Response to Comments Received During 30-day Comment Period

ICR 202401-0970-018 Public Comments

COMMENT 1:

To whom it may concern,

Being in Early Head Start since July 2023, the recruitment and hiring process for EHS has been difficult in Charlottesville, VA.

Professional Development:

For the professional development practices, Virginia licensing requires four (4) trainings to be completed before a teacher can even step into a classroom, or that is best practice. One that takes 10 hours to complete, one that takes 3 hours to complete, one that takes 5 hours to complete, and the other that takes 3 hours to complete. These have to be completed first before any teacher can take any of our trainings that our Head Start has including curriculum and positive discipline, which we use Conscious Discipline and takes 10+ hours to complete.

Recruitment:

We had ads for our positions for Early Head Start on Indeed, Facebook, four (4) local radio stations, a job fair that was broadcasted for two (2) weeks through social media and radio stations, flyers, word of mouth. Since being hired in July 2023 and reopening the classroom in November 2023, I have hired five (5) people. One of the employees resigned in January 2024 due to personal reasons. With that, I have four (4) employees for Early Head Start.

Hiring:

One of the biggest challenges that we have faced is the requirement for EHS teachers to have an Infant/Toddler CDA. With the pay that we offer to these EHS teachers, we are majorly underfunded for there to be the requirement of an Infant/Toddler CDA or higher. We offer between $15.84-$19.45 an hour ($32,947.20- $40,456 a year) for teachers in EHS. These are not livable wages in Charlottesville, VA and the surrounding counties.

RESPONSE:

The professional development, recruitment, and hiring practices and challenges identified in this comment are consistent with the type of information that will be systematically asked of all respondents as part of this information collection. This will allow for the production of nationally representative estimates that can inform program planning, training and technical assistance, and future research.

COMMENT 2:

It is not clear to me what the purpose of a national survey on staff recruitment, training and professional development would serve. Communities across the country are so diverse that I question how would the data be used. My recent experience has been that data from a survey like this would only serve to compare programs and critique or penalize those that, on paper, are not engaging in the same activities as other programs. This would be an unfair comparison. In addition, every EHS program must submit a grant that describes all their professional development and training plans. Why require programs to

complete a survey when that information is already available to ACF? The topic of staff recruitment is completely separate from PD and training and I suspect that this topic is added to the survey in order to micromanage EHS programs and again, critique or penalize, those that do not appear to be doing either 'enough' or 'the right things' to recruit staff. Please do not use my tax dollars to collect information you already have to weaponize it against EHS programs who are already struggling alongside the rest of the country to recruit and retain qualified staff to do the already challenging work of caring for underserved populations in this country. I have attached an article from the US Dept. of Commerce titled 'Understanding America's Labor Shortage.'

RESPONSE:
This information collection is a one-time national survey of respondents from Early Head Start (EHS) grant recipients regarding practices to ensure that center-based infant and toddler teachers as well as home visitors have sufficient knowledge, training, experience, and competencies to fulfill the roles and duties of their positions. This depth of information is not systematically collected of EHS grant recipients by the Office of Head Start. Participation in this information collection is voluntary and responses from participating grant recipients will not be shared with the Office of Head Start or the public. It is intended to produce nationally representative estimates of EHS grant recipients’ teacher and home visitor recruitment, training, and professional development practices. Findings are intended to inform the Office of Head Start in their efforts to support EHS grant recipients. Specifically, findings are intended to inform program planning and training and technical assistance as well as to inform future research of relevance to the EHS workforce.