The Dreaded Deficiency Determination: How to Prepare and React

December 3, 2025

To maintain status as “high performing” and to automatically receive new five-year funding awards without needing to re-compete, Head Start programs must refrain from being the subject of “deficiency” determinations. Under the Head Start Act and the Designation Renewal System, a “deficiency” occurs when The U.S. Department of Health and Human Services (HHS) determines a Head Start agency suffers “a systemic or substantial material failure … in an area of performance that the Secretary determines involves” any of six factors, such as “a threat to the health, safety, or civil rights of children or staff” or “the misuse of [granted] funds.” 42 U.S.C § 9832(2). If a grantee fails to correct the deficiencies, HHS may initiate proceedings to terminate the grantee’s Head Start designation.

Because Head Start deficiency determinations have significant impacts for your program, this webinar will cover HHS’s legal bases for imposing deficiencies, the ramifications for your program, how to incorporate policies and procedures that follow performance standards governing grantees’ Head Start programming, and how to potentially challenge the imposition of such deficiencies before your federal funding is altered.

This training is important for any program hoping to proactively take steps to avoid the consequences associated with deficiencies.

The on-demand version of this webinar will be available for purchase one week after the conclusion of the live webinar. 

Please note: This webinar is offered as a complimentary product to all Head Start Training Package holders. For more information on our Head Start Training Package, click here or contact us.

Target Audience

  • Executive Directors
  • Head Start Directors
  • Management Team
  • New Leadership/Management Staff
  • Any program personnel who run orientations and trainings for new employees

Learning Objectives

After this webinar, you will be able to:

  • Understand the process by which the Office of Head Start levies deficiencies and how such a determination could impact your federal funding award;
  • Plan for trainings, programs, policies, and procedures to address common deficiency-related areas before they arise; and
  • Improve your ideas about how to communicate and negotiate with Head Start officials after deficiency determinations are made. 
Course summary
Available credit: 
  • 1.25 Certificate of Attendance
  • 1.50 CPE
Course opens: 
10/13/2025
Course expires: 
01/04/2026
Event starts: 
12/03/2025 - 1:00pm EST
Event ends: 
12/03/2025 - 2:15pm EST
Cost:
$185.00
Add to calendar: 

Mindy B. Pava

Mindy serves as a Partner in the firm’s Litigation & Government Investigations, Federal Grants, Health Care and Education practice groups, where she focuses her practice on advising federal grantees (including health centers) as they navigate all facets of administrative and judicial review. A seasoned litigator, she also represents organizations in health care and other industries in responding to civil investigative demands and federal subpoenas. [Full Bio]

Participants can earn up to 1.50 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.

ATTENDEE REQUIREMENTS FOR CPE CREDIT

If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:

  1. Answer at least 5 of the polling questions during the webinar
  2. Complete the evaluation survey after the conclusion of the webinar or in the follow-up email

Upon completion of these requirements, we will email you your CPE Certificate within two (2) weeks.

ADDITIONAL INFORMATION

  • Prerequisites: None 
  • Target Audience: Executive Directors, Head Start Directors, Management Team, New Leadership/Management Staff, Any program personnel who run orientations and trainings for new employees
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based

Feldesman LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).

Available Credit

  • 1.25 Certificate of Attendance
  • 1.50 CPE

Price

Cost:
$185.00
Please login or register to take this course.

Access to the recorded version of this webinar is included in your purchase.

You will have access to the recordings for 180 days after enrollment. Once posted to your account, you can view each webinar anytime on-demand during the access period identified in your purchase confirmation. For additional information on viewing and accessing webinars, view our full terms and conditions here.

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