Child Care Facilities: Federal Agencies Need to Enhance Monitoring and Collaboration to Help Assure Drinking Water is Safe from Lead
Fast Facts
Children exposed to lead can experience serious developmental delays. Many young children spend significant amounts of time in child care settings, including Head Start centers.
We conducted a nationally-representative survey of Head Start centers. Based on that survey, we estimate that:
26% tested for lead in their drinking water; 10% of those found lead and all took action to remediate
43% had not tested
31% did not know if they had tested
We made 4 recommendations to federal agencies to promote lead testing of water in child care facilities and to improve collaboration across the federal government to do so.
Highlights
What GAO Found
The Department of Health and Human Services' (HHS) Office of Child Care (OCC) provides states with resources and technical assistance to help determine if drinking water in child care facilities is safe from lead. However, the office does not require that drinking water be tested because there is no requirement to do so under the OCC-administered Child Care and Development Block Grant, a key federal funding source for states to subsidize child care. Nonetheless, some states require child care providers to test their drinking water for lead.
HHS's Office of Head Start (OHS) has performance standards that require grantees to provide safe drinking water to children, but OHS does not ensure grantees comply with them. For example, OHS does not require grantees to test their water or document that it is safe from lead, nor does OHS check grantees' compliance with this standard during monitoring reviews. According to an OHS official, the office limits the number of standards it monitors to more efficiently use its limited resources. However, without documentation, OHS does not have reasonable assurance that Head Start grantees provide safe drinking water. In fact, an estimated 43 percent of Head Start centers had not tested their drinking water for lead in late 2018 or 2019, and 31 percent did not know whether they had tested, according to GAO's nationwide survey. (See figure.)
Estimated Percent of Head Start Programs That Tested Centers' Drinking Water for Lead
Note: These results are generalizable to the population of Head Start centers that receive their water from a public water system. A majority of Head Start centers (an estimated 84 percent) receive their water from these systems. GAO's survey was administered from October 2019 to January 2020 and asked Head Start centers to report information based on the 12 months prior to completing the survey. The thin bars display the 95 percent confidence intervals for each estimate.
The Environmental Protection Agency (EPA) has awarded grants to help child care facilities test for lead in drinking water, but has not taken sufficient action to ensure its 2019 Memorandum of Understanding (MOU) with OCC and OHS, which encourages lead testing, is being executed. EPA officials said they plan to meet semi-annually, in part to track progress toward achieving the MOU's outcomes. However, EPA has not yet reached agreement with its MOU partners regarding their roles and responsibilities, nor determined how it will routinely update and monitor the MOU. Without these actions, EPA, OCC, and OHS efforts are lacking practices identified as critical to effective interagency collaboration, according to GAO's prior work.
Why GAO Did This Study
Children who are exposed to lead can experience serious developmental delays. Many young children spend significant amounts of time in child care settings. GAO was asked to review efforts to address lead in drinking water at child care facilities.
This report discusses (1) how OCC oversees and supports states' use of Child Care and Development Fund funding to determine that drinking water in child care facilities is safe from lead, (2) how OHS ensures Head Start grantees provide drinking water that is safe from lead, and (3) the extent to which EPA collaborates with OCC and OHS to support lead testing in child care facilities. GAO reviewed relevant laws, regulations and documents, and conducted a generalizable survey of 762 Head Start centers. To obtain information on lead testing and remediation, GAO also visited or interviewed 11 child care providers and Head Start grantees in four states that were selected for geographic variation and the presence of state laws for lead in drinking water.
Recommendations
GAO is making four recommendations, including that OHS require grantees to document that water provided to children is safe from lead, and for EPA and HHS to improve their collaboration. HHS concurred with our recommendations. EPA neither agreed nor disagreed with our recommendations but said it believed they were redundant with existing activities. GAO continues to believe these recommendations are warranted.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Health and Human Services | The OHS Director should require Head Start grantees to document that water provided to children has been tested for lead. OHS could determine various ways that are feasible and efficient for grantees to satisfy this requirement; for example, verification could be done through OHS' current grantee data collection or monitoring processes. (Recommendation 1) |
HHS updated its monitoring protocols, began monitoring, and produced findings related to testing for lead in Head Start facilities. Specifically, in fiscal year 2022, OHS monitoring reviews focused on grantee processes for lead inspections and in fiscal year 2023, OHS further refined its monitoring protocols by asking grantees to show how they protect children from exposure to lead in paint or water in their facilities.
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| Department of Health and Human Services | The Assistant Secretary for the Administration for Children and Families should direct OCC and OHS to develop an agreement with EPA on their roles and responsibilities in implementing the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. For example, these agreements may include the ways in which guidance and information will be shared with states and Head Start grantees, such as through webinars or email, and how frequently. (Recommendation 2) |
HHS agreed with this recommendation and has worked closely with EPA to implement it. HHS has completed activities to implement the MOU. For example, in the fall of 2022, EPA held a webinar titled "Testing Water for Lead in Head Start Facilities" which included guidance on testing water for lead in Head Start facilities. In addition, in the spring of 2023, EPA and HHS issued a Dear Colleague letter that describes resources and funding, including grant programs, that can help child care facilities test for and remediate lead, as well as other actions states can take to protect children from exposure to lead in drinking water. Lastly, EPA, OCC and OHS co-developed and presented 3 webinars for child care and Head Start programs on the 3Ts program (Training, Testing, and Taking Action). More than 600 early childhood providers and programs attended each of the 3 webinars. We believe these actions address the recommendation.
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| Environmental Protection Agency | The Assistant Administrator of the Office of Water should develop an agreement with HHS's Offices of Child Care and Head Start on their roles and responsibilities in implementing the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. For example, these agreements may include the ways in which guidance and information will be shared with states and Head Start grantees, such as through webinars or email, and how frequently. (Recommendation 3) |
At the time of the report, EPA neither agreed nor disagreed with this recommendation and considered it to be redundant with existing activities. However, EPA has completed activities to implement the MOU. For example, HHS explained that EPA meets monthly with the Office of Child Care (OCC), Office of Head Start (OHS), and Office of Early Childhood Development (ECD) to support ACF's efforts to increase and improve lead testing and remediation in child care and Head Start programs. EPA is also working with OCC and OHS to develop webinars to provide information to relevant officials (e.g., State Child Care Administrators, State Head Start Collaboration Directors) to provide information about 3Ts and EPA's updated training modules, training and technical assistance, and connect with State Water Safety Administrators to discuss prioritizing use of federal funds for lead remediation in child care and Head Start programs. Lastly, EPA, OCC and OHS co-developed and presented 3 webinars for child care and Head Start programs on the 3Ts program (Training, Testing, and Taking Action). More than 600 early childhood providers and programs attended each of the 3 webinars. We believe these actions address the recommendation.
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| Environmental Protection Agency | The Assistant Administrator of the Office of Water should direct the Office of Water to specify how it will track progress toward the outcomes of the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities and determine how it will regularly monitor and update the MOU. For example, the Office of Water could develop performance measures for each of the MOU's outcomes. In addition, the Office of Water could submit annual reports on progress toward achieving the MOU's outcomes or it could plan to update the agreement at specific intervals. (Recommendation 4) |
EPA is addressing this recommendation, establishing a means by which to track progress toward implementing its Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. EPA scheduled and held regularly occurring meetings with MOU partners, including national associations and select federal agencies, in which partners report on their activities to implement the MOU. For example, the Department of Health and Human Services reported on progress in developing a rule to require testing for lead in drinking water in Head Start facilities. As of May 2024, EPA is consulting with MOU partners on four potential collaborative projects that best support the strategic goal and aligns with partner's programmatic efforts. EPA plans to publish an MOU Meeting Outcomes document of these projects by the end of 2024.
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