Auditing the Head Start Program
as Part of Your Single Audit:
Avoid Common Pitfalls
A Governmental Audit Quality Center Web Event
October 11, 2012
Administrative Notes
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Presenters
Ann Linehan, Deputy Director
• Office of Head Start
Terry Ramsey, CPA
• U.S. Department of Health & Human Services
Belinda Rinker, JD
• Senior Advisor to the Office of Head Start
Jim Belanger, CPA
• Director, Fiscal Operations, Program Monitoring
Eric Formberg, CPA, CGFM
• Plante & Moran PLLC
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What We Will Cover
Overview of the Head Start Program
Compliance Requirements
Common Program Findings
Audit Quality Issues
Tips for Avoiding Pitfalls
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Overview of the Head Start
Program
Ann Linehan, Deputy Director
Office of Head Start
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Purpose of Head Start
Head Start is a Federal
program that promotes the
school readiness of children
ages birth to five from lowincome families by enhancing
their cognitive, social, and
emotional development.
•
•
Early Head Start provides services
to pregnant women and families
with children up to age three.
Head Start serves children age
three to five and their families.
Together the two programs
are commonly referred to as
Head Start.
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Head Start Services
Each year, Head Start / Early Head Start
programs provide comprehensive services
to over a million eligible children and
families.
Comprehensive services include early
childhood development and education,
health, family engagement, and community
partnerships.
Community Assessment determines
program model/s: center-based, homebased, or family child care.
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Head Start Grants and Eligible Entities
Head Start grants are provided directly to local
agencies by the Administration for Children and
Families, Office of Head Start, with no
intermediary state funding agency.
Eligible agencies include local public or private
nonprofit agency, including community-based
and faith-based organizations, or for-profit
agency, within a community. See Head Start Act
Sec. 641(a)(1) [42 U.S.C. 9836].
Recipients may designate delegate agencies to
operate all or part of the Head Start program.
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ACF Office of Head Start Geographic Regions
Note: Region 11 (American Indian/Alaska Native) and
Region 12 (Migrant and Seasonal Head Start) have national
administrative offices in Washington, DC.
Regional Contact Information: http://www.acf.hhs.gov/programs#region
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Head Start Grants
The current federal funding is nearly $8
billion.
The smallest grant is $190,664 and the
largest is $210 million.
With over 1600 grantees, the average funded
enrollment per grantee is 595, ranging from
15 to 22,348 children.
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Early Childhood Learning and Knowledge
Center (ECLKC)
http://eclkc.ohs.acf.hhs.gov/hslc
Head Start Performance Standards
Head Start Act
Monitoring Protocol
Training and Technical Assistance Centers
Governmental Audit Quality Center
Program Instructions
Information Memorandums
Head Start Announcements
…and more!
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Governance Structure
Head Start agencies must establish and maintain a
formal structure for program governance,
including a governing body and a policy council.
See Head Start Act Sec. 642.
 The governing body has fiscal and legal responsibility for
the Head Start agency.
 The policy council is responsible for supporting program
direction. A majority of policy council members must be
parents of children who are currently enrolled in the
agency’s Head Start program.
 Delegate agencies must establish a policy committee.
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Monitoring Reviews
Head Start agencies must be monitored to
determine compliance with all applicable
requirements. See Head Start Act Sec. 641A.
 Review Types: Triennial, First Year, Other
 Monitoring teams include fiscal reviewers.
 Agency receives a written report identifying any areas of
deficiency or noncompliance and is given a timeframe to
correct all findings
 The protocol used to conduct reviews can be found on the
ECLKC website under the Monitoring & Reports tab.
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Regulatory Developments
Limitation of grant period to five (5) years.
See Head Start Act Sec. 638. [42 U.S.C.
9833].
Designation Renewal System at 45 CFR Part
1307 identifies seven conditions which, if
met, requires a Head Start program to recompete for a five-year grant.
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Regulatory Developments, cont.
Three of the seven DRS conditions relate to fiscal
operations.
§1307.3(e): an agency has been suspended from the
Head Start/Early Head Start program by ACF during the
relevant time period covered under §1307.7.
§1307.3(f): an agency has been debarred from receiving
Federal or State funds or has been disqualified from the
Child and Adult Food program (CACFP) during the
relevant time period covered under §1307.7.
§1307.3(g): An agency has been determined within the
twelve months preceding the responsible HHS official's
review under § 1307.7 to be at risk of failing to continue
functioning as a going concern.
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Compliance Requirements
Common Head Start Program Findings
Audit Tips
Presented by:
Terry Ramsey
Belinda Rinker
Jim Belanger
Eric Formberg
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Session Goals
Explain Head Start requirements most likely
to be misunderstood by auditors.
Identify common Head Start risk factors and
provide audit tips.
Help auditors perform an effective and
efficient audit of the Head Start program.
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Materials Highlight Requirements
Unique to Head Start
Basic single audit knowledge is assumed.
Audit Standards (GAAS & GAGAS)
OMB Circular A-133, Audits of States,
Governments, and Non-Profit Organizations
A-133 Compliance Supplement
OMB Administrative and Cost Principle Circulars
Federal Audit Clearinghouse reporting
Ability to write proper audit findings
 Register for AICPA Web Event titled, Writing Up Government
Audit Findings, October 19, 2012, click here.
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Information Provided is not a Substitute for
Compliance Supplement or OMB A-133
Session covers only areas identified as
common risks for Head Start programs.
An individual entity’s risk may be different
Auditor must still comply with OMB
A-133 and consider all requirements
identified in the Compliance
Supplement.
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Overall Program & Entity Risks
Head Start not designed to make money.
Only covers costs that are reasonable, allowable
and allocable (RAA) for the accomplishment of
program objectives
At best, entity relying on Head Start funding
breaks even.
 Grantee must insure that costs are allowable or
cover unallowable costs from other revenue
sources
Entity primarily funded by Federal grants at
higher risk for unallowable costs, particularly
match.
 Limited options to cover unallowable costs
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Overall Audit Tips
Combine similar areas if practical.
Ensure samples target risk areas.
Be alert to:
Improperly allocated costs
 Both direct and costs claimed as match
Cost shifting
 Particularly around beginning and end of period
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Activities Allowed
Program Services
Funds must be spent for program
services consistent with the Head Start
Performance Standards.
See list of allowable activities in Compliance
Supplement
If unsure whether a cost is allowable:
Check the program regulations (45 CFR
1301 – 1311) at the Policy & Regulation
tab on the ECLKC website (provided
earlier).
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Activities Allowed
Capital Expenditures
Must have ACF prior approval.
Necessary for purchase or sale of items of
equipment that meet or exceed the Federal
acquisition cost level of $5,000.
 Required for all facilities activities funded in
whole or in part with Head Start funds as
described in 45 CFR Part 1309 including:
 Construction
 Initial Purchase or Down Payment
 Major Renovation
 Mortgage Principal and/or interest
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Activities Allowed
Transportation Costs
Transportation costs to and from Head Start centerbased programs and other program activities are only
allowable if provided in accordance with Head Start
Transportation Regulations (45 CFR 1310).
Transportation of center- based children must be in
a compliant vehicle with an age and weight
appropriate child restraint system.
Related risk area: time and cost of parent supplied
transportation in a non-compliant vehicle is not
allowable as match.
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Activities Unallowed
Nutritional Services
The Head Start Performance Standards at 45 CFR
1304.23 require grantee agencies to use funds from
the US Department of Agriculture (USDA), Food and
Nutrition Service (FNS), Child Nutrition Programs as
the primary source of payment for meal services.
The most common USDA program utilized by Head
Start programs is the Child and Adult Care Food
Program (CACFP).
Head Start funds may only be used to cover those
allowable costs not reimbursable by USDA.
Parents may not be charged for Head Start nutrition
program participation.
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Activities Unallowed
Nutritional Services Audit Tips
Food costs charged to Head Start present a risk of
questioned costs.
Ask why costs not charged to USDA
Validate that costs are allowable
Validate that USDA would not reimburse costs
Determine if grantee has been suspended or
debarred from USDA participation
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Cost Allocation
Direct Allocation Method
Many smaller grantees do not have approved
negotiated indirect cost rate.
Shared costs are allocated as direct costs
based on benefit to each program.
Occupancy costs of shared facilities
Personnel working for multiple programs
 Teacher for both Head Start and child care
 Executive Director for multiple program agency
Busses shared with Head Start and public schools
Communication systems and other equipment
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Cost Allocation
Direct Allocation Method
Entity should have a written cost allocation
plan describing the basis and method for
allocating shared costs.
ACF does not review or approve direct cost
allocation plans
Cost allocation plans may be informal, such as
annotated spreadsheets
Method must provide for an equitable
allocation of costs to each program based on
benefit received.
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Cost Allocation Risks
Actual allocation of costs not in accordance with cost
allocation plan.
All costs allocated based on single basis such as level
of funding rather than benefit to program.
Over-allocating costs to Head Start to cover
deficiencies in other funding sources.
Failure to include all shared costs in the cost
allocation plan.
Double charging for same costs by inclusion in a
negotiated indirect cost rate agreement and direct
charging through allocation.
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Cost Allocation Audit Tips
Determine whether cost allocation plan:
 Fairly allocates costs based on relative benefits received
 Uses reasonable allocation bases
 Is consistently applied to all programs
 Allocation methods supported by the accounting system
Indirect costs are charged per negotiated indirect cost
rate agreement both in terms of rate and base.
Test documentation supporting allocations to insure
that they are reasonable, allowable and allocable.
Be alert to identified cost allocation risks.
Listen to an archived “open to the public” GAQC Web
event on Understanding Indirect Cost Rates: A Primer
for Auditors Performing Single Audits.
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Activities Allowed & Cost Principles Risks
Inadequate source documentation.
More common for match and shared costs
Lack of written fiscal procedures.
Engaging in procurement activities without free
and open competition.
Inadequate documentation for shared personnel
compensation expenses.
Payroll records
Daily time records for non-exempt employees
Personnel activity reports
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Activities Allowed & Cost Principles Risks
Journal Entries
Journal entries indicate costs moved from other
programs to Head Start.
Costs entered before or after award period to
shift costs between award periods.
Multiple adjusting entries needed at end of award
period.
Audit tips:
Test supporting documentation for journal entries
Check for approval or purchases and sales of
facilities and equipment
Be alert to unusual journal entry activity,
particularly at year end
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Activities Allowed & Cost Principles Risks
Internal Controls
Basis for allocation of costs is not supported
or source documentation is lacking.
Small programs may not have sufficient staff
to effectively segregate fiscal
responsibilities.
Credit card use and petty cash access may
not be adequately limited.
Bank account reconciliation shows unissued
checks as outstanding.
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Other Activities Allowed Risks
Extensive use of Head Start funds for professional medical
and dental services.
Head Start must be payer of last resort
Dental services often area of highest risk
Compensation to individual employee paid in excess of
Executive Level II ($179,700). Not in 2012 Compliance
Supplement, will be added to 2013 Compliance
Supplement.
 If paid in excess, Head Start may not pay any part of the
compensation (42 U.S.C. 9498, Sec. 653)
 May not allocate pro rata part below $179,700 to Head Start
 May not be included in negotiated indirect cost rate agreement
or allocated direct costs
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Activities Allowed & Property
Real property, facilities, equipment and related assets
purchased in whole or in part with Head Start funds must be
used for program purposes.
Grantees must adequately protect Head Start assets.
Head Start funds more facilities activities than any other
ACF program, including 3,632 current facilities.
Facilities activities allowed under 45 CFR Part 1309 include:
 Purchase (initial or through payment of mortgage principal
and/or interest)
 Construction (applies only to new facilities)
 Major renovation as defined in 45 CFR 1309.3
Use of Head Start funds for facilities activities results in a
Federal interest which must be protected by filing a notice
in the public record or posting for modular units.
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Activities Allowed & Property Risks
Equipment inventory is not updated and reconciled to
source documents as required every two years.
Equipment or facilities are not properly insured for
property damage and liability.
Grantee uses Head Start funds for a facilities activity
without prior ACF approval.
Notice of Federal interest is not filed in the public
record or posted on a modular unit.
Property subject to a Federal interest is pledged as
collateral without ACF approval.
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Activities Allowed & Property Risks
Required ACF rights of notice, cure and substitution are
not included in leases, mortgages or subordination
agreement.
Facilities are sold or transferred without ACF
disposition instructions and compensation of Federal
share.
Rent is charged at full fair market value instead of
depreciation or use allowance under capital (material
equity) leases and related party leases.
Depreciation uses a basis other than acquisition cost or
uses accelerated depreciation rather than straight line
for facilities.
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Activities Allowed & Property Audit Tips
Identify capital expenditures and determine if ACF
consent to purchase was received.
Examine leases to identify any that are capital
leases or involve related parties.
 If so, determine if ACF permission was received for
pledge of property
Review lines of credit to determine if property
purchased in whole or in part with Head Start funds
was pledged as collateral.
 If so, determine if ACF permission was received for
pledge of property
If Head Start funds were used for facilities activities
insure notice of Federal interest was filed or posted.
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Eligibility & Earmarking
Children must be age-eligible for the Head Start program. Not
in 2012 Compliance Supplement, will be added to 2013
Compliance Supplement.
 At least three years old by the date used to determine eligibility for
public school in the community.
 Early Head Start serves pregnant women and families with
children under age 3.
Required percentage of income eligible families.
 90% of children from low income families below the poverty line,
including homeless families and those eligible for public
assistance
 May have up to 10% of children from non-low income families
 Under certain circumstances may have an additional 35% of
children from families up to 130% of the poverty line
 Indian tribal programs have unique eligibility requirements
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Eligibility & Earmarking
Grantee must examine documents for proof of
eligibility, but not required to retain copies.
 Acceptable documents include tax forms, W-2’s, pay stubs,
statements from employers and proof of receipt of public
assistance
Head Start provides a recommended form entitled
Head Start Eligibility Verification (OMB 0907-0374).
The employee who reviews documents and
determines eligibility must provide a signed
statement to be retained in the child’s records:
 Identifying what documents were reviewed
 Stating the child is eligible to participate
Grantees are strongly encouraged to retain copies of
the documentation reviewed.
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Eligibility & Earmarking
Head Start grantee must enroll 100% of funded
enrollment.
 Actual enrollment must be reported monthly, including
reason for any shortfall below funded enrollment
Not less than 10% of enrolled children must be
children with disabilities.
 Funded enrollment less than 10% requires waiver
Risk of failure to enroll sufficient income eligible
children.
Enrollment of children who are not age eligible.
Failure to identify documents relied on to
determine eligibility or sign verification.
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Eligibility and Earmarking Audit Tips
Encourage grantees to follow Head Start guidance
and use forms provided for eligibility verification.
Test regularly at points throughout the program
year (end of months).
Compare various sources of enrollment and
attendance to determine consistency, such as
monthly enrollment reports and CACFP meal
counts.
Highest risks include children enrolled whose
families are not income eligible and failure to meet
overall required percentages for low income
families and children with disabilities.
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Program Income
No Participation Fees
Programs may not collect fees for Head Start
services or participation, including meals.
However, if a parent volunteers to pay all or part
of the child’s costs, it may be accepted
 Recorded as program income
 Must be used for allowable program costs
Program may collect co-payment for non-Head Start
child care services as part of an extended day
(commonly referred to as wrap-around services).
Program income may also be received from rental of
property purchased with Head Start funds.
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Program Income Audit Tips
Determine if the program is collecting any fees from
Head Start parents.
If so, examine fees for allowability (not for Head
Start services)
Then determine whether allowable fees are used
for program costs
Be alert to income from equipment sales such as
vehicles purchased with Federal funds but no longer
needed for program purposes.
Watch for applicable credits mischaracterized as
program income.
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Cash Management & Period of Availability
Red Flags for Year End Float Risk
Risk conditions at year end:
 Head Start has funding not drawn down from HHS
Payment Management System (PMS)
 Other programs have bills without available cash to pay
 Entity is short on cash
Red Flag actions at year end:
 Pull down all available funding from HHS PMS
 Books next year’s expenses in current year
 Journal entries with no support
 Allocating other program costs to Head Start
 Writing checks with no supporting invoices
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Cash Management & Period of Availability
Audit Tips for Year End Float Risk
Understand each program’s cash flow.
 Possible delays in receipt of state child care funds
Be alert to unusual year end transactions.
 Understand business reasons
Test supporting documentation for journal entries.
 Especially charges under agreements for shared services
Review year end direct cost allocations and indirect
cost charges.
 Consider possibility of over-allocating to Head Start
Inquire why year end checks do not clear promptly.
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Cash Management Risks & Audit Tips
Standard cash management requirements apply to
Head Start programs.
Risk results from ability of Head Start programs to
draw down cash from HHS PMS in advance of
expenditures. Availability of cash may lead to:
 Drawing down excess cash not needed for
disbursement
 Loaning Head Start funds to another agency program to
cover delayed receipt of funds
Early drawdown not minimizing time elapsed
between drawdown and payment.
Drawdown based on accrued expenses not
disbursed until later date (or next fiscal period).
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Matching (Non-Federal Share)
The Federal share of the total cost of a Head
Start program may not exceed 80% of the total
budget.
 A written waiver from ACF may be provided if grantee
requests waiver and meets specified criteria
 Waivers apply for one year, but grantee may reapply
for subsequent years
Grantees are required to contribute at least 20%
of the total costs of the program through cash or
in-kind.
Grantee notice of award (NOA) reflects amount
and proposed sources of grantee match.
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Matching (Non-Federal Share) Risks
Economic conditions have reduced cash donations and
historic sources of large in-kind donations, such as
free space.
 Increased risk entity cannot meet required match
 Most matching is in-kind, often multiple small amounts
Property and services claimed as matching not meeting
cost principles.
 Valuation is overstated
 Donated items are not used for program services
 Volunteer services not benefiting the Head Start program
 Cash claimed when donated, not when used
 Inadequate documentation of volunteer services
 Claiming Federal source funds as match
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Matching (Non-Federal Share) Audit Tips
Consider existence of identified risks.
Determine whether documentation supporting
amounts claimed as match indicate:
 Reasonable, allowable, and properly allocated
 Fairly valued, especially volunteer time
 Received or spent in correct grant period
 Actually occurred
 Benefited the Head Start program
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Administrative Cost Earmark
Costs of developing and administering Head Start
may not exceed 15% of total program costs,
including the required non-Federal match.
 A written waiver from ACF may be provided for a
period of time not to exceed twelve months if grantee
requests waiver and meets specified criteria
Administrative costs include:
 Salaries and fringe benefits of executive personnel
 Organization-wide planning costs
 Accounting and auditing
 Purchasing and personnel functions
 Maintenance and operation of administrative space
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Administrative Cost Earmark Risks
Administrative costs may be misclassified as
programs costs.
Dual benefit costs fully allocated to Head Start
program.
 Employees with both administrative and Head Start
responsibilities charged all to Head Start
 Costs of administrative facility maintenance and
utilities charged completely to Head Start
Charging administrative costs through direct
allocation which are already include in the
approved indirect cost rate.
Indirect costs which are categorized as
programs costs should be explained.
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Administrative Cost Earmark Audit Tips
Determine whether accounting system properly
identifies and classifies costs between program
and administrative costs.
Ensure all program costs are identified
including those provided through matching.
Determine cost reasonableness by reviewing
annual budget.
Test costs for proper allocation between
program and administrative cost classifications.
Calculate whether administrative costs exceed
the 15% limit.
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GAQC Resources
GAQC Web site (www.aicpa.org/GAQC)
Governmental Audit Quality Center
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Just Released!
Auditee Resource Center – Open to the Public
• Why quality audit important?
• Auditee resources – some existing resources for auditors and
some new (single audit, Yellow Book, other compliance audits,
and financial statements audits)
o Archived Web events
o Practice aids
o Articles
o Access to GAQC Alerts
• Links to Publications
• Link to Conferences and other training available
• Access the Auditee Resource Center
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GAQC Resources – Tools & Aids
New! Yellow Book Independence Practice
Aid
Single Audit Practice Aids
• SEFA Practice Aids (both for the auditor and auditee)
• Internal Control Practice Aids
• Illustrative Auditor’s Reports
Peer Review Checklists
Archived GAQC Alerts and GAQC Web
events
AICPA Audit Guide, Government Auditing
Standards and Circular A-133 Audits
Governmental Audit Quality Center
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GAQC Resources – Web Events
Challenges with Fair Value Measurements for NPOs*
Understanding Indirect Cost Rates: A Primer for Auditors
Performing Single Audits*
New 2011 Yellow Book*
Understanding the New AICPA Yellow Book Independence
Practice Aid*
Updated Schedule of Expenditures of Federal Awards (SEFA)
Practice Aids (for SAS 119)
Subrecipient Monitoring: An Auditee and Auditor Perspective*
2012 Compliance Supplement and Related Best Practices
Fun and Games with Not-for-Profit Functional Expenses
Preparing for Your Single Audit: An Auditee Perspective *
Single Audit Fundamentals On-Demand Series
* Open to the Public
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Questions ?????
Governmental Audit Quality Center
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Closing Remarks
Auditors play a vital role in assuring that Head Start
agencies manage grant funds effectively to support
excellence in services to children and families.
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