take effect?

Dr. Futrell: Thank you. Effective immediately. Programs can go ahead and move forward in updating their program policies and procedures on eligibility determinations to enroll children or to add those to the wait list who are receiving SNAP benefits. Programs can do it now. Again, it's additional tool to determine eligibility for children and families. Do it now if it meets your needs in your community, that is.

Catherine: Great. Thank you so much. And the next one is really about implementation. And I know there'll be questions continuing as we said are getting to some of the main questions. How should programs verify families receive SNAP benefits in order to verify eligibility for Head Start?

Heather: Catherine, I keep talking about the regulations and the policies and procedures, but I'm going to say this particular regulation in the Head Start Program Performance Standards is at 1302.12(1)(2). It covers eligibility verification. But essentially, the staff involved in eligibility determination process should examine and maintain documentation from either the state, local, or tribal public assistance agency that shows the family is receiving public assistance. And I can give you a couple of examples, but depending on what that looks like in your state and what you would need in order to verify that process, may look different for every individual program. I can't specifically address individual local or state documentation efforts, but I can say, it could include a copy of the SNAP approval or notice or something that would verify that they're eligible. It could be some other type of documentation. It could be an electronic benefits card. Again, depending on the location, that card may be all you need. But it may be different in every state.

Again, I say that trying to address a very large audience. You all will need at your local level to determine if that information is sufficient enough to be able to determine or place that family or identify them as categorically eligible for public assistance based on this revised definition. Again, proceed with caution, and make sure that you are capturing all of what you need to for that verification process.

Catherine: Heather, thank you so much. And those are really important reminders as we move to implement this policy. We need to direct this next question to Heather as well because it also flows with the implementation and what programs really need to do as they implement this policy. How should programs record SNAP eligibility determinations in the program files?

Heather: Yeah, good question and good follow-on. Programs are required to keep eligibility determination records for every participant. Your records or your files should indicate whether a child was determined eligible either through family income or through categoric eligibility. And if a family is determined to be categorically eligible for services, your records should also reflect what category, and respective records should be maintained accordingly. In other words, if you're going to be determining eligibility based on a child in foster care. If that's the case, then you would maintain specific documentation, specific for that eligibility determination. If you're talking about public assistance based on SNAP, you would need to secure documentation in accordance with how the eligibility determination is being made.

And I would just say here too as a friendly reminder, programs can maintain their records electronically. It doesn't have to be a hard copy file. You can keep electronic records, just making sure that you're securing the right ones for those eligibility determinations.

Catherine: Thank you so much, Heather. Those are all very ... And next, I have a question for Dr. Futrell. Will this ACF guidance allow programs to enroll more children? Think this is a question that we'll be hearing often.

Dr. Futrell: Thank you. Hate to start with a no, but no, it doesn't. This really helps with eligibility determination based on the current funded enrollment, so this will not increase a program's funded enrollment. However, we do think that programs will be able to find additional eligible families to add to your wait list or fill any vacant spots that you may have.

Catherine: Thank you so much, Dr. Futrell. And that really concludes most of the questions that we really wanted to get answer for everyone in the webinar today. And we thank you for your participation. Want to make sure to note that the materials that in the letter from Dr. Futrell that were released along with the information memorandum include some additional – they include some frequently asked questions that we just went over. Also included, that we have updated, just made a change to the eligibility verification form that's available to programs. And now SNAP is listed specifically next to the public assistance box so that you can easily use that form now as you go forward.

Please do continue to send in questions. You can send in questions to the contact us button at the ECLKC, and you can also certainly send questions to your Regional Offices. We will continue to collect questions, to monitor questions, and to work with Regional Offices and all of the Head Start community to ensure that the questions people are asking receive answers in a timely manner. Stay tuned. Please be sure you look at the materials, again, as you're digesting this and making plans to implement this new exciting policy in your program. Again, thank you all for being part of the webinar, and we look forward to seeing this roll out. Thank you. Any other last comments, Dr. Futrell?

Dr. Futrell: I said thank you and just noting that we've been answering the questions we could in the chat. And then we'll read through them all, and any questions that we didn't get to, we'll be sure to use that information as we roll out additional information about this IM and this new policy. But we're super excited and hopeful that it really helps us to reach children and families in new and special ways as we're building back. Thank you, Catherine. Thank you, everybody.