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Can a member of a governing body provide services to the Head Start agency in return for compensation?

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Can a member of a governing body provide services to the Head Start agency in return for compensation?

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Section 642(c)(1)(C)(ii) of the Head Start Act prohibits members of the governing body from receiving compensation for serving on the governing body and providing services for compensation to the Head Start agency. As a decision-maker, a governing body member is expected to act in the best interest of the Head Start grantee. As a vendor who provides services to the agency, an individual has an interest in continuing a beneficial relationship with the grantee. These interests are in conflict and this situation is prohibited by the statute. Section 642(c)(1)(D) of the Act allows an exception if the individual holds a position as a result of public election or political appointment, and such position carries with it a concurrent appointment to serve as a member of a Head Start agency governing body. In such cases, the Head Start agency is required to report the conflict of interest to OHS.

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