STOP THE HHS DESIGNATION RENEWAL SYSTEM (DRS)
IN 2007 CONGRESS ENACTED THE HEAD START REAUTHORIZATION, AND EMPOWERED THE SECRETARY OF HHS TO ADOPT REGULATIONS WHICH WOULD IMPROVE PERFORMANCE OF HEAD START PROGRAMS. INSTEAD, THE SECRETARY ADOPTED THE DESIGNATION RENEWAL SYSTEM (DRS), AN UNFAIR, UNREASONABLE AND ARBITRARY SYSTEM WHICH ONLY PENALIZES WELL MANAGED PROGRAMS WHILE DOING NOTHING TO IMPROVE LOW PERFORMING PROGRAMS. THE DRS IMPOSES IRRATIONAL, CAPRICIOUS AND RETROACTIVE TRIGGERS WHICH DESIGNATE HIGH PERFORMING HEAD START PROGRAMS AS “LOW PERFORMING,” AND REQUIRES THE RECOMPETITION OF AT LEAST ONE THIRD OF ALL PROGRAMS REVIEWED IN EACH YEAR. THE OHS DRS USES OUTDATED AND INACCURATE INFORMATION RELIES ON POORLY TRAINED CONTRACTORS AND RESULTS IN AGENCY MANIPULATION OF DATA AND RESULTS. THE DRS UNREASONABLY DISCRIMINATES AGAINST HIGH PERFORMING PROGRAMS. DRS RELY ON PRIVATE CONTRACTOR CLASS: PRE-K REVIEW AS A QUALITY ASSESSMENT TOOL, EVEN WHILE CHANGING THE RULES AND PROCEDURES OF THE CLASS: PRE-K RUBRIC. DRS TAKES ISOLATED ISSUES AND MAKES THEM SINGLE TRIGGERS FOR RECOMPETITION, IN THE FACE OF OVER 1,800 APPLICABLE ACF/OHS REGULATIONS, PROCEDURES AND OBLIGATIONS. SECTION 641 (B) (5) OF THE HEAD START ACT STATES THAT HHS “SHALL NOT USE THE RESULTS OF A SINGLE ASSESSMENT AS THE SOLE METHOD FOR ASSESSING PROGRAM EFFECTIVENESS OR MAKING AGENCY FUNDING DETERMINATIONS.” INSTEAD, THE DRS RULES DO USE THE RESULTS OF A SINGLE CLASSROOM ASSESSMENT (THE “CLASS”) TO LABEL A PROGRAM LOW QUALITY AND PUTS SUCH PROGRAMS INTO RECOMPETITION FOR FUNDING. UNDER THE DRS, THE MERE EXISTENCE OF A DEFICIENCY, NO MATTER HOW OLD OR LONG AGO IT WAS CORRECTED, AUTOMATICALLY LABELS THE HEAD START PROGRAM AS “LOW QUALITY.” THIS SYSTEM IS NOT WHAT CONGRESS AUTHORIZED OR WANTED IN 2007 WHEN IT RENEWED THE HEAD START ACT. WE URGE YOU AS OUR REPRESENTATIVES WHO ENACTED THE 2007 HEAD START ACT TO PLEASE USE YOUR LONG-ESTABLISHED AUTHORITY TO HOLD HEARINGS TO INVESTIGATE ALL ASPECTS OF THE DRS AND THE DESTRUCTIVE IMPACT IT IS HAVING ON PROGRAMS. THE DRS REGULATIONS UTTERLY FAIL TO MEASURE THE QUALITY OF LOCAL AGENCIES AND TO COMPLY WITH THE CLEAR DIRECTIVES OF CONGRESS.