A federal review of the U.S. Virgin Islands Head Start program found that the V.I. Department of Human Services did not properly verify almost 10 percent of the children registered for Head Start for eligibility.
The inspectors found, in some cases, data was not entered properly, and sometimes the wrong year’s standard’s applied. As a result, inspectors could not verify that the territory’s neediest children were necessarily the ones receiving the program’s benefits.
The report released this month by the Office of the Inspector General for the U.S. Department of Health and Human Services, covered the 2010 fiscal year. It found procedural issues that caused it to question the eligibility of 84 of the 894 children enrolled in the program.
Head Start is an early childhood education program funded by the federal Department of Health and Human Services. It provides early childhood education, health, nutrition and parent involvement services to low-income children and their families. Eligibility is largely based on income, although local programs include other eligibility criteria, such as disabilities, homelessness and services needed by other family members. Families must earn less than the federal poverty level. Programs are required to allocate 10 percent of its enrollment to children with disabilities.
The USVI Head Start program serves more than 78 percent of the total number of low-income children age 3 to 4 years. The auditors reviewed documentation supporting DHS’s determinations for 120 of the 894 children enrolled in Head Start.
The 894 limit has been the same for years, according to Human Services Commissioner Christopher Finch, who discussed the inspection in a telephone interview with the Source. He said if the funds were available, the program could easily enroll another 100. "Or 200. Or 300. It’s in really high demand," he said.
Because of the limit, the system awards points based on a variety of factors to make sure the neediest children are included. And because of the faults found in the study, it wasn’t always possible, the study showed.
"We could not determine whether the neediest children in the Virgin Islands received priority when DHS filled Head Start enrollment slots because DHS (1) entered inaccurate information in COPA (Child Output Planning Assessment) when calculating children’s financial eligibility, (2) did not retain documents used to determine whether enrollees were categorically eligible, and (3) did not meet the required enrollment level for children with disabilities," the inspectors wrote.
On the basis of those sample results, the auditors estimated that 84 children – almost one in 10 – received more priority selection points than they should have, potentially placing them in the Head Start program ahead of needier children on the program’s waiting list, the report said.
The auditors recommended that DHS ensure that the neediest children receive priority when filling Head Start enrollment slots by ensuring that financial eligibility determinations are based on accurate information, retaining a record of the documents reviewed and relied upon to determine whether a child is categorically eligible, and ensuring that the enrollment and/or waiver requirements are met for children with disabilities.
In its response, signed by Finch on March 31, DHS wrote that it generally concurred with the findings and recommendations, and offered explanations for some of the problems and how they have been corrected.
Finch said Tuesday that staff have undergone more training to make sure the data is recorded correctly, and steps have been taken to assure that the proper year’s income standards are put in the system as soon as they are available.
The issue of documenting homelessness is more difficult, Finch added. If a person has an address, that’s easy to check, but it’s much harder to document the negative – that they don’t have an address.
Further, he said, homeless families often find themselves beholden to others, sleeping on couches in another person’s rented home. If that person has a lease with a limit on the number of people who can live there, he will not be eager to provide documentation that another person or family is taking shelter there.
In the response included in the report, Finch wrote: "We disagree with the request for additional documentation or formal documentation for the two (2) homeless families. In both cases, the family’s situation was documented and no formal documentation could be obtained. In those cases the places where the persons were staying could not provide documentation without jeopardizing themselves and the families they were receiving shelter from.”
“Local homeless shelters tend to allow short term stays only,” Finch continued. “Thus it is not uncommon in the Virgin Islands for homeless mothers and children to move from house to house staying with friends or relatives. The families fit the … definition of homeless in that they had ‘no fixed, regular, and adequate nighttime residence’ of their own and often their transient presence in the place they were staying constituted a lease violation. For those who are not residing in a shelter at the time of application, formal documentation of homelessness is difficult to get.”
"We believe our staff thoroughly determined that the two families in question met the definition of homelessness and to deny them the points based on the inability to provide documented proof would be to largely render the homeless preference unusable," he said.
Overall, Finch said Tuesday, the inspection provided a measuring stick for the territory’s Head Start and showed them where and how to "tighten up" documentation and record keeping. "All of which we have done," he added.
