3 ways Head Starts can respond to the NPRM’s call for pay equity
The Early Head Start (EHS) and Head Start (HS) staff compensation landscape is readying for transformation with the introduction of the November 2023 Notice of Proposed Rulemaking (NPRM). The NPRM proposes new and enhanced changes to the Head Start Program Performance Standards (HSPPS) in three main areas: workforce support mental health and other quality improvements.
While the current HSPPS remains in effect until a final rule is issued later this year, the workforce section of the NPRM proposes competitive EHS and HS staff compensation by August 2031. More specifically, it calls for concerted efforts in establishing pay equity for education staff and emphasizing greater alignment with preschool through third-grade teachers’ wages in local or neighboring school districts.
The NPRM also has two other significant workforce elements outlined:
- Requiring programs to pay all staff a wage at least sufficient to cover basic costs of living
- Requiting, providing or facilitating access to employee benefits for full-time staff (e.g., health insurance, paid leave and short-term behavioral health services)
While the NPRM’s directive is clear, many agencies are uncertain how they will implement such changes without federal funding, even if they have seven years to do so. Here are three recommendations to assist your agency plan and prepare for these changes:
1. Pay equity
Obtain and monitor your local and neighboring school district salary schedules. Most can be found online by searching “salary schedules” and the district’s name.
Before incorporating the salary schedules for teaching positions in your next wage comparability study, don’t forget to convert annualized wages into hourly wages by understanding the public school teachers’ employment contracts, specifically, how many months/days they work in a year.
While two school districts may pay their first-year bachelor’s degree teachers $50,000 annually, their hourly rates may differ. For example, in a district where teachers work 1,850 hours per year, the equivalent hourly rate would be $27.03 per hour. And in a district where teachers work 1,664 hours per year, the equivalent hourly rate would be $30.05 per hour. Both still earn $50,000 annually based on their working agreement, but their hourly rates are different.
To further address current market pressures and general talent shortages, use published wage and salary surveys to obtain your reputable insights. Also include other relevant industry and sector data, such as preschools and daycares, aligning with your agency characteristics to complement your nonprofit and public school district data.
2. Salary structure
The labor market is competitive and dynamic, making it critical to be proactive when planning minimum pay requirements and wage comparability in your salary structure.
Don’t wait five years to complete your next wage study and salary structure full cycle update. The market will continue to move, and wage growth will continue to increase, potentially causing your employee wages and compensation philosophy stated practices to lag the market.
You should also continue to monitor the annual Executive Level II pay cap threshold, announced every January. For 2024, this amount is $221,900 annually. Use this to set your salary structure maximum(s) for any staff compensated using federal HS dollars.
Similarly, set appropriate pay minimums (or pay floors) in your salary structure inclusive of a living wage. Don’t wait for the NPRM to pass and take effect to incorporate sufficient wages to allow staff to provide for themselves and their families.
3. Employee benefits
Familiarize yourself with and adhere to existing federal, state and local laws. (Your jurisdiction may already require this compliance.)
Research and determine the most appropriate type of employee leave program to support your agency, such as vacation and sick time or paid time off. Additionally, consider HRIS integration capabilities and limitations.
Conduct an analysis or engage your insurance broker or third-party administrator to determine the competitiveness of your employee benefits offerings for your local market and organization size.
Partner with your local and neighboring school districts to understand their employee benefits. Consider statewide plans and, if needed, complete a FOIA request to obtain information for each school and district.
How Wipfli can help
The changes proposed in the NPRM will have an unprecedented impact on HS and EHS programs.
Wipfli can help you proactively navigate these changes with data-driven foresight. Our industry-experienced team is ready to help you apply tailored solutions to meet your organizational needs and the market you operate within. Begin by downloading our wage comparability study RFP, or learn more about how we can support your organization and staff by helping you prepare for the NPRM changes.
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