South Dakota Head Start Association

Response to NHSA Comments on the Proposed Federal Performance Standards

The South Dakota Head Start Association (SDHSA) is providing these comments as direction to the NHSA
as that organization prepares to make comments regarding the Proposed Federal Performance
Standards.
SDHSA appreciates the opportunity to provide comment. In general, the revisions suggested in the
performance standards will support improved quality for Head Start children across the nation. SDHSA
appreciates the strengths-based approach and the elimination and reduction of number of standards for
compliance keeping the focus on quality.
Revised Head Start Models:
SDHSA supports NHSA concerns/comments regarding the revised Head Start models.
Additional Comments from SDHSA:

Advocate for the Head Start home-base program option to be considered as a standard
program option (not locally designed) with no waiver process required, and keep 32 week
implementation. 1302.24
Concern if no financial support is provided for implementation of the revised Head Start
models - potential is great for reduced enrollment. 1302.21(c)(3)
Concern if financial support is provided of Grantees ability to meet local non-federal share
match consider a quick and easy waiver process

Full-Year Dosage:
SDHSA supports NHSA concerns/comments regarding Full-Year Dosage:
Additional Comments from SDHSA:

Provide opportunity for Head Start programs to align number of days of service with local
school districts (instead of mandating 180 days) this would support partnerships already
established and may alleviate some facility concerns. 1302.21(c)(1)
If 180 days continues to be mandated clarification needed if the 180 days includes any
professional development days for staff.
Advocate options for part-day programming based on community needs.

Changing Ages Served:

South Dakota does not have any publicly funded pre-kindergarten programming available at this time.
This is a concern as a possible reduction in Head Start program slots (if funding is not received for
implementation of the performance standards) will negatively affect thousands of children if they
cannot be served by local Head Start programs there are limited other options for them.
Shifting Family Focus: 1304.40
SDHSA supports NHSA concerns/comments regarding Shifting Family Focus and would advocate that the
Early Head Start and Head Start home-base models support family engagement.

Parent Committees:
SDHSA support NHSA concerns/comments regarding Parent Committees
Additional Comments from SDHSA:

Supports the change in Policy Council representatives being allowed to serve for 5 years if local
bylaws allow. 1301.4 (d)(3)
No concerns with elimination of Parent Committees gives program alternate ways to provide
family/parent engagement opportunities.

QRIS: 1302.53(e)
South Dakota does not have a state or local Quality Rating and Improvement System in place. While we
would be supportive of such QRIS, there is no indication that any funding at the state level now or in the
near future to implement one.
Attendance Systems: 1302.16(a)(1-2)
SDHSA supports NHSA concerns/comments regarding Attendance Systems. Would advocate for
elimination of specific time period in which program needs to contact family of child absent.
Credentials: 1302.90(b)(4)
SDHSA supports NHSA concerns/comments regarding Credentials. We would advocate that the Early
Head Start center-based teaching qualifications remain as they currently are.
Supporting Children Without IEPs
SDHSA feels this is an unnecessary provision in that Head Start programs are required to individualize
services for all children.
Curricula: 1302.32
SDHSA supports NHSA concerns/comments.
Health and Safety: 1304.22
SDHSA supports NHSA concerns/comments.
Criminal Background Checks:
SDHSA supports NHSA concerns/comments. No suggestions for timelines.
Data Governance: 1302.101(4)(iii)
SDHSA supports NHSA concerns/comments. Guidelines will not be restrictive to programs in
implementing high quality services may support more state-wide data work in South Dakota.
Distinct Service Areas:
SDHSA supports NHSA concerns/comments and is supportive of this option.

Additional Comments:
SDHSA would like advocacy for additional funding to support the mentor-coaching current workloads
in programs will not support this implementation. Suggestion was to advocate for how training funding
could be used to support the implementation of this standard. 1302.92 (b)(4)
SDHSA supports the community assessment moving to align with the 5-year grant cycle.
SDHSA is comfortable with impasse procedures as they are written. 1301.5(b)

These comments were written, approved, and are respectfully submitted by the Board of Directors of
the South Dakota Head Start Association:
Jane Leite, President
Rick Thaler, Vice President
Tom Hopper, Treasurer
Brenda Knouse, Secretary
Carmen Stewart, Past President
Sue Glodt, Director Representative
Steph Lebeda, Director Representative
Marcus Bevier, Director Representative
Vicki Lowry, Director Representative
Anne Reddy, Director Representative
Carmelita Bear Ribs, Director Representative
Tammy McDaniel, Staff Representative
Sharon Roberts, Staff Representative
Joyce Harmon, Staff Representative
Jodi Berscheid, Staff Representative
Dayle Blasius, Staff Representative
Melissa Johnson, Staff Representative
Becky Anglin, Staff Representative
Jill Winter, Staff Representative
Nicole Glines, Friend Representative
Renee Olson, Friend Representative
Shontell Mason, Friend Representative
Shalyn Torpey, Friend Representative
Nikita DeVoll, Parent Representative
Rachel VanderLey, Parent Representative
Diana Hendricks, Parent Representative
Sheila Hanson, Parent Representative
Michelle Klingbile, Parent Representative
Kathy Cruse, SD Head Start Association Executive Director