Workforce Policies in the Updated Head Start Program Performance Standards

Workforce Policies in the Updated Head Start Program Performance Standards

Glenna Davis: Welcome, everyone, to the Workforce Policies in the Updated Head Start Program Performance Standards webcast. It is now my pleasure to turn the floor over to our Deputy Assistant Secretary for Early Childhood Development, Katie Hamm. Katie, the floor is yours.

Katie Hamm: Thank you so much, Glenna, appreciate that. Good afternoon or good morning depending on where you're joining us today. I want to start by acknowledging that our hearts and minds are with all of those who are recovering from Hurricane Helene. We're thinking about folks in North Carolina, in Tennessee, in Georgia and Florida as they recover from the hurricane. Today we are here to talk more in - depth about new policies to support the Head Start workforce that are included in the updated Head Start Program Performance Standards. We know that many of you today are aware that about a month ago, the Office of Head Start published updated Head Start Performance Standards, if we want to start our slides, thank you. I wanted to just start to remind folks about the goals. I think we all have a shared goal of supporting the Head Start workforce and making sure that they have the job quality, the wages and the benefits they need to be effective in our Head Start programs.

The more we learn about early childhood, the more we confirm that it is that interaction between children and adults that really drives quality, and it's important that that workforce has the wages, the benefits and the job standards that they need in order to do that well. Our objective with these standards were to retain and attract the high - quality workforce that we know can support children who are furthest from opportunity, and that includes addressing mental health needs and areas of program where quality is evolving and is needed to meet the communities that we serve.

Every day I hear from early educators around the country and Head Start directors that we need to make meaningful structural changes to the Head Start program, and that really starts with making sure that the workforce has the supports that they need. Now these policies were informed by conversations with people, the comments that we received on the proposed rule, data and research, policy experts in the field and reviewing those 1,300 public comments in response to our initial proposal. We know that that strong positive and consistent relationship between young children and their educators are the critical foundation for positive learning experiences, and we've also heard how when that is disrupted, it can have a negative impact on the children and families and on the quality in the program. Head Start staff also tells that compensation is a big part of helping them feel valued and important in their work environment, and it's important to retaining them as well, if we want to go to the next slide.

Now all of you know that Head Start has long been the gold standard in early education for going on 16 years, and that really comes down to each person in Head Start delivering high - quality services that exemplify the Head Start mission, that original mission from the 1960s that we were going to make sure that children who are furthest from opportunity have the best that we have to offer when it comes to early education. That means that education staff can support early learning and relationships that help children grow. Family service staff plays a critical role of engaging and supporting economic stability of families. Bus drivers, custodians, kitchen staff are critical for providing safe transportation, clean learning environments, nutritious foods for the children and families in Head Start programs, and none of this is possible without capable, consistent leadership that help build engaging and positive work environments for all staff.

Over the years, children and families in Head Start have benefited from staff earning better credentials and bringing more experience to the program services, but the compensation has not kept pace. Head Start programs across the country share with us that they are losing staff to other employers. That includes things like food service, retail, other education programs like local elementary schools because these industries pay better and offer better benefits, and many staff also say that their hearts are in Head Start. They want to be able to stay in Head Start, but they can't afford to feed their own families and pay their rent if they stay in Head Start, and that is at the heart of why ACF made changes to the standards: to stabilize the Head Start workforce. That starts with providing adequate compensation for the rewarding yet oftentimes challenging work that they do. We reached a tipping point where we could no longer continue to operate without rethinking how we support and compensate staff, we had to take a decisive action to ensure that Head Start was on a sustainable path for the next 60 years. If we want to go to the next slide.

I want to provide a little bit more context. I think that historical context is important to understanding the moment that we're in right now. Even if we just look at wages without any other parts of compensation, we can see that Head Start wages are just not up to par with their high qualifications and high job demands. Our Head Start staff are well - qualified. Back in 2007 Congress called on Head Start teachers, half of Head Start teachers nationwide, to get a bachelor's degree, and about 70% of our Head Start preschool teachers have a bachelor's degree. The Head Start community overachieved, but unfortunately the average wages did not keep pace. We might need to click on this slide to see more of the chart, there we go. Thank you.

If you look at comparable jobs that you might find in a community, kindergarten teachers, public preschool teachers, you can see that our Head Start teachers earn just under $39,000 annually. We're not keeping pace with very similar roles in communities. We're not paying them anywhere close to what we're paying kindergarten teachers and public school preschool teachers. If we want to go to the next slide, we can see. I talked about that change in 2007, starting in 2011 more than half of our teachers had a bachelor's degree, but you can look at the pay and see that it's barely kept up with inflation.

As we were asking people to get degrees, to do more in the classroom, we haven't paid them more. We can't continue to make progress at the expense of fair pay for teachers. We can see if we go to the next slide what the cumulative impact of this was. We asked teachers to get more degrees. We didn't keep pace with even, barely keeping pace with inflation, and we see that when you look at similar roles that require similar credentials like the kindergarten teachers and the preschool teachers in public schools, it's not surprising we see turnover continue to increase pretty steadily since 2011. Then the pandemic hit. We know that other sectors kind of retained their staff, started paying more, retail, food service, as I mentioned, and we see that when the pandemic hit, there's a real big increase in turnover. That gets us to this point where a big turnover rate in Head Start is just not sustainable.

We're not producing enough early education teachers in this country to keep up with a turnover rate like that, and it impacts services for children and families. I appreciate you staying with me for that. I really think it's important to understand how we got to this point in order to understand the moment that we are in. We have a wonderful team who's going to walk you through some of the changes in the Head Start Performance Standards that relate to wages and benefits and wellness and engagement. I am joined by Khari Garvin along with leaders from his team and the Office of Head Start. We cannot ask for a better champion for Head Start staff than Director Garvin, and I'm pleased to turn things over to him now to walk us through the rest of the webinar, Khari?

Director Khari Garvin: Well, Katie, thank you. You're very generous with your words. Good morning to some and good afternoon to others. I am very pleased to be here as well, and as Katie just shared, these new standards represent a major step forward for Head Start, for our workforce as well as for the whole early childhood field, and these are really sweeping changes. They're policies that will change the lives of children's staff and families for the good.

It's Head Start's job to be bold and ensure that we have a strong, high - quality program for years to come. These new workforce standards are critical to taking us there and adapting to meet the evolving needs of the communities that we serve, after we published the NPRM, staff in the Office of Head Start spoke to hundreds of people from programs across the country to hear what they thought of our proposal, and we listened, and we read all 1,336, but who's counting, submitted public comments and incorporated all of that feedback into these final rule policies.

We're really grateful for the many teachers and parents, program administrators, advocates and even members of Congress who submitted comments to help us get this right, and the overwhelming sentiment, overwhelming, is that we heard in public comments was agreement about the need to better to support the Head Start workforce, even if not everyone agreed about how to do that. It was clear that programs are facing real workforce challenges that demanded a response. A lot of people had feedback on how our plans meet that challenge and how we can best support them to meet the needs of their individual communities, these updated standards are stronger thanks to your feedback and thanks to your partnership.

Let's turn to some of the most important changes to the workforce policies in the updated standards. Let's move to the next slide, thank you. We heard from many of you who expressed concerns that implementing new workforce standards without additional federal funding could have a disproportionate impact on small and rural programs that are already operating on tight budgets and have no wiggle room as they need to maintain a sufficient number of slots to ensure program viability and economies of scale. We recognize these challenges, and we recognize them to the point that we've added an exemption for small programs for wage and benefit policies. This is an automatic exemption. It does not require programs to apply for, approval or special waivers or anything like that.

Small programs must still make measurable improvements in compensation over time, though, but given the challenges we know that many small programs would face with fixed cost and without economies of scale to absorb increasing costs for compensation, small programs with 200 or fewer Head Start slots are exempt from most wage and benefits standards. Again, I say small programs with 200 or fewer Head Start slots are exempt from most wage and benefit standards, let's talk through that. Now we've gotten some questions about what this really means including whether the 200 slots are set at the agency or the grant level, questions like how does it apply to agencies with delegates or multiple program locations? It also questions around how this applies to slots that are funded by state or local funds, first of all the small program exemption is determined at the agency level, not the grant level. This means that an agency that has two or more grants would not be exempt for any one particular grant that is at or below 200 slots, but instead they would only be exempt if across all of their grants they had a combined 200 or fewer funded slots. Let's take a look at a couple of examples to make this clear.

Agency A in this scenario that I'm sharing has a total of 340 Head Start - funded slots including an Early Head Start grant funded for 100 slots, the question is, would the program be exempt from workforce requirements for the staff funded by the Early Head Start grant since the funded enrollment for that specific grant is at or under 200 slots? I'm trying to read your minds here. The answer is no. This program would not be exempt, or this agency, rather, would not be exempted just because of that one grant that it operates that has less than 200 slots because a determination is made, again, at the agency level. This agency is not exempt and would need to start planning for compliance with the workforce wage and benefit requirements across all of their services.

Now let's look at Agency B. Agency B has a total of 440 slots funded across three delegate agencies. Each of the delegate agencies on their own would meet the condition of 200 or fewer slots. Would these delegate agencies be eligible for an exemption? Again, the answer is no. The determination is made at the agency level, and the total funded enrollment for the agency is 440 total. The agency will need to work with delegates to plan to meet the wage and benefit standards across their program. Let's look at two other examples that would be eligible for the exemption.

These next two examples, pardon me, will be eligible for the exemption, look at Agency C. Agency C has a total of 146 slots funded across two different grants. This agency would be eligible for the exemption because this agency is funded for under 200 slots across all of their grants, and finally let's look at a program that has both federally funded and state - funded slots. We're going to call this one Agency D like David. Agency D has a total of 60 funded slots, which is the number that is reflected on the notice of award. The program also serves children with state - funded Pre - K slots. State - funded slots are only included in the 200 or fewer count if they are used as a match and are factored into the total enrollment on the notice of award.

If the 200 state - funded slots were included on the federal NOA or notice of award, then this program would not be exempt. However, in this case the total agency - wide Head Start funding enrollment is 60, so this agency is exempt under the small program exemption. However, if this agency had more than 200 funded slots that are included on this notice of award across the agency, whether these are federally or locally funded, the agency would not be exempt. This exemption recognizes that small agencies need flexibility, or they really need additional flexibility to address wages and benefits in a sustainable way. However, we know that staff of small programs also need their compensation. Small programs are still expected to make measurable improvements to compensation, and we will be working with these programs to support these efforts. Let's go on to the next slide.

We also clarified policies and added additional flexibility for wage policy implementation in a few other areas. First, we received questions about which staff are covered by wage policies and whether these apply to contracted staff. In the updated standards, we clarify that the pay parity requirements apply to all teachers and education staff funded by Head Start including both grant recipients, employees as those whose salaries are funded by Head Start for a contract such as those who work at partnership sites. I want to say this again. Again, in the updated standards, we clarify that the pay parity requirement apply to all teachers and education staff funded by Head Start including both grant recipient employees as well as those whose salaries are funded by Head Start through a contract such as those who work at partnership sites. We also provided some additional flexibility for how programs determine appropriate comparison salary to meet the pay parity requirements.

While programs with more than 200 slots will be required to ensure that education staff are paid an annual salary comparable to public school, preschool teachers in their local or neighboring school district, programs can use an alternative method to determine appropriate comparison salaries. They can use a benchmark that is equivalent to at least 90% of the annual salary of a kindergarten teacher in public school settings. Finally, because we know that there were concerns about whether sufficient funds would be available to support increased compensation, we added a secretarial waiver authority. What that means is, is that if the average annual increase in appropriation for the prior four years is less than 1.3%, the secretary of the Department of Health and Human Services can establish a waiver process in the year 2028.

Programs must be quality benchmarks and be in a position where they need to reduce enrolled Head Start slots to be eligible for that waiver. Programs that receive a waiver must continue to make improvements over time on wages to the extent possible. Now I want to underscore something about what I'm talking about, about the waiver. I want to underscore that this waiver can be exercised 4 years from now only if the appropriations are well. We know that Head Start has a long history of bipartisan support on Congress, and we actually are looking forward to continue to partner with Congress to meet the needs of children and families across the country while maintaining the standards of excellence for which Head Start is known, programs should not anticipate this waiver will be available and should instead begin planning for full implementation of these new standards.

This waiver authority can be seen more as a stopgap measure in place in response to concerns about the uncertainty of funding availability and in case of historically low appropriation. We want all of our grantees, both new grantees and those who have been operating for a long time, to begin preparing. Now wages are only one piece of the compensation package. We included important new standards to provide Head Start with comprehensive benefits as well. We know that our staff are sometimes leaving our program to take jobs in other industries because they can secure better benefits for their own families, and in other cases Head Start programs already have robust benefits for their staff and because of that are retaining quality staff in their programs.

In addition to the small programs exemption, which applies to benefits and wage policies, we made some additional changes from the NPRM to the final rule around benefits. Although we encourage Head Start programs to offer retirement benefits, we do not include this as a requirement in the final rule. We also removed the paid family leave policy, although we strongly encourage programs that are already offering paid family leave to continue to do so and encourage programs that do not to offer those benefits if feasible. We made the paid leave policy more flexible for all programs including allowing programs to pull sick, vacation and other types of leave or to offer different systems of determining leave and leave accrual, recognizing the various approaches leave programs have in place already.

We also extended the implementation timeline for the staff benefits from 2 to 4 years to allow more time for planning and more time for implementation. Jess and Tala will cover more details on each of our final rule, wage and benefit policies in a moment as well as offer some tips for getting started on each of these new standards, but first I'd like to take a moment to talk about the timeline for implementation of all these workforce policy changes. Now as I said earlier, this is hard but important work, and we can take time to do it right and make the incremental improvements over time to get there. I want to be clear that we have intentionally provided an extended implementation timeline for these standards. We want to give programs time to thoughtfully plan for how to make these changes and to give Congress time to invest in Head Start even more. We extended the compliance timeline for staff benefits to 4 years. We still have a long timeline for wages. Those do not have to be fully implemented until 7 years from now.

That's August of the year 2031, but we want you to start planning now and to begin working towards these goals right now, and we will be with you in that process. Our team is ready. We're poised, and we're working hard to continue to listen to your questions and challenges along the way, offering you resources and technical assistance to support your work, and I can't wait to hear from many of you at our regional roundtables over the next month. With that, I'll turn it over to Tala, the Deputy and Director of the Office of Head Start, and Jess, the Policy Division Director, to talk through the final rule policies and tips for getting started to improve compensation and well - being of the Head Start workforce. Jess and Tala, all yours.

Captain Tala Hooban: Thank you, Khari. I am Tala Hooban. I'm the Deputy Director for the Office of Head Start, and I am excited to share some of the resources and tips to help you all get started on these important policy changes for the workforce. As Khari mentioned, our overall goal with these wage provisions is to promote the wages that reflect the value and the commitment of our Head Start staff as well as our qualifications and our experience. Jess, can you remind everyone of what the goals are for the four interrelated standards that we will walk through today?

Jess Bialecki: Yes, it's so nice to be with all of you today. Again, my name is Jess Bialecki. I'm the Policy and Planning Division Director here at the Office of Head Start. Our goals with each of these standards are to promote competitive wages of all staff, number one. Number two, ensure that educators are paid as educators with an annual salary that is comparable to public school teachers, three, ensure that all staff meet basic needs and that we are not reinforcing poverty - level wages and then, four, reducing disparities in wages by age of child served, that our Early Head Start and our Head Start preschool educators are making comparable wages, of course adjusted for any differences in qualifications or experience.

Captain Tala: Thanks, Jess. Let's go ahead and dive into each one of these now.

Jess: All right. Our first new wage standard requires programs to establish or update a pay structure for all staff positions. Now we assume most programs already have a pay structure which you might call a wage ladder or a salary scale or something similar like that in place. This standard requires programs to take a good look at this pay structure and ensure and consider the responsibilities, the qualifications, the experience and the schedule or hours worked, and, again, the intent of this change is to really promote competitive wages across all staff positions in the program.

Captain Tala: As you said, Jess, many programs already have a pay structure in place, but with this new requirement, there is an expectation that programs will revisit and update their salary scales to reflect their new standards. As a first step, we recommend using ACF's Early Care and Education Workforce Salary Scale Playbook. It provides practice guidance to build and implement a comprehensive and competitive salary scale. It includes examples of how Head Start programs and others have approached decisions about making adjustments based on role, experience, qualifications, hours and any other factors. Some of the key steps outlined in the Playbook are on this slide. This is not something that can be done overnight, and we understand this. It is not something you're expected to complete right away. It is something that we expect you will be working on over the next few years so that you have a guidepost in place as you chart a path towards pay parity and the other new wage standards.

Jess: Thanks, Tala. I just want to point out that we dropped the link in the chat to that Salary Scale Playbook, highly encourage people to check that out if you haven't already. Our second new wage standard requires programs to make significant measurable progress to pay parity for Head Start education staff with kindergarten through third grade teachers. Now notice I said progress to pay parity for kindergarten through third grade. The way that we are saying that need to achieve that progress for parity is that by August 2031, programs must ensure that each of their education staff members is paid an annual salary that is at least comparable to the annual salary paid to public school preschool teachers in their local school district, and there's already a question about this in the chat, by education staff we mean those Head Start staff who are working directly with children in classrooms or homes as part of their daily job responsibilities. That can include our Head Start teachers, assistant teachers, home visitors and family childcare providers. We also clarified this to include expressly contractors and Early Head Start childcare partnership staff, as Khari mentioned. Now when determining the salaries for these staff, we expect programs to consider and make adjustments based on staff roles, responsibilities, qualifications and experience, and we're going to talk a little bit more about that in a minute. Do want to note that programs can also benchmark their wages to a neighboring school district if salaries are higher there, of course, or to 90% of kindergarten teacher's salaries instead of public - school preschool teachers should they choose.

Captain Tala: OK, I know the standards can be a little bit confusing. Jess, do you mean that all Head Start teachers have to make the exact same amount as teachers in their local school districts?

Jess: Yeah, great question, no. That was one of the big misconceptions after the proposed rule, I'm really glad that we're having a chance to clarify here. Look at the screen here. Right now, things in many places look like the picture on the left. You've got two teachers with the same experience, the same degree, the same work schedule who are earning different amounts just because one teaches in a public school - based preschool, and one teaches in Head Start. These changes require that these two teachers earn the same amount because they both have 12 years of experience. Both have bachelor's degree in early education, and they both work full - day, full - year schedules, but that's not always true, we know. There are often real differences between Head Start educators and public - school educators in terms of their responsibilities, experience or other factors, and programs can and should based on these updated standards adjust their salaries to account for that.

In these examples, there are differences in the schedule and hours worked, let's look at the left first. The public school teacher has the same responsibilities, experience, education and hours worked as the Head Start teacher, but the public - school teacher only works for a traditional school year while the Head Start teacher works year - round. In this case, we should adjust the salary up for the Head Start teacher to reflect the longer schedule. The Head Start teacher should earn more than the public - school teacher for them to have pay parity. Now in the example on the right, once again everything is the same between the two teachers, except this time they both worked a traditional school year with summers off. The public - school teacher here works a full day, while the Head Start teacher works a partial day. There we adjust the salary down for the Head Start teacher for account for fewer hours worked, here there's pay parity between the two teachers even though the Head Start teacher is earning less.

Captain Tala: Thanks, Jess. That makes so much more sense. What about the teachers that are working in Early Head Start?

Jess: Great question, Tala, this brings us to the first new wage standard that we want to highlight today: That wages must be comparable across Head Start preschool and Early Head Start staff, and since this came up in the Q and A already, and I'm passionate about this one. I'm going to ad - lib a little here and mention that another change in our updated standards is establishing that the umbrella term for Head Start programs regardless of the age served is Head Start or Head Start program. Early Head Start is what we are now using to refer, and we have been, to pregnant women, birth through 3, and then Head Start Preschool we are using to refer to programs serving ages 3 through 5, let's go back. Wages must be comparable across Head Start preschool and Early Head Start staff for those with similar qualifications and experience. That means that wages shouldn't differ just because of the age of child served, but that for education staff who serve in similar positions, again, with similar qualifications and experience, they should also have wages that are similar.

Captain Tala: That's great, that means that two teachers with the same role, experience, qualifications and schedules working in Early Head Start and Head Start preschool should have similar salaries.

Jess: Yes, Early Head Start education staff are also covered by the parity standard, and this standard expressly requires comparable pay across ages served. You can see here on the screen that two teachers with the same experience, qualifications and schedule should not be earning different amounts just because one works in Early Head Start, and one works in Head Start preschool.

Captain Tala: Now just clarifying, what can you tell us about how to think about this, especially as it relates with costs?

Jess: Yeah, for programs that completely understand and hear this, concerned about the cost of implementing the new standards, I do want to reemphasize some important flexibilities that programs have in how pay parity is implemented, that it fits the needs of the program. As the examples highlighted, programs can and really are expected to adjust salaries up or down based on differences in all case factoring, that may mean that some gaps between average Head Start teacher wages and average Pre - K teacher wages in your community could remaining depending on your local context such as the qualifications of Pre - K teachers and Head Start teachers. If you have different qualifications largely, those gaps may remain as well as differences in the schedules or hours worked or other factors. And then, again, just want to highlight that programs do have flexibility in determining the comparable wages such that they can use an alternative benchmark of at least 90% of kindergarten teacher salaries as their target or public - school salaries in a neighboring school district if those are higher than their local district. And then one more thing, of course, that we want to point out is that we're talking about a 7 - year timeline here. These changes are not happening overnight, and it's likely that most programs will be thoughtfully and incrementally making progress.

Captain Tala: Thanks, Jess, for that reminder. I think programs have asked us this already and so just to put a clear point on it, how do we find comparable salaries for public Pre - K or kindergarten teachers?

Jess: Yeah, that's a great question, and we have some tips on this slide. First I would say many school districts publish salary scales or schedules online, especially when negotiated through collective bargaining. We recommend by starting by searching online to see if you can find a current salary scale for your local elementary school. We know that some of the data needed to inform the Head Start comparable salaries may not always be included in that published salary schedule. For example, some salary schedules include information about staff experience and qualifications but may not include information about the schedule or the hours worked, or some salary schedules may provide information on K - 12 teachers but not include Pre - K teachers in their published salary schedules, you can reach out directly to your LEA, your local education agency, to request additional information that's needed to inform your benchmark for your target salary. We encourage you to talk to your Office of Head Start program specialist in the regional office and your technical assistant providers if you're having trouble, and you need help. That's what we're here for.

Captain Tala: Thank you, Jess. These are great first steps, and you've shared a lot here about pay parity for education staff, and I'm seeing the chat, and the Q and A come up. What about all other staff in Head Start programs?

Jess: Yeah, thanks, Tala, the final new wage standard requires that by August 2031, the minimum pay for all staff must be at least sufficient to cover basic cost of living in the program's local geographic area. I'm not going to read off the slide here, but you'll see a list of what that basic cost of living includes and who it covers, and we know even given that information, we've heard questions from many of you about how a program will determine what minimum pay would allow staff to cover these costs.

Captain Tala: We have heard that question a lot, including in the chat today and then Q and A today, and we have some initial resources to share what might be helpful as you do your research on how to determine minimum pay levels that would allow staff to afford basic needs. The MIT Living Wage Calculator, the University of Washington Self - Sufficiency Standard and the Economic Policy Institute's Family Budget Calculator are each tools that can help you think about what's possible in your communities and how to apply that to your individual program context that you can inform the development of a base wage, or a minimum pay for all staff. Now we want to talk about staff compensation. Wages are just one piece of the issue. As Khari mentioned, it's also important to provide Head Start staff with comprehensive benefits. Far too many of our early care and education workforce lack employer - proved benefits that workers in other industries are offered. Jess, can you tell us a bit about the new benefit standards?

Jess: Yes, absolutely, the updated standards require programs to provide several benefits to full - time staff. Now those are ones we consider full - time if they're working 30 hours or more per week during the program year. Those include, one, access to health insurance either through an employer - sponsored plan or by connecting staff to other health insurance options, two, access to short - term behavioral health services at no or minimal cost to the employee and, three, paid leave. Now for part - time staff, programs must connect these staff with health insurance options, and then finally for all staff, programs must facilitate connections to those who are eligible to childcare subsidy programs and public service loan forgiveness. Let’s look a little deeply at the health insurance standard because we know this is a big one. For full - time staff, again, working 30 or more hours per week when the program is in session, programs are required to either, one, provide and contribute to employer - sponsored health care coverage or, two, educate, connect and facilitate the enrollment of employees in health insurance options in the marketplace, state - specific health insurance marketplace or Medicaid.

For programs that are required to offer employer - sponsored coverage under the ACA or for those programs that elect to do so anyway, we encourage coverage similar to that offered by the Silver, Gold or Platinum plans in the Marketplace. Now for part - time staff who work for fewer than 30 hours a week when the program is in session, the final rule requires programs to at minimum make staff aware of and facilitate their enrollment in health care coverage options that they may be eligible for in the marketplace, and that includes, and I think this is really important, premium tax credits and could include Medicaid.

Captain Tala: Thanks, Jess. We've already heard some questions from programs about how they can facilitate staff enrollment in Medicaid or the Health Insurance Marketplace. Because know that health coverage for early care and education workforce broadly lags behind, the AFC Office of Early Childhood Development partnered with the Centers for Medicare and Medicaid, CMS, to improve coverage rates for the early childhood education workforce through outreach and enrollment support. To get started on this, programs can use ACF's Health Coverage Toolkit for the Early Care and Education Workforce and the partnerships with health navigators and assisters in your community to support enrollment. CMS, Centers for Medicare and Medicaid, has a great resource where you can search for and find local navigators and assisters to connect staff to more support with enrollment. Programs can use these tools to plan information sessions or offer as resources to staff to enroll in Medicaid or Marketplace options where appropriate. We're working on more tools and resources to assist programs in this area stay tuned over the next few months.

Jess: Thanks, Tala, keeping us moving, another new product that's standard is a requirement that programs support staff to acquire short - term free or low - cost behavioral health services. Tala, can you tell us a little bit about how programs can work on supporting staff in this area?

Captain Tala: Sure, we know that many programs already have the support in place. For some programs, you may be able to leverage an existing employee assistance program or EAP to offer these to staff. Others may offer an employer - sponsored group health coverage or another health insurance option that includes behavioral health services, and finally programs may already be partnering with behavioral health agencies in a community to support children and families. Programs can leverage these partnerships to offer support to staff for their mental and behavioral health as well.

Jess: Thanks, Tala. Another new benefit standard is that all full - time staff must receive paid leave. Many commenters shared when we put out our proposed rule that they have pooled these models without specific numbers of sick or vacation days and flexibility for staff to take leave for any covered reason. The commenters requested more flexibility in the paid leave policy in recognition of the varied approaches leave that they may already have in place. As Khari mentioned before, we did in fact make the paid leave policy more flexible for programs, and we've already heard some questions about what this could look like and the ways that programs can offer paid leave to staff.

Captain Tala: That's right, and the bottom line is, there's a lot of flexibility here. It's a big step forward in our standards to have a requirement around paid leave. Programs can offer time off without distinguishing between the different types of leave, or they can choose to offer specific types of leave like vacation and sick leave separately. We know that programs currently use many different strategies for this, we don't want to get in the way, and we know the way staff accrue or build up their leave is also something that programs determine now, and we want to continue to allow that. Of course, FMLA still applies, which means that programs required under FMLA must follow job protections for most employees during extended illness, caregiving or following the birth of a child. We also strongly encourage, although do not require, that programs provide partial or full wage replacement for family leave. Many states and local communities have paid leave policies, and we encourage the programs to facilitate access to these programs as well. Now, Jess, can you tell us about childcare and loan forgiveness?

Jess: Yes, absolutely, the new standards also require programs to connect eligible staff, important, eligible staff with information about childcare and loan forgiveness programs that they may be eligible for and to facilitate access to these programs. Programs must provide information and childcare resources as well as facilitate access to childcare subsidies. Now want to note here that the updated standards include an option for programs to prioritize the enrollment of eligible children of staff in Head Start services. Just want to mention that but highlight that, that is for eligible children of staff. For each staff member who may be eligible, a program must also facilitate access to the Public Service Loan Forgiveness program, the PSLF, or other applicable student loan debt relief programs. What that means is, programs must provide timely certification of employment that employees can complete their applications. Tala, let's focus about some of our tips for getting started, facilitating access to these childcare and loan forgiveness programs.

Captain Tala: That's great. We will share more on this in November when we will be focusing on ERSEA, but as the programs work on updating selection criteria for Head Start services based on your community needs assessment, we encourage that you think about the option to prioritize the enrollment of eligible children of staff members. This slide also highlights several actions programs can take to support staff in accessing childcare information and childcare subsidies, which includes sharing information with staff, providing Internet access, timely income and employment certification like Jess mentioned and assisting staff in their applications. The Federal Public Service Loan Forgiveness program is an important opportunity and benefit for which many Head Start staff are eligible. Programs can play a critical role in educating staff about the Public Service Loan Forgiveness and support their application process, again, including timely certification of employment, which is necessary for staff to complete their application. We really encourage you to share these federal resources on PSLF or Public Service Loan Forgiveness with your employees and make sure they know that they may qualify due to their important public service in Head Start. And our final few slides on workforce highlight an important aspect of supporting a workforce that goes beyond compensation. We want to make sure that programs are a healthy, positive place for staff to work where they feel empowered and supported each day, and they give their best for children and families. Now I'm going to ask Jess to discuss the changes that are designed to support a positive work climate in programs to promote overall staff health and wellness and facilitate positive interactions between staff and children.

Jess: Thanks, Tala, and as a former early childhood teacher and program director, this one is important to me, excited to talk about it a little bit. I want to acknowledge that many programs have already taken important steps in this space, but let's talk through requirements. First we include a requirement that programs must support a culture of wellness promotion and staff empowerment in their programs. Next, programs must provide adequate breaks to staff during their workday. Now I want to note here. This is an area where we received a lot of comments on the NPRM, and we responded specifically to remove the requirement for adult - sized furniture in classrooms, and we also made changes to staff breaks. We removed the requirement for brief unscheduled breaks, and we did not specify the length of scheduled breaks in terms of number of minutes to allow for more flexibility for programs. And then finally, the final goal also requires management style that engages and responds to employee feedback.

Captain Tala: What does this look like in action? Well, OHS published an information memorandum or IM earlier this year that highlights strategies that programs can take to support mental health and well - being of children, families and their workforce. In this IM, several strategies to support staff wellness are highlighted in addition to those described in an earlier information memorandum from 2021 on this same topic. We recommend that program leaders receive foundational training in supporting the workforce mental health such as psychological first aid training. We also recommend that programs establish communities of practice or reflective supervision groups to create safe environments that disclose wellness or mental health challenges and to receive support. Finally, it's important that staff are both engaged and aware of their rights as employees. We shared a lot of tips today on how to get started on these new workforce policies, and I hope those were helpful.

Here are some guidelines to keep in mind: Remember that many programs already meet a lot of the new standards, take a look at what you're already doing for your workforce, reflect on where you need to grow and change. How are you supporting your staff and making them feel empowered? Have you already improved your benefits package to be a more competitive employer? And the next step is to look at what changes remain. I'd encourage programs to look at two things. First, look at which standards have early compliance timelines and, second, look at those standards that are going to require some advanced planning. We all know we're not going to do this overnight. We're doing this together, and only you can prioritize what changes to tackle first in your program, but that may be where I would start. We now have about 8 minutes left, we're going to respond to a couple of questions that we've seen come in through the Q and A box. Jess, what questions are you seeing?

Jess: Sure, lots of great questions, and I do want to assure. I know that we are not going to have time in 8 minutes to get to all of them here, but these are important to inform our future TA and resources, and we do want to make sure that we get those questions. All of them are noted. The first question I'm seeing, I see, "How should a Head Start program choose which school or school district to benchmark wages to for pay parity, especially for programs with service areas that may span many school districts?” Great question, and we understand and agree with the complexities involved in assessing and moving to pay parity with public school educators. Because of this complexity and the very context in which our programs operate, the updated standards maintain the flexibility in how pay parity is assessed and operationalized, programs have flexibility to determine which of their local public schools to benchmark salaries to, and programs operating in multiple locations are not expected to necessarily develop multiple pay scales in all cases. Yet on the other hand, they can choose to if they service different geographic regions with different costs of living, in which case it may be most practical for programs to differentiate wages based on these different areas. If you're right next door, it may not make sense. If you've got a larger geographic distance and a larger difference in cost of living, it may make sense. One way to think about this may be to look at [Indistinct] patterns in enrollment. Which local elementary schools and districts do children in your program feed into? If they're feeding into multiple school districts with different salary scales, you may want to at least assess the salary for the educators in those districts as part of your planning process.

Captain Tess: Thanks, Jess. Here's another question we've received, and I think this might be the last one we have time for. What should programs do if they're fully enrolled and anticipate struggling to meet the new wage requirements?

Jess: Yeah, thanks, Tala. This is a great question, programs that are fully enrolled and anticipate facing challenges in meeting the new wage requirements should begin planning now for how to comply over the next several years. Now remember the full implementation of the wage standards will not occur until 2031 or do not need to occur until 2031, which is really intended to allow programs time to adjust. Programs are encouraged to start by discussing their budgets and potentially restructuring their budgets and exploring options such as reallocating funds, reducing slots through a Change in Scope request or identifying other efficiencies. Some commenters on the NPRM also highlighted the potential of leveraging multiple funding streams and braiding funds as a strategy to support the implementation of wage improvements and program stability. We really support programs exploring and using a variety of funding sources including federal, state, local and private funds which can provide a more robust financial foundation for programs to address wage adjustments without compromising service delivery. Layering funds is an acceptable and honestly encouraged practice that can enhance quality in early childhood programs, we really encourage programs to explore these options as part of their strategic planning for implementing the new wage and benefit requirements while also recognizing that states and localities vary significantly in the availability of non - federal early childhood investments. In all of these contexts, the Office of Head Start will provide technical assistance to help programs navigate these changes, ensuring that they can maintain service quality while working towards meeting these new standards over the timeline.

Captain Tala: Thank you, Jess, and I'm sorry to say. Those are all the questions we have time for today, but as we close out, we want to encourage you to be on the lookout for more from our Nurturing the Promise campaign, this lovely logo. This is the branding that we will be used on all events and resources we share to support information about the updated standards. We continue to develop new resources and are tailoring supports to where you need it most, and we want to hear from you. As Khari mentioned, we're planning a series of roundtables across the country in the month of October, which starts tomorrow, and these are all opportunities for us to hear directly from you to make sure that what we develop is responsive to your needs. A few other notes about what's coming up in October: We will start to headline specific topics from the updated standards for each month, in October we start with child health and safety. ERSEA, as I mentioned before, is in November. Then we will be coming back to dig deeper with you all on workforce and other topics. Meanwhile we're also training all of our Office of Head Start staff across regions to ensure that everyone understands the new standards that we can provide you with top - notch customer service when you have questions. We have a lot of content up on the Early Childhood Learning and Knowledge Center website or the ECLKC. Some of the highlights are listed on the slides and as a reminder, the recording of this webinar will be available using the same link you used to register for the webinar later today. We are glad you joined us today, and we're continuing to develop resources to support your work, we want to hear from you. Please help us by responding to our closing poll, and I hope you have a great week and happy Monday.