Incident Reporting Requirements in the Head Start Program Performance Standards

Incident Reporting Requirements in the Head Start Program Performance Standards

Glenna Davis: Hello and welcome everyone to the Incident Reporting Requirements in the Head Start Program Performance Standards webcast. It is now my pleasure to turn the floor over to Captain Tala Hooban, who is the acting director for the Office of Head Start. Captain Hooban, the floor is yours. 

Capt. Tala Hooban: Thank you so much, Glenna, and I'm loving seeing the numbers tick up for the number of participants. It just goes to show how important this is for our Head Start family. Hello, Head Start. Good afternoon. Good morning. I'd like to start by welcoming you all to the webinar today. Today we are talking about incident reporting, and I am incredibly happy to be here today, to kick us off. But you have a great team that's going to run through the content with you.

As Glenna mentioned, my name is Tala Hooban. I'm the acting director for the Office of Head Start, and I am joined today by Jessica Bialecki, the director for the Policy and Planning Division. Cynthia Romero, a program specialist in the, in the Division of Oversight in the Office of Head Start. Thank you again for joining us today.

I know people are just ticking in. The important topic is child safety. We all, really, really believe in this, obviously in the Office of Head Start as well as our programs. Creating a culture of safety is fundamental to making sure that we have high quality services in our programs. Promoting health and safety and preventing significant incidents in Head Start programs is everyone's responsibility and obviously you share that with us.

It's clear that we all share this goal and we want to make sure we support our teachers and staff to make sure we, we keep our children safe in our programs. As you'll hear from Jess next, the focus is on reporting and the ins and outs of what to report when it's important to report an incident and how reporting is one piece of creating the culture of safety and it is very nuanced.

So really appreciate you guys being on today. We hope that we can clear up some questions today through today's webinar. As always, if there are a lot of questions, we will follow up with more information in our website. I will turn it over to Jess Bialecki, our director of Policy and planning.

Jessica Bialecki: Thanks so much Tala, and I'm so excited to be with all of you today. My name, like Tala said, is Jess Bialecki. I'm the director of the policy and planning division with the Office of Head Start. There's nothing I love more than starting my week off with 2000 plus Head Start grant recipients, staff leaders, it is the best way to start a week.

So excited to be here. I’m particularly excited to be with you today to talk about the, about incident reporting, and to share more details specifically about the information memorandum, the IM that was published back in November. We're going back to November 7th, 2024. The focus of this webinar will be the standards on incident recording.

I do want to note that we're not going to get into the details on updates to monitoring protocols or the RAN process specifically. But we recognize that it really is impossible to fully separate the standards, and the policy related to child health and safety from monitoring. Right. I was the program administrator.

We know that we all want to know how are we going to be looked at and held to, those standards. We have, my wonderful colleague here from the Office of Head Start Oversight Division, Cynthia Romero. We'll be, going back and forth throughout this webinar in discussion. We understand how important it is for the policy goals and the intent that we discuss here to be carried through to how programs are monitored and held accountable.

We are working hand in hand, with our monitoring team and, and we look forward to, to being, in discussion today. One other word on what we'll be covering and what we won't be covering today. The incident reporting requirements, as you probably know, do include a broader set of reportable incidents then we'll discuss today.

The focus of today's webinar and the IM that we published in November 2024 is specifically the reporting of child health and safety incidents. We know that the standards also require programs to report, for example, legal proceedings by any party that are directly related to program operations. We require reporting if an agency has filed for bankruptcy or agreed to a reorganization plan as part of a bankruptcy settlement.

There's other things that we do require reporting around, but our focus today in this webinar, as it was in the IM that you see up on the screen, is really focused on the reporting of child health and safety incidents. Our plan for this webinar, is to really break down the IM section by section.

Take what we know sometimes can feel like, really policy, sort of technical language into real world examples. What you need to know in the day to day in your programs. We'll also provide answers to a number of questions that we've received since we released this IM in November. We want to highlight resources that we provided in the appendix of the, IM just to make sure that you're all aware of these tools, which we think can be really helpful in supporting you and determining whether or not to report an incident.

Before we go into the specifics of the I’m, I do want to step back briefly and speak to two areas we think provide some helpful context for the IM the first area is really clarifying the types and purposes of reporting. We think this context is important in understanding parts of the, IM. Then the second is the big picture on why, why does this all matter in the first place?

While we think that this, IM provides clarity on what's reportable, I also want to say we know nothing in this space is sort of black and white, and it would really be misleading for us to try to make it seem that way. We are not going to be able, in the context of this webinar to answer every scenario that's going to come up in, in our programs.

I know, again, as a, as a former early childhood teacher and administrator, one of the, the best and the hardest things about working in this field is that it's full of surprises and you never know what each day is going to bring. But what we do want to do is provide a firm grounding in the why and in the spirit of the policy, the intent of the policy, so that you can use that when you're navigating the nuances that inevitably will surface. Cynthia, I'll turn it over to you. 

Cynthia Romero: Thank you, Jess. Let's talk about types and purposes of reporting. First, we have mandated report reporting as professionals in the early childhood space. Everyone is likely familiar with mandated reporting. Mandated reporting is the term for reports required by federal, state, local, and tribal laws designed to alert the appropriate child protection authority and or other required authority of known or suspected child abuse and neglect.

To be clear, a mandated report is a report to the appropriate child protection authority. The process requirements and details of this system exist entirely outside of OHS, ACF, HHS, and instead are at the state, tribal, or local level. The purpose of these reports is to ensure that all children are safe and protected, and to ensure that child protection authorities can do their jobs.

Mandated reporting laws require that certain professionals like you report child abuse and neglect concerns. Those, some states require that all people report. Many states identify specifically which professionals are mandated reporters. Such as teachers, childcare providers, social workers. These are the professionals who work in Head Start programs and are usually on that list of specific professionals.

Now, it's important to be clear here that some things that require a mandated report will also require an incident report to OHS, but it's also important to understand that not all mandated reports necessarily need to be reported to OHS. We're going to talk about that, a little bit later in the webinar.

The second type of reporting is incident reporting. Incident reporting is the term we use for incidents that need to be reported to OHS. Now, the list of incidents that the standards required to be reported to OHS goes beyond those related to child health and safety, but we're going to focus on child health and safety portions for this training, the process requirements and details of the incident reporting exist entirely within OHS.

We have created our own process. Not all incidents that need to be reported to OHS will rise to the level of a mandated report. We'll talk about more about why that is and the purpose of reporting incidents to OHS more broadly. Next slide.

A lot of people have questions about how licensing interfaces with this reporting system, so we're going to talk about that. Each state and territory has a system to receive and respond to reports of possible childcare, health and safety violations. Each state and territory may have different requirements for what they want reported. We understand that's common reaction for Head Start programs to conclude that they must report everything that they report to state licensing and or other required authorities to OHS as well.

But we want to take a moment to make clear that not all licensing reports and or reports to other required entities need to be reported to OHS. We can return to this point later in the webinar when we work through some specific examples. We're going to have lots of examples to talk about later today. Next slide, handing it over to Jess. 

Jessica: Thanks, Cynthia. Yeah, I'm really happy we started with that grounding. Now like I said, I want to talk just a little bit about the why? This is something that, again, like I said, I feel really passionate about, as a, as a former teacher and, and administrator and as the mom of, two, almost 4-year-old twins.

In a perfect world, I think, you know, we want to always identify situations that are at risk for getting worse and provide people with support so that nothing ever that is awful happens. We think about that as a sort of preventative continuum. I want to describe the ideal way that this system would work and the purpose behind it.

Again, understanding that there's so much gray, in, in our work. First we have a type of incident where something happens and maybe it's not best practice, so maybe it's, you know, a raising of a voice. But it's more of a coachable moment or an example of a best practice not being followed. In these cases, you know, programs can probably self-correct.

We could give teacher, a teacher some coaching, and do some professional development. but it's the kind of thing that if it continued or it escalated, the program would probably need some additional outside support. Generally, you know, the Office of Head Start doesn't regard these types of situations as ones that should be reported to the Office of Head Start.

Though I'll say of course, context always matters and there may be situations where something like that is, is reportable or should be reported. In this way of thinking, kind of what's next in the continuum is that a program may need additional support. Maybe the coaching wasn't successful and that the behavior that isn't best practice is starting to become a pattern.

Or maybe it's something that feels a little more severe. That's where there's definitely more gray area. Whether this requires a report to the Office of Head Start is context dependent. But it's when programs may need support to address the situation so that it stops and it doesn't escalate.

Then later on, and again, I know this is a bit of an oversimplification, but we do want to think about this as a continuum. So later on in the continuum is the point at which OHS needs to get involved in a different or more urgent or more targeted way. In this case, maybe the behavior continued even after the program was given support, or maybe the incident was so severe that sort of significant urgent action is needed.

In large part, these are the incidents that we expect to be reported to the Office of Head Start. As these behaviors, you know, become more frequent or more severe, the Office of Head Start has a different role in addressing the situation. Whether it's, you know, continuing to keep an eye on things, offering support or stepping into take an action.

That's really the reason for the reporting process. The why of it all. We think it's really important in any conversations that we have around child health and safety requirements, that we ground people in the why. Again, want to be a, want to be clear this isn't a rubric. As much as I think we all in some ways would like, one, I love a good rubric, we don't think we really can have an all-inclusive, comprehensive rubric around this.

You know, this is a framing of how to think about the purpose of reporting the intent. When the prevention work rests with Head Start programs and when it rises to the level of reporting to, you know, the Federal Office of Head Start, I want to say we also recognize that this represents a shift and may not align with how many of you have experienced Head Start's reporting requirements in the past.

We've been asked if this shift in policy towards incident reporting is intended to reduce the number of incident reports that come to the Office of Head Start. We've been asked like, are you trying to get fewer reports? I want to be clear, the goal is to focus incident reporting on the more serious incidents so that Head Start resources at both the federal and the program level are being used to protect child safety and to reduce administrative burden.

It's really about the continuum. I was talking about these incidents or interactions that programs can manage at the program level. Then those down the continuum that rise to the level of involving the office of Head Start. Because we do know there is a risk to over-reporting. There's an unintended consequence we think of potentially jeopardizing child safety if both federal staff and programs are focused on kind of every incident at every part of that continuum and reporting it, instead of really focusing on elevating and escalating the most serious incidents that actually involve child endangerment, abuse, or neglect. With that, I'm going to turn it back to, to Cynthia. 

Cynthia: Thanks, Jess. We're going to talk about the IM right now. Now that we talked about the types and purposes of reporting and the bigger picture of why it all matters, let's talk about the IM you can, um. Get the link from the chat. I believe that Glenna has added it there, and feel free to use it as a reference in front of you.

The largest section of the IM is a section that focuses on reportable incidents that affect the health and safety of children. The incident reporting requirements describe the where, the who, the what, and when for reporting incidents to OHS. Next slide. There. I'm seeing the link in the chat right now.

Let's first talk about the who and the where of incident reporting and these criteria apply specifically to child health and safety. The standards require that the program submit an incident report related to any significant incidents that affect the health and safety of a child that occur in a setting where Head Start services are provided, and a child that receives services fully or partially funded by Head Start Grant, or a child that participates in a classroom at least partially funded by a Head Start grant, or involves a staff member, contractor, or a volunteer who participates in a Head Start program or classroom at least partially funded by Head Start.

These criteria apply to all children regardless of whether the child involved receives Head Start services, or the child participates in a classroom that is at least partially funded by Head Start.

Let's break this down piece by piece. The first factor you want to consider is where the incident occurred, if the incident occurred. In a setting where Head Start services are provided, it may be reportable. This is intended to capture any setting for which Head Start funding is used. For example, it could include the Head Start learning, setting, the playground, any transportation that's used by Head Start program or on a program approved excursion.

The next thing you want to consider is the who, who was involved in the incident. Let's start with the adult involved in that incident. If it was a staff member, contractor or a volunteer who participates in a program or classroom that is at least partially funded by Head Start, then this factor may also make the incident reportable.

In these cases, it may be important for Office of Head Start to receive an incident report because these incidents can have broader implications for other children served in the program, including those funded by Head Start dollars. Let's consider for a second if a staff member uses physically abusive behavior with a child who is not receiving Head Start Services.

If we know that the staff involved in the incident also has opportunities to interact with other children who are receiving Head Start Services, there's an open risk there. Especially if there are not robust policies, procedures, and systems in place to protect children. It's still important for Office of Head Start to know about these incidents involving staff who fall into this category.

However, let's say the staff member, contractor, or volunteer did not meet those criteria programs still need to consider the circumstances of the child involved in the incident. If the child involved in the incident receives services funded by Head Start or participates in a classroom funded by Head Start, including partial funding, the incident may be reportable.

Now, some incidents involve both of those two. Such as a child that participates in a Head Start funded classroom, and staff that participates in a Head Start funded classroom. That would also be reportable if it meets these other criteria as well. Another question we have received is whether an incident should be reported if it occurs during wraparound service hours, like before or after care.

The answer is that it depends. It still has to meet both conditions of a setting where Head Start services are provided, and either a child who receives Head Start services or an adult paid in part or in full with Head Start funds. If we assume the wraparound care is in a setting where Head Start services are provided, we still need to think about the who.

If it's not a child funded at all with Head Start dollars, nor an adult funded at all with Head Start dollars, the answer would be no. But if the child is funded with Head Start dollars or an adult is paid with Head Start dollars, then the answer is yes. It could be that both are supported with Head Start dollars, but it only needs to be one. I want to highlight again as the table in the IM shows and as the graphic in the appendix to this IM also shows a reportable incident. Must meet where condition in the left column and at least one of the who conditions in the right column. Passing it off to Jess. 

Jessica: Thanks Cynthia. We can go to the next slide and I'm going to start, just take a minute to walk through the examples that are included in the, IM. As we talk a little bit more about where and the who. Incident example one. We have an incident that occurs on an elementary school playground that is used by a Head Start classroom on site. The incident involved a third-grade teacher using inappropriate discipline with a third-grade student resulting in the student's hospitalization.

The third-grade teacher involved is not a Head Start volunteer and does not participate in the classroom in any way, nor is the teacher's position funded by Head Start Resources. This one does not require an incident report to OHS. The incident would be significant as it required the student to be hospitalized.

It did meet the conditions of the where column as it did occur in a setting where Head Start services are provided at Playground that is used by the Head Start program. Most importantly here, it did not meet the conditions of the WHO column as neither the child nor the teacher involved, participated in a program or classroom, at least partially funded by a Head Start grant.

That one, that one probably feels a little more clear cut. Let's go to incident example two. This incident occurs in a mixed funded classroom where Head Start services are provided. The incident involved the assistant teacher using inappropriate discipline with a student in the classroom, again, resulting in the student's hospitalization.

The individual student involved is not funded by a Head Start grant. Now, the determination on this one is that it would require an incident report to the Office of Head Start. This incident is considered significant again as it required the student to be hospitalized. We're going to talk, I think in, next we'll talk a little more about this idea of significant and medical attention.

The incident here also met the conditions of the wear column. It occurred in a setting where Head Start services are provided a mixed funded Head Start classroom. While the individual child is not funded by a Head Start grant, they do participate in a classroom at least partially funded by a Head Start grant.

And because the child participates in a classroom supported by Head Start resources, that is sufficient to meet the conditions of the WHO column and thus would require an incident report to the Office of Head Start, regardless of the funding source that provides the salary for the adult involved.

Furthermore, in this case, the condition of the WHO column is also met by the adult. Because we did say that the assistant teacher is a staff member that participates in a classroom at least partially funding by a Head Start grant. Two examples there. Tala back to you. 

Capt. Hooban: I'm just checking in on you guys.

There's been a lot of content thrown at you, so if you don't mind, we're going to do a pulse check, just a quick knowledge check. It’s anonymous, so be as transparent as possible please. How confident are you feeling in your understanding of where and the who of incident reporting to the Office of Head Start?

As you could see, we were trying to be, fun with our responses. Just so folks know, I think most of you are feeling in the middle. I think I'm following mostly. Then there's a lot of, got it. I'm the expert now, so I'm really excited about that because this is always fun for me. I think we can go ahead and close out the, the poll Glenna, I. Again, when once the more you we get feedback on this, the more we'll be able to develop content for you guys, that’ll help support you. Back to you, Cynthia. 

Cynthia: Thanks, Tala. I'm loving all the thumbs up and the hearts. This shows that you guys are really involved in taking the importance of this health and safety, so seriously, really appreciate it.

Now we're going to talk about the what. Let's do a quick overview. This part of the IM and this slide captures the minimum expectations for reporting incidents that affect the health and safety of a child. There's a lot of content on this slide, I know, but you can refer to it in the standards themselves.

This slide lists the incidents. I'm not going to walk through them in detail here because we're going to go through each type of incident noted in the IM, one by one and spend more time with what it means for those things to be significant. Next slide. OK. Let's dive in. Let's start with any mandated reports regarding agency, staff, or volunteer compliance with federal, state, tribal, or local laws addressing child abuse and neglect, or laws governing sex offenders.

Any mandated reports. OHS requires an incident report. If a program becomes aware that an agency, staff or volunteer is reported to Child Protective Services or to law enforcement agencies for suspected child abuse and neglect of any child in their care, regardless of whether the child is currently enrolled in a Head Start program.

For example, I know this is new for you all, so I'm just going to take my time with this. For example, if a Head Start staff member is arrested on a child neglect charge that was reported to Child Protection authorities, regardless of the location, OHS still requires an incident report. This information is important for OHS to know even if the child neglect occurred outside the program.

This is a reportable incident that is the exception to the where and who framework that we just discussed. As we noted previously, there are some mandated reports that do not, I'm sorry, that do require an incident report to OHS and others that do not. In this case, it does need to be reported to OHS because it's a mandated report regarding agency staff or volunteers.

I want to pause here to note that a report to OHS does not equal a finding. We know that incident reporting has, over time been understood by some people to be the same thing as a finding. Like a report is made and a finding is issued, but we want to be clear that this is not the case. Mandated reporting of confirmed or suspected child abuse and neglect in other cases such as a parent or a caregiver that is not funded by the Head Start grant occurs in a child's home, does not need to be reported to OHS.

For example, if there's a suspected child abuse or neglect in the home of a child enrolled in a Head Start center-based program, staff do not need to report that to OHS through the incident reporting process. Now, as mandated reporters, state, tribal, or local laws would likely require staff to report this concern to the appropriate child protection authority, but this is a process outside of O-H-S-A-C-F and HHS.

Suspected or known maltreatment or endangerment of a child by staff, consultants, contractors, or volunteers. This is the second category. This is a reference to the standards of conduct in section 1302.90 of the Performance Standards. In that section of the standards 1302.90 C, we outline what behaviors we consider to be inappropriate when interacting with and caring for children.

These behaviors are considered incidents that must be reported to OHS. Those four main categories are outlined here, and they align with the definitions of child maltreatment and endangerment that have been adopted by the Centers for Disease Control and Prevention. The CDC. These were established through extensive consultation with experts to recommend consistent terminology related to potential child maltreatment.

The four categories include corporal punishment or physically abusive behavior, sexually abusive behavior, emotionally harmful or emotionally abusive behavior and neglectful behavior onto Jess.

Jessica: Thanks Cynthia. Let’s keep going on what. Here we're going to switch gears a bit, to talk about serious harm or injury of a child resulting from a lack of preventative maintenance of a Head start facility. That could be a classroom bathroom on a playground, a bus, or other approved transportation.

Now let's look more closely, and I've seen this come up a bit in the Q&A already about what we mean by that and the kinds of situations that rise to the level of significant, so serious harm or injury. By that we mean things that require immediate professional medical attention, including either hospitalization or emergency room.

Medical treatment could include things such as a broken bone, a severe sprain, chipped or cracked teeth, head trauma, deep cuts, contusions or lacerations or animal bites. A bit later in the webinar we'll look at some examples and we'll try to apply that definition to some specific situations. Again, we know that we can't possibly be exhausted.

I want to highlight that this is examples. But we do want to give you, those examples to anchor what we mean by serious harm or injury. OK? Let's keep going. Next slide. Serious harm injury or endangerment. Notice that we have serious harm or injury as we did in the last slide, but we've added the word endangerment of a child resulting from lack of supervision while in the care or under the supervision of program staff.

OK, so let's break that down. What do we mean by serious harm injury or endangerment resulting from a lack of supervision? Lack of supervision includes leaving a child alone anywhere on the grounds of a head start facility. That could be a classroom bathroom playground. As well as outside the facility in a parking lot on a nearby street or on a bus or other program approved transportation or excursion.

We're talking about a walk to a nearby, park, if that is a program approved excursion. As noted above, serious harm or injury requires immediate medical attention. Now, this requirement represents a change from the prior policy of reporting, all instances when a child has been unsupervised for any length of time.

The requirement now is that programs report any incident in which there has been that serious harm or injury or endangerment resulting from lack of supervision. Now know everybody's sort of next question is what do we mean when we say endangerment? Endangerment involves conduct that puts children at reasonable risk of harm.

Can include supervisory neglect. Examples include, but aren't limited to, leaving children in situations where they have access to dangerous chemicals or toxins, choking hazards or life-threatening substances. Unsupervised or unrestricted exposure to vehicular traffic, extreme temperatures, risk of drowning or risk of leaving the facility alone, leaving children alone with access to unknown or unauthorized adults leaving a child unsupervised, such that their basic needs cannot be met, or knowingly failing to protect a child from maltreatment, perpetrated by another caregiver in the program now as programs, and we recognize that you as programs will need to make these determinations about whether a lack of supervision result in endangerment.

You should examine each situation on a case-by-case basis and consider factors such as one the child's age and developmental needs. Two, the length of time the child was left unsupervised and or the inherent dangers of the child's unsupervised environment. My, you know, things like increased dangers that are present in a vehicle, or unrestricted access to water play equipment, a playground that's situated near a busy road or a highway, a lobby that's near the entrance to a building.

Building these considerations matter because a child could experience a situation differently based on these factors. Is a child an infant and unable to ask for help or move, you know, independently, or, you know, is a child a 4-year-old? Sleeping in a room where there are no dangers present. Was a child left for one minute or 30 minutes.

Really want to emphasize here that the context matters when we're talking about endangerment. This policy requires programs to conduct a thorough assessment of risk based on the potential harm to children and programs should be able to demonstrate how you went through that assessment process and made that determination considering all relevant factors, including those that we described above.

I want to point out here, there's a really great resource that cited in the IM from the American Academy of Pediatrics, really sort of talks to directly this endangerment definition and that we think can help programs with these determinations. Cynthia, back to you. 

Cynthia: Thank you. Let's continue discussing what, the significant incidents that affect the health and safety of a child. We're going to talk about unauthorized release of a child. Here it's any incident in which a child was released from a head start facility or a bus or other authorized, sorry, approved program, transportation to a person without the permission or authorization of a parent or legal guardian or whose identify, identity has not been verified.

A few summary comments below. Um. Now that we have talked through this list of reportable incidents, first, the standards indicate that reportable incidents, including the four additional types, are at a minimum. There could certainly be other reportable incidents that are not necessarily related to preventative maintenance and supervision.

As with many of our standards, the list of reportable incidents under 13020.102D is not an exhaustive list. Second, it's our intent that taken together this list of reportable incidents is intended to hit the right balance between reporting important things but not comparatively minor things, and to be clear about what constitutes significant.

Soon, we'll walk through some more examples. Together to gain experience applying the OHS resources to specific scenarios. But if you encounter, encounter a particularly complex situation and you're unsure if an incident would be considered significant after applying the process, we discuss, communication with the Office of Head Start can be helpful.

Lastly, as we mentioned at the outset, we know there will always be gray in this area. We know everyone wants hard and fast answers on whether specific incidents are reportable, whether know there's a lot of discussion about how much reporting is too much and what might fall through gaps if we require fewer reports.

This IM, and this webinar doesn't fix all of that. It doesn't erase the gray. But we hope that this guidance will allow us to move toward more clarity. Before we look more closely at specific scenarios of incidents, let's turn to the section of the IM about the incident reporting timeline. Next slide. I'm going to pass this to Jess to go over it with you. 

Jessica: Thanks Cynthia. Now that we've covered the where, the who and the what of incident reporting, let's shift to the when. To be clear from the outset, the timeline for reporting applies to any incident report, even though we're focusing in this training on reporting significant incidents affecting health and safety of children.

OHS requires programs to submit an incident report immediately, but no later than seven days following the incident. I do want to emphasize immediately here. That is the ideal scenario that OHS is. Notified that an incident occurred immediately following the incident, an incident that meets the criteria that we've been talking about right now.

We also understand that there are situations in which a program needs some flexibility with the time for recording, such as when there are immediate safety concerns that really need to be taken care of or resolved first, or when a program is focused on immediate needs to comply with law enforcement or other authorities.

That's why the updated standards specify that the report must be submitted no later than seven calendar days following the incident. Programs do have some additional time if they need it. The required reporting timeframe begins when a program, and importantly, that includes any program, staff, contractor, or volunteer, including those at a delegate agency of a Head Start, grant recipient.

Learns that an incident occurred or learns that an allegation that an incident occurred that meet the criteria we've discussed. To ensure consistency, because we've heard some, you know, different interpretations of this in the past, to ensure consistency and operationalizing this requirement, OHS recognized the day a program, so that's an agency or delegate agency of a grant recipient, learns of an incident as day zero.

If a program reports an incident to OHS on or after day eight, the program will not be in compliance with this requirement. The requirement provides an upper limit of seven calendar dates. So, for example, as you see on this slide, and this is also in the appendix to the, IM on Tuesday, you know, the 12th.

In this example, a child falls from a playground because a rusty railing fails. The child was taken to the hospital to treat a concussion Tuesday. We've got preventative maintenance, serious harm or injury due to preventative maintenance. Tuesday the 12th is day zero. The program should report the incident to OHS immediately, but no later than the following Tuesday the 19th.

On Wednesday the 20th. That report would be overdue. Now I want to pause here because you know, a common question. We, this is a common question we received. We've been asked how immediately, and no later than seven calendar days following the incident is the same as no later than seven days after the grant recipient learns that the incident occurred.

What we want to say is that in the vast majority of instances, we assume that someone in the program is learning about the incident on the day that it happened. The day that it occurred. Since when we say someone at the program, we mean all program staff, contractors or volunteers, including at a delegate agency.

There's also a standard related to training as well as management systems, which is in 1302.101, where programs are required to implement a management system that ensures all staff are trained to implement OHS incident reporting procedures. In other words, programs must make sure all staff know how to report incidents if they occur, which would give all staff the information and tools they need to report incidents as soon as they learn about them.

Now we've been asked about an incident that occurs at a delegate agency, for example, and, you know, a concern that it can take longer for that delegate agency to reform that recipient. For the recipient then to inform OHS. In this case, the timeline is based on when the staff member, contractor, or volunteer in the delegate agency learned the incident occurred.

They, that they would still need to make sure they, you know, quickly report that to their grant recipient. The grant recipient is reporting it within the seven-day timeline. We think there are few, if any, examples where the date when the program learned the incident happened would be different than the date the incident occurred, based on this guidance.

You know, it's possible that, that, you know, that could happen. But if there is a difference, the clock would begin when the program learned of the incident. Anybody at the program staff, contractor or volunteer? Do want to note that to ensure programs are reporting significant incidents regarding the health and safety of children to their assigned, program specialist or to their, regional leadership official.

We'll talk a little bit about the centralized reporting, system that we have, moving forward. OHS will review publicly available information and reports from the grant period. When you have a, a monitoring review, we would review publicly available information and reports, and failure to report a significant incident for which a report was required based on our criteria we've talked about here, within that required timeframe would subject the program to a monitoring finding. All right, Cynthia, back to you. 

Cynthia: Thanks, Jess. We know that recipients have heard about this timeline, and so we have received some feedback and we're just going to go over some of that with you right now. For example, we've heard concerns about the timeline because a program may not know all the details of what happened, or they feel like they need to investigate the incident.

This is really the focus of one of the final sections in the IM information required in incident reports, we want to emphasize that submitting your initial incident report doesn't stop you from updating it at a later time with additional information. In fact, we encourage programs to communicate with Office of Head Start, and that includes informing Office of Head Start about what they know at the time, and also updating OHS on what information is pending and why and when you expect to know more.

It is also really important for programs to understand that, especially for incidents involving potential abuse or neglect of a child or legal issues, programs should consult with the appropriate federal, state, local, or tribal requirements about what is appropriate for a program to investigate programs.

May need to exercise extra caution in those cases and ensure that they're not interfering with other systems processes. That said, OHS notes that state, local and tribal reporting requirements to child welfare agencies are not a substitute for reporting to OHS and programs should not wait to learn the outcome of reports to those state, local, and tribal entities.

Before reporting to OHS. Generally, these entities are investigating whether a violation of state or local law occurred, whereas OHS'S responsibility is to provide oversight with regard to the Head Start Program Performance Standards. However, programs are encouraged to indicate that an investigation or adjudication is underway when they submit an incident report to OHS ready for a pulse check. 

Capt. Hooban: Let's do it, Cynthia. Thank you. I'm back. If you were asked to explain to a friend what types of incidents to report to OHS, how confident do you think you'd feel? One is I'd nail it, I'd stumble a little bit, or I'd need a lifeline and it's looking real tight, real tight between, I'd nail it, and I'd stumble a little bit, so that's amazing.

Lena, let me give it one more second. I'm just seeing the nominator go up. Thank you, guys. Look at the emotions. I see a lot from the chat of people joining in between their classroom breaks. Thank you for joining. This will be recorded and posted online, so if you missed anything, it'll, it'll be on HeadStart.gov once we, fix the transcription. Thank you for joining in such a busy day. I think we can close it out. Glenna, I'm back to you, Cynthia. 

Cynthia: Thanks Tala again, I'm loving all the hearts and thumbs up. Everybody is so engaged. Let's do some more examples. I’ve seen some questions come through about specific scenarios, so let's go through a few more.

Scenario one, a child has a small bump from a bug bite while their head, while their Head Start classroom was out on the playground. First, let's think about where it occurred. It occurred on a playground where Head Start services are provided, so we would continue to the next step. Next, we think about who is involved in this case, the scenario involved, a child participating in a classroom funded by Head Start.

There is no adult identified, but the who Criterion is either or. We would continue to the next step. Next is the question about whether it's significant is what occurred significant, and we can look at examples here. There's no report to Child Protective Services that involved a staff or volunteer.

No suspected or known violation of standards of conduct and no unauthorized release. Those all seem pretty clear. What the program would want to look further into in this scenario might be whether there was serious harm or injury. In this scenario, there was not. Then the program would also want to check whether there was concern about the child being in danger due to lack of supervision, which again, doesn't fit this scenario.

After running through this sequenced assessment, I would say that this scenario does not require an incident report to OHS, but you may work with T&TA as needed to get additional support in these areas. For example, are there internal policies or procedures that would be good to examine? For example, the program may want to look at health and safety data to determine whether this happens often when children are out on the playground.

If so, maybe there are some actions the program can take to prevent this from happening more. Or perhaps the program can look at data and realize that this child, specific child tends to get bug bites quite often, and it really bothers the child in class. Perhaps the program can think about engaging with the family to see if there is something they can do to help support this child more, or this could really be a minimal issue and there is no further action needed from the program. Jess take us through scenario two. 

Jessica: Yeah, I'll take it. Scenario two. A teacher assistant brought six children to the restroom and returned to the classroom with five children. Later, when sitting down for another activity, the teacher assistant noticed the child was unaccounted for and found the child in the bathroom.

The child was believed to be in the restroom for 30 minutes. Let's think first about the, where right this occurred in a location where Head Start services are provided. Then let's consider the who in this scenario. The teacher assistant is a staff member of the Head Start program. This criterion is either or, but in this case, the child also receives services fully or partially funded by a Head Start grant.

After the where and the who, we think about whether what happened is significant. When there is a lack of supervision. The focus is whether there was serious harm injury or endangerment like we discussed in the prior scenario. If there's no serious harm or injury and it, you know, doesn't, we're not hearing about any serious harm or injury sort of medically.

Here we think about endangerment. We consider those factors that we noted in the prior scenario. Let's say in this case, you know, we have a three-year-old in a restroom, we may consider whether they have access to an unknown or unauthorized adult. Maybe they're in a program in a school district where there’s, you know, other, other adults, in the building who you know, might not be known or authorized, or what is in their immediate surroundings.

We also consider the length of time here. We're talking about 30 minutes. We would consider this likely, I consider this to be a reportable incident given the length of time the child was alone. Also perhaps, again, depends on the building, but who may have had access to that restroom while the child was there for that extended duration of time. Alright, Cynthia, back to you for number three. 

Cynthia: OK folks, how are you doing? Show me with your emojis. I'd love to see those thumbs up. Let's go through another scenario where we've heard from the field, what if a center-based Head Start performance, preschool program becomes aware that there was a suspicion of child maltreatment or endangerment of a child by their parent or another adult in the child's home.

Let's start with the where in this case, we already know that the scenario did not occur in a setting where Head Start services are provided it occurred in the child's home, so this would not require a report to OHS. However, a program may need to refer to their state, local, and tribal laws about mandated reporting of child abuse and neglect to a child protective agency or law enforcement if whatever occurred meets definitions under the Child Abuse Prevention and Treatment Act, or CAPTA.

Again, your program may also want to consider whether there are internal policies and procedures that are relevant here, such as perhaps increasing opportunities for family engagement and support services. I also want to note that we do sometimes have programs reach out to the regional offices when something really serious occurs in the home because they want some T&TA support and that is completely OK to do. Just because something doesn't require a formal report, it shouldn't stop programs from reaching out for supports when they need them.

Jessica: Thanks Cynthia. I'm going to jump in because we've gotten a few questions in the Q&A, about home-based EHS programs and I actually think it could be, as I'm thinking about the scenario you just named, I could imagine someone saying like, “What if it’s, a home where someone is providing home-based early Head Start services?”

Cynthia: Absolutely. 

Jessica: The question we got was like, if in a home-based early Head Start program, the home would be considered a setting where Head Start services are provided. I want to affirm yes. Head Start services can be provided, through, a home-based setting. There are, instances right, in which, a child's home might be a setting in which Head Start services are provided.

I think for, you know, for example, for this question, you'd want to look at the timing of when, the, the suspicion of maltreatment or endangerment happened in the child's home, and whether that was a time during which Head Start services were being provided, if it's an EHS home-based program. While I think generally, it would not require a report to OHS if, it just happened in the child's home, if it were an EHS home-based program, and those services were provided at the time being provided at the time of the maltreatment or endangerment.

Then, that, that would fall under the were. Little bit of a tangent there, but since it seemed related to questions that we were getting, I wanted to, to jump in. Let's move to scenario four. I think we've got five total, so, we’re doing all right on timing. Scenario four, a program is informed that a kindergarten teacher spanked a kindergarten age child on a playground where Head Start services are provided.

This, you know, feels a little bit like the, the third-grade example, that we talked about earlier, talked earlier. Let's talk about the where, yes, it occurred on a playground where Head Start services are provided. Let's talk about the who. The child does not participate in a classroom funded by Head Start, at least in part.

But the program would still need to know whether the kindergarten teacher participates in any Head Start funded services. If not, so if the kindergarten teacher does not participate in any Head Start funded services, then no incident report to the Office of Head Start would be required. We would not be meeting the who.

 Again, the program could consider whether other state, local, or tribal reporting requirements in definition apply, such as those under CAPTA. Or perhaps if they have a relationship with the school district, they may want to bring it to their attention in case it violates their policies. Now, if the program found out that yes, that teacher who spanked the kindergarten age child also participates in Head Start services, then we would continue on to with the what and whether it was a significant incident that affected a child's health or safety.

 

In this case, banking clearly falls under what OHS requires programs to report based on the standards of conduct because it is a form of corporal punishment. But again, whether the program reports it to the office of Head Start, depends on whether that kindergarten teacher participates in Head Start services in some way. Alright, back to you Cynthia.

Cynthia: Thanks Jess. OK, here we have another scenario, and this is a child getting hurt on a playground and I did see a few questions come in, so hopefully this answers it for you. This child tripped over his shoelaces on the playground and his knees got scraped. Let's start with the where in this case, the scenario occurred in the setting where Head Start services are provided.

It occurred on the program's playground outside. Next, we think about the who that was involved in this case. This scenario involved a child participating in a classroom funded by Head Start. There is no adult identified, but the who criterion is either or again. We would continue to the next step.

Next is what occurred significant, and we can look at examples here. There was no report to Child Protective Services that involved a staff or volunteer, no suspected or known violation of standards of conduct and no unauthorized release. The question now becomes was their serious harm or injury?

While the child was injured, the scrape and simple first aid response did not rise to the level of a serious injury. The program may consider a lack of preventative maintenance on the playground, but this situation arose from untied shoes rather than a more widespread issue on the playground that could result in injuries to other children. After running through this sequenced assessment, I would say that this scenario does not require an incident report to OHS. Jess, you want to take the next one? 

Jessica: Sure. Yeah. I said five before, but I, I forgot that we have this last one. Number six. This is one I think where we're going to get a little bit into the gray. A bus driver and aide thought all children had been dropped off at school, but a child enrolled in the Head Start program was hiding on the bus. The child was left unsupervised for eight minutes. Let's think first about the, where this occurred on a bus, where Head Start services are provided. We've got the where as applicable.

We go to the next one. Let's walk through who was involved. In this scenario, the child receives services fully or partially funded by a Head Start grant. The bus driver and aide are staff or contractors of the Head Start Program. Again, while this criterion is either or, you don't need both the child and the staff in this scenario, the who appears to meet both part of that, the child and the staff.

We looked at the where and the who we turned to whether what occurred is significant. When there's a lack of supervision, the focus shifts again to whether there was serious harm injury or endangerment. Again, a reminder that serious injury, harm or injury is typically requires immediate professional medical attention.

Then endangerment involves conduct that puts children at reasonable risk of harm and can be considered similar to supervisory neglect or failure to supervise. Again, I'm going to emphasize whether a child has been endangered, really needs to be examined on a case-by-case basis. Again, a program should consider factors so such as the child's age or developmental needs.

A child who's three or four years of age would likely experience time on unsupervised differently, than an infant or toddler. The length of time the child was left unsupervised. This is a key policy shift because previously we said any period of time kind of unsupervised was, you know, reportable incident.

Now we're not saying a specific period of time triggers an incident that needs to be reported, but it is something that we need to take into account. Then the inherent dangers of the unsupervised environment. Was there water nearby? Is there unrestricted traffic access to traffic? Or could the child leave the facility alone?

Or is the child really in a protected environment? Where they're safe and secure. Given all that, let's turn back to our, our bus incident here. Honestly, this situation is context dependent. Where is the bus parked? Is it accessible to traffic? Is it a fenced in parking lot where a child would not be able to leave the premise?

What was the age of the child? You know, there could be an argument here that there was not endangerment, but it definitely involves probing further. The key with this, and this is what I really want to emphasize as, as we think through the intent of this, is that programs must be able to demonstrate how you've made your determinations and considered all the relevant factors described in the IM.

I also do want to mention again here that there is a distinction between reporting incidents and receiving findings. Just because an incident is reported doesn't mean it will always result in an A NCA non-compliance or a deficiency. I do want to, again, raise that because I think, many times those two get, conflated. One other thing I realized, as I said, we've, I've been mentioning age a number of times. We did say age and developmental needs and as we know, you know, with age go developmental needs, but then they're also, you know, children are on, you know, children are all very different and have a range of kind of, ways in which they may developmentally progress.

You may have, an older child who still has developmental needs due to disabilities or, or other needs that they have that are typical of a, a much younger child. You would want to take that into account as well. Alright, Cynthia, back to you.

Cynthia: Thanks Jess. We are so excited to introduce this new process. We're going to talk about the new centralized function, the OHS Incident Triage team. Our goal is to promote greater consistency and to reduce burden on the newly aligned regional teams. OHS is centralizing the management of child health and safety incident reports and other complaints or issues that are submitted through HeadStart.gov.
 
The change reflects a broader shift in OHS structure and is designed to bring clarity, stability, and streamline support to you, the grants recipients and OHS staff alike. By transitioning this process to a centralized function, OHS aims to ensure uniform response across the country, while also providing regional teams with space to focus on continued engagement, oversight, and support of you, the grant recipients, to understand the changes in how grant recipients will submit incident reports and how OHS will receive them.

Let's quickly talk about the historical process for reporting incidents. Up until June 1st, there were generally three ways that OHS learned of a child incident or another complaint or issue. The first one was submission of the complaint via HeadStart.gov. The second one was a review of state or local licensing report. The third one was through an email or phone call between the recipient, or another concerned party and the regional office. Jess, can you continue?

Jessica: Absolutely. On June 1st, 2025, we implemented a change to the way that, recipients report incidents to OHS. Instead of emailing or calling the regional office, grant recipients must submit the incident or other issue in HSES correspondence to include the resource mailbox ohsincidentreport@acf.hhs.gov.

I love all the reactions. I'm glad that you all, I'm excited about this, and I'm glad that we're seeing, others are as well. Now once the incident is submitted to that resource mailbox, a centralized team of staff, we're calling the OHS or Office of Head Start Incident Triage. Triage team, ITT.

They will act in place of regional offices to document the incident in HSES issues tracking and follow up with the recipient regarding the issue. Starting June one, the revised methods of reporting an incident, an issue or child incident to OHS is as follows. Submission. Well, these are, these are options. 

There is still the option of submission of complaint via HeadStart.gov. There, you know, we can, it can be reported by us reviewing a state or local licensing report as I mentioned earlier. Then, as we've discussed here in HSS, correspondence to the OHS Infinite Triage Team at ohsincidentreport@acf.hhs.gov.

Now, once that report is received in HSES correspondence, the team will document the issues accordingly, review the issue and initiate follow up if more information is needed, and then that team will notify relevant OHS teams for further action if necessary, such as, you know, potentially, again, not always, but potentially initiate a monitoring review of the recipient or, and, or potentially refer the grant recipient for training and technical assistance support the ITT, the incident triage team.

That centralized team will also close the loop with the grant recipient once that intake of information is complete. Now you may wonder why we are moving this function out of the regional offices and into a more centralized format. We really believe that this transition supports our shared goal of ensuring that every child health and safety report is handled with consistency, clarity, and care.

Our regional teams to be very clear, will continue to play a vital role, an absolutely critical role in partnering with grant recipients. This change, we think, frees them up to focus more deeply on technical assistance and long-term prevention strategies, as well as all of the grant management work that they do back and forth.

OHS is also building a more streamlined, trauma-informed process that reduces stress and confusion, both for grant recipients and for OHS staff. Now I want to be clear, we are still learning, and your feedback will help us refine this process as we go. If you have questions or concerns, please do feel free to send them in HSES correspondence to that email ohsincidentreport@acf.hhs.gov. Cynthia, back to you. 

Cynthia: Thanks Jess. I just want to emphasize that we're super excited about this centralized system and I'm so glad to see the positive feedback, coming through the emojis. I want to talk to you a minute about, the sample incident reporting form. This is something that we created, for recipients as, a go-to form.

It's not required, but we published, this back in fiscal year 24, and then we had a new version in fiscal year 25. But recently in June, again, June 1st, we published a new sample incident reporting form on HeadStart.gov. This new form replaces the previous sample incident reporting forms from previous years.

This new form reduces the content on the previous form by 30%. We were extremely intentional about what information we want to collect. It aims to collect as much data as possible on an incident at the time of reporting, which should help to reduce the back-and-forth dialogue OHS and grant recipients may have followed an incident report, but it will also improve OHS response time when an incident is first reported to when a RAN decision is made.

RAN is the risk assessment notification in response to a child health and safety incident. We hope that this incident reporting form provides consistent response across regions to child incident reporting requirements. Use of this specific sample form again, is not required. If you as a grant recipient currently use a child incident form that captures the same information, then the program's existing form may be used to report child incidents to OHS before passing it over to Tala to close out. I want to check in with Kate to see how we're doing on time, and I think we might have some time for questions. Is that right, Kate? 

Kate Troy: That's right, yes. We have about a little less than 10 minutes, maybe like eight minutes for questions. We will be, taking some live. Stay tuned. We tee them up in the moment.

Jessica: I think I'm good to, do you want to, can I start with answering a couple that we've seen in the Q&A that showed up multiple times or, yes. That's great. Thanks. Please. I do want to preface, I would be, I wish we had all afternoon to, or morning for some of you to, to chat about these because we recognize that we, there's no way we could address all the individual questions or scenarios in this time, but let's do a few.

Then we will definitely use all of these robust, I'm just like blown away by how good these questions are to inform future resources, and TA opportunities. I'm seeing a question around, a couple of questions that are similar. Am I hearing that we do not need to send all incident slips for our children for typical and nothing severe, like if a child is bit, or a child falls and scrapes their knee. A similar question, someone said is, you know, a child bumped their head and required stitches. Again, this is a shift. We know for, for many, many people really is a shift for us with our standards. What we are saying is that if there is serious harm or injury, that we would want that to be reported if it is a result of a lack of preventative maintenance.

A child bumped their head because, the, the pavement was not being, you know, taken care of, in, the outdoor play area. There was like a, a hazard that was not addressed through preventative maintenance. They fell and hit their head, and it required stitches, right then we would, because, you know, we need to be doing those regular checks, to make sure the environment is safe.

Now, like I said, I also have two four-year-olds and they trip and fall all the time, not due to lack of preventative maintenance. There can be absolutely things that happen in the course of a program's, you know, day that aren't related to preventative maintenance or related to lack of supervision.

I've had my children fall in front of me sometimes, right, while I'm watching them. What we're saying is we don't need those things reported that aren't due to that lack of preventative maintenance or that lack of supervision. Again, that's for serious harm or injury. Or not serious harm or injury.

Like in some of the examples we talked about, so just to be really crystal clear on that, or as crystal clear as we can arm or injury, that's those things requiring sort of immediate medical attention are required to be reported when they're the result of lack of preventative maintenance, or when they or endangerment are the result of a lack of supervision.

Cynthia: Jess, I think that answers this next question. This recipient said, I'm hung up on the lack of preventative part of the, all of this. Some of these things happen regardless of the lack of prevention. Are we operating under the premise that all incidents are somehow tied to a lack of prevention? And I think I heard you say no.

Jessica: Yeah. I want to circle back. Someone had a, a good question asking for example, and we didn't have one as part of our examples around, emotionally harmful or abusive behavior. That category. Cynthia, do you want to, I think maybe give how we define it in the Performance Standards and then maybe give an example of what we might be referring to?

Cynthia: Cynthia, you're on mute. Sorry, one second. Yeah. Jess, we're defining it as emotionally harmful or abusive behavior is, defined by behaviors that harm a child's self-worth or emotional wellbeing. Examples, including but not limited to using seclusion, using, or exposing a child to public or private humiliation or name calling, shaming, intimidating, or threatening a child.

This is in line with the CDC definitions that we talked about earlier. One example that comes to mind and if this is, a true incident that was reported, a child had an accident where they, went to the bathroom on themselves and a teacher then proceeded to shame them and make them clean it up by themselves while everyone else in the class watched. This would be a very good example of something that would be emotionally harmful, emotionally abusive behavior. Hopefully that helps. 

Jessica: Thanks Cynthia. Another one that we're seeing that I saw was, related to the timeline for reporting. And someone said, if a teacher knows of an incident but does not report it to their supervisor, what day is day zero? There we would say that it, day zero is when the teacher knows of the incident. 

If the teacher observed the incident happening or knows the incident that is day zero, even if that teacher didn't report it to their supervisor, at that time. The reason is that we really want to make sure that those, you know, reporting, training, pieces are in place and that all staff, and contractors and volunteers are trained in whatever the grant recipients, protocols, processes, and procedures are, for their agency in reporting up incidents.

To be clear, we're not saying that that teacher needs to report to the federal Office of Head Start. They do need to follow their internal agency's reporting protocols, and that all needs to happen within that seven-day timeline so that the grant recipient, whoever is responsible for, for reporting to OHS based on the processes and procedures for that recipient is reporting that reportable incident to OHS in that seven-day timeline.

Cynthia: I also want to mention Jess, supporting this, it's very rare that this is going to happen, that no one besides the teacher knows about it because of the ratios that we require in the classrooms. Especially, with Early Head Start, we require two teachers at all times with Head Start, two teachers at all times. It's very rare that one person would know about it and the other wouldn't. That other person in the classroom has the responsibility to report if that behavior is dangerous. 

Jessica: I'm recognizing we've got four minutes left. Tala, should I hand this back to you, or do you want us to field one more?

Capt. Hooban: I don't see that many easy ones in there, but if there's one that you see, repetitively, I think we can handle one more. 

Jessica: I'll talk about I you one about the, where I feel now that I've, you know, again, I could probably go on all day, so cut me off. I did see a question about the bus since we brought it up and someone said, you know, is the bus considered a place where Head Start services are provided?

I just do want to be really clear, cause I think a lot of times we think like classroom or playground. A bus or other program approved transportation is considered a place where Head Start services are provided. Similar for if you are outside the building on a program approved excursion. Alright, with that, thank you all Tala, I'll turn it back to you.

Capt. Hooban: Thank you all so much for joining. I don't know if you guys can see, but there's approximately 3,300 people on this webinar and we received over 200 questions. We really didn't have, the time we thought we had to answer those questions, but we will work on some follow up information and seeing some feedback about not being able to easily find a sample incident form.

We'll circle back on some of those things. Again, thank you for joining today in this lovely group of 3,300 of my closest friends. This was a lot of content to digest and honestly, we will continue to find ways to support programs as we're implementing these reporting requirements in the Performance Standards.

We will continue to spend time answering our questions that come in through the Q&A and so that we can provide training and technical assistance when necessary. I also want to encourage you to view the attachments to the incident reporting information memorandum. I am on HeadStart.gov because there's also lovely graphics that were displayed during this webinar. They're also in the information memorandum. Thank you again for spending some time with us today and thank you for all that you do for children and families. Have a great Monday.