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Federal Register / Vol. 86, No. 227 / Tuesday, November 30, 2021 / Rules and Regulations 23,035 Head Start staff will not meet the vaccination requirement and also not receive an exemption. The upper-bound vaccine coverage scenario reflects all Head Start staff
that do not meet the vaccination requirement receiving an exemption. Under our primary scenario, 11,517 Head Start Staff will not meet the vaccination requirement and also
68091

not receive an exemption from the vaccination requirement.

Table 16. Head Start Staff COVID-19 Vaccine Requirement Response Possibilities
Outcome U oder Policy Scenario
Low
Primary
High
Fully Vaccinated Rate
86.6%

90.8%

95.0%

Exemption Rate
5.0%

5.0%

5.0%

Compliance Rate, Pre-Turnover
91.6%

95.8%

100.0%

Turnover
249,965

261,483

273,000

Potential Head Start Staff Turnover
23,035

11,517

0

Head Start Staff in Compliance, Pre-

Costs Associated With Head Start Staff Vacancies
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In this section, we describe our approach for valuing the costs associated with Head Start staff vacancies associated with quitters that are attributable to the interim final rule.
We follow many of the assumptions contained in the Benefits section that outline the value of time savings for parents and caretakers of children attributable to the
interim final rule through vaccine coverage and reduced COVID19 cases among Head Start teachers. For each COVID19 case averted, parents and caretakers experienced 190 hours of time savings, assuming each COVID19 case lasts two weeks. To value the countervailing risk of staff vacancies, we adopt an assumption that each Head Start staff that quits in response to the interim final rule will leave a vacancy that lasts an average of two weeks. This assumption is intended to reflect an average duration among vacancies that are filled faster and vacancies that are filled slower than two weeks. It is also intended to be inclusive of any efforts by Head Start centers that anticipate resignations on the effective date of the policy to identify replacements when the vaccine requirement takes effect. We also anticipate that Head Start centers will be able to prepare in advance for these vacancies and reduce the impact on families through increased caseloads per staff. This preparation would not be possible for absenteeism due to a COVID19 case or outbreak. We reduce the average number of
families affected by half, which results in an overall estimate of about 95 hours of time costs for parents and caretakers of children receiving Head Start services per vacancy from resignations. We are not aware of another estimate of how long a typical vacancy of this nature lasts; however, given that we anticipate this to be a significant cost attributable to the interim final rule, we have determined that these assumptions are more justified, in the context of this analysis, than not monetizing this cost. We acknowledge significant uncertainty in several of these estimates and discuss the nature of and implications of each source.
We also include a cost of training the replacement Head Start staff. We assume that new-employee training takes an average of 40
hours, and we adopt a value of time based on the median wage rage of preschool and kindergarten teachers of $14.36 per hour.133
We double this wage to generate a fully loaded wage that accounts for benefits and other indirect costs. Table 17 reports the costs of vacancies and costs of training under the vaccine coverage scenarios.

133 https www.bls.gov/oes/current/naics4_
624400.htm.

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We anticipate some staff employed by Head Start programs will choose to leave the program due to vaccination and mask mandates. There are already significant challenges in recruiting and retaining staff among early care and education providers including Head Start and the requirements in this rule could exacerbate this issue for certain programs, resulting in programs not being able to fully staff their classrooms. This could also result in costs to programs to recruit new qualified staff to replace those staff that leave the program and may result in interruption of services for children and families.