1304.51

Return to Main Menu or Goto 1304.52

1304.51

Management Systems and Procedures

(a) Program Planning

(b) Communications - General

(d) Communication with Governing Bodies and Policy Groups

(e) Communication Among Staff

(f) Communication with Delegate Agencies

(g) Record-keeping Systems

(h) Reporting Systems

(i) Program Self-Assessment and Monitoring

Introduction to 1304.51

The objective of 45 CFR 1304.51 is to establish dynamic and cohesive management systems that support continuous improvement and foster commitment to providing the highest level of services to children and families in accordance with legislation, regulations, and policies.

Management systems and procedures are part of each program’s on-going and organized approach to managing Head Start services. They are all connected and inter-related with each impacted by the others and all influencing and influenced by program services. The graphic below is intended to convey this message. With all of these systems, the emphasis is as much on the process involved in their implementation as it is on the product that may come from implementation.

The standards in this section are written to allow grantees great flexibility in designing the approach that will work best in their program and community. Through designing and implementing effective systems for program planning, communication, record-keeping, reporting, and program self-assessment and monitoring, each Head Start program has greater ability to integrate the various functions of Head Start and provide high quality services to children and families.

Performance Standard

1304.51(a)(1)(i)-(iii)

(a) Program Planning.

(1) Grantee and delegate agencies must develop and implement a systematic, ongoing process of program planning that includes consultation with the program’s governing body, policy groups, and program staff, and with other community organizations that serve Early Head Start and Head Start or other low-income families with young children. Program planning must include:

(i) An assessment of community strengths, needs and resources through completion of the Community Assessment, in accordance with the requirements of 45 CFR 1305.3;

(ii) The formulation of both multi-year (long-range) program goals and short-term program and financial objectives that address the findings of the Community Assessment, are consistent with the philosophy of Early Head Start and Head Start, and reflect the findings of the program’s annual self-assessment; and

(iii) The development of written plan(s) for implementing services in each of the program areas covered by this part (e.g., Early Childhood Development and Health Services, Family and Community Partnerships, and Program Design and Management). (See the requirements of 45 CFR Parts 1305, 1306 and 1308.)

Rationale: Program planning occurs in a continuous cycle, involving key members of the Head Start community. Planning, therefore, is critical for setting clear program goals and for defining an organized approach to program services driven by the specific priorities of the community. This rationale serves 45 CFR 1304.51(a)(1)(i)-(iii).

Related Information: Many planning activities are mandated by regulations, including:

	completion of the Community Assessment (see 45 CFR 1305.3 and 45 CFR 1304.51(a)(1)(i)),
	formulation of long-range program goals and short-term program and financial objectives (see 45 CFR 1304.51(a)(1)(ii)),
	involvement of policy groups in formulating long-range goals and short-term objectives (see 45 CFR 1304.50(d)(1)(iv)),
	development of written plan(s) for implementing services in all program areas (see 45 CFR 1304.51(a)(1)(iii)), and
	completion of program self-assessments and agency and delegate monitoring activities (see 45 CFR 1304.51(i)).

Also see 45 CFR 1304.50(d)(iii) and 45 CFR 1304.51(a)(2), on involving policy groups in program planning.

Guidance: Program planning is an active and dynamic process in which ideas and strategies are shared, discussed, and updated as local circumstances and the needs of children and families change. Planning involves key members of the Head Start community, including staff, parents, governing body, policy group, advisory committee members and community representatives; and any plan represents the viewpoints of persons affiliated with all program options and all agency locations. The planning process also results in a written plan or a series of plans that describe an agency’s approach to serving children and families. This plan or series of plans will impact all program products and processes so that all aspects of the program reflect an integrated approach to services.

Planning strategies include:

	Orienting participants to the mission, goals, and philosophy of the agency and the Head Start program; and
	Scheduling times for planning that are appropriate and convenient for those involved, paying special attention to the kinds of accommodations that parents may require in order to participate.

Planning begins with the Community Assessment, through which agencies collect data about community strengths, needs, and resources. Agencies use these data to make decisions about the types of services they will provide for children and families. Examples of decisions that agencies make on the basis of the Community Assessment include:

	the program options and settings the agency will provide, such as the center-based, home-based, combination or family child care locations, and the hours of operation,
	the organizational structure it will use to implement these options,
	the kinds of staff skills and experience the agency needs, including the staff composition necessary to reflect the languages, cultures, and heritage of members of the community, and
	the services that the agency will provide directly and those it will provide through community collaboration and referrals.

Agencies consider the ways in which they could collaborate with other local service providers in conducting the Community Assessment and in interpreting its results. For example, agencies could conduct joint, initial Community Assessments or annual updates with other organizations, such as child care agencies and other organizations serving young children and their families. They could also meet with representatives of such organizations to discuss the roles each agency plays in meeting identified community interests and need or to leverage local resources.

Goal setting is an ongoing, dynamic process that stems from the Community Assessment and helps to establish agreed-upon priorities about what the agency expects to accomplish in the short- and long-term. Once established, goals and objectives are periodically reviewed and revised to respond to changes in the community.

It is helpful to distinguish between long-range program goals and short-term program and financial objectives in the planning process. Program goals are usually broad statements of what the program wants to accomplish in an overall sense and in each of the program areas. Program and financial objectives include specific steps that need to be taken to accomplish the long-range goals. The target date for achieving short-term objectives is often one year or less.

A written plan or set of plans is an outcome of a process of program planning that documents the agency’s strategies for implementing the Head Start Program Performance Standards and other applicable regulations, along with its own goals and objectives. For example, an agency may choose to prepare a single "strategic plan" which comprehensively discusses the results of the planning process. Another agency may choose to write separate plans for each service area. Agencies are encouraged to "tailor" plans to their own requirements. In addition, the outcomes of the planning process may include changes in grantee procedures (e.g., Community Assessment, recruitment) or documents (e.g., statement of goals and objectives, curriculum for children).

The process for developing the written plan(s) can vary widely from agency to agency. However, the process invariably includes developing a strategy for involving parents, staff, and policy group members in the development of the plan or plans.

As needed, consultants may be called upon to assist with preparing specific sections of the plan. Staff also can consult with the Health Services Advisory Committee in developing sections of the plan dealing with Early Childhood Development and Health Services.

Performance Standard

1304.51(a)(2)

(2) All written plans for implementing services, and the progress in meeting them, must be reviewed by the grantee or delegate agency staff and reviewed and approved by the Policy Council or Policy Committee at least annually, and must be revised and updated as needed.

Rationale: Policy group members are involved in reviewing program plan(s) to ensure they adequately reflect the needs and concerns of enrolled children and their families.

Guidance: Written plans are meant to be "working documents." Therefore, a review of plans and agency progress toward meeting the objectives of those plans could be a regularly scheduled topic at staff and policy group meetings. Examples of strategies for involving staff and policy group members in the regular review of plans include:

	Introducing staff and policy group members to program plans through small group orientation sessions;
	Providing updated information about program plans in regular bulletins or newsletters; and
	Organizing program staff and policy group members into committees or subcommittees charged with making necessary revisions or updates to the program plans or selected portions of those plans.

Performance Standard

1304.51(b)

(b) Communications - general.

Grantee and delegate agencies must establish and implement systems to ensure that timely and accurate information is provided to parents, policy groups, staff, and the general community.

Rationale: A communication system ensures the exchange of information that allows individuals to become fully involved in program activities and to make group decisions that promote a quality program. To be effective, information flows to and from parents, staff, governing bodies, delegate agencies and community groups. This rationale serves 45 CFR 1304.51(b)-(f).

Related Information: More specific guidance on communication with parents, governing bodies and policy groups, staff, and delegate agencies is provided in 45 CFR 1304.51(c). For information about communicating with community partners, see 45 CFR 1304.41(a).

Guidance: When establishing systems of communication, agencies consider the following issues:

	What information is important to members of the Head Start community;
	When people need to receive information;
	How the information should be communicated; and
	Whether communication flows both to and from parents, governing bodies, delegate agencies, policy groups, staff, and the general community in a timely fashion.

Communication comes in many forms: informal and formal, written and face-to-face, verbal and non-verbal, textual and graphic. Strategies used to communicate often can be as important as the content of the message being communicated.

Performance Standard

1304.51(c)(1) & (2)

(1) Grantee and delegate agencies must ensure that effective two-way comprehensive communications between staff and parents are carried out on a regular basis throughout the program year.

(2) Communication with parents must be carried out in the parents’ primary or preferred language or through an interpreter, to the extent feasible.

Related Information: Head Start regulations require effective communication with families in a language that each family understands (see 45 CFR 1304.52(b)(4)), and the conduct of specific activities that enhance staff-parent communication, including:

	opportunities for engaging in a family partnership agreement process (see 45 CFR 1304.40(a)(2)),
	home visits involving parents, home visitors or teachers, and, as appropriate, the enrolled child, and other staff members (see 45 CFR 1306.33 and 45 CFR 1304.40(i)),
	staff-parent conferences conducted as needed, but at least twice a year (see 45 CFR 1304.40(e)(5)),
	representation by parents and staff on Individualized Education Program (IEP) development teams (see 45 CFR 1308.19), and
	ongoing communication with parents regarding follow-ups that address identified health needs (see 45 CFR 1304.20(c)(1)).

See 45 CFR 1304.40(e)(3) for additional information on communicating with parents regularly, and 45 CFR 1304.50(d)(2)(ii), on policy group and Parent Committee communications with parents.

Guidance: The communication system includes opportunities for agencies to share and receive information on program activities, goals, and philosophy, as well as opportunities for parents to share and receive feedback on their child. Such communication is carried out in a variety of ways, such as:

	orientation activities,
	regular, informal telephone or face-to-face conversations, or notes in the parents’ preferred language, and
	newsletters.

To make communication efforts more effective, the agency communicates, to the extent possible, in the parent’s preferred language. Examples of ways to communicate with parents in their primary or preferred language include:

	Collaborating with local community organizations, such as ethnic associations and refugee or immigrant aid agencies, for assistance in communicating with parents; and
	Drawing upon parents and members of the local community to obtain bilingual staff and interpretation services and to ensure sensitivity to family culture and heritage (see 45 CFR 1304.52(g)(2)).

Performance Standard

1304.51(d)

(d) Communication with governing bodies and policy groups.

Grantee and delegate agencies must ensure that the following information is provided regularly to their grantee and delegate governing bodies and to members of their policy groups:

(1) Procedures and timetables for program planning;

(2) Policies, guidelines, and other communications from HHS;

(3) Program and financial reports; and

(4) Program plans, policies, procedures, and Early Head Start and Head Start grant applications.

Related Information: See 45 CFR 1304.50(d)(1)(ii) for information on communication between governing bodies and policy groups.

Guidance: As a part of the communication system, agencies use strategies to ensure that members of governing bodies and policy groups understand the information specified in this Performance Standard and its implications. Strategies include:

	Providing new members of governing bodies and policy groups with an orientation packet, as described in the guidance to 45 CFR 1304.52(k)(4), and with the appropriate training necessary to understand and participate in collective decision-making;
	Ensuring that policy group and governing body members have adequate preparation time to review and "digest" material they receive from the agency; and
	Facilitating discussions and an open exchange of ideas on program plans, policies, procedures, and reports at the meetings of policy groups and governing bodies.

Performance Standard

1304.51(e)

(e) Communication among staff.

Grantee and delegate agencies must have mechanisms for regular communication among all program staff to facilitate quality outcomes for children and families.

Guidance: An effective staff communication system supports the ongoing exchange of information among staff, is focused on quality of services, and represents the best interests of children and families. Effective formal and informal communication methods include:

	Establishing a supportive climate in which open and frequent staff communication is encouraged and appreciated, so that staff can freely share their ideas and concerns and provide constructive feedback to their colleagues and supervisors;
	Considering various ways that regularly scheduled staff meetings at all levels of the agency can be used to facilitate staff input and discussions; and
	Utilizing computer technology to support and enhance staff communication and to minimize geographical constraints —through electronic bulletin board systems, electronic mail, and Internet access.

Performance Standard

1304.51(f)

(f) Communication with delegate agencies.

Grantees must have a procedure for ensuring that delegate agency governing bodies, Policy Committees, and all staff receive all regulations, policies, and other pertinent communications in a timely manner.

Guidance: It is the responsibility of each grantee agency to design procedures for ensuring that delegate agencies receive, understand, and respond to pertinent information in a timely manner. Strategies to accomplish this include:

	Bringing representatives from the delegate agencies together when new regulations, plans, policies, program instructions or information memoranda are released by the Head Start Bureau or the grantee agency;
	Providing regular informational meetings, newsletters, a central library of resources, and joint staff training and technical assistance;
	Designating regular grantee staff liaisons to delegate agencies; and
	Making use of current technologies (such as conference calling, electronic bulletin boards, and E-mail) that minimize communication constraints related to distance.

Performance Standard

1304.51(g)

(g) Record-keeping systems.

Grantee and delegate agencies must establish and maintain efficient and effective record-keeping systems to provide accurate and timely information regarding children, families, and staff and must ensure appropriate confidentiality of this information.

Rationale: Effective record-keeping and reporting systems provide the information needed to individualize programs for children and families, to monitor the quality of program services, to assist in program planning and management, and to ensure the delivery of quality services. These systems also provide documentation that agencies are meeting program requirements and other Federal, Tribal, State, and local laws. To ensure that privacy rights are respected in these systems, safeguards are developed and maintained. This rationale serves 45 CFR 1304.51(g)-(h).

Related Information: Agencies are required to develop written confidentiality policies to ensure that all staff are aware of and implement those policies correctly (see 45 CFR 1304.52(h)(1)(ii)).

Regulation 45 CFR 1304.41(c)(1)(i) requires agencies to coordinate with schools and other agencies to ensure that relevant child records are transferred to and from other child placements or schools, which includes transfers among Head Start migrant programs and centers.

State or Tribal law may dictate the length of time that certain records are maintained; and recipients of Federal grants are required to maintain their records, in principle, for a minimum of three years.

Guidance: In building an effective record-keeping system, agencies consider what information they need to collect, who needs to receive it, and how it should be stored. The following factors are considered when establishing and maintaining record-keeping systems:

	Use of standard forms. Standard forms simplify information collection and record keeping, if they are designed in a way that minimizes unnecessary writing.
	Recording and storage of useful information. Staff are encouraged to review periodically the usefulness of recorded information and to avoid the unnecessary paperwork and files associated with information duplication.
	Confidentiality of information. The agency’s policy on confidentiality of information incorporates the following:

	Controlling access to files and prohibiting parents and volunteers from reviewing any records other than their own;
	Developing family permission forms for the release of information to and from agencies or individuals, and storing forms signed by the responsible adult; and
	Familiarizing relevant staff with all laws governing confidentiality policies, particularly as they pertain to interagency collaborations in which information about children and families is shared.

Use of computer technology. If used properly, computers allow staff to:

	Share information readily across wide geographical distances;
	Quickly aggregate financial or program data for use by program planners or decision makers;
	Generate and produce standard forms used regularly by agencies; and
	Up-date, store, and retrieve program records quickly and easily.

Transfer of records. When children and families transition from Head Start, records go with them with parental consent. Especially among migrant programs, where grantees assist with the rapid transfer of records to the families’ next destination, effective record-keeping systems ensure a smooth, timely transfer.

Performance Standard

1304.51(h)(1)

(h) Reporting systems.

Grantee and delegate agencies must establish and maintain efficient and effective reporting systems that:

(1) Generate periodic reports of financial status and program operations in order to control program quality, maintain program accountability, and advise governing bodies, policy groups, and staff of program progress; and

Guidance: The following are strategies to consider when designing and implementing effective and efficient reporting systems:

	Identification of critical reports. Staff are encouraged to consult with each of their funding sources and with their State and local licensing agencies for complete lists of reports that agencies may be required to produce in areas such as personnel qualifications, facilities and property, and health, safety, and sanitation. In addition, management staff may wish to consult with governing bodies and policy groups to determine the discretionary reports that will allow those groups and staff to most effectively plan and manage the program and its finances.
	Report content and structure. Agencies produce reports that are clear, accurate, and readable. These reports will help staff, governing bodies, and policy groups with varying levels of experience and education to make informed decisions concerning the program.
	Frequency of reports. Establishing a time schedule for the release of reports allows staff, governing bodies, and policy groups to schedule meetings when up-to-date information is available.

Performance Standard
1304.51(h)(2)

(2) Generate official reports for Federal, State, and local authorities, as required by applicable law.
Guidance: Examples of official reports that are likely to be required of local agencies include:

reports required by the Head Start Bureau, HHS or other offices, including Program Information Reports (PIRs), financial audit reports, and reports of financial status and expenditures (SF-269s),

annual returns filed by independent non-profit agencies with the Federal Internal Revenue Service (IRS) and, in some States, with State agencies,

forms providing information on payroll taxes, such as Social Security (FICA) taxes, withholding of income taxes, Federal unemployment (FUTA) and State unemployment taxes,

reports of meals served, menus, and training provided for the USDA meal programs,

program enrollment reports, including attendance reports for children whose care is partially subsidized by another public agency, and

other reports required by Federal, State, Tribal, or local law.

Performance Standard
1304.51(i)(1)

(i) Program self-assessment and monitoring.

(1) At least once each program year, with the consultation and participation of the policy groups and, as appropriate, other community members, grantee and delegate agencies must conduct a self-assessment of their effectiveness and progress in meeting program goals and objectives and in implementing Federal regulations.
Rationale: As a method of measuring agency accomplishments, strengths, and weaknesses, self-assessment allows for the continuous improvement of program plans and service delivery methods; and for the enhancement of program quality and timely responses to issues that arise in the community, the program, and among enrolled families. The self-assessment process also provides an opportunity for involving parents and community stakeholders, and for making staff more aware of how the program is viewed by its consumers. This rationale serves 45 CFR 1304.51(i)(1)-(3).

Related Information: See 45 CFR 1304.50(d)(1)(viii) for information on policy group participation in the annual self-assessment.

Guidance: A critical element to a successful self-assessment is the ongoing participation and oversight of the policy groups. After considering the following suggested steps, each grantee and delegate agency establishes its own structured self-assessment process:

Specify a time schedule. As part of the continuous cycle of program planning, self-assessments are scheduled in a way that responds flexibly to the agency’s need for review and evaluation.

Select a self-assessment team. Depending upon the specific focus of the self-assessment, consider including staff, policy group members, parents, representatives from community organizations, governing body members, and staff from other Head Start agencies on the self-assessment team. Staff may participate in reviews of program areas outside their own area of responsibility to build a broader base of staff expertise, perspective, and understanding of how the organization works as a team.

Provide training about the self-assessment process. Agencies are encouraged to provide all members of the Head Start community with information concerning the purposes of the self-assessment, the agency’s preferred methods of accomplishing an assessment, and the agency’s policy on confidentiality. Members of the self-assessment team can be assigned specific roles and be trained for those roles.

Assess the program by collecting information about program practices, and comparing that information with the goals and objectives established in program plans and with the Head Start Program Performance Standards and other relevant Federal, Tribal, State, and local regulations. All aspects of program operations can thus be evaluated. Agencies are encouraged to draw upon a variety of monitoring tools, in addition to the Head Start Program Performance Standards and monitoring instruments used by the Federal government, to help them with their task.

Analyze and share findings. Agencies are encouraged to analyze assessment findings and to openly discuss what the data have to say about agency strengths, weaknesses, and accomplishments with staff, policy groups, and governing bodies. Grantee agencies also may consider sharing self-assessment findings with Regional Office staff, before Federal reviews, in order to improve linkages between self-assessment and Federal monitoring processes.

Develop and implement action plans. Strong action plans identify the specific steps that agencies need to take in order to build on program strengths and to implement the changes necessary to correct areas of weakness. Plans indicate where responsibility for change lies and the time frames in which change should occur.

Make evaluations ongoing. The impact of proposed changes are evaluated during subsequent self-assessments, to ensure that the results of the changes are beneficial to the program and to the children and families served.

Performance Standard
1304.51(i)(2)

(2) Grantees must establish and implement procedures for the ongoing monitoring of their own Early Head Start and Head Start operations, as well as those of each of their delegate agencies, to ensure that these operations effectively implement Federal regulations.
Rationale: Ongoing, regular monitoring by grantee agencies helps to assess grantee and delegate operations, to ensure that necessary steps are being taken to meet Federal regulations as well as local goals and objectives, and to ensure that appropriate interventions are taken in a timely manner. Ongoing monitoring also helps to build trust and strong partnerships between grantee and delegate agencies, which allow them to share best practices and program strengths and to support one another’s progress toward program excellence.

Related Information: See 45 CFR 1304.51(h)(1) concerning the maintenance of reporting systems to control program quality and maintain program accountability. See 45 CFR 1304.51(d) and (e) on the maintenance of regular and effective communication with governing bodies and policy groups and among staff.

Guidance: Internal grantee monitoring is an ongoing process in which an agency analyzes program reports, self-assessment findings, written plans, and other important documents to determine whether its program of services and fiscal operations are in compliance with Federal regulations.

Grantees with delegate agencies are encouraged to use their own monitoring responsibilities as an opportunity to build cooperative relationships between grantee and delegate agency staff. Strategies that help agencies build these interdependent relationships include:

Holding regular meetings between the staff of each agency, to decide how the groups can best work together to support one another’s program goals and services;

Ensuring the participation of grantee agency staff and parents on the self-assessment teams of delegate agencies, as well as on those of their own programs; and

Providing training and technical assistance in areas identified by grantee or delegate agency staff or governing bodies.

Performance Standard
1304.51(i)(3)

(3) Grantees must inform delegate agency governing bodies of any deficiencies in delegate agency operations identified in the monitoring review and must help them develop plans, including timetables, for addressing identified problems.
Related Information: A process for appeals to grantees by current or prospective delegate agencies is established in 45 CFR Part 1303, Subpart C; 45 CFR 1304.60, and 45 CFR 1304.61.

Guidance: In order to assist delegate agencies’ governing bodies in their oversight responsibilities, grantee agencies:

Develop strong cooperative partnerships with delegate agencies that allow grantees to support delegates’ efforts to reach their goals and to both implement quality services and identify problems early (see 45 CFR 1301.51(i)(2) for additional information);

Establish mentoring relationships so that well-performing delegate agencies assist those who are performing less well;

Promptly inform delegate agency governing bodies of any problems identified through the grantee agency’s work with and review of the delegate agency programs or through the Federal monitoring process;

Enter into dialogue with delegate agencies to address any disagreements about identified deficiencies;

Work with delegate agencies to set priorities for addressing areas of deficiency in delegate agency operations, including the development of the quality improvement plan (QIP);

Establish schedules to ensure that deficiencies in delegate agency operations are corrected in a timely manner; and

Specify the consequences of deficiencies that are not corrected and mutual grantee and delegate agency responsibilities for correcting them.

Return to Main Menu or Goto 1304.52

	reports required by the Head Start Bureau, HHS or other offices, including Program Information Reports (PIRs), financial audit reports, and reports of financial status and expenditures (SF-269s),
	annual returns filed by independent non-profit agencies with the Federal Internal Revenue Service (IRS) and, in some States, with State agencies,
	forms providing information on payroll taxes, such as Social Security (FICA) taxes, withholding of income taxes, Federal unemployment (FUTA) and State unemployment taxes,
	reports of meals served, menus, and training provided for the USDA meal programs,
	program enrollment reports, including attendance reports for children whose care is partially subsidized by another public agency, and
	other reports required by Federal, State, Tribal, or local law.

	Specify a time schedule. As part of the continuous cycle of program planning, self-assessments are scheduled in a way that responds flexibly to the agency’s need for review and evaluation.
	Select a self-assessment team. Depending upon the specific focus of the self-assessment, consider including staff, policy group members, parents, representatives from community organizations, governing body members, and staff from other Head Start agencies on the self-assessment team. Staff may participate in reviews of program areas outside their own area of responsibility to build a broader base of staff expertise, perspective, and understanding of how the organization works as a team.
	Provide training about the self-assessment process. Agencies are encouraged to provide all members of the Head Start community with information concerning the purposes of the self-assessment, the agency’s preferred methods of accomplishing an assessment, and the agency’s policy on confidentiality. Members of the self-assessment team can be assigned specific roles and be trained for those roles.
	Assess the program by collecting information about program practices, and comparing that information with the goals and objectives established in program plans and with the Head Start Program Performance Standards and other relevant Federal, Tribal, State, and local regulations. All aspects of program operations can thus be evaluated. Agencies are encouraged to draw upon a variety of monitoring tools, in addition to the Head Start Program Performance Standards and monitoring instruments used by the Federal government, to help them with their task.
	Analyze and share findings. Agencies are encouraged to analyze assessment findings and to openly discuss what the data have to say about agency strengths, weaknesses, and accomplishments with staff, policy groups, and governing bodies. Grantee agencies also may consider sharing self-assessment findings with Regional Office staff, before Federal reviews, in order to improve linkages between self-assessment and Federal monitoring processes.
	Develop and implement action plans. Strong action plans identify the specific steps that agencies need to take in order to build on program strengths and to implement the changes necessary to correct areas of weakness. Plans indicate where responsibility for change lies and the time frames in which change should occur.
	Make evaluations ongoing. The impact of proposed changes are evaluated during subsequent self-assessments, to ensure that the results of the changes are beneficial to the program and to the children and families served.

	Holding regular meetings between the staff of each agency, to decide how the groups can best work together to support one another’s program goals and services;
	Ensuring the participation of grantee agency staff and parents on the self-assessment teams of delegate agencies, as well as on those of their own programs; and
	Providing training and technical assistance in areas identified by grantee or delegate agency staff or governing bodies.

	Develop strong cooperative partnerships with delegate agencies that allow grantees to support delegates’ efforts to reach their goals and to both implement quality services and identify problems early (see 45 CFR 1301.51(i)(2) for additional information);
	Establish mentoring relationships so that well-performing delegate agencies assist those who are performing less well;
	Promptly inform delegate agency governing bodies of any problems identified through the grantee agency’s work with and review of the delegate agency programs or through the Federal monitoring process;
	Enter into dialogue with delegate agencies to address any disagreements about identified deficiencies;
	Work with delegate agencies to set priorities for addressing areas of deficiency in delegate agency operations, including the development of the quality improvement plan (QIP);
	Establish schedules to ensure that deficiencies in delegate agency operations are corrected in a timely manner; and
	Specify the consequences of deficiencies that are not corrected and mutual grantee and delegate agency responsibilities for correcting them.