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Federal Register / Vol. 86, No. 227 / Tuesday, November 30, 2021 / Rules and Regulations
Table 17. Costs of Staff Vacancies Impact
Low
Primary
High
23,035

11,517

0

95

95

95

2,187,747

1,093,873

0

$20.55

$20.55

$20.55

$44,961,638

$22,480,819

$0

Replacements
40

40

40

Value of Time
$28.72

$28.72

$28.72

Subtotal, Training Costs
$26,462,078

$13,231,039

$0

Total
$71,423,717

$35,711,858

$0

Vacancies Hours per Vacancy Total Hours Value of Time Subtotal, Vacancy Costs
Table 17 presents cost estimates that vary by the vaccine coverage scenarios, which directly impact the number of vacancies that we attribute to the interim final rule. For these calculations, we adopt a common estimate of two weeks for Head Start centers to fill these vacancies. As noted in the baseline section, early care and education providers are currently experiencing significant challenges in recruiting and retaining staff that are attributable to the COVID19 pandemic and general trends in early care and education labor markets. The general trends in early care and education labor markets suggest that filling these vacancies could take longer than two weeks.
However, the interim final rule directly addresses the risk of SARSCOV2
transmission at Head Start centers. The vaccination and masking requirements might lead to new hiring of employees who would not feel safe working in these environments absent these rules. This effect would reduce the average time to fill each vacancy.
Alternatively, this could represent an additional source of benefits not captured in the main analysis elsewhere.
These cost estimates reflect one approach to account for the cost of staff vacancies.
Other approaches may be reasonable. For example, in the context of its interim final rule with comment period that requires COVID19 vaccinations for workers in most
health care settings that receive Medicare and Medicaid reimbursement, CMS calculates the likely magnitude of hiring costs by applying an analysis of the direct hiring costs for workers in the long-term care sector.134 After updating for inflation, CMS reports a direct hiring cost of $4,000 per worker.135 The total cost estimates in Table 17 amount to $3,100
per worker. Substituting CMSs per-worker estimate would result in a range of total cost estimates from $0 to $92 million, with a central estimate of $46 million.
The cost of staff vacancies estimates also reflect an estimate of the value of time of $20.55 per hour, which we also use to estimate the benefits from reduced absenteeism. In a sensitivity analysis for those benefits, we applied a higher value of time of $25.10. Performing an identical sensitivity analysis for these costs yield a higher central estimate of vacancy costs of $27.5 million, which is a $5.0 million increase compared to the estimate in Table 17. This value of time would also yield a higher estimate of vacancy costs under the low-coverage scenario of $54.9 million, which is a $10.0 million increase compared to the estimate in Table 17.
In addition to the costs we identify and monetize related to staff vacancies, we also note the potential costs associated with reduced support from volunteers. However, as with staff, it is also conceivable that some
individuals who do not currently feel safe volunteering at in-person Head Start settings will feel comfortable volunteering under the interim final rule. On net, this could increase the support Head Start centers receive from volunteers.

134 Dorie Seavey, The Cost of Frontline Turnover in Long-Term Care, Better Jobs Better Care Report, Washington, DC: Institute for the Future of Aging
Services, American Association of Homes and Services for the Aging. 2004

135 https www.govinfo.gov/content/pkg/FR2021-11-05/pdf/2021-23831.pdf.

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Cost to Head Start Staff and Volunteers to Get Fully Vaccinated We identify a second cost related to Head Start staff and volunteers getting fully vaccinated. We adopt an estimate of 2 hours as the time necessary to receive one COVID
19 vaccine dose, and adopt a simplifying assumption that each individual induced to get fully vaccinated under the interim final rule will receive two vaccine doses. This estimate is intended to be inclusive of scheduling time; commuting time; time receiving a vaccine dose; waiting time, including after receiving a vaccine dose to watch for any reactions; and recovery time.
We value the time spent to get fully vaccinated using a $20.55 per hour value of time, described above, for a total value of time per person of about $82. We also include costs associated with the vaccine doses and costs of administration. Using an estimated $20 cost per dose of vaccine, $20
as the cost per vaccine administration, we compute the cost of vaccine doses and administration of $80 per person. Table 18
reports the total costs related to vaccination.

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