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yo" | ADMINISTRATION FOR <@ CHILDREN CZ FAMILIES Office of Head Start | Ath foor shington DC | ecike-ohs.acthhs.gov ‘To: Board Chairperson From: Responsible HHS Official Mr. Chris Brady ‘Ms. Ann Linehan Board Chairperson Acting Director, Office of Head Start Jefferson County Board of Education 900 S Floyd St Early Childhood Office Louisville, KY 40203-2331 date F217 Overview of Findings On 3/7/2017, the Administration for Children and Families (ACF) conducted a monitoring review of the Jefferson County Board of Education Head Start and Barly Head Start programs We wish to thank the governing body, Policy Council, staff, and parents of your program for their cooperation and assistance during the review. This Head Start Review Report has been issued to Mr. Chris Brady, Board Chairperson, as legal notice to your agency of the results of the program review. Based on the information gathered during our review, a determination has been made that Jefferson County Board of Education is a grantee with at least one area of deficiency in its Head Start and Early Head Start programs. If you anticipate that you will not be able to correct all deficiencies within the correction time specified in this report, you must submit a letter to your ACF Regional Office requesting an extension with an explanation as to why an extension is necessary. The letter requesting an extension must be submitted prior to the expiration of the original corrective action time period. In order to allow for sufficient time to consider extension requests, we ask that you submit your request within 10 days following receipt of this report. Extension requests shall not be considered approved unless you receive such approval in writing before the deadline for correction. The report provides you with detailed information in each area where program performance did not meet applicable Head Start Program Performance Standards, laws, regulations, and policy requirements. Please contact your ACF Regional Office with any questions or concems you may have about this report. Distribution of the Head Start Review Report Copies of this report will be distributed to the following recipients: Capt. Robert Bialas, Regional Program Manager Ms, Alicia Yarbrough, Policy Council Chairperson Jefferson County Board of Facaton o¥cH010368/2017 Dr. Donna Hargens, CEO/Executive Director ‘Ms. Rina Gratz, Head Start Director Overview Information Review Type: Other-Offeite Organization: Jefferson County Board of Education Program Type: Head Start and Early Head Start Field Lead: Mrs. Loren Jackson Funded Enrollment HS: 1319 Funded Enrollment EHS: 232 762017 ‘ntp/fece obs ats gov/stesandards Page 2 of Jefferson County Bord of Fdveation o4cH01036822017, Glossary ‘A glossary of terms has been included to explain the various terms used throughout this report. E Compl a on sce Measure (CM) The specific statements that collectively assess the level of program performance foreach Key Indicator, focusing on one or more Federal regulation critical othe delivery of quality services and the development of strong management systems, Strength ___Annew and/or unigue way of reaching the community Compliant [No findings. Meets requirements of Compliance Measure Concern ‘An area or areas of performance whieh need improvement or technical assistance. These items should be discussed with the Regional Office and do not include a timeframe for correction Noncompliance ‘A finding that indicates the agency is out of compliance with Federal requirements (including, ‘but not limited to, the Head Start Act or one ot more ofthe performance standards) in an atea ‘or areas of program performance, but does not constitute a deficiency. Noncompliances require a writen timeline of correction and possible technical assistance (TA) oF guidance {rom their program specialist, and if not corrected within the specified timeline, can become a deficiency Deficiency ‘An area or areas of performance in which an Early Head Stator Head Stat grantee agency is ‘notin compliance with State or Federal requirements (including but not limited to, the Head Start Act oF one or more ofthe regulations) and which involves (A)A threat to the health, safety, or civil rights of children or staff (B) A denial to parents ofthe exercise of ther full roles and responsiblit program governance: related to (©) A future to perform substantially the requirements related to Early Childhood Development and Health Services, Family and Community Partnerships, or Program Design land Management; or (D) The misuse of Head Start grant funds (ii) The loss of legal status or financial viability, as defined in part 1302 of this ttle, loss of| permits, debarment from receiving Federal grants or contracts or the improper use of Federal funds; or (ii) Any other violation of Federal or State requirements including, but nt limited to, the Head Start Actor one or more ofthe performance standards ofthis ttle, and whieh the {grantee has shown an unwillingness or inability to correct within the period specified by the responsible HHS official, of which the responsible HHS official has given the grantee writen notice of pursuant to section 1304.61 726207 hup.ecke fs aths govisltandards Page 30f9 Jefferson County Board of Education osc1i010368/2017 Summary of Findings Finding Type Caen ‘Safe Learning Environments §1302.90(0)(1)(WA-B, HS and EHS O4CHOI0368 30 days Deficieney DEG ‘Safe Learning Environments §1302.90 (e)(U)(») HS OACHOIO368 30 days Deficiency Safe Learning Emvironmens — §1302.102 (d(D(W(A) “HS —«OSCHOI0368 30 days Deficieney| New Deficiency Determination {$1302 Program Operations. Deficiency 1302.90 Personnel policies. (@) Standards of conduct. (1) A program must ensure all staf, consultants, contractors, and volunteers abide by the program's standards of conduct that: (Gi) Ensure staf, consultants, contractors, and volunteers do not maltreat or endanger the health or safety of children, including, at 2 minimum, that staff must not: (A) Use corporal punishment (B) Use isolation to discipline a child; (D) Use or withhold food asa punishment or reward; (F) Use any form of emotional abuse, including public or private humiliation, rejecting, terrorizing, extended ignoring, or corrupting a child; (G) Physically abuse child; Oth ss (g2017) ‘The grantee didnot ensure all staff abided by the program's standards of eonduct refraining from ‘maltreatment of or endangering the health and safety of children, including a a minimum, staff did ‘not engage in corporal punishment, use emotional or physical abuse, or humiliation; and employ methods of discipline that involved isolation, the use of food as punishment or reward, or the denial of basic needs. The grantee had thirteen incident reports of staff not abiding by the standards of ‘conduct from October 2016 through May 2017. The grantee provided various documentation regarding each incident including email correspondence, licensing reports, Child Protective Services (CPS) reports, and grantee incident reports. Incident One (On October 28,2016, a parent reported tothe Principal at Zachary Taylor Elementary when she «dropped her preschool aged child off at school that morning, the instructional assistant yanked her child by the arm and stated, “I'm not putting up with this today." The Principal contacted the ‘Compliance Specialist to report the incident and also reported the incident CPS. An internal investigation found the allegation ofthe instructional assistants language tothe ehild to be inconclusive due tothe lack of an eyewitness to confirm the event occured. In addition, the investigation found the allegation that the instructional assistant grabbed the child by the forearm to be inconclusive due othe lack of an eyewitness, However, the instructional assistant did make physical contact by holding the child's hand firmly as confirmed by her statement. The ‘assistant completed a conference summary to discuss behavior concerns with the Prine behavior and seclusion guidelines and expectations. CPS declined to investigate the incident. Incident Two (On December 1, 2016 the grantee received an email communication with a completed internal investigation report from the Jefferson County Public Schools (JCPS) Compliance and Investigation Department related to incidents that oceurred a the George Unseld School. The investigation Was initiated following an anonymous call to CPS regarding the classroom teacher's treatment of two 4- year-old children. review ofthe CPS repor found the findings against the teacher were Substantiated forthe following behaviors: rising her voice, speaking harshly to, and verbally 762017 Inpecke hs set hs govslestandands| Page 40f9 Jefferson County Board of Education o4cHOINR68!2017 theatening the children; grabbing the children by the arms; taking achld into closet alone and out ofthe view of other staf; and forcefully putting a child ona cot. Inan interview, the Head Start Director reported the parents of both children were notified ofthe incidents and both parents chose to have their children remain inthe classroom with the teacher. due process meeting was conducted with th teacher, the Union representative, and the district administrator and as a result of the ‘meeting, the teacher was suspended without pay for 5 days. Incident Three ‘On December 12, 2016 an incident occurred at Tully Elementary. A teacher instructed a3-year-old child to stop pouring his milk out ofthe carton onto his fruit, The child refused to comply, and the teacher told him if he did not stop he would have to eat the mixture. He continued to pour the milk ‘onto the fruit and proceeded to throw the milk/fuit mixture onto the table, Subsequently, the teacher scooped the items off the table, put them back ont the child's tray, wrapped the child between her farms and legs, and forced him to eat the items. According to the grantees report, the cafeteria ‘Assistant Manager and the instructional assistant observed the incident and reported the event to the ‘Assistant Principal. The child's parent was informed of the ineident and told the child would be assigned to another classroom: however, the parent declined to have the child removed from the classroom, Inan interview, the Head Stan Director said the incident was reported to CPS by the Assistant Principal for investigation; however, CPS declined to investigate the incident, Additionally, the Principal contacted the Board's Compliance and Investigation Department and Employee Relations to conduct the grantees internal investigation. The outcome ofthe investigation and the employee's due process was forthcoming at the time of the review. A meeting occurred with the Principal, the teacher, and the Union, Asa result the teacher was given a writen reprimand for treating a child in an embarrassing manner. Incident Four (On January 12, 2017 an incident occurred at Carrithers Middle School, A resource teacher observed a preschool aged child siting on the eapet nex oa teacher, The child was being reprimanded by the teacher for behaviors the resource teacher didnot observe, The child began sereaming, and the teacher placed her hand over the child's mouth. The resource teacher walked aver and removed the teacher's hand from the child's mouth and proceeded to report the incident to the Principal. CPS was notified but declined to take the case. The Principal requested an internal investigation by JCPS. Compliance and Investigation which was pending at the time of the review; the staff member was {temporarily reassigned to another classroom, Incident Five (On February 14, 2017 an incident occured atthe Duvalle Education Cente. The Site Adminstrator received a call fom a parent alleging her preschool aged child had her cot flipped over by an instructional assistant which resulted i a Scratch on the child's lose back, While the Site Administrator investigated the situation, a second instructional assistant shared additional concerns ‘regarding the instructional assistant in question. The second instructional assistant reported the ‘instructional assistant in question grabbed an uncooperative child by the upper arm/shoulders and tossed him onto the child-sized couch in the classroom. She further reported the instructional assistant ‘in question was dealing with a different child over cleaning up play centers when he allegedly used ‘profanity withthe child, put both hands on the child's shoulders, and forcefully pushed the child ‘down until he cleaned up the center. CPS was notified, and the investigation was pending atthe time ‘of the review. The instructional assistant in question was reassigned to another classroom pending the ‘outcome ofthe investigation. Incident Six (On February 23, 2017, an incident occurred atthe MeFerran Early Childhood Center. The Site ‘Administrator informed the Regional Office that a parent reported her preschool aged child said an instructional assistant took her into the bathroom and smacked her hands. CPS was notified and the status of the investigation was pending. JCPS Compliance and Investigation was notified and an internal investigation was also pending. Incident Seven (On February 28, 2017, an incident was reported by the Principal ofthe Laukhuf Elementary School. ‘The Principal reported an instructional assistant witnessed a teacher gab a preschool aged child by the collar Bone after he ran tothe back of the oom: the eh fell othe floor sereaming, The instructional assistant sated the teacher checked the child's shoulder after she realized the instructional assistant observed the incident, The teacher stated she wanted to make sure she didnot 7262017 ‘mipectk obs athe govilestandards Page 5 of Jefferson County Board of Fuaton o4CH010368/2017 leave a mark on the child. The instructional assistant also reported other classroom staff would squceze the finger area of children’s hands to get them to ine up and follow directions, She also reported when they were in the gym, one teacher had a bag of balls which she thew ata child when he refused to get inline. The bag hit him, and the child fell tothe ground, Another instructional assistant confirmed the incident in the gym occurred. The incident report stated the Principal was working with taf to confirm dates ofthe other events described. The status of disciplinary action for Stal failure to report the addtional incidents immediately was pending. CPS was also notified, and the status ofthe investigation was pending. Incident Fight (On March 9, 2017, a second incident oecurred at the George Unseld Early Childhood Learning Center. The Site Administrator reported to the Regional Ofice the parent of a preschool aged child alleged the childs instructo.-not the same staff member involved in Incident One--yanked her child's arm and firmly held his hand eausing an injury. The mother took the child tothe emergency room late in the evening where a medical professional teated him for pain inthe arm, CPS was notified and the status of the investigation was pending. The grantees internal investigation found that twas ‘unsubstantiated that the instructor hed the child's arm tightly. However, based on interviews with staff it was substantiated the insiructor handled the child inappropriately and was too forceful The instructor was issued a Wetten reprimand on May 25, 2017. Incident Nine On March 9, 2017, an incident occurred at Wheatley Elementary. A parent reported to the Regional Office her preschool aged child was hit and dragged to his cot by his teacher. CPS was notified, and the status ofthe investigation was pending. A review ofthe grantee's Personnel Allegations report found the matter would be handled internally atthe schoo. Incident Ten ‘On April 20,2017, an incident occurred atthe Edwards Education Center. An Instructional Coach reported to the Regional Office an Early Head Stat (EHS) staff member pulled an EHS child by her arm, picked her up, placed the child on her back on top ofa cushion onthe floor, and threw a dress-up ‘ape at her face. The child started to scoot her body toward the table away from the staff member who then sai, "Don't move your butt back there, get your own toys." The sal member proceeded to throw a doll on the flor near the child. CPS was notified and at the time ofthe review the status of the investigation was pending, Incident Eleven (On May 1, 2017, a second incident occurred atthe Duvalle Education Center involving a different stafT memiber than reported in Incident Four, The Associate Principal reported to the Regional Ofice 8 parent alleged on May 1, 2017, astafT member took her preschool age child into the athroom and slapped him across the face. The child eonfimed the allegation--stating it occurred because he hit another child first~and the Associate Principal noted ared mark onthe child's face. CPS was notified and the status ofthe investigation was pending a the time of the review. ICPS Compliance and Investigation was also notified, and that investigation was also pending atthe time ofthe review. Incident Twelve (On May 18, 2017 atthe Alex R. Kennedy Elementary, a teacher lifted a preschool aged child's cot vertically to wake him from his nap causing the child to tumble on the floor. The report also stated the teacher grabbed another child's et and dragged it over to her desk and dropped it tothe floor stating tothe child, “Now you willbe quie.™ CPS was notified, andthe results of the investigation were pending atthe time ofthe review. Incident Thirtcen ‘On May 18, 2017 a report was received by the grantee from the Principal ofthe George Unseld Learning Center stating a teacher leaned over and continuously spoke loudly and harshly in preschool aged child's face for waving his paper around, The instructional assistant who reported the incident stated the teacher was very loud and the ehild was visibly upset and erying harder than she hnad ever seen him ery. The child later told his masher thatthe teacher also bit his ear, CPS was notified, and the results ofthe investigation were pending. atthe time ofthe review. ‘The grantee didnot ensure all staff abided by the program's standards of conduct refraining from ‘maltreatment of or endangering the heath and safety of children including at a minimum, staf did not engage in corporal punishment, use emotional or physical abuse, or humiliation: and employ methods of discipline that involved isolation, the use of ood as punishment or reward, or the denial of basic needs: therefore, the grantee was not in compliance with the regulation, 782017 Ingpfeste os at hhsgov/slelstandards Page 6 of Jefferson County Board of Edeation oscii010368/2017 ‘Timeframe for correction: 30 days ‘This finding constitutes deficieney as defined under Sec. 637(2)(A)(i) of the Head Start Actas a systematic or substantial material failure in the area of performance thatthe Secretary determines involves a threat tothe heath, safety, o civil rights of children and staf, {$1302 Program Operations. Deficiency 1302.90 Personnel policies. (6) Standards of conduet. (1) A program must ensure all staff, consultants, contractors, and volunteers abide by the program's standards of conduct th (©) Ensure no child is left alone or unsupervised by staff, consultants, contractors, or volunteers hile under their care. Otber-Oftsive (1/1201) ‘The grantee did not ensure children were not lft alone o unsupervised while under the care of sa. ‘Three incidents of children being left unsupervised were repored since January 18, 2017, Incident One ‘A 3-yearold child enrolled atthe grantee’s Kerrick Elementary Schoo! location was tet inthe ‘lassroom unattended for approximately 10 minutes on October 26,2016. A review ofthe program's incident report submited by the Head Start Dieector to the Regional Office via email found a child ‘vas left unsupervised inthe classroom/hallway area at Kerrick Elementary School for approximately 10 minutes. Two contracted Family Advocates were visting the program to conduct hearing and vision screenings and reported-aftr classes departed for lunch inthe eafeteria~they heard a ‘whimpering sound in the hallway outside of the classroom and subsequently found a child erying across the hall, One ofthe Family Advocates went to console the child and learned his class fet for luneh without him. The Family. Advocate took the child to his teacher inthe cafeteria and was informed by the teacher the child was ina timeout when they departed the classroom and she must have forgotten him, A review of a written statement from the Lead Teacher noted most of the children were washing their hhands to prepare for lunch while she was working with three children having behavior issues. The ‘ther staT in the classroom proceeded to lin up the children and one child was asked to leave the line and sit on the carpet as he was pushing other children. The staff did not notice the ehild had not returned tothe line when they departed for the cafeteria, The teacher admitted she did not look around to see if all ofthe children were in line and did not recall iFshe counted the children before leaving the classroom to go to the cafeteria, The two Family Advocates and their Supervisor reported the incident tothe Principal of Kertick mentary School on October 27, 2016. The incident was reported to Child Protective Services (CPS) on November 1, 2016; however, CPS declined to investigate the inident. The Principal met With the staff involved in the incident and reminded them children must be counted to ensure they ‘were accounted for at al times. The Principal also completed a corective action plan to ensure ‘expectations for child supervision were clearly communicated. Incident Two ‘On October 1, 2016, atthe Tully Elementary location, the Principal was approached by an early childhood resouree teacher, who shared that one ofthe early childhood classes had a preschool aged child Tet unattended for an undetermined amount of time during the lunch period. A review of the ‘gantee's overview of the incident found the assistant teacher led the class to lunch and the substitute ‘was the last staff person to leave the room. When the class arrived atthe lunchroom, the substitute ‘thought one child was missing from their head count of 16 children; however, didnot search for ‘missing child. The assistant teacher then went on her lunch break and when she returned to the classroom following her break found the child in the clastoom unattended, The child was sitting ina chair with headphones on and playing with an iPad and was unharmed. A review of the grantee's Personnel Allegation report found the substitute was placed on a "do not return to this sit" ist atthe request of the Principal. The incident was reported to CPS; however, they declined to investigate the incident Incident Three (On February 20, 2017 atthe Duvalle Education Center, a preschool aged child wandered away from 76207 Impeelke obs ae as govhsletandards Page 7of9 Jefferson County Bord of Education oscv0103682017 the classroom and was found by another staff member in another location of the building. The ‘estimated time the child Was unattended was 2 minutes. A review of footage from the surveillance Videotape confirmed the incident occured, The Site Administrator stated the class was being supervised by two instructional assistants at he time of the incident. Meetings were held with both Stal members to review expectations for supervising children. CPS was notified of the incident and declined to investigate ‘The grantee did not ensue children were no lef alone or unsupervised while under the care of staf therefore, the grantee was not i compliance with the regulation. “Timeframe for correction: 30 days ‘This finding constitutes a deficiency as defined under See. 637(2)(A)(i) ofthe Head Start Act asa systematic or substantial material failure in the area of performance that the Secretary determines involves a threat to the health, safety, or eivl rights of children and staf, {$1302 Program Operation 1302.102 Achieving program goals. (@) Reporting. (1) A program must sub Reports, as appropriate, to the responsible HHS official immediately or as soon as practicable, related to any significant incidents affecting the health and safety of program Participants, circumstances affecting the financial viability ofthe program, breaches of personally identifiable information, or program involvement in legal proceedings, any matter for which notification or a report to state, tribal or local authorities is required by applicable Jaw, including at a minimum: (A) Any reports regarding agency staff or volunteer compliance with federal, state, local laws addressing child abuse and neglect or laws governing sex offenders; Deficiency bal, or Other-Ofisite (1/18/2017) ‘The grantee did not establish and maintain efficient and effective reporting systems that generate official reports for Federal, tate, and local authorities, as required by applicable law. Seven incidents ‘of staff not abiding by the standards of conduct were reported tothe Regional Office more than 3 ays afer the incidents occurred, All seven incidents were reported to licensing and ther agencies as required Incident One (On October 27, 2016, an incident involving an unsupervised child occured atthe Kerrick Elementary ‘School site. The incident was reported to Regional Office on November 9, 2016, 13 days afer the incident occurred. Incident Two On October 28, 2016, a parent reported to the Principal that when she dropped her child off that ‘momming at Zachary Taylor Elementary te instructional assistant yanked her ehild bythe arm. The incident was reported o the Regional Ofice on November 9, 2016; 12 days after the incident occurred. Incident Theee On December 1, 2016, the grantee received an email communication with a completed internal investigation epor from Jefferson County Public School (ICPS) Compliance and Investigation ‘describing a teacher atthe George Unseld School who did not refrain from malteating children i the

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