In 2010, the Government Accountability Office (GAO) released a bombshell report describing findings of fraud at Head Start centers across the country.  Prompted by hotline tips, the GAO conducted a series of undercover tests in which investigators posed as families and tried to enroll children in Head Start programs, even though the families were not eligible for Head Start services. 
The results described in the GAO report are shocking:
"In 8 out of 13 eligibility tests, our families were told they were eligible for the program and instructed to attend class. In all 8 of these cases, Head Start employees actively encouraged our fictitious families to misrepresent their eligibility for the program. In at least 4 cases, documents we later retrieved from these centers show that our applications were doctored to exclude income information for which we provided documentation, which would have shown the family to be over-income. Employees at seven centers knowingly disregarded part of our families’ income to help make over-income families and their children appear to actually be underincome. This would have had the effect of filling slots reserved for underincome children with over-income children. At two centers, staff indicated on application forms that one parent was unemployed, even though we provided documentation of the parents’ income. A Head Start employee at one center even assured us that no one would verify that the income information submitted was accurate."
In one case, a Head Start employee said of the fictitious family’s excess income “Now you see it, now you don’t.”
This is the stuff of nightmares for Head Start directors.  And, in this political environment, another scandal would be catastrophic for the Head Start program.  For these reasons – and others – it is vitally important that Head Start directors remember lessons learned from the GAO investigation, starting with these:
1.       Make sure you are sending this message: eligibility determinations are serious business.  It's likely that you already emphasize how important eligibility determinations are, but remember that actions speak louder than words.  Employees performing eligibility determinations should be required to document and justify their activities, and not just on a simple one page form.  We recommend that eligibility determinations be supported by detailed documentation and explanations.  The added work required to complete eligibility determinations will send a message that these determinations are serious business.
2.       Create a culture of transparency.  Every Head Start agency should have a whistleblower policy that encourages good-faith reporting of illegal practices or conduct.  If you don’t yet have a whistleblower policy, or you want to see how your existing policy compares to others, check out the National Council of Nonprofits’ Whistleblower Policy resource page.
3.       As President Reagan said, “Trust but verify.”  All ERSEA employees should be trained early and often on Head Start eligibility rules.  But you should also develop monitoring materials and randomly audit eligibility determinations.  Make a record of your monitoring activities. 
4.       Use the GAO investigation as a teaching tool.  Next time you do professional development for ERSEA employees, assign the GAO report as required reading and host a round table discussion about the findings.