Head Start Health Premiums • Public Charge Rule Rescinded •
Action Against Ransomware Attacks • Head Start Duration Requirements

OHS Issues Guidance on Paying Health Insurance Premiums

Summer is finally here, and with its arrival many Head Start programs have questions about how to navigate the issue of paying for group health plan premiums for their seasonally furloughed employees. The issue is particularly complicated this year, in light of the American Rescue Plan’s new COBRA premium assistance tax credit. On June 2, 2021, the Office of Head Start (OHS) issued Information Memorandum (IM) ACF-IM-HS-21-02 to provide guidance on furloughed employees’ health plan premiums.

2018 Public Charge Rule Discouraging
Immigrant Use of Public Benefits Rescinded

The controversial 2018 public charge rule (the Rule) has been rescinded by U.S. Citizenship and Immigration Services (USCIS) as of March 9, 2021. The Rule made it more difficult for immigrants who use federal, state, or local government benefits to receive visas and green cards. CAAs may now advise their clients that receipt of public benefits such as Section 8, Medicaid, and SNAP will not count against them in a proceeding that requires a public charge determination, such as a green card application. USCIS has removed content related to the Rule from affected USCIS forms, which are listed here. More information about the pre-existing 1999 public charge rule, which is currently in effect, can be found here.

White House Urges Action Against Ransomware Attacks

Responding to growing cybersecurity concerns arising from recent, high-profile ransomware attacks, on June 8, 2021 the White House released a memo, “What We Urge You To Do To Protect Against The Threat of Ransomware”. The memo urges businesses to implement several strategies and practices that can protect their data and other private organizational information against ransomware and other cyberattacks.

Head Start Service Duration Requirements Take Effect August 1

For Head Start grantees, the deadline to provide plans for at least 1,020 annual hours of planned class operations over the course of 8 months per year for at least 45 percent of their center-based funded enrollment is quickly approaching. By August 1, 2021, grantees must either share compliant program designs with their Regional Office or request a waiver of the requirement in the Head Start Enterprise System (HSES).

This Legal Update is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance (T/TA) Center. It was created by Community Action Program Legal Services, Inc. (CAPLAW) in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services Cooperative Agreement – Grant Award Number 90ET0482-01. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.

The contents of this publication are intended to convey general information only and do not constitute legal advice. Any communication through this publication or through CAPLAW’s website does not constitute or create an attorney-client relationship. If you need legal advice, please contact CAPLAW or another attorney directly.