Attachment C - OHS Monitoring Review Report - 09CH012691 (3).pdf

Program Performance Summary Report
To: Authorizing Official/Board Chairperson
Ms. Ann O'Brien 
City of Phoenix 
200 W Washington St 
Fl 17 
Phoenix, AZ 85003 - 1611 
During the week of February 10, 2025, the Administration for Children and Families (ACF) conducted a monitoring review of City 
of Phoenix to determine whether the previously identified finding(s) had been corrected. The Office of Head Start (OHS) would like 
to thank your governing body, policy council, staff, and parents of your program for their cooperation and assistance during the 
review. This monitoring report has been issued to Ms. Ann O'Brien, Authorizing Official/Board Chair, as legal notice to your agency 
of the results of the program review.
Based on the information gathered during this review, we have closed the previously identified finding(s) which are included in this 
report. Any open finding previously identified but not discussed in this report will remain open. The grant recipient will receive a 
Follow-up review to determine the compliance status of those findings.
Please contact your Regional Office with any questions or concerns you may have about this report.
DISTRIBUTION OF THE REPORT
Copies of this report will be distributed to the following:
Ms. Cynthia Yao, Regional Program Manager 
Ms. Jacqueline Edwards, Chief Executive Officer/Executive Director 
Mrs. Patricia Kirkland, Head Start Director 
Mrs. Patricia Kirkland, Early Head Start Director 
From: Responsible HHS Official 
Date: 04/01/2025 
Tala Hooban 
Deputy Director, Office of Head Start
ATTACHMENT C

Grant(s) included as part of this review
Grant Recipient Name
Grant Number(s)
City of Phoenix
09CH012691 
Glossary of Terms
Term
Definition
Area of Concern (AOC)
An area in which the agency needs to improve performance. These issues should be discussed 
with the grant recipient's Regional Office for possible technical assistance.
Area of Noncompliance 
(ANC)
An area in which the agency is out of compliance with Federal requirements (including but not 
limited to the Head Start Act or one or more of the regulations) in one or more areas of 
performance. This status requires a written timeline for correction and possible technical 
assistance or guidance from the grant recipient's program specialist. If not corrected within the 
specified timeline, this status becomes a deficiency.
Corrected
The original finding identified has been reviewed, along with any applicable supporting 
evidence, and now meets the requirements of the applicable regulation.
Deficiency
As defined in the Head Start Act, the term "deficiency" means:
(A) a systemic or substantial material failure of an agency in an area of performance that the
Secretary determines involves:
(i) a threat to the health, safety, or civil rights of children or staff;
(ii) a denial to parents of the exercise of their full roles and responsibilities related to
program operations;
(iii) a failure to comply with standards related to early childhood development and health
services, family and community partnerships, or program design and management;
(iv) the misuse of funds received under this subchapter;
(v) loss of legal status (as determined by the Secretary) or financial viability, loss of
permits, debarment from receiving Federal grants or contracts, or the improper use of 
Federal funds; or
(vi) failure to meet any other Federal or State requirement that the agency has shown an
unwillingness or inability to correct, after notice from the Secretary, within the period 
specified;
(B) systemic or material failure of the governing body of an agency to fully exercise its legal and
fiduciary responsibilities; or
(C) an unresolved area of noncompliance.
Uncorrected
The original finding identified has been reviewed, along with any applicable supporting 
evidence, and does not meet the requirements of the applicable regulation.
City of Phoenix

Performance Summary
This section contains an overview of compliance information determined through this review. Detailed information can be found in 
the Review Details section.
Content Area
Performance 
Area
Applicable 
Standards
Grant Number(s)
Primary Review 
Finding Status
Timeframe 
for 
Correction
Follow-up 
Compliance 
Level
Significant 
Health and 
Safety Incidents 
Safety Practices 
1302.90(c)(1)(ii)
09CH012691 
DEF
N/A
Corrected
City of Phoenix

Review Details
This section of the report provides details on grant recipient performance in each Content Area and Performance Area with a 
previous or new finding.
Significant Health and Safety Incidents
Included below are details on any relevant findings within this Content Area.
Performance Area: Safety Practices
Follow-up Details 
Corrected - 1302.90(c)(1)(ii)
Summary
Grant Number(s) Cited: 09CH012691
Timeframe for Correction: N/A
Performance Standard Details 
Regulation Text: 1302.90 Personnel policies. (c) Standards of conduct. (1) A program must ensure all staff, 
consultants, contractors, and volunteers abide by the program's standards of conduct that: (ii) Ensure staff, consultants, 
contractors, and volunteers do not maltreat or endanger the health or safety of children, including, at a minimum, that 
staff must not: (A) Use corporal punishment; (B) Use isolation to discipline a child; (C) Bind or tie a child to restrict 
movement or tape a child's mouth; (D) Use or withhold food as a punishment or reward; (E) Use toilet learning/training 
methods that punish, demean, or humiliate a child; (F) Use any form of emotional abuse, including public or private 
humiliation, rejecting, terrorizing, extended ignoring, or corrupting a child; (G) Physically abuse a child; (H) Use any 
form of verbal abuse, including profane, sarcastic language, threats, or derogatory remarks about the child or child's 
family; or, (I) Use physical activity or outdoor time as a punishment or reward.
Compliance Details
Based on the Follow-up review, this finding has been corrected.
The grant recipient ensured staff members and other adults connected to the program did not maltreat or 
endanger the health or safety of children.
•
Additional details from this review event:
The grant recipient revised its standards of conduct, trained staff, and monitored the implementation of new 
procedures.
•
The revised standards of conduct described strategies that promote safe, nurturing, and responsive environments.
•
A review of June 2024 training documents found topics included Conscious Discipline and standards of conduct 
that supported positive guidance, language development, routine and redirection support, and engaging 
interactions and environments.
•
The quality assurance manager stated the grant recipient utilized the standards of conduct classroom walk-
through visits monitoring tool quarterly, and the active supervision/standards of conduct tool annually. The data 
collected from the monitoring tools were used to ensure compliance, make data-driven decisions on professional 
development, and recognize what is needed to enhance centers’ overall performance and effectiveness. 
•
Initial Finding
Parent Review Type: RAN - Parent Review Date: 12/14/2023
City of Phoenix

Parent Review Finding Level: DEF - Performance Standard Number: 1302.90(c)(1)(ii)
Grant Number(s) Cited: 09CH012691
Timeframe for Correction: 30 Days
Performance Standard Details 
Regulation Text: 1302.90 Personnel policies. (c) Standards of conduct. (1) A program must ensure all staff, 
consultants, contractors, and volunteers abide by the program's standards of conduct that: (ii) Ensure staff, consultants, 
contractors, and volunteers do not maltreat or endanger the health or safety of children, including, at a minimum, that 
staff must not: (A) Use corporal punishment; (B) Use isolation to discipline a child; (C) Bind or tie a child to restrict 
movement or tape a child's mouth; (D) Use or withhold food as a punishment or reward; (E) Use toilet learning/training 
methods that punish, demean, or humiliate a child; (F) Use any form of emotional abuse, including public or private 
humiliation, rejecting, terrorizing, extended ignoring, or corrupting a child; (G) Physically abuse a child; (H) Use any 
form of verbal abuse, including profane, sarcastic language, threats, or derogatory remarks about the child or child's 
family; or, (I) Use physical activity or outdoor time as a punishment or reward.
Compliance Details 
The grant recipient did not ensure all staff abided by the standards of conduct to refrain from maltreating and 
endangering the health and safety of children, including using physical abuse.
•
The grant recipient did not adequately implement this standard, contributing to multiple child safety incidents 
within the past 12 months.
•
Additional details from this review event:
The grant recipient had two incidents of staff members at the Cactus Kids Preschool partnership location using 
unacceptable discipline methods with children.
•
On September 29, 2023, the center's assistant director used their index finger to snap a 2-year-old child in the 
mouth, stating, "You will not bite my teachers.”
•
On November 9, 2023, a parent observed 2 EHS teachers pulling 2 children apart, pushing the first child to the 
ground, and slapping the child on the mouth several times. The teacher then instructed the second child to hit the 
first child. One of the EHS teachers then grabbed the first child's hand and used her finger to flick the child's hand 
several times, then proceeded to hold the child to allow the second child to hit him. 
•
  
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City of Phoenix