Surviving the Funded Enrollment Initiative: Helpful Strategies from an Attorney's Perspective

February 13, 2024

Access the on-demand webinar here.

Underenrollment has been on the minds of many Head Start grant recipients for the last few years. According to a 2022 report issued by the National Institute for Early Education Research, Head Start enrollment dropped nationwide by 33% in the aftermath of the COVID-19 pandemic. Less than two years before the start of the pandemic, the Office of Head Start issued the Full Enrollment Initiative, ACF-PI-HS-18-04 on June 5, 2018, which implements Section 642(g) of the Head Start Act and delayed enforcement until early 2023. Although enrollment has picked up significantly, many programs still have found themselves on underenrollment plans.

This session provides an attorney’s perspective on how to avoid a designation of “chronically underenrolled,” what to consider if your program does receive the designation, and what happens if your program is unable to meet 97% of enrollment at the end of the 12-month plan. We will consider strategies like requesting slot reductions or conversions and improved recruitment efforts to keep your agency in compliance, as well as how to appeal unfavorable decisions for potential reduction in funding. 

Target Audience

  • CEOs, Executive Directors / Head Start Directors
  • CFOs
  • COOs
  • ERSEA Managers
  • Other staff
  • But all are welcome! 

Learning Objectives

After this webinar, you will be able to:

  • Understand the requirements of Section 642(g) of the Head Start Act and ACF-PI-HS-18-04
  • Outline how to conduct internal monitoring to verify whether your program maintains full enrollment, to the Head Start requirements
  • Know your appeal rights in the event that your program is designated as chronically underenrolled
Course summary
Available credit: 
  • 1.00 Certificate of Attendance
Course opens: 
Course expires: 
Event starts: 
02/13/2024 - 1:00pm EST
Event ends: 
02/13/2024 - 2:30pm EST

Nicole Bacon

Nicole Bacon, a Partner at the firm, works in the firm’s Federal Grants, Litigation, and Health Law practice groups. Nicole offers her clients specialized guidance in compliance with federal grant law including specific programmatic requirements as well as the Uniform Administrative Requirements, Cost Principles and Audit Requirements of Federal Awards. Nicole represents a variety of community-based organizations, before State and Federal courts as well as administrative bodies. [Full Bio]

Ted Waters

Serving as Managing Partner of the firm since 2003, and a member of the Health Law and Federal Grants practices since 1992, Ted focuses his practice on helping organizations to solve problems. Ted’s expertise in financial, cost reporting, reimbursement, and administrative issues is widely recognized, and illustrated by his selection as a 2014, 2015, 2016, 2018, 2019, & 2020 Washington, D.C. Super Lawyer in health care. Ted routinely handles challenging issues for clients such as government audits, internal investigations, and litigation. [Full Bio]

Participants can earn up to 1.80 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


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

  1. Answer at least 6 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.


  • Prerequisites: None 
  • Target Audience: CEOs, Executive Directors / Head Start Directors, CFOs, COOs, ERSEA managers, other senior staff - but all are welcome! 
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based
  • Attendance Requirements: In order to be awarded the full credits, you must respond to six (6) polling questions.

Feldesman Leifer 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 (formerly

Available Credit

  • 1.00 Certificate of Attendance


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