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ADA, AAPD comment on new Head Start standards

September 29, 2015

By Jennifer Garvin

Washington — The ADA and American Academy of Pediatric Dentistry submitted comments Sept. 17 on new Head Start Performance Standards, proposed earlier this year and which include increased emphasis on oral health.

In a joint letter, ADA President Maxine Feinberg and AAPD President Robert L. Delarosa voiced support for the new standards, which are the first comprehensive overhaul of the standards since they were originally published in 1975, according to a release from the Department of Health & Human Services’ Administration for Children and Families.

By updating the performance standards, Head Start said it hopes to utilize “best practices and the latest research on what works in early education to foster healthy child development and school readiness.”

In the letter, the ADA and AAPD focused on the following Subpart D-Health Program Services:

  • The provision that mandates parents must provide proof that their child is up-to-date “on a schedule of age appropriate preventive and primary medical and oral health care” within 90 days of enrollment.
  • The requirement to assist parents, as needed, in obtaining any prescribed medications, aids or equipment for medical and oral health conditions.
  • The provision that allows program funds to be used for professional medical and oral health services when no other funding is available.
  • The requirement to assist parents, as needed, in obtaining any prescribed medications, aids or equipment for medical and oral health conditions.
  • The provision that a program “must promote effective oral health hygiene by ensuring children age one and over are assisted by appropriate staff, or volunteers, if available, in brushing their teeth once daily.”
  • The requirement that programs “must collaborate with parents to promote children’s health and well-being by providing medical, oral, nutrition and mental health education support services that are understandable to individuals with low health literacy,” and that this opportunity includes learning about preventive oral health care.

For the provision that “a program must help parents continue to follow recommended schedules of well-child and oral health care,” ADA and AAPD recommended the following language be added:

“A program should utilize a separate dental periodicity schedule as required by the state’s Medicaid Early and Periodic Screening, Diagnosis, and Treatment program, consistent with that recommended by professional organizations such as the American Academy of Pediatric Dentistry.”

Regarding the provision that Head Start programs “must facilitate and monitor necessary oral health treatment and follow-up” including providing fluoride supplements and topical fluoride treatments in communities which lack adequate fluoride levels, the ADA and AAPD recommended that Head Start help families establish a “dental home” which they defined as the “ongoing relationship between a dentist and the patient, inclusive of all aspects of oral health care delivered in a comprehensive, continuously accessible, coordinated, and family-centered way.”

Additionally, both the ADA and AAPD supported the provision that a program must assist “all enrolled pregnant women to access comprehensive services through referrals that, at a minimum, include nutritional counseling, food assistance, oral health care, mental health services, substance abuse prevention and treatment and emergency shelter or transitional housing in cases of domestic violence.”

Head Start began in 1965 as a way of promoting school readiness for children in low-income families by offering educational, nutritional, health, social and other services. According to Head Start, it has served more than 32 million children, birth to age 5, and their families.

HHS anticipates publishing a final rule in 2016. A complete list of the proposed standards can be found here.