Since the onset of the COVID-19 pandemic, Head Start programs have faced unprecedented challenges and responded with flexibility, innovation, and dedication. Head Start sites and communities are continuing to move towards fully in-person, comprehensive services. As they do so, the Office of Head Start (OHS) expects programs to take actions that are feasible, reasonable, and safe as they continue providing services and implementing management and oversight systems.

Per the Office of Management and Budget’s (OMB) memorandum M-21-20, OHS has the authority to provide several administrative and fiscal flexibilities during the COVID-19 pandemic, which will be available until the Public Health Emergency (PHE) declaration ends. Programs should maintain documentation to address any variations in their normal fiscal practices made in response to the COVID-19 outbreak.

Administrative and fiscal flexibilities are the following:

• Prior approval for the purchase of equipment (45 CFR §75.308(c)(1)(xi)). Recipients may purchase equipment needed to respond to COVID-19 with a value of up to $25,000 without prior ACF approval.
• Budget modifications (45 CFR §75.308(e)). Prior approval is waived for budget transfers between direct cost categories for an aggregate amount not to exceed $1 million.
• Procurement by noncompetitive proposals (45 CFR §75.329(f)(2)). OHS recognizes that COVID-19 has created a public emergency for all recipients. Competitive solicitations may result in delays that impair a recipient's ability to respond to or recover from COVID-19. OHS is authorizing recipients to engage in sole-source purchasing to obtain goods and services needed for COVID-19 response and recovery, if justifiable.
• Exemption of certain procurement requirements (45 CFR §75.328; 2 CFR §200.319(b)). As appropriate, OHS will waive the procurement requirements related to geographical preferences. Recipients must maintain appropriate records and documentation to support any charges against a federal award.
• Extension of financial and other reporting (45 CFR §75.328, 45 CFR §75.342 and (d)(1); 2 CFR §200.328, 2 CFR §200.329 and (e)(1), 2 CFR §200.329(e)(1)). Recipients may request an extension to submit financial performance and other reports up to three months beyond the required due date. The reports must be submitted at the end of the extension period. In addition, recipients must continue to submit open/closed center status reports and enrollment information without postponement.
• Governing body approvals. At a minimum, a statement must be submitted confirming that governing body and Policy Council members available for contact have given their approval of continuation and post-award amendment applications.
• Non-federal match waivers. OHS will continue to approve requests for waivers of non-federal match in applications, including, but not limited to, continuation, COVID-19, and cost-of-living adjustment applications. To request a waiver of non-federal match, place the amount of $0 in Section C of your SF-424A. No separate waiver request is required. The issuance of a Notice of Award constitutes approval of the requested waiver. Recipients who need a waiver of match on a previously issued grant award must go through the formal waiver process.
• Administrative cost waivers. If a recipient estimates development and admin­istrative costs will exceed 15% of total approved costs at any time within a given project period, the recipient may submit a waiver request of the requirement. Requests must be submitted via budget revision in the corresponding budget period. These requests must explain why costs exceed the limit and describe the recipient’s plan to reduce develop­ment and administrative costs to comply with the 15% limit after the waiver period.

Additionally, the guidance from ACF-HS-IM-19-01 General Disaster Recovery Flexibilities applies to programs impacted by COVID-19. Although there are no formal waivers for the number of days of service provided via center-based programs, or number of home visits and socializations provided via home-based programs, programs will not be expected to make up the days missed due to COVID-19.

Please be advised that no Head Start requirement or Head Start Program Performance Standards (HSPPS) requirement will be waived where failure to comply either results in unreasonable risk to the health and safety of children or constitutes fraud or misuse of federal funds. Recipients must be able to assure the safety of children in their care and financial accountability for funds and property.

COVID-19 One-time Supplemental Funds

• The Coronavirus Aid, Relief, and Economic Security (CARES) Act, 2020 (P.L. 116-136), provided $750 million for programs under the Head Start Act, including up to $500 million for supplemental summer programs. All CARES Act funding, including for voluntary summer programs, was distributed as one-time funding by formula based on each grant recipient’s funded enrollment. OHS provided updated guidance in ACF-PI-HS-20-04 so all recipients could respond to the unique and constantly evolving circumstances within their communities during the COVID-19 pandemic.
• The Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act (P.L. 116-260), provided $250 million in supplemental funds, distributed as one-time funding by formula based on each grant recipient’s funded enrollment.
• The American Rescue Plan (ARP) Act (P.L. 117-2) provided $1 billion for Head Start programs. All Head Start, Early Head Start, and Early Head Start-Child Care (EHS-CC) Partnership recipients were eligible to receive additional funds proportionally based on funded enrollment levels. For more information on ARP funds, please view ACF-PI-HS-21-03.

The $750 million in the CARES Act, $250 million in the CRRSA Act, and $1 billon in the ARP Act add up to $2 billion in additional funding the Head Start program received to support staff, children, and families during this unprecedented time.

Webinars

• The Head Start Program: COVID-19 Implications and Other Program Updates, 11/16/2021 
  This Governmental Audit Quality Center archived webinar was co-sponsored by OHS in partnership with the American Institute of Certified Public Accountants. Topics include an overview of the Head Start program, new pandemic funding for programs and allowable uses, pandemic-related flexibilities, and auditing the Head Start program. The presenters for this event included several staff from the U.S. Department of Health and Human Services (HHS) and two auditors who have experience auditing Head Start programs.

• Performance Progress Reporting, 5/10/2022
  During fiscal year 2021, Head Start grant recipients received funds appropriated under the CRRSA to aid with their continued response to COVID-19, as well as ARP funds to support programs in returning to in-person services and other activities. A statement subjecting the award to the submission of a Performance Progress Report (PPR) was included in the Terms and Conditions for each award. This webinar focused on the instructions and frequency for submitting the PPR, which should complement activities/projects identified in budget submissions and the “COVID-19 One-Time CRRSA and ARP Spending Plan” report.

Relevant FAQs

The following FAQs were included in the Performance Progress Reporting webinar held on May 10, 2022. For additional questions, please contact your assigned program and grants specialists using the Correspondence tab in the Head Start Enterprise System (HSES).

Why is a Performance Progress Report required for HE, HA, HN grants, but not for other Head Start grant awards?

Under section 45 CFR §75.342 of the Uniform Guidance, a PPR must be submitted for all grant awards. Under regular operating awards, this requirement is met through the Program Information Report (PIR), submitted annually.

Are separate PPR reports required for CRRSA and ARP funds?

No. Only one PPR report is due for both CRRSA and ARP funds. Please refer to the Terms and Conditions of your Notice of Award.

• Separate Annual and Final SF-425 reports are required for the CRRSA “C5” and ARP “C6” funds.
• A single Tangible Personal Property Report SF-428, SF-428B, and SF-428C as necessary, is due at close out of the grant — at the same time as the Final SF-425 federal financial reports. SF-428S can be used to designate between “C5” and “C6.”
• A Real Property Standard Report (SF-429A) is not required for CRRSA and ARP awards where there is no real property.

If funds from this award are used for any purpose requiring a 45 CFR Part 1303, submitting applicable SF-429 B and C is required:

• First SF-429 A is due as an attachment to the Annual SF-425 in PMS
• Second SF-429 A is due in On-Line Data Collection (OLDC) 30 days after the grant has expired
• Third SF-429 C is due in OLDC on the same due date as the Final SF-425

Can programs submit a budget revision?

Yes. Recipients are required to report deviations from budget or project scope or objective. They must also request prior approvals from HHS awarding agencies for budget and program revisions in accordance with Revision of Budget and Program Plans, 45 CFR §75.308.

Can COVID-19 funds be used for facilities?

Yes. COVID-19 funds can be used for facilities. CARES and CRRSA funds must be used to prevent, prepare for, and respond to activities related to COVID-19. Should a recipient seek to use these funds for facilities, it must be in connection with prevention, preparation, and response activities around COVID-19. ARP funds do not have the same limitations and can be applied to activities carried out under the Head Start Act, as referenced in ACF-PI-HS-21-03.

Depending on the breadth and scope of the project, the requirements of 45 CFR §1303.44 may also apply. This would require a separate application for the purchase, construction, or major renovation of a facility. At a minimum, if the project was not included in the initial application and the funds were not originally allotted for facilities activities, a budget revision will be necessary to adjust funding levels to the appropriate object class categories (e.g., construction, equipment). Additionally, OHS strongly encourages recipients to engage with the Regional Office early in project planning to discuss process, impact for the program, and other possible considerations unique to the request.

What is the deadline to use COVID-19 supplemental funds (CARES, CRRSA) and ARP funds?

COVID-19 supplemental and ARP funds are available for recipients to use through the end of the budget period they received the award. Recipients may request an extension for planned activities where funds cannot be fully expended during the budget period.

Where will recipients submit their PPR?

Recipients must download and complete the PDF version of the PPR found on the ACF website and submit via GrantSolutions. For additional guidance, please refer to the document titled, “GrantSolutions User Guide Grant Recipient Process: Performance Progress Report” under the Resources tab in HSES.

When are PPRs due?

Recipients must submit a PPR within 90 days following the end of a reporting period. Reporting periods are in 12-month increments. For example, for awards with a budget/project period of April 1, 2021 through April 1, 2023, the first report would cover the period of 04/01/2021 through 03/31/2022 and would be due on June 29, 2022.

Are SF-428 (tangible property) and SF-429 (real property) reports and applicable attachments required?

The Terms and Conditions of awards do not waive the requirement of the SF-428 and applicable attachments. If there is no activity to report on the SF-428, indicate it in field 8 of the form. The SF-429A (no property) report is not required for these grants. Applicable SF-429 reports are required if recipients use any funding issued under the award for activities subject to the requirements of 45 CFR §1303 – Subpart E.

Field 3a of the PPR form asks for the Data Universal Numbering System (DUNS) Number. With the transition from DUNS to the Unique Entity Identifier (UEI), which number should a recipient include in this field?

Although the current OMB approved version of the PPR asks for the DUNS, a grant recipient may include its UEI.

How can a recipient access GrantSolutions?

Follow the steps under “Recipient User” on the Request a User Account page on GrantSolutions.

What is the difference between the PPR and Federal Financial Report (FFR), and how do they relate?

The PPR focuses on the overall performance and status of planned activities of a reporting period for an award and the FFR is required to report the status of funds for grants. Although the PPR narrative may include an explanation of expenditure data, the FFR is a statement of expenditures associated with the grant. The PPR and FFR should complement one another as they both pertain to all planned and completed activities throughout a reporting period. For HE, HA, and HN grant awards, separate FFRs are due on each source of funds (CRRSA “C5” and ARP “C6”). However, the PPR must cover both source of funds.

Our organization submitted a budget revision/carryover/extension request in HSES and has not yet received a response. Who can we contact?

Typically, these requests take up to 30 days to review, and approval is provided through the issuance of a Notice of Award. For inquiries regarding submitted requests, please contact your assigned program and grants specialists through the Correspondence tab in HSES.

Can recipients use funding for recruitment or incentive pay?

Recipients may use funding for reasonable recruitment bonuses or other incentive pay consistent with their established personnel policies and procedures.

Last Updated: June 28, 2023