Defining Quality in EHS-CCP & Expansion by Billy J. Starr, MBA-CGAP
“Excellence is never an accident; it is the result of high intention, sincere effort, intelligent direction, skillful execution, and the vision to see obstacles as opportunities.”
The most important aspect to consider with EHS and EHS-CCP is that operating an EHS program is not the same as with Head Start; and not for the faint-of-heart. Besides the health & safety, risk aversion, layering of funding, and finding competent partners, you’re serving the most vulnerable population. These are all challenging aspects of Early Head Start, yet the tip of the iceberg.
There are many conditions that are essential, yet basic, to the success of these programs. In this series, we expect to leverage our experience(s) through working with numerous EHS (CCP) start-ups, specifically since the expansion in 2015, to discuss best practices and capacity-building actions. We will explore through a sequence of online training events, essential resources, and tools that contribute to a program of quality,
We will explore over the upcoming weeks the following topics:
- EHS & EHS-CCP (Part-1): Fiscal Essentials
- EHS & EHS-CCP (Part-2): Importance of Partners & Agreements
- EHS & EHS-CCP (Part-3): What You Can’t Learn from the Regulations
Each “part” will be prefaced with an article (like the one you’re reading now) written by a subject-matter expert in their field of expertise. In some instances, these articles will be written by current federal-adjacent employees and/or contractors, in which case, they will be identified by their tenure and scope of work (to protect the innocent…or guilty… depending on your perspective). Nevertheless, their insight, as you will discover, will be invaluable.
I have the distinction of hosting “Part-1“ – Fiscal Essentials. I’ve worked in some capacity within Head Start for over 20 years, mostly with monitoring and compliance, but also within T/TA (nationally and regionally). My last residency was as the Fiscal Manager for Monitoring & Compliance and SME for Fiscal Management. It will be an assiduous, yet enjoyable, expedition to see how far down the rabbit hole we’ll go. Hopefully, after indulging in this article, you’ll join us for Part-1 and keep coming back for more!
Engaging Fiscal…before it engages you
There are a few critical matters that should be addressed regarding the fiscal management of EHS and partnerships with early childcare. In the capacity of program operations which involve multiple partners and funding sources, there are elements that are essential to regulatory compliance; but other elements that lend themselves to best practices. This content can be narrowed down to the following four sections:
- Analysis & Assessment
- Cost Allocation
- Agreements
- Fiscal Reporting
EHS expansion grantees that are working with the National Center (PMFO) or with a fiscal consultant, may have a “checklist” which walks them through some of these elements. Difficulties in each of the four sections are often interrelated; therefore, grantees (along with partners) may want to address each topic together. Your Fiscal Consultant should be able to provide a checklist and assist you with the Action Steps. Still, some grantee-partners may engage in the completion of the checklist when the partnership is forming; others might find it helpful in refining the fiscal aspects of their partnership. Grantee-Partners should consider including many of the areas addressed in the checklist in their written agreement.
The primary resources in this area that your Fiscal Consultant should provide include information and tools related to:
- Policies and procedures – addressing coordination of resources
- Making financial decisions
- Contracts and formal agreements
- Sustainability
- Childcare subsidies
- Allocating, monitoring, and reporting on funding
A Closer Look
Let’s consider our first element, Analysis & Assessment. Early in the start-up process, there should be a discussion concerning the financial sustainability of potential partners. Whether it requires the review of prior audit reports (e.g. A-133 audits); or an independent fiscal assessment performed by your Fiscal Consultant, due diligence should be given to the financial health of any entity that a grantee is considering partnering with. This provides grantees with a feasibility analysis for which to make decisions on fiscally sound partnerships.
Please take note, that not every element applies to every partnership. However, each query should stimulate awareness and discussion between partners. This helps to build a solid understanding and ultimate agreement on the financial aspects of the partnership. The ultimate goal of the Fiscal Consultant is to help partners effectively manage limited early education financial resources and to advance quality and services for children and their families through well-designed partnership endeavors.
Let’s take a closer look at a couple more elements.
Cost Allocation, a requirement to allocate the costs of shared resources, can be met by using logical and rational methods to ensure that each EHS activity (and program for multi-funded agencies) is paying only its fair share of cost. This requirement is a staple of grants management to ensure one funding source is not subsidizing another. Generally, the methods used to allocate a shared cost should be the simplest, most straightforward approach. When there is a collaborative activity between Early Head Start and a federally-funded early childhood program, the costs of shared resources in two cost categories, equipment, and non-consumable supplies, are not required to be allocated between the programs. While these two categories were generally small in Head Start budgets, this exception will serve EHS-CCP programs well in reducing barriers to effective collaboration (Head Start Act Section 640 (a)(5)(E)(ii)). (See 45 CFR 74.34 and 45 CFR 74.35 for requirements relating to Equipment and Supplies, respectively). Your Fiscal Consultant will be able to facilitate a discussion around what will be the best allocation scheme for your project.
Contractual agreements are an integral part of the start-up process for grantees, and nothing can lead to a more dysfunctional relationship than a one-sided or poorly written contract. Agreements should be written cooperatively with your SME, then reviewed by your legal counsel. There are quite a few essentials and fundamentals that should be encompassed in a well-drafted partnership agreement. We’ll discuss each one in detail in our upcoming training series.
Fiscal reporting is crucial and fundamental to accountability and transparency. It frames the narrative of what planned objectives have been achieved; and provides an informative view for stakeholders about the results of operations, financial position, and cash flows of your initiatives (and organization). The information used by recipients directly affects the way decisions are made regarding the allocation of resources. During Part-1: Fiscal Essentials, we’ll discuss the value of certain reports versus others; what your staff should be receiving; as well as keeping your cognizant funding agency content with your timely and accurate reporting.
It’s About Capacity
The BSA Group is dedicated to developing the technical skills and capacity of Head Start and the early childhood education community. Because we know, up-close, how it can totally change a child and family’s life. We hope you enjoyed this week’s article, and hope you’ll join us for Part-1 of our series and other upcoming capacity-building events, online and across the country.
Join us on August 15, 2019, at 2:00 pm (EST)
*** Part-1: Fiscal Essentials: In this first of our series, participants will receive a free cost allocation budgeting module to assist in allocating costs by function/activity. The first 40 participants to sign-up will receive one hour of consultation services. Sign-up Now!***
