On March 10, 2022, NHSA submitted comments on the Proposed Information Collection Activity for the Head Start Program Information Report (OMB #0970-0427). NHSA appreciates the important role that the Program Information Report (PIR) plays in supporting oversight activities of Head Start programs and is advocating for two proposed changes to be clarifyied or removed.

1. Ethnicity and Race: The proposed information collection indicates the Ethnicity and Race section of the PIR will include an additional column allowing respondents to select “Unspecified” as opposed to “Hispanic or Latino origin” or “Non-Hispanic or Non-Latino origin” starting in program year 2022-2023. We appreciate HHS’s effort to encompass the widest variety of races and ethnicities, but the addition of this column is inconsistent with the U.S. Census, which the PIR claims to follow. The 2020 Census Questionnaire addressed race and ethnicity in separate questions and did not offer an “Unspecified” answer choice. In its results, the Census only reported responses for the two choices offered, declining to report how many respondents chose not to select one of those answer choices.
2. Average Salary and Benefits: The proposed information collection indicates the Average Salary and Benefits section of the PIR will include an additional column for the average benefit costs for each staff category starting in program year 2022-2023. There was no justification provided for this change and no guidance on how programs should calculate Average Benefits. We assume the goal is to better understand employee compensation, but this change will pose an enormous administrative burden on Head Start programs. Calculating the average benefit costs for 18 different benefits for certain groups of employees within their workforce will be incredibly time-consuming for HR and finance professionals at Head Start programs.