Pedro is in his second school this academic year; his family moved from Texas to Michigan to harvest cherries.

Nancy was a freshman in high school last year, but now she has left school to pick apples with her father.

Thelma dreams of being a nurse someday, but knows she’ll never have enough credits to graduate from high school because her family keeps moving back and forth from California to Oregon.

These are the children of America’s migratory workers, and their education suffers as a consequence of their family’s mobile way of life. The purpose of the MEP is to locate these children, determine whether they are eligible for the program, and, if so, provide them with the supplemental instructional and support services they need to succeed in school.

Our nation’s economy depends upon workers who perform a variety of temporary and seasonal jobs that help produce, harvest, and process crops, livestock, poultry, fish, shellfish, dairy, and other agricultural products. The workers who fill these jobs are often forced to piece together a number of agricultural or fishing jobs to make a living that will sustain them and their families throughout the year. These jobs are often located far from one another, requiring the worker to move and reside temporarily in an area near the work. Due to economic necessity, many workers and their families migrate back and forth from a home base^[2] to locations where they can obtain one or more of these temporary or seasonal jobs. The workers who move in search of such work are known as “migratory” agricultural workers or fishers.

Migratory agricultural workers and fishers share a number of common characteristics that pose significant challenges in their lives:

• They repeatedly relocate for work due to economic necessity.
• They are often isolated from services.
• They are “working poor” as a result of the low wages they are paid for their labor.
• They often reside in sub-standard living conditions.
• They frequently have low levels of education.
• They are subject to inadequate or non-existent health care.
• They often feel isolated from the larger community because they come from a different culture and frequently speak a language other than English (some speak indigenous languages, making it difficult to find interpreters and translated materials).
• They often move to and from other countries (especially Mexico).
• Many live in fear due to documentation and legal status issues.
• These characteristics and life experiences create unique educational circumstances for the children of migratory workers and young migratory workers who move regularly.
• Migration means changing schools, teachers, and curricula, and often chronic absenteeism for school-age children. Changing schools diminishes a student’s sense of belonging and makes it more difficult to participate in the classroom and extracurricular activities.
• Children of migratory workers often have limited opportunities to learn the English language because their parents may not be proficient in English. Furthermore, children who spend part of the year in countries (and schools) in which English is not commonly spoken do not have as much opportunity to learn and practice English.
• Migratory parents’ low levels of education and socioeconomic status often limit the amount and quality of educational support that can be offered in the home.
• Health insurance and wages that ensure adequate access to health care for young children and adolescents are not generally provided by temporary and seasonal jobs in agriculture and fishing.
• Because they are temporary residents, migratory workers and their children are often treated like outsiders and may face discrimination. This fact may limit their access to services to which they are entitled.
• Students may not receive academic credit for courses they have completed when states do not have an active system for granting and transferring course credits earned within the state, or accepting course credits earned in other states.

Migratory children are known to be at high risk of school failure due to these characteristics and experiences. The unique educational needs that arise from the migratory lifestyle and the challenges our nation’s schools face in effectively educating a highly mobile and disadvantaged population keep that risk high.

Migratory out-of-school youth (OSY) who work in agriculture or fishing rather than attending school are at an even greater risk of failing to obtain the level of education required to succeed in life. These OSY may travel with families, an older relative or crew chief, in small groups, or alone. In the Consolidated State Performance Reports (CSPR) for 2014-2015, States identified 35,165 OSY eligible for services, which was 10.5 percent of the total population of migrant students identified as eligible for services (332,335) (ED, ED Data Express, 2014-2015). OSY face all of the obstacles to education encountered by other migratory students, plus additional challenges. OSY are seldom connected with the community in which they live, and as a result, the MEP may be their only link to education, support, and the medical services they need.

² Many migratory families have a home base or hometown where they live for much of the year. They travel or migrate from this home base to other places to work. ↑

In 1966, the U.S. Congress amended Title I of the ESEA to include a new section: Part C—Education of Migratory Children. Through this amendment Congress authorized, for the first time, a program that provided states with federal financial assistance to help improve the educational opportunities and academic success for the children of migratory agricultural workers. This program was called the Migrant Education Program, or MEP.

The ESEA, as amended by the ESSA, states that the purpose of the MEP is

1. to assist states in supporting high-quality and comprehensive educational programs and services during the school year and, as applicable, during summer or intersession periods, that address the unique educational needs of migratory children;
2. to ensure that migratory children who move among the states are not penalized in any manner by disparities among the states in curriculum, graduation requirements, challenging state academic standards;
3. to ensure that migratory children receive full and appropriate opportunities to meet the same challenging state academic standards that all children are expected to meet;
4. to help migratory children overcome educational disruption, cultural and language barriers, social isolation, various health-related problems, and other factors that inhibit the ability of such children to succeed in school;
5. to help migratory children benefit from state and local systemic reforms. (Section 1301 of the ESEA, as amended)

The principal operational goal of the MEP is to ensure that all migratory students meet challenging academic standards so that they graduate with a high school diploma or receive a High School Equivalency Diploma (HSED) that prepares them for responsible citizenship, further learning, and productive employment.

The MEP was designed to help migratory children find success through education. Preparing a preschooler for kindergarten, helping a student learn to read or enhancing their English language proficiency, ensuring a child’s promotion to the next grade, and helping a high school student earn credits toward graduation are just a few examples of activities that the MEP supports. However, before the MEP can provide any services, MEP staff must determine that a child is eligible for the MEP. To understand migratory child eligibility, it is important to review the law.

According to sections 1115(c)(1)(A) (incorporated into the MEP by sections 1304(c)(2), 1115(b)), and 1309(3) of the ESEA, and 34 C.F.R. § 200.103(a)), a child is a "migratory child" if the following conditions are met:

1. The child is not older than 21 years of age; and
1. the child is entitled to a free public education (through grade 12) under state law, or
2. the child is not yet at a grade level at which the LEA provides a free public education; and
2. The child made a qualifying move in the preceding 36 months as a migratory agricultural worker or a migratory fisher, or did so with, or to join a parent/guardian or spouse who is a migratory agricultural worker or a migratory fisher; and
3. With regard to the qualifying move identified in paragraph 3, above, the child moved due to economic necessity from one residence to another residence, and
1. From one school district to another; or
2. In a state that is comprised of a single school district, has moved from one administrative area to another with such district; or
3. Resides in a school district of more than 15,000 square miles and migrates a distance of 20 miles or more to a temporary residence. (NRG, Ch. II, A1)

Note for the three terms defined in both the statue and program regulations (“migratory child,” “migratory agricultural worker,” and “migratory fisher”), the statutory definition in the ESEA, as amended by the ESSA, takes precedence. In addition, the term “in order to obtain” no longer appears in statute, and its definition in 34 CFR § 200.81(d) is therefore no longer applicable.

Children who fit the above definition are eligible for MEP services. However, only those children who are between the ages of three and 22 (i.e., have not had a 22^nd birthday) are counted for state funding purposes.

Working for the MEP means you are affecting the lives of the nation’s most disadvantaged children. Without the MEP, no one would be looking out for these children.

Identification means actively looking for and finding migratory children and youth. Recruitment means making contact with the family or youth and obtaining the necessary information to document the student’s eligibility and enroll them into the MEP.

The ID&R of migratory children is essential because the SEA must create a record of eligibility for each migratory child before he or she can receive any of the MEP’s educational or supportive services. The longer it takes a state to find a migratory child, the more time passes before the child receives the extra services he or she needs to succeed. Furthermore, the children who are most in need of MEP services are often the most difficult to find. Migratory children who are not identified may experience problems such as delays in placement or incorrect school assignment; failure to count partial credits or inappropriate course sequence for graduation from the student’s home-based school; and obstacles to receiving necessary supplemental services. Even if an individual migratory child does not receive direct services, it is important to identify all migratory children so their needs can be assessed and monitored to plan future services if a need does arise.

Effective ID&R is a challenge for the MEP. The proper and timely ID&R of migratory children may be a difficult task for a number of reasons:

• Not all temporary or seasonal workers are eligible for the MEP because the worker must have moved due to economic necessity from one residence to another and from one school district to another and have (1) engaged in new qualifying work soon after the move, or (2) if the worker did not engage in new qualifying work soon after the move, actively sought such employment and had a history of moves for qualifying work. The eligibility requirements for the MEP require strong analytical skills to properly evaluate eligibility.
• Migratory families are inclined to be self-sufficient and are not accustomed to seeking help outside of their own circle of family and friends.
• Children of migratory workers are often invisible, quietly coming and going, and not attracting much attention in a new community. If these children are not actively recruited, many would not be in school (they may accompany their parents to work or be left alone at home) or receive services from the MEP.
• Finding and recruiting many OSY who travel without their families or in groups of OSY is especially challenging. The traditional in-school recruitment model is not feasible because this population has no contact with the school district. Recruitment of OSY is most successful when it occurs at work sites, in the field, and at businesses where these youth work, as well as in housing where they live.
• Migratory families often do not speak or read English or are English language learners (ELLs), and some are not literate in their native language.
• Frequently, there are significant cultural barriers and misunderstandings between the migratory family and the community in which they reside.
• The places where migratory families work and reside are often located in remote areas, and employers may be uncomfortable if their employees have outside visitors during the workday. Employers may also discourage outside visitors because of concerns about liability, productivity, or the legality of their workers.
• There is considerable turnover in migratory agricultural and fishing work. The work is often difficult, dangerous, and, under the best circumstances, results in only modest wages. Living conditions in farmworker camps and other temporary, poorly maintained housing can be hard on all of the family members. Yet, while many migratory workers move into easier and more stable employment, others remain in or re-enter the migratory labor pool because they view the temporary or seasonal work in agriculture or fishing as their only employment option in the workforce.
• The MEP may not be able to serve all migratory children; the children may not currently need supplemental academic help or they may not be deemed a priority for service. Therefore, some families may not see an immediate benefit to their child being identified and may forgo the process.

For these and other reasons, the MEP needs to employ trained staff to identify and recruit migratory children. These staff members are usually called “recruiters,” and they receive extensive training in a basic set of procedures on how to find and recruit migratory children for the MEP.

There are many state MEP organizational structures. An example of an MEP structure is found below in Figure 1. While the MEP is administered by a single office (OME) within ED, organizational structures below the federal level differ from state to state. Throughout the country, staff works on the MEP at the local, state, and federal levels.

Figure 1. A Typical MEP Organizational Structure

Role of Federal MEP Staff. OME administers the MEP nationally and provides guidance and support to SEAs that receive grants. The OME has several responsibilities, including providing national leadership, conducting special initiatives, helping ED to calculate state MEP allocations, monitoring state programs for compliance with federal requirements, collecting and analyzing student performance data, developing regulations and guidance, and providing technical assistance on how to implement the MEP. A federal program officer (i.e., contact person) is assigned to each state to assist and monitor its implementation of the MEP.

The OME has developed Non-Regulatory Guidance (NRG), a policy document that is written in an easy-to-follow question-and-answer format to help SEAs and LOAs understand the requirements that apply to the MEP and to suggest ways to implement them. As statutory or regulatory requirements change, OME updates the NRG to help clarify the policies as they relate to the MEP. Recruiters are strongly encouraged to study the Chapters II and III of the NRG on “Child Eligibility” and “Identification and Recruitment.”

Role of State MEP Staff. ED awards MEP formula grants to SEAs, which are solely responsible for the operation and administration of the program; most SEAs subgrant a portion of their MEP grant to LOAs, which help SEAs administer and operate the program. At the state level, most states have a MEP Director who is responsible for overseeing all aspects of the administration of the program, including the state’s ID&R system. The MEP Director may also have program responsibilities for other federal programs. The focus of the state MEP Director is to provide overall leadership and direction for the state as a whole, and to ensure that local programs comply with all applicable laws and other requirements. The state is responsible for finding and enrolling migratory children from across the state, for determining their unique needs, and for developing a service delivery plan that uses resources in an equitable and effective manner. Most states also have ID&R Coordinators who provide statewide leadership and guidance to recruiters. When a recruiter asks a question that cannot be answered at the local level, the recruiter should raise the question at the state level for a response. It is important to recognize that each state has its own policies and procedures regarding chain-of-command and how to address questions and concerns. The recruiter should check with an immediate supervisor to learn the protocols in his or her state.

Role of Local MEP Staff. At the LOA level, the emphasis is on finding and serving individual migratory children. The recruiter, perhaps with assistance from other local staff, finds migratory children, determines whether they are eligible for the MEP, and helps connect them with appropriate services. Once the child is identified and the child’s needs are assessed, educators and others at the district level who serve migratory children may provide extra services that are beyond those offered by the local school. For example, MEP teachers and tutors may provide in-home tutoring, after school coursework, or summer programs. Migratory children may also be eligible to receive services through other programs serving migratory students, such as

• The High School Equivalency Program (HEP), under which ED provides competitive grants to colleges, universities and non-profit organizations to help migratory and seasonal farmworkers and their immediate family members who are 16 years of age or older to obtain a HSED certificate or equivalent to gain employment, enter postsecondary education, or the military.
• The College Assistance Migrant Program (CAMP), under which ED provides competitive grants help migratory and seasonal farmworkers and their immediate family members complete their first undergraduate year of study in a college or university.

Local school districts that receive a subgrant from the SEA to serve migratory children are responsible to the state MEP. When a recruiter or anyone else at the local level has a question or needs support, the recruiter should turn to an immediate supervisor for assistance. The supervisor may be an ID&R staff member or a local program coordinator who has broader duties. Local projects are often asked to gather local data for the state for evaluation purposes and also to inform state decision makers.

The MEP helps meet the academic needs of an important and often overlooked sector of our society: migratory children. If it were not for the efforts of the MEP at the local, state, and federal levels, migratory children might remain invisible. In many cases, migratory children would not be identified or served if MEPs did not employ a network of recruiters to find and enroll them into the program. Without a record of eligibility, these children would not be able to receive the additional services they need to be successful. There are many layers of support at the local, state and federal levels of the MEP, so the recruiter should never feel that he or she is alone.

A good recruiter is determined more by his or her aptitude and attitude toward performing the unique responsibilities of the job than by any formal educational process.

Recruiters are very important because they often serve as the first contact between a migratory family or youth and the local school district, as well as the community at large. Also, for OSY, the recruiter may be the first direct contact with someone outside of their work crew. The initial contact is crucial because it provides the recruiter with the opportunity to determine whether the child may be eligible for the MEP. During this visit, the recruiter also sets the tone for the home-school relationship. It is the responsibility of the recruiter to be helpful without allowing the family or youth to become overly dependent on his/her assistance. The recruiter is often considered an ambassador in the eyes of migratory parents, the school district, agricultural employers, and the community. For example, a bilingual recruiter may be instrumental in explaining important school policies to a migratory family and may be an important connection for an OSY to educational and social service opportunities. In this way, the recruiter is the main link between the migratory family or youth and the MEP and other resources.

The recruiter’s primary job is to find and enroll eligible migratory children into the MEP. Locating migratory children can be hard work, and the recruiter must become skilled at performing a range of duties and adapting to situations to be successful. While recruiting migratory children is the recruiter’s primary responsibility, he or she also often plays an important role in helping to ensure that these children receive vital educational and social services. Thus, while “recruiter” is the most commonly used term to describe this staff position, other terms used include

• advocate
• home visitor
• recruitment specialist
• interviewer
• school liaison
• community liaison
• outreach worker

The MEP recruiter’s primary responsibilities include the following:

• learning the MEP eligibility requirements
• establishing and maintaining a recruitment network
• becoming familiar with locations where migratory families and youth live and work
• finding migratory children and their families and youth
• explaining the MEP to migratory families and youth
• interviewing migratory families and youth
• making preliminary determinations on the eligibility of the child and youth
• completing the Certificate of Eligibility (COE)
• collecting child eligibility and other basic program data
• implementing state quality control procedures
• following ethical standards and confidentiality laws
• facilitating communication among migratory families, schools, agricultural
  employers, and the community

The recruiter often has job responsibilities beyond ID&R. For example, the recruiter may help migratory families navigate the unfamiliar, and sometimes unfriendly, environment that families might encounter in a new community. As mentioned previously, the recruiter may also work as an advocate, translator, home-school liaison, or parent involvement coordinator.

Great recruiters are made, not born. If a recruiter doesn’t feel ready to do the job, the recruiter should work with a supervisor to identify and develop the skills needed to be successful.

Experienced ID&R coordinators say that, as a general rule, it takes about three years for a recruiter to fully learn the job. The specific skills required to be a great recruiter are developed over time using strategies such as those described in Chapter 3. If the recruiter does not initially possess these skills, the supervisor can help the recruiter cultivate them.

When ID&R coordinators and MEP administrators are asked about “a great recruiter” or “their best recruiter,” certain characteristics emerge. A great recruiter is able to

• make correct eligibility decisions,
• document child eligibility accurately and clearly,
• manage time wisely,
• work independently,
• remain flexible and adapt to a constantly changing environment,
• relate well to others and gain their trust,
• create positive relationships with agricultural employers,
• use effective interviewing (i.e., questioning) skills,
• maintain appropriate relationship boundaries,
• follow confidentiality laws,
• demonstrate personal integrity, and
• speak local migratory families’ native language and exhibit cultural sensitivity.

Few recruiters come to the job with all of the skills that make a great recruiter. Effort, enthusiasm, and a willingness to learn are necessary. Although it may take a number of years to be considered great, it is within the grasp of every recruiter to achieve excellence.

Each recruiter has stories about things that went wrong or that could have been done differently in carrying out his or her roles and responsibilities. These lessons learned may help the new recruiter avoid pitfalls that experienced recruiters have faced.

Know About the Local MEP. The recruiter must know more than just recruitment. As stated earlier, the recruiter is often the face of the MEP to families, OSY, schools, and the local community. A recruiter is also a champion for the MEP. A migratory family will often ask the recruiter questions about MEP services that the school and other programs offer, such as does the MEP offer a pre-school program, is there a summer school, are dropouts eligible for the MEP, and what programs are available to help my son/daughter graduate? The recruiter should learn about the MEP and other school and community programs that migratory children and families are eligible to receive.

Develop A Recruitment Network. A recruitment network is a system of contacts, including individuals, agencies, and other institutions, that provide information on how to identify and locate potentially eligible children. Establishing a recruitment network and developing a strong working relationship with each member of that network is an important way of finding migratory children who may be eligible for MEP services. When done properly, a recruitment network can serve as the eyes and ears of the recruiter. Key sources of information include employers, schools, community-based agencies, commercial establishments, and others. The recruitment network is further explained in Chapters 4 and 5.

Determine Work Priorities. The recruiter often has many roles. If the recruiter is expected to recruit and do other work for the MEP, the recruiter should determine the work the supervisor considers the highest priority and allocate time accordingly. For example, the recruiter, with guidance from the supervisor, may need to decide which of the following activities would be most productive: attending a job fair to recruit, staying in the school’s main office to meet new families that may be eligible for the MEP, knocking on doors to canvass for new families, or translating at the MEP after-school program. In order to prioritize, the recruiter will need to assess which of these activities provide the greatest benefit to the MEP.

Give the MEP Its Due. If a recruiter is paid by more than one funding source, the recruiter should ask an immediate supervisor how much of his or her time is paid from MEP funds and how many hours per week should be spent on ID&R activities. The recruiter should then devote that amount of time to MEP work. If the school asks the recruiter to spend MEP time on work that does not directly benefit the MEP (e.g., playground or lunchroom duty or translating for non-migratory parents), the recruiter should respectfully decline. If the school insists that the recruiter spend MEP-funded time on non-MEP work, the recruiter should contact a supervisor. Similarly, a recruiter who works full-time for the MEP should guard his or her time to make sure all work activities benefit the MEP.

Ask Questions. There are many people who work in the MEP who are willing to help the recruiter do the job correctly. If the recruiter has a question or does not understand how something should be done, the recruiter should ask someone who is knowledgeable and write down the answer. In this way, the recruiter will become increasingly knowledgeable over time.

Make Ethical Decisions. The recruiter will meet families and youth who have great needs. The recruiter may believe that those children need and deserve help, even if they do not qualify for the MEP. On the other hand, the recruiter may meet families whose children clearly qualify for the MEP, but may not find them as deserving. Because of these feelings, the recruiter may experience internal conflict about making accurate eligibility decisions. Each recruiter brings a set of personal beliefs and biases to the job; the recruiter will need to put these personal feelings aside in order to make objective decisions based on the MEP eligibility criteria.

Maintain Appropriate Relationship Boundaries. The needs of migratory families can be overwhelming to a recruiter. However, it is important for a recruiter not to make promises that cannot be kept. The recruiter should exercise caution in assisting needy families and youth with non-educationally related needs. Good judgment and tact must be used in deciding when and for how long to help a family. For example, a migratory family that has recently arrived from another country is often more dependent on the recruiter’s guidance, assistance, and support than a family who has spent more time in the U.S. The bilingual recruiter may be the only one who can make a school appointment for a family, help the family resolve an unpaid medical bill, or direct the family to other services in the community. However, there is a fine line between providing support to a family and hindering the family’s ability to become self-reliant. The recruiter should learn when it is appropriate to help a family and when to refer the family to other local services. The best service a recruiter can provide migratory families or youth is to help them develop skills that will enable them to become increasingly independent.

Be Aware of Federal, State and Local Requirements. States and LOAs may have their own requirements for the recruiter that go beyond the federal requirements. For example, if the vast majority of migratory families are of Mexican origin, a state may require the recruiter to know Spanish and demonstrate sensitivity to the various cultures of Mexico. Other state-specific requirements may include responsibility for knowing and understanding privacy laws and reporting suspected cases of child abuse or child abduction. Recruiters also need to become familiar with the Family Educational Rights and Privacy Act (FERPA), the federal law that protects the privacy of student education records from unauthorized release. While these areas should be part of every recruiter’s training, if the recruiter is not aware of FERPA or the applicable state privacy, child abuse, or other relevant laws, the recruiter should ask a supervisor.

Volunteers Expand Services. A well-established volunteer network can provide recruiters with resources outside of the realm of MEP funding and can be called into action when a recruiter is feeling overwhelmed with service requests. Despite assumptions to the contrary, many people are interested in assisting the migratory community—churches, students at institutions of higher learning, retirees, community members, and various coalitions frequently seek a fulfilling volunteer experience. A recruiter’s impact can increase exponentially when working in collaboration with a strong volunteer network.

Remember That a Recruiter Is Not Alone. Being a recruiter can sometimes seem like a lonely job. However, ID&R is a team effort. It is important for the recruiter to understand that identifying, recruiting, and determining the eligibility of migratory children is the mutual responsibility of the recruiter and the ID&R team. When the recruiter has questions or needs help, there are other people who work in the MEP at the local, state, and federal levels who can assist. For example, local program staff may be able to provide leads on children who may be eligible for the MEP, a recruitment supervisor may help in planning recruitment strategies, and state staff may be able to assist in resolving eligibility questions. Spending a day in the field shadowing a fellow recruiter can also be beneficial to learn new recruiting techniques and get a different perspective from another person who understands the challenges facing recruiters.

Reaching migratory children and youth is at the heart of the MEP, and the importance of effective recruitment cannot be overemphasized. Without a good recruiter, the neediest migratory children may not be served. The effective recruiter can become the center of a network that connects migratory families and youth to schools and communities. When migratory families trust the recruiter, they are much more likely to tell him or her when new migratory families move into an area. When growers and other employers trust the recruiter, they are more likely to allow recruitment at the employment site and to support the MEP. Recognizing the value of these networks is the beginning of great recruiting. Chapter 3 will discuss how the recruiter learns the job.

To successfully find migratory children, the recruiter must have a clear idea of who to look for and the best strategies for finding them. Training both novice and veteran recruiters can be compared to teaching someone to drive a car. Just as a driver education instructor would not put a new student driver behind the wheel of a car on a busy road, those who administer the MEP at a state or local level should not send a new recruiter out to find and interview migratory families or youth without proper instruction and guided practice. Similarly, veteran recruiters, like veteran drivers, may need a defensive driving course once in a while to refresh their knowledge and skills.

The process that a new driver goes through to learn the “rules of the road” is similar to the process that a new recruiter goes through to learn the basic MEP child eligibility requirements. Learning the rules of the road generally involves both classroom instruction and independent study, as does learning basic MEP eligibility definitions. Likewise, the guided practice that a new driver receives with the help of a driver education instructor or parent is similar to what the new recruiter should receive under a knowledgeable and experienced recruitment mentor. Finally, before a new driver may operate a car alone, he or she must pass a driver’s test. Along the same lines, the new recruiter should demonstrate proficiency in recruiting eligible children before being allowed to work independently. Some states require the new recruiter to take a certification examination or survey that measures the recruiter’s ability to make correct eligibility determinations.

Furthermore, state and local personnel should not assume that veteran recruiters do not need continual training and development. As in some states, where drivers may have to take a vision test or a road test to renew their license, veteran recruiters will need to retrain and relearn as laws and regulations change. Beyond new laws and regulatory changes, veteran recruiters should seek out at least one professional development opportunity a year to enhance skills and knowledge.

The recruiter and an immediate supervisor should work together to build and maintain the recruiter’s knowledge and skills. This chapter will discuss the general knowledge and skills of ID&R, the types of training a recruiter might receive, and other strategies to help the recruiter learn, or relearn, the job of ID&R.

OME has developed the National ID&R Curriculum that identifies the core knowledge and skills that it believes a recruiter needs to master in order to properly identify and recruit migratory children and make preliminary eligibility determinations.

The National ID&R Curriculum consists of eight modules, each based on one or more chapters of the National ID&R Manual. The content of each module is taught through research-based instructional strategies designed to meet the needs of all learners. Participants will use the four modalities of recruiting (reading, writing, listening, and speaking) to process the content being delivered, and the trainer will facilitate the learning process by actively monitoring, questioning, and clarifying, when needed.

Each module consists of 1-3 levels designed to allow the trainer the option of selecting specific topics to train based on the composition of the audience. Level 1 will provide the basic information for the module topic, which makes it ideal for new recruiters and/or MEP staff members to use as a refresher for veteran recruiters. Subsequent levels provide additional topics of study related to the module, which make them ideal for follow-up or in-depth trainings.

The National ID&R Curriculum was created to transform the National ID&R Manual’s set of knowledge and skills into a training experience The curriculum is based on the following five objectives:

• State and local MEP recruiters understand the background of the MEP, the ID&R process of the MEP, and the duties and responsibilities of a recruiter. As indicated by this first objective, the recruiter will learn about the purpose, basic history, and organization of the MEP. In addition, the recruiter will learn the basic eligibility requirements and the general process for ID&R. Finally, the recruiter will become aware of his or her basic duties and responsibilities.
• State and local MEP personnel implement practices that result in the efficient ID&R of migratory children. To satisfy the second objective, the recruiter will learn how to develop a recruitment network, how to determine where migratory families and youth live and work, and how to locate them. The recruiter will also learn to understand and respect the diversity of migratory children, youth, and their families in order to interact with them effectively. The recruiter will practice how to explain the MEP to migratory families and youth and will learn how to organize and manage his or her caseload. Finally, the recruiter will learn how to take appropriate precautions to ensure personal safety.
• State and local MEP personnel implement practices that result in reliable and valid child eligibility determinations. For this third objective, the recruiter will master the child eligibility requirements under the MEP. The recruiter will also demonstrate the knowledge and skills needed to effectively interview a family or youth. The recruiter will learn to make valid and reliable preliminary child eligibility determinations and to implement quality control activities.
• State and local MEP personnel are aware of and adhere to ethical standards of behavior in child eligibility determinations. The recruiter will practice ethical behavior when determining a child’s eligibility.
• State and local MEP personnel implement practices that strengthen coordination and collaboration between migratory families, schools, and the community. The recruiter will demonstrate the ability to facilitate coordination and collaboration between migratory families, schools, and the community. The recruiter will practice meeting planning, facilitation, and team building.

States may want to consider developing their own ID&R training programs that are customized to the specific needs and characteristics of their states. For example, the recruiter should know about the local MEP including services offered, dates of operation, hours, and contact information. Here are some other topics that state and local training programs should consider, including

• how the state and local ID&R system is organized, including reporting relationships;
• state and local ID&R policies and procedures, including required paperwork;
• the content of the state and local ID&R plans, when available;
• demographic information regarding the characteristics of local migratory agricultural workers and fishers and their children, as well as their mobility patterns;
• state methods of collecting and maintaining data on migratory children;
• the recruiter’s role in the state’s quality control process and how to assist in developing and implementing the state or local plan for quality control, such as the mandatory federal re-interviewing requirements; and
• the organizations with which the SEA and LEAs expect the recruiter to coordinate and the amount of time the recruiter should allocate to this coordination.

The National ID&R Curriculum provides a structure that can be used to teach the newest recruiter the basic knowledge and skills needed to properly identify and recruit migratory children. It can also provide the most veteran recruiter with an understanding of more advanced recruitment concepts that prepares the recruiter for a stronger leadership role in the MEP. In combination with the National ID&R Curriculum, an individual state ID&R orientation, on-going training, and the National ID&R Manual, recruiters will discover the wide range of knowledge and skills necessary to become an effective MEP recruiter. States should continually work to improve their overall ID&R system and sharpen the knowledge and skills of new and veteran recruiters alike.

The new recruiter generally receives basic training from an ID&R coordinator, a state-approved trainer, a local program coordinator, and/or a highly knowledgeable and skilled recruiter. This training often starts in a classroom or one-on-one setting and is generally followed by independent study and on-the-job training in the field. The on-the-job training often pairs the new recruiter with a highly skilled staff member until the new recruiter is ready to recruit or conduct an interview alone.

Classroom or Individual Training. By the end of the basic training, the recruiter should be able to correctly answer questions such as

• Why are migratory children identified and recruited? See Chapter 1.
• Who is eligible for the MEP? See Chapter 7.
• How do I find eligible children and youth? How do I develop an ID&R action plan? See Chapter 4, Chapter 5, and Appendix II.
• How do I conduct an interview? How do I explain the MEP to the family? What local services are available? See Chapter 6.
• How do I determine if a particular child is eligible for the MEP? See Chapter 7.
• What do I do if I encounter a situation that is not covered in the Sample Interview Script? See Chapter 6.
• How do I fill out a COE? See Chapter 8.
• How is my state’s student eligibility data collected, used, and stored? See Chapter 8.
• What ethical standards should I follow? See Chapter 2, Chapter 6, Chapter 7, and Chapter 8.
• What should I know about the language and culture of migratory families in my area? See Chapter 1.
• What safety precautions should I take when recruiting? See Chapter 5.
• What state and local laws should I know about? See state ID&R material.

After the classroom or individual training ends, the new recruiter should work with a supervisor to explore what other federal, state, and local training materials and opportunities are available, and use this information to develop a long-term personal training and development plan. SEAs and LOAs generally offer training on the MEP that recruiters are required to attend, and SEAs also hold an annual national ID&R conference that features workshops with updated ID&R information and methods. Even though not all recruiters may be able to attend a national MEP conference, the state and local staff generally obtain and disseminate information from the conference.

Independent Study. In addition to taking the basic classroom training, the recruiter should study key documents on his or her own. In particular, the new recruiter is encouraged to study the materials provided in the initial training, use the National ID&R Curriculum as a way to gauge progress in learning the suggested knowledge and skills, self-check through a review of the learning objectives listed at the beginning of each chapter and the use of the chapter checklists provided in Appendix XIIl, and carefully read and study relevant documents, such as

• the law and regulations (including the instructions to complete the National COE);
• the NRG;
• the National ID&R Manual;
• state ID&R materials (if available);
• the State’s Comprehensive Needs Assessment (CNA) and Comprehensive State Plan, also known as the Service Delivery Plan (SDP);
• applicable state and local laws, regulations, and policy guidance;
• relevant state and local ID&R action plans (more information will be provided in Chapter 5); and
• the RESULTS website (https://results.ed.gov).

The goal of independent study is for the new recruiter to become familiar with these key documents and resources and to know where to find answers to basic questions about ID&R and child eligibility. It is critical for the recruiter to stay up-to-date on the latest changes in guidance and policy at both the state and federal levels.

If you’re a new recruiter, find a good, experienced recruiter and ask if you can tag along when he or she makes home visits. After a few visits, attempt your first MEP introduction or conduct a parent interview. You’ll learn far more seeing it done and doing it than you will just talking about it or reading an ID&R manual. You might try this even if you are not a new recruiter. The really great recruiter is always trying to learn new things.

Field-Based Training. Many states try to match new recruiters with mentors who are highly knowledgeable and skilled. At first, the new recruiter will shadow the mentor on recruitment visits to observe how to conduct an eligibility interview. The new recruiter should observe how the mentor makes the initial contact, explains the MEP, conducts an interview (paying particular attention to what questions are asked to determine whether the child is eligible for the MEP), and handles questions, problems, or concerns that arise. After each visit, the mentor and new recruiter should debrief and discuss the interview and eligibility determination. The new recruiter may find it helpful to shadow several mentor recruiters to observe the different strengths of each.

After watching several interviews, the new recruiter should begin to conduct a small part of the interview with the mentor’s guidance. Each time the new recruiter conducts a part of an interview, the recruiter should talk with the mentor about how the interview went and ask the mentor for feedback or advice on how to improve for the next interview. This conversation should be away from the family or youth that was interviewed. As the new recruiter’s interviewing skills improve, he or she can take over more of the interview process until comfortable conducting a full interview. By the end of the peer-mentoring portion of the training, the recruiter should be able to properly conduct an interview, determine child eligibility, complete a COE form, and perform other key duties.

Sometimes, especially in small states and very isolated areas, mentoring may not be practical. In this case, the recruiter should try to practice interviewing through a role-playing exercise during the classroom training, perhaps with another new recruiter. Practice is important as it makes the actual interview flow naturally and helps to ensure that the recruiter collects all of the required information to complete the COE and make the preliminary eligibility determination. In situations like this, the recruiter should discuss with his or her supervisor other ways to obtain adequate training and/or mentoring opportunities, including contacting a nearby state able to send an experienced recruiter for a limited time (three to four days).

Some states require the recruiter to pass a certification exam or answer questions to demonstrate the recruiter’s knowledge of child eligibility requirements. The purpose of these tests is to assess whether the new recruiter fully understands program eligibility requirements and can apply them to determine if a child is eligible for the MEP. If the recruiter’s state does not have a certification exam or knowledge check, the recruiter should conduct a self-check to test how thoroughly he or she understands the MEP child eligibility requirements (see Appendix IX). If the recruiter does not pass the certification exam or knowledge check, the recruiter should talk with an immediate supervisor to find out which topics to study and arrange for further training.

Learning how to recruit properly is a process that does not end when the recruiter has finished the training activities. The recruiter will continue to learn as he or she identifies and recruits migratory children. It is important for the recruiter to ask questions about any eligibility situation that is unclear and to seek direction and guidance from supervisors and peers to become highly knowledgeable and skilled.

Regular Meetings with the Supervisor. The new recruiter should meet regularly with the immediate supervisor to discuss child eligibility questions and other concerns that arise. Ideally, a supervisor will provide regular feedback during the training process; however, it is equally important for the recruiter to ask for regular feedback on whether he or she is properly applying the child eligibility requirements. This is vital during the first few months on the job to prevent any misunderstandings from becoming ingrained.

Performance Assessments by Supervisors. As part of the system of state quality controls, SEAs or LOAs are required to complete an annual review and evaluation of ID&R practices of individual recruiters [34 CFR § 200.89(d)(2)]. While supervisors may conduct a performance review with seasoned recruiters in an office setting, supervisors generally observe each new recruiter in the field. This allows a supervisor to provide comprehensive feedback on the recruiter’s rapport building, interviewing, decision-making, and documenting skills. The purpose of this observation is for the supervisor to see how the new recruiter approaches interviewing migratory families and making and documenting preliminary eligibility determinations. It is imperative that supervisors schedule observations with new recruiters. The recruiter should also request feedback on completed COEs to make sure they are being done properly.

Regular meetings and performance assessments also present an opportunity for the new recruiter to suggest ways of improving local ID&R efforts and to identify any training and development activities that would increase productivity. Suggestions from a new recruiter can be particularly useful to the supervisor because a new recruiter will view the system with fresh eyes and may be able to identify productivity solutions that are invisible to those who are comfortable with the process.

Recruiter Support System. The new recruiter should develop a network of other recruiters locally, regionally, or even nationally with whom to share tips and discuss problems. Recruiting can be stressful work; it is important to create a safe learning environment in which the recruiter feels free to share experiences and to learn from successes and failures. The recruiter may find it useful to work with mentors, peers, and the recruitment network to develop an individual ID&R action plan or to adapt an existing plan (more information on ID&R plans is provided in Chapter 5). The recruiter is encouraged to try promising new ID&R strategies and to share the results (both good and bad) with peers.

The recruiter may find it helpful to go on recruitment visits with outreach workers from other programs or agencies. For example, a recruiter may wish to join outreach staff from the National Farmworker Jobs Program (NFJP), administered by the U.S. Department of Labor, to learn how they approach migratory families and to learn more about the services they provide (more information on other agencies and organizations that provide services to farmworkers and their families is found in Appendix II).

The law that authorizes the MEP is updated generally every six to eight years. When the law is updated, ED will issue updated MEP regulations and guidance. Periodically, there are changes to other federal and state laws that affect migratory families as well, such as immigration or privacy laws. To properly identify and recruit migratory children, the recruiter must keep up with changes in the law, regulations, and guidance that affect the eligibility of migratory children (more information on other laws that may affect migratory families is found in Appendix I). The recruiter should also periodically visit the MEP web page at the U.S. Department of Education (https://oese.ed.gov/offices/office-of-migrant-education/migrant-education-program/) and the RESULTS website (https://results.ed.gov) for updates and resources. Keep in mind that the recruiter should initially attend his or her state MEP’s training and review state informational resources for MEP program changes and updates before going to the federal level.

To stay current, the recruiter should participate in advanced child eligibility training and ongoing professional development to continually update and improve needed knowledge and skills. The recruiter should make a point of attending local, regional, statewide, and national trainings when possible. Regardless of years of experience, recruiters and supervisors who do not participate in ongoing eligibility training are more likely to make mistakes when making child eligibility determinations than those who are trained regularly. In particular, experienced recruiters may be tempted to apply policies that were learned as new recruiters out of habit, even though those policies may be out-of-date. Timely training and regular meetings can help experienced recruiters overcome these old habits. Some questions a recruiter may want to answer after going through advanced eligibility training include

• Have any changes been made to the child eligibility requirements for the MEP? If so, what are they?
• How do I determine child eligibility in difficult cases?
• How can I strengthen my recruitment network?
• How can I improve my interviewing skills?
• What common mistakes have recruiters made in determining child eligibility and/or filling out COEs and how can I avoid making those mistakes?
• What ethical dilemmas could I encounter and how do I handle them?
• How are these and other recent changes reflected in my district, region, or state?

The recruiter, with the supervisor’s approval, may also want to explore professional development opportunities in other relevant areas, such as education reform, the language and culture of local migratory families, transient populations, negotiation skills, dealing with difficult people, public speaking, immigration issues, agricultural issues, time management, stress management, and safety and emergency training. The recruiter can check the listings at local universities, colleges, community centers, and other organizations for relevant course offerings and training.

In addition to training offered by the state, OME hosts an annual conference in which the latest information on MEP-specific issues, including eligibility and recruitment topics, is presented. It is important to note that not all states have the same policies and practices; therefore, it is crucial that conference participants check with their state or local administrators before implementing policies or practices presented at the OME Conference. Information on the conference can be obtained from the RESULTS website (https://results.ed.gov). In addition, there are regional, state, and national conferences, trainings, workshops, and meetings that include sessions and information on ID&R.

There are a number of ways in which the recruiter can learn the job of ID&R: participating in a new recruiter training program, studying the NRG and other key resources, working with a mentor, meeting regularly with a supervisor, and developing a support system. Having knowledgeable and well-trained recruiters is an ongoing responsibility of both the individual recruiter and the MEP administrator. Regardless of what training opportunities are available, it is the recruiter’s job to work with the supervisor to learn the MEP child eligibility requirements and to ask the supervisor for help when questions arise on whether a child qualifies for the MEP. Remember, regardless of the size of the migratory student population, and whether the recruiter’s position is full-time or part-time, all states hold recruiters to the same standard: to conduct timely and proper identification and recruitment of eligible migratory children.

The first step in the process of determining if children are eligible for the MEP, however, is to locate them. Chapter 4 provides specific information on how to find migratory children.

Networking creates a supportive system to share information and services among individuals and groups having a common interest. (National ID&R Curriculum)

The recruiter often finds locating migratory children to be the most time consuming and labor intensive ID&R responsibility, particularly since the children who have the greatest needs are often the most difficult to find. While recruitment consists primarily of finding and interviewing families, it is by no means a simple task. The process is strenuous and requires many skills including communication and building effective relationships with migratory families and youth, the agricultural community, and service providers who work with migratory families. The recruiter should also learn how to approach key community leaders to make them aware of the MEP and to gain their respect. Over time, experienced recruiters recognize that migratory families, agricultural employers, and service providers who work with migratory families are helpful to the recruiter in locating other migratory families, children, and OSY. Building this level of personal trust and an awareness of the benefits of participating in the MEP should be every recruiter’s goal.

This chapter addresses the type of research the recruiter and other MEP staff should conduct to learn about local agricultural activities, farmworker labor, and organizations that serve the local migratory community. This information will help the recruiter and supervisor determine the best way to identify and recruit eligible migratory children.

The value of developing key contacts within the migratory community cannot be overstated. As a starting point, the recruiter should learn as much as possible about his or her recruitment area. In particular, the recruiter should find out what is known about the local migratory community and which local people and organizations are trusted within that community. Local people and organizations are the recruiter’s best sources of current and accurate information and referrals. Once the recruiter has identified these important contacts, the recruiter should determine how best to build strong working relationships, to exchange information on an ongoing basis, and to promote the MEP.

The recruiter may be instructed by his or her supervisor to “talk with farmers” or “go to the schools.” But a new recruiter, or even a seasoned recruiter taking on a new territory, needs to know which farms and schools are the most likely to have migratory children in order to be productive. Conducting basic research will help the recruiter find migratory children more quickly and efficiently. This is particularly true for those children who are not in school and are more difficult to identify, such as preschool children and OSY.

Some key questions the recruiter should try to answer through this research include

• What is already known about migratory workers in my local area?
• Who are the local agricultural and fishing employers?
• What are the employers’ work activities (e.g., packing freshly picked apples)?
• Which of their jobs are temporary or seasonal?
• Which employers hire migratory workers (i.e., workers who have moved to this community to do this type of work)?
• Where are the employers located?
• Where do the migratory families who work for these employers reside in the local area (e.g., migratory labor camps, inexpensive apartments, trailer parks)?
• Where do the migratory workers in the area come from (i.e., where do they consider their home base to be)?
• When do migratory workers leave the area (i.e., what time of year)? Do they look for temporary or seasonal employment in agriculture and fishing in other places? When do they return?
• Where do migratory workers go to seek employment?
• What type of seasonal or temporary employment do they seek?

This type of information can be found through a number of sources including websites and the field offices of federal, state, and local agencies that focus on agriculture, fishing, labor, and housing issues. LEAs and community organizations that work with migratory families are also good information sources.

Some general Internet sites can be helpful resources for a recruiter. For example, a recruiter can go to an Internet mapping service, such as Google Maps (https://maps.google.com) or Map Quest (https://www.mapquest.com), and enter the name of a local town and state and a search word (e.g., migratory, migrant, orchard, farm, nursery, name of a specific crop, laundromat). The mapping service will provide names and addresses of businesses or organizations related to the search word along with a map that indicates where each is located. More information on using electronic tools to recruit is discussed later in this chapter and a list of resources that the recruiter can use is found in Appendix II of this manual.

In some communities migration patterns are so well established that the local MEP staff know in which residences migratory families and youth live and which employers hire them. In these areas, the MEP staff can often share successful, time-tested methods for finding and enrolling migratory children. Also, many MEPs have recruitment databases that contain helpful information including a list of employers in the area who hire temporary and seasonal migratory workers, approximate dates of workers’ arrivals, the jobs conducted by workers, and their housing unit locations. While recruiters in areas that receive migratory workers may first go to the local migratory labor camps to interview families, the recruiter should also look outside of traditional locales because migration, employment, and housing patterns may change over time. Although a specific approach and strategy may have been successful in the past, this does not mean it will always be successful. It is important for the recruiter to continually conduct new research to find all eligible migratory children in the recruitment area.

Over time, recruiters have developed a shared vocabulary of terms related to ID&R. Knowing these terms makes it easier for the recruiter to conduct research to effectively locate local migratory workers and their families. While states and local project sites often develop their own terms, the following are terms that are commonly used in many states that recruiters may benefit from knowing.

Home Base. Many migratory families have a home base, or hometown, where they live for much of the year. They travel or migrate from this home base to other places to work for temporary or seasonal work. For example, a migratory family might consider Florida to be its home base; the family members live in Florida all winter and work through the citrus harvest in the spring, but then they move to South Carolina to work during the peach harvest. They might also travel to other states or locations and then return to their home base in Florida in the fall.

Send and Receive. A location may either send migratory workers (i.e., workers live in a particular place for most of the year but move to other places to work) or receive migratory workers (i.e., workers come from other places to this place to work). In the example given above, Florida is the family’s home base, so Florida is the sending state. When the family moves to South Carolina to work, South Carolina becomes the family’s receiving state. Some areas send and receive migratory families. A county may receive migratory workers who move from state to state (interstate) as well as those who simply move from place to place within a state (intrastate).

Migratory Streams. Historically, the majority of migratory workers were believed to follow one of three distinct patterns of migration: (1) the Eastern stream, (2) the Mid-continent stream, and (3) the West Coast stream. The Eastern stream flowed east of the Appalachian Mountains, the Mid-continent stream flowed to and from Texas in all directions, and the West Coast stream flowed between Arizona, California, Oregon, and Washington.

Follow-the-Crop Migrants. The term “follow-the-crop migrants” comes from the U.S. Department of Labor’s National Agricultural Workers Survey (NAWS). The term refers to workers who travel at least 75 miles to “multiple U.S. farm locations” over a 12-month period in order to work. This term is now a relative rarity. These workers make up just 5 percent of those surveyed by the NAWS in 2007-09, down from a high of 14 percent in 1992-94 (United States Department of Agriculture, Economic Research Service, 2012).

Shuttle Migrants. The term “shuttle migrants” also comes from the NAWS. The term refers to migratory farmworkers who move more than 75 miles between a home base in the off-season and one or more farm job(s) located in the U.S. during the harvest season. For example, a migratory farmworker who lives in Mexico, travels to the U.S. to obtain a seasonal farm job in agriculture, and then returns home to Mexico to live inexpensively or to supplement his or her farm earnings with nonagricultural work during the off season is considered a shuttle migrant. Shuttle migrants can travel both domestically (i.e., within the U.S.) and internationally. The term is not defined for purposes of establishing eligibility for the MEP.

Bi-national shuttle migrants (usually between Mexico and the U.S.) are often sensitive to changes in economic conditions, employment opportunities, and immigration policies. As these conditions change, so do the migration patterns of workers (e.g., when migratory workers move, where they move from and to, how many move, what type of employment they seek, etc.). The recruiter needs to be aware of any changes in migration patterns.

Settled Out. This term means that the migratory child or family has become permanently established in an area and has stopped migrating for seasonal or temporary farm work.

When I started recruiting, I talked to the recruiters who found the most migratory children. I asked if they would introduce me to the people who were the most respected by migratory families. Over time I’ve developed many good friends, and they help me do a better job of finding migratory children.

As the recruiter begins researching the local migratory community, the recruiter should become familiar with the information sources that are essential to building an effective recruitment network. A recruitment network is a system of contacts, including individuals, agencies, and other institutions, that provides information on identifying and locating potentially eligible children. Establishing a recruiting network and developing a strong working relationship with each member of that network is an important way of finding migratory children who could be eligible for MEP services. When done properly a recruitment network can serve as the eyes and ears of the recruiter.

The five most common information sources when building a recruitment network are

• employers;
• local school staff;
• community contacts, organizations, and commercial establishments;
• other government agencies; and
• migratory families and youth.

The recruiter should encourage members of the recruitment network to refer potentially eligible children to the MEP. At the same time, the recruiter should let network members know that only MEP staff can determine whether a child is eligible to receive MEP services. As a result, network members should be careful not to promise families that their children will receive services. The key sources of information to consider in establishing a recruitment network are discussed below.

In my state, our relationship with local growers is so good that they give us a carbon copy of the pre-employment forms that job candidates fill out when they apply for work. They avoid privacy concerns by having the applicant sign an agreement that the information can be shared. The pre-employment forms help us recruit more efficiently and we also staple it to the hard copy of the COE to corroborate the worker’s employment.

Employers. The recruiter should identify the local employers that are the most likely to hire migratory agricultural workers or migratory fishers. Once identified, it is important to establish good working relationships with them and to explain the value of the MEP, since employers can serve as the greatest allies in the recruiter’s ID&R efforts. Making a good first impression with agricultural employers is key; their cooperation is necessary for the recruiter to gain entry to places where migratory families and youth work and to obtain permission to interview migratory workers during work breaks or after hours.

To break the ice with a new employer it is often beneficial for an administrator to send a letter to the employer that explains the MEP and asks for the employer’s help in identifying potentially eligible children (see Appendix V). The administrator may also wish to follow up with a telephone call. Once the administrator has made this initial contact, the recruiter can contact the employer directly, using the letter as a conversation opener. It is important for the recruiter to gain the trust of the employer, which can be done by demonstrating honesty, responsibility, confidentiality, and consideration to the employer. The recruiter should maintain regular communication with the employer while being mindful that farmers are busy people. The recruiter should make sure not to overburden the employer with constant inquiries as this is sure to diminish their working relationship. The recruiter should do his or her best to make conversations direct and to the point. Additionally, the recruiter should take notice of times when the employer seems less busy, as these times provide quality opportunities to build relationships. When an employer is dealing with a crisis on the farm the recruiter should turn around and come back another time; this is not the time to promote the MEP. The recruiter should wait for a time that is convenient to the employer to explain the purpose of the program and how the employer might benefit from participating in the recruitment network. The best chance for a successful working relationship with agricultural employers is to create a win/win situation. For example:

• Many workers have children and will seek employment in areas that can provide extra services for their children.
• Workers whose children are engaged in school are less likely to leave their jobs, which reduces costs associated with employee turnover.
• Workers whose children are engaged in school are often more productive since they are less concerned about their children and, therefore, better able to concentrate on their jobs. Their children are less likely to be brought to the workplace (creating a liability problem for the employer), to miss school in order to care for a younger sibling, or to be left in an unsupervised home.
• A small investment of time on the part of the employer can result in a happier workforce and better relationship with the larger community.

Because of these benefits, employers are generally supportive of having employees and their families participate in the MEP. In addition, the recruiter can provide other valuable resources to an employer, such as referring migratory families to other useful services including a local migratory health clinic. The recruiter should also build relationships with migratory labor contractors or crew chiefs who can alert the recruiter when new workers who have children are hired.

The recruiter should develop and maintain profiles of the major employers that hire temporary or seasonal agricultural or fishing workers in the local recruiting area. When consolidated, these individual profiles will create an informational directory that the recruiter can expand over time, ultimately serving as the primary agricultural recruitment tool. This resource is not only beneficial to the current recruiter, but it also builds a historical record for future recruiters who may one day take over the region. A profile survey form could include

• general information regarding the workplace (e.g., name, owner, foreman, etc.);
• directions to the work site;
• crops or products, hiring practices (i.e., peak hiring dates);
• housing offered; and
• other facts pertinent to the specific geographic MEP area or work conditions.

The profile form could also include personal notes that are helpful for the recruiter’s future reference, such as where the employer prefers the recruiter to park or the best times of day to visit. Additionally, profiles can reference safety concerns or anecdotes summarizing positive and negative experiences at the work site. A sample workplace survey form that can be used to gather profile data is included in Appendix III. Other sample survey forms are also provided.

Schools. The local schools are another important source of information for the recruiter since schools collect information on every child who enrolls and withdraws. Developing school-based information sources requires the recruiter to think about with whom migratory families are likely to interact within the school (e.g., school secretaries, registrars, attendance clerks, school nurses, guidance counselors, teachers, superintendents, principals, bus drivers, cafeteria workers, and staff members from Title I, Part A, and Title III programs). For example, the family will go to the main office to register, see the nurse to have immunization or health records checked, and in the case of secondary students, visit a guidance counselor to develop the student’s class schedule and check transcripts. A knowledgeable and cooperative secretary can be helpful to the recruiter by referring potentially eligible students and their families to the MEP. In many cases, migratory children ride school buses that transport them to and from school. When bus drivers are educated about basic eligibility requirements, they can inform the recruiter when new children board the school bus at places where farmworkers often live. It is important to ensure that these valuable contacts are aware of the MEP and know how to contact the recruiter with leads.

It is also important to carefully establish and nurture a relationship with district and/or school administrators. Administrators can support the recruiter’s efforts by providing access to key district or school staff, providing information on newly arrived children, and communicating throughout the system that the recruiter’s work is important to the district, schools, and families.

We get permission from the local grocery stores where migratory workers shop most frequently to put flyers about the MEP in grocery bags.

Many local community organizations are funded to provide outreach, social, health, or legal services to migratory and seasonal farmworkers. The recruiter should think about which organizations and services migratory families and OSY are most likely to use in the local community. For example, migratory families may attend local churches, wash their clothes at the local laundromat, shop at local ethnic food markets and flea markets, enroll in ESL classes, enroll their children in Head Start, visit community health centers, and use local cultural centers. They may also receive benefits from local service agencies or farmworker organizations. The recruiter should also think about which agencies and organizations collect data on migratory workers or communicate with farmers in the area (e.g., farm bureaus, growers’ associations).

As with the employers, the recruiter should develop a listing or profile of the businesses or organizations that are the best sources for locating migratory families and OSY. Some communities have interagency committees that work together to coordinate the services that they provide to migratory families and OSY, and may even have community service fairs for migratory workers during peak hiring periods. At service fairs, local service providers typically set up temporary intake offices in a single location to allow migratory families to sign up for a number of benefits and services at one time. This provides a great opportunity for recruiters to enroll migratory children in the MEP and to share important information.

Temporary agencies are another good source for finding leads on seasonal and temporary farmworkers. Many temp agencies provide workers for farms and processing plants on a regular basis. Working with these agencies may open another door to potentially eligible migratory families.

It is also important for the recruiter to think about where migratory families are likely to live, such as migratory labor camps, local apartment complexes that offer month-to-month leases, or shared houses or trailers (sometimes located on the farm itself). The recruiter should cultivate relationships with the owners or managers of these housing units because they can become vital members of the recruitment network. For example, they can alert the recruiter when migratory workers begin moving into the community. The recruiter should visit migratory housing regularly since housing complexes that have previously housed migratory families and/or OSY may have changed policies for accepting new tenants. In this case, the recruiter will need to determine where these workers now reside and start building a relationship with the owners or managers of those units.

Some organizations may not be able to share their contact lists, but may be willing to include information about the MEP in mailings that they send out to local farmers.

Other Government Agencies. The MEP is not the only government program that serves the migratory community. For example, the U.S. Department of Health and Human Services’ Health Resources and Services Administration (HRSA) provides grants to public and nonprofit health centers that support the development and operation of migrant clinic sites throughout the United States and Puerto Rico (https://bphc.hrsa.gov/uds/datacenter.aspx?fd=mh).

The Migrant and Seasonal Head Start Program provides grants to local public and private non-profit and for-profit agencies to provide comprehensive child development services to preschool children of migratory and seasonal farmworkers and their families, with a special focus on helping preschoolers develop the early reading and math skills they need to be successful in school. Other programs that serve the migratory community may include the Women, Infants, and Children (WIC) Program, the Housing Assistance Council, the Migrant Clinicians Network, and Head Start Centers. The recruiter should keep in mind that not all organizations have the same definition of “migrant” or “migratory” as the MEP, and should check with each organization before referring clients. The recruiter should also realize that not everyone who is served by these programs is eligible for MEP services.

Each state has a land grant college or university that addresses agricultural issues and supports a statewide system of Cooperative Extension offices. Extension agents and outreach professionals for each Cooperative Extension office often have in-depth knowledge of local farms and crops and have many contacts in the farming community. Cooperative Extension offices may also offer annual statewide activities, such as farm shows or agricultural days that are good places to meet employers. In addition to local Cooperative Extension offices, recruiters may find the national online extension site (http://www.extension.org) a valuable resource. “eXtension” is an interactive learning environment delivering researched information from land grant university minds across America. The recruiter can enhance his or her knowledge of agricultural crops and industries to better understand and communicate with the farm community in the recruitment regions. Furthermore, the recruiter can find useful research and articles specifically on migratory farmworkers by typing “migrant” into the search engine.

In addition to Cooperative Extension offices, state Departments of Agriculture are another diverse source of information for the recruiter. Most state Departments of Agriculture have marketing boards for the different commodities, such as meat, dairy, fruits and vegetables, etc. These boards are composed of employers and can provide the MEP with access to other employers. Additional sources of information might include state agencies that license or inspect migratory labor camps, National Farmworker Jobs Training Grantees (https://www.doleta.gov/Farmworker/html/NFJP.cfm), and One-Stop Career Centers. Many One-Stop Career Centers (http://www.servicelocator.org) have outreach workers that visit migratory workers regularly. To identify whether a One-Stop Career Center has an outreach worker, you may contact the center directly or contact the State Monitor Advocate (http://www.doleta.gov/programs/MSFW.cfm).

Some government agencies maintain electronic tools that may be of assistance to the recruiter. For example, the National Agricultural Statistics Service (NASS) (http://www.nass.usda.gov/) operates a comprehensive on-line database on agricultural production. NASS conducts hundreds of surveys every year and prepares reports covering virtually every aspect of U.S. agricultural production including numbers of hired farm labor and contract farm labor. Data are available at the state and county level; some data are available by zip code. There is also an Interactive Statistical Map (see Figure 2 below).

Figure 2. The National Agricultural Statistics Service Website

The NASS website enables you to conduct a county level search (https://www.agcensus.usda.gov/Publications/2012/Full_Report/Census_by_State/).

While the data obtained can be valuable in finding out total production data, information about individual farms is not available to the recruiter on the NASS site.

Another diverse resource is the U.S. Department of Labor. This is the government agency that manages the National Agricultural Workers Survey (NAWS) (http://www.doleta.gov/agworker/naws.cfm). This survey is the most comprehensive employment-based, random survey of the demographic, employment, and health characteristics of the U.S. crop labor force. The Department of Labor also maintains the iCERT Visa Portal site (http://icert.doleta.gov/index.cfm). This site provides current and past job order postings for H2A workers made by agricultural employers. The H2A temporary labor certification program allows farms to contract temporary workers when local labor force is not available. While not all H2A workers are eligible due to MEP age requirements, the recruiter may find this site useful for identifying agricultural employers who contract H2A workers. The site is user friendly.

Migratory Families. It is important for the recruiter to develop strong relationships with migratory families. Migratory parents can inform the recruiter about the kinds of community activities in which they participate and the services they use, which is useful information as the recruiter develops a recruitment network. Additionally, migratory parents whose children are currently in the MEP can often provide information regarding other migratory parents who live in their neighborhood, go to their church, or work at a neighboring farm. Finally, migratory families who have had good experiences with the MEP are more likely to seek out the MEP when they move to a new town.

Migratory Out-of-School Youth (OSY). OSY have unique needs resulting from their migratory lifestyle. Some recruiters state that it is even more difficult to locate and recruit the OSY population than it is to locate and recruit migratory families. Fortunately, providing services to OSY can be very rewarding.

OSY need advocates: people who can both motivate them and help them access needed services. Young people not in school have little or no access to federal or state resources.

Recruiting students by waiting in the school for migratory families to come through the door is like lying under a cherry tree with your mouth open. Sooner or later, a cherry will fall in your mouth, but look at all of those you lost out on.

The primary benefit of a recruitment network is to get referrals of potentially eligible migratory children and youth. For example, a community healthcare worker in an agricultural region may notify the MEP if a large number of new families have their children immunized at the local clinic at spring planting time. Each time the recruiter interviews a migratory family the recruiter should ask if the family knows of other migratory families or OSY in the area that the recruiter should visit. Furthermore, the recruiter should actively seek out new organizations to add to the recruitment network. It takes time and effort to build and sustain a recruitment network since the recruiter must continually make fresh contacts, as well as nurture long-standing contacts. However, the benefits outweigh the time commitment required. Here are some strategies for building and maintaining networks.

Personal Relationships Build Professional Relationships. Migratory families often use personal relationships to share information about jobs, housing, schools, and services (including MEP services). Information shared within these informal networks often moves faster than more formal communications (e.g., learning about job openings by word-of-mouth versus in a newspaper). The recruiter can learn valuable lessons from migratory families about how to develop and maintain a network. Over time, the recruiter will develop his or her own networking and communication strategies to develop a strong professional recruitment network.

First Impressions. Making a good first impression can be critical when a recruiter meets a potential member of the recruitment network. The recruiter should be friendly, but should also be sensitive to the responsibilities and workload of the contact. The recruiter who is met with resistance may find it helpful to locate someone who already has a good relationship with the contact and who can allay any concerns the contact might have about the MEP (e.g., a peer, a respected school or community leader, another local agricultural employer who has given permission to do so, or a migratory family who is familiar with the MEP).

Importance of Trust. It is important for the recruiter to earn the trust of migratory families and agricultural employers, as well as the trust of professional organizations that serve the migratory community. Migratory families often have good reasons for being careful about whom they trust. They are vulnerable because they may not have legal standing in the U.S. or financial security. In addition, the words “migrant” or “migratory” may have a negative connotation attached to it for some families, so the recruiter may need to be careful about terminology. In other languages, the word “migrant” may imply or be confused with immigration status. Organizations that work with migratory families recognize the importance of maintaining the trust of their clients and therefore are careful about the information they share and with whom they share it.

The recruiter who is trusted by migratory families and youth reaps many benefits including having migratory families seek him or her out to enroll their children in the MEP and refer other migratory families to the program. Families are also more likely to share the personal employment and family information that is needed to document their children’s eligibility for the MEP (including qualifying employment that may have been performed without a legal work permit or for cash). The recruiter who is trusted by those who work with migratory families can gather important information on where migratory families gather, live, and work.

Trust is built slowly and is based on the experiences migratory families and organizations have with the individual recruiter and with the MEP. Some steps the recruiter can take to build trust include the following:

• Provide clear information on why the recruiter is interested in finding migratory families.
• Describe what migratory families can expect from the MEP.
• Keep promises to migratory families and organizations; be careful not to make promises that cannot be kept.
• Protect the family’s privacy and confidentiality by not discussing other migratory parents and children except in the most positive and professional manner. Always ask permission before sharing information with other professionals or organizations (in writing, if needed).

Develop a Personal Relationship. As with everything else, personal relationships are key to achieving success and to feeling fulfilled. This is true for both recruiters and members of the recruiter’s network. Learning specific information about key contacts can help the recruiter develop an effective professional relationship with members of the recruitment network. For example:

• What is the crew chief’s name?
• When is the school secretary’s birthday?
• Has a local farmer fully recovered from a recent illness?
• When is the best time of day to catch Jaime, an OSY?
• Where do local migratory workers congregate on a Saturday night?

Many successful recruiters make an effort to learn these types of details, include them in their contact sheets, and act on them. For example, the successful recruiter asks about the secretary’s children each time they meet, wishes people a happy birthday, asks for the crew chief by name, visits Jaime at 7:00 p.m. after he gets off work, and participates in the social life of the migratory community.

Communicate Regularly. The recruiter should maintain ongoing contact with the members of the recruitment network by attending key meetings and events. Schools, employers, and community service providers may have their own meetings, or may have collaborative groups that meet for everyone’s benefit. In addition to maintaining professional contacts, this is an opportunity for the recruiter to educate the recruitment network on the MEP. If it is not possible to have ongoing one-on-one contact, there are other ways the recruiter can develop and maintain professional relationships. For example, occasional telephone calls can be an effective way of reminding contacts about the services and successes of the MEP. It is important that the recruiter follow up with contacts regularly to get new information and to let the contact know the relationship is valued.

Follow Up Quickly on Referrals. Each time the recruiter receives a referral it is important to call or visit the contact to acknowledge the referral and to share the results, particularly if it resulted in a child’s enrollment in the MEP. Many programs send cards or official letters from the MEP offering thanks. Taking the time to follow up with contacts validates their effort and good will and can motivate them to provide future leads.

If the recruiter does not follow up on leads quickly, migratory children may not receive extra support and educational services they urgently need. Furthermore, contacts may stop providing leads if the recruiter does not visit the family or youth in a timely manner.

Getting information through personal contacts is one of the most valuable strategies the recruiter can employ. The recruiter should think carefully about how to establish good relationships with key members of the recruitment network, and how to increase their awareness and understanding of the MEP. For network contacts to understand the benefit of sharing information, the recruiter and the MEP must be perceived as credible and as delivering a quality service.

Surveys/Questionnaires. Surveys are another effective way of gathering information from the recruitment network. Survey forms often vary depending on where and how they are administered. However, common survey questions often include

• Have you or your family moved within the past three years?
• Have you looked for work in agriculture or fishing?

Some programs try to ask questions in more than one way on a survey form in case the reader does not fully understand the question the first time. The following are common types of surveys:

• Employer/workplace surveys. The recruiter should survey local employers to determine which ones are the most likely to hire migratory workers (see the sample Migrant Education Program Workplace Survey form in Appendix III). Once the recruiter has identified these employers, the recruiter should encourage them to have new employees complete a MEP survey as part of the hiring process. Other programs have found success by having MEP surveys and recruiter contact information inserted in with workers’ paychecks. The purpose of the MEP survey is to identify those workers who are the most likely to have children who qualify for the MEP (See the sample Migrant Education Program Employee Survey form in Appendix III.)
• School surveys. The recruiter should determine the schools that are the most likely to enroll migratory students based on the presence of a local agricultural community and industry and ask them to distribute migratory surveys to every family during the annual registration process. These schools should also be encouraged to distribute surveys to families who enroll their children after the school year begins (See the sample Migrant Education Program School Survey form in Appendix III.)
• Community agency surveys. The recruiter should encourage community agencies to include screening questions as a part of their intake process to help the MEP identify migratory families. At the same time, the recruiter may refer families to these agencies, where appropriate. This two-way cooperation benefits all involved. Sometimes agencies will want the recruiter to refer clients to them but will not reciprocate. If this is the case, the recruiter should advise his or her direct supervisor. A meeting on the supervisory level between the agency and the MEP may resolve the problem.

The recruiter should ask if the state or local project has conducted any surveys. If so, the recruiter should find out what forms were used and when the surveys were last updated. If the state has not been conducting surveys, the recruiter should initiate the process. As mentioned previously, over time, the collection of surveys will serve as a detailed directory for the recruiters key recruitment networks.

The recruiter should be aware that survey forms alone are not sufficient to record or document a child or youth’s eligibility for the MEP. However, information obtained through surveys provides a good starting point for recruitment efforts by identifying those families who are the most likely to have children who qualify for the MEP, the employers who are the most likely to hire migratory laborers, etc. All states are required to use a COE form to document a child’s eligibility for the MEP (see Chapter 8 for detailed information on completing the COE).

I work closely with the Chamber of Commerce and give out materials from the local town such as lists of business and community resources, maps, and emergency contact phone numbers.

Promotion. In addition to using the recruitment network for referrals or surveys, the recruiter can also use the network to promote the MEP. To use this strategy, the recruiter provides promotional materials to employers, schools, community organizations, and previously recruited migratory families to share with other families that might be eligible for the MEP. In this way, migratory families learn about the MEP and can contact a recruiter to see if they are eligible for services.

Promotion through a network can happen in a variety of ways. The National Institute of Cancer’s Pink Book identifies several ways to promote a program, including interpersonal, organizational, or mass media promotions. These strategies have been adapted to the MEP, as described below:

Interpersonal Promotion. Every time a contact in the recruitment network meets with a family, interviews a family, or makes a home visit, there is an opportunity for that contact to share information about MEP services and to disseminate information about the MEP. Other examples of interpersonal promotion include using a hotline that migratory families can call when looking for MEP services, or having informal discussions about the MEP at migratory “hotspots.” Materials and equipment that can support interpersonal promotion include business cards and toll-free numbers. Even providing a small informational item like a school calendar may remind the migratory family that the recruiter and the MEP are available to help the child participate effectively in school.

Organizational Promotion. A common organizational promotion is to present at a community agency meeting or workplace to educate potential members of the recruitment network about the MEP. This could occur during a regularly scheduled meeting or at a special community fair. A particularly effective form of organizational promotion is providing awareness training about the MEP for key contacts (e.g., bus drivers, registrars, attendance clerks, school nurses, counselors, and teachers). Other common organizational promotions are MEP newsletters, articles in newsletters of other organizations that serve migratory families, posters, brochures, and display tables.

Mass Media Promotion. Mass media offers one of the best means of promoting the MEP to a broad group of people. Radio, television, and newspapers may reach remote areas that the recruiter cannot easily or efficiently explore. Local radio stations and newspapers may be willing to broadcast community service announcements that welcome migratory families to the area. These announcements should reflect the language and culture of the local migratory population (e.g., Spanish-language radio stations in areas where migratory families are predominantly Latino). Newspaper stories, letters to the editor, and visits from local politicians are all ways to maintain community awareness of the MEP and are examples of strategies that help the recruiter “get the word out.” Posters left in strategic places such as churches, supermarkets, laundromats, convenience stores, auto repair shops, health clinics, and other locations that migratory families frequent can educate migratory families who may have eligible children or migratory youth about MEP services.

The recruiter should be aware of community sentiment regarding migratory and farmworker issues; some communities may react to MEP mass media promotions in a negative way. If the recruiter is unsure how the local community will accept mass media promotions, he or she should talk with fellow recruiters and/or the state ID&R coordinator before including it in the ID&R action plan. Furthermore, the recruiter should follow state and local policies on media review, releases, and approvals. In any mass promotion, the recruiter should provide clear information on the basic eligibility requirements so as not to be flooded with families who need help but are not remotely eligible for program services. However, recruiters should avoid providing too much specific information on eligibility requirements so families do not learn the eligibility requirements and provide the information they believe the recruiter wants. In response to specific questions about eligibility criteria, it is best to say, “There are general eligibility requirements and guidelines, but program eligibility is determined on a case-by-case basis.”

Promotions may be particularly effective at reaching the migratory community in both densely and sparsely populated areas. It may be too difficult or expensive to recruit in these areas, so promotions can be used to encourage migratory families to find the MEP, rather than the reverse. Promotions can also be done through cultural or social clubs that may attract migratory farmworkers.

In any promotion of the MEP, it is important to present a consistent message. In particular, everyone who comes into contact with the MEP should have the same understanding of its mission. Promotions should also use uniform symbols or images. One of the greatest tools the recruiter can use is the national MEP logo (shown in Figure 3). Families who are familiar with the MEP may recognize the logo when they arrive in new areas. This familiarity can make the recruiter’s job easier.

Figure 3. The Migrant Education Program Logo.

In order to effectively conduct ID&R activities the recruiter needs to research the local migratory community, develop relationships with key contacts, build and use the recruitment network, and find migratory children. Gathering information on the migratory community before beginning recruitment activities can save both time and effort. Furthermore, it helps the recruiter prioritize key activities and manage time efficiently. Once the recruiter has identified areas that are likely to have migratory families and youth, the next step is to develop an individual action plan. Chapter 5 will discuss developing action plans, contacting migratory families, and implementing safe practices while recruiting.

Every year I work with the recruiters in my region to develop a recruitment calendar. The calendar lists the best times to recruit based on crop cycles, dates of important school events like school enrollment and kindergarten orientation, and when employers do most of their hiring. Each quarter, we compare what the recruiters planned to do with what they actually did and decide how we want to change the recruitment calendar for the next year. We’ve learned how to use our time more efficiently.

Now that the recruiter has determined where migratory families are the most likely to live and work, the recruiter needs to use that information to develop a personal recruitment action plan. Action plans come in many different forms and have different names (e.g., recruitment calendar, “to do” list, time management plan). The goal of an ID&R action plan is to become more efficient at finding all eligible migratory children.

Reasons for Developing an Action Plan. An action plan helps the recruiter, the supervisor, and other recruitment staff, organize and prioritize recruitment activities and establish timelines for their completion. The recruiter who has clear objectives and a plan for reaching them is more likely to be successful than a recruiter who leaves things to chance. The primary reasons for developing an action plan include the following:

• The process of creating an ID&R action plan forces the recruiter to think about what should be accomplished, to establish recruitment objectives, to decide the best way to attain these objectives, and to develop specific action steps and timelines for their completion.
• An ID&R action plan encourages the recruiter to be efficient and to use time wisely.
• ID&R action plans keep the recruiter focused and on task. Recruiters will face many different situations in the field and on the job; an action plan focuses the recruiter to a specific set of tasks.
• The completed ID&R action plan can serve as the basis for evaluating the recruiter’s efforts and for continually adjusting and improving the recruiter’s strategies for finding migratory children.
• If the recruiter leaves the job (e.g., retires, moves), the new recruiter has a clear blueprint of how to recruit in the local area.

Contents of an Action Plan. Action plans are developed at the state, local, and individual level.
Following are some examples of what a plan at each of these levels could include:

1. State. The state action plan provides overall direction for recruiters from across the state. It includes the State’s ID&R objectives, as well as strategies, staff assignments, and timelines to meet those objectives. The state action plan, which may be part of the comprehensive state plan for service delivery or the State’s ID&R manual, could also include useful resources like
1. a statewide map of where migratory families live and work;
2. a calendar with seasonal crop activities;
3. profiles of major crops and employers;
4. recruiter resources (e.g., technical assistance provided by the State, toll-free numbers for recruitment questions, agencies that serve migratory workers and families, related websites);
5. state laws and state and local recruitment policies (e.g., child abuse reporting requirements);
6. the State’s MEP ethics and safety policies; and
7. the State’s quality control procedures, such as the prospective re-interviewing plan.
2. Local. The local action plan should build on the State’s plan and should provide direction for local recruiters. In some states, particularly small states, the local MEP may use the state action plan rather than developing a local plan. The local plan should have ID&R objectives that support the State’s objectives, as well as strategies, staff assignments, and timelines to meet those objectives. The local action plan could also include useful resources like
1. procedures that focus on recruiter safety (see below) and related contacts;
2. a consolidated calendar that tells when to recruit in specific areas (including information like seasons for major crop activities, housing availability, school calendar);
3. maps or directions to major employers, agencies, and schools;
4. who to contact at specific farms, agencies, or schools;
5. enrollment procedures for specific schools;
6. hiring procedures used by individual employers; and
7. any memoranda of understanding (MOUs) between service providers.
3. Individual. The recruiter’s individual action plan should build on the state and local action plans, should be detailed and specific, and should translate into a schedule or “to do” list for the recruiter within a specific timeframe (see the example in Appendix VI). The recruiter’s initial action plan may be rather basic, but the objectives should evolve and improve over time. Year-round recruiters may work with their supervisor to develop an action plan or recruitment calendar. Part-time or summer recruiters may receive very specific instructions from their employer so they can start recruiting migratory children immediately. The local MEP should review the recruiter’s action plan to make sure it is consistent with the project’s recruitment priorities and the state action plan. Action plan recruitment objectives generally consist of the following four parts:
1. what the recruiter will do
2. when the recruiter will do it
3. how the recruiter will do it
4. how the recruiter will measure success

The following are sample recruitment objectives:

• I will visit five agricultural or fishing employer(s) every month as documented by my activity log. (Note: The number of employers visited may vary by district and/or state).
• I will conduct employer surveys with at least six new growers in my recruitment area within the next 12 months as documented by the completed survey forms. (Note: The number of employers visited may vary by district and/or state).
• I will spend three days recruiting at the turkey processing plant in October when they hire seasonal Thanksgiving workers, as documented by my activity log.
• I will implement one new idea from this manual each month as documented by the completed actions on my task list.

Again, note that the recruitment objectives listed above are only examples. It is very important to understand that while it is good to set recruitment objectives such as the examples listed above, the recruiter should NEVER set an objective that establishes a recruitment quota or specifies that more migratory children will be found next year than were found in the current year. For example, a recruiter should NEVER set a recruitment objective that requires finding five percent more children in the coming year than were found in the last year. Furthermore, if the recruiter’s supervisor sets a recruitment quota, the recruiter should report the practice to the next level supervisor or the MEP state director (see the Sample Recruiter Ethics Guidelines in Appendix VII). These kinds of hard objectives or quotas are tied not to correct eligibility determinations but to annual increases in numbers. They therefore raise conflicts of interest that may not only create serious questions about the reliability of a recruiter's eligibility determinations, but also undermine the entire local or state MEP.

The individual action plan can serve as both an evaluation of the recruiter’s work and a time management tool. To evaluate his or her own work, the recruiter may wish to ask questions such as

• Were all of the objectives (i.e., action items) completed?
• Were they completed on time?
• Were the objectives (and the recruiter’s work schedule) revised as the recruiter learned more effective recruitment strategies?
• How can the objectives be improved to find all migratory children while making better use of the recruiter’s time?

The recruiter may also wish to evaluate the strategies in the action plans by asking new migratory families and recruitment network contacts how they heard about the MEP and by tracking the promotional strategies to learn which ones have been the most effective. Updating the ID&R action plan should be an ongoing task.

Each time a recruiter is hired or re-assigned, it is an excellent opportunity to conduct the research needed to develop new local and individual ID&R action plans or to update existing action plans. The recruiter who is new to an area brings fresh thinking to the task and an interest in learning about the local migratory community. Supervisors should gather as much information as possible from departing seasoned recruiters. Supervisors should make sure data logs and contacts have been updated and should consider conducting an exit interview that makes note of any suggestions the recruiter has for improvements. This will help prepare for the next recruiter’s action plan. If available, the recruiter should review state and local ID&R action plans to see what information already exists and talk to local MEP staff about whether any updates are needed. If there is no state or local plan, the recruiter should talk to local MEP staff about how past ID&R efforts were organized. Where action plans have not been developed, the recruiter’s plan could become a starting point for local or state planning.

I look forward to our end of season debriefings. We celebrate our accomplishments and plan for the coming year.

Time Management. To maximize productivity and manage time wisely, the recruiter should work with an immediate supervisor. For example, the recruiter may plan to canvass a migratory camp and visit a Migrant Head Start center located in the same area on the same day. Scheduling visits to several sites that are located in the same geographic area on the same day saves time and travel expenses. Some basic things the recruiter should consider when setting a schedule include the following:

Weekly/daily considerations:

• the best days/hours to work (early mornings, nights, weekends)
• the best times to visit migratory families, schools, and employers
• which employers, farms, or growers to visit in the current week
• when to promote the program with community agencies
• when to be in the office to complete paperwork and follow up on leads
• how the work schedule can be changed when needed

Monthly considerations:

• when to submit daily recruiter logs and other paperwork to the supervisor
• attending monthly recruiter meetings
• whether all schools, growers, employers, and farms have been contacted for
  the current month

Annual considerations:

• the high recruitment seasons
• activities during low recruitment seasons
• when and how often training is conducted
• when professional development should be scheduled
• when to take vacations

To find local migratory farmworkers, I follow the port-a-john trucks to the fields and post flyers about the program on the inside of the doors.

The recruiter’s research and the recruitment network should help identify when and where
migratory families can be most easily found. Some common recruiting sites include work sites, schools, community organizations, and migratory families’ homes. Each of these recruiting sites is discussed below.

To get my foot in the door when I visit a new employer, I bring along someone the employer knows and trusts.

The recruiter may find it productive to visit the employer’s work site and interview migratory families in the fields, processing plant, or migratory labor camps. Depending on the history and the local MEP’s relationship with a particular employer, the approach may differ. For example, is this the MEP’s first contact with this agricultural employment site or does MEP have a pre-established relationship? To prepare, the recruiter may want to do the following:

• Use research and the recruitment network. The recruiter should use the previous research to determine which local employers are the most likely to employ temporary or seasonal migratory farmworkers or fishermen, including which employers have employed migratory workers in the past.
• Meet with individual employers. As discussed previously, if this is a first contact, the recruiter may wish to have the supervisor help establish the recruiter’s credibility with migratory employers by sending a letter about the MEP and following it up with a phone call. This gives the employer advance notice that the recruiter will visit and provides information about the MEP. While an unannounced visit is sometimes the only course of action in order to reach an employer, attempting to provide advance notice is recommended when possible.

In whatever manner the encounter is made, when the recruiter does meet with the employer, the recruiter should

• introduce himself or herself (a firm handshake is common in the agricultural community);
• determine the employer’s knowledge of the MEP;
• as appropriate, explain the purpose of the MEP;
• determine if the employer has temporary or seasonal jobs;
• solicit the employer’s cooperation in recruiting migratory children;
• determine which workers are the most likely to qualify for the MEP or to have a child or spouse who qualifies;
• find out the best times to interview workers (e.g., provide information about the MEP and the upcoming recruitment visit by including it with their paychecks) and which languages the workers speak;
• find out if there are any workplace requirements that the recruiter needs to obey (e.g., parking locations, farm or plant safety measures, where to meet workers);
• schedule the recruitment visit;
• when meeting with key personnel, the recruiter should remember to keep the meeting short, positive, and to the point;
• conduct onsite recruitment – onsite recruitment usually involves direct interviews with family and youth to determine eligibility (see Chapter 6 on Interviewing Migrant Families and Youth); and
• follow up – after the meeting, the recruiter should
• thank the employer;
• discuss the results of the recruitment visit (e.g., how many migratory children were identified);
• solicit feedback on how the employer thought the recruitment visit went and whether any changes need to be made for future recruitment visits;
• ask the employer to inform MEP staff when new workers are hired who might qualify for the MEP or might have a child or spouse who qualifies;
• schedule future recruitment visits; and
• request that employers put MEP contact information in new employee packets or allow the recruiter to hang posters in the employee break room.

I had a hard time getting a school to work with me, so I had my coordinator send the school a letter of introduction and call the school principal. The school was much more open the next time I visited.

The recruiter may find it beneficial to recruit during annual school enrollment periods or to participate in community health fairs or other community outreach efforts. When recruiting at these venues, the recruiter may find it useful to have families fill out “pre-qualification” forms to identify the parents who are the most likely to have children who are eligible for the MEP. If the pre-qualification form looks promising, the recruiter can interview the family immediately. Establishing a positive relationship with school personnel is very important. Many recruiters work with school registrars by having MEP surveys or pre-qualification forms inserted into the school’s new student enrollment packets. Promising surveys then get mailed to the ID&R office, allowing for the screening of potentially eligible families throughout the year. The local recruiter follows up with a phone call to further screen the family for eligibility details, and if eligibility looks good, sets an appointment to visit the family as soon as possible. To find possible leads, the recruiter may want to find out which children are enrolled in other school-based programs that often enroll migratory students, like the ESL program. Similarly, the recruiter should attend community service fairs where local service providers set up temporary intake offices in a single location to allow migratory families to sign up for a number of benefits and services at one time. As with agricultural employment logs and profiles, recruiters may find it useful to keep school profiles detailing the primary MEP contact at the school (registrar, guidance counselor, school nurse, main office secretary, etc.). When the recruiter maintains a contact log, he or she is establishing a record of communication that helps to maintain the relationship. Email is another common form of communication with school personnel.

Get a copy of the student handbook from all the schools in the area where you recruit. Read the handbooks and become familiar with the policies for such things as attendance, discipline, graduation requirements, and grading periods. Keep the handbooks for reference. Then you’ll be prepared to help the parents when they have questions.

Residence-based Recruitment. Canvassing, or going door-to-door, is the primary form of residence-based recruiting. However, if there is insufficient preparation or research done before conducting a canvass, it may not be the most efficient method. For example, it can be extremely efficient to go door-to-door looking for migratory children in a migratory labor camp. On the other hand, it can be extremely inefficient to randomly go door-to-door in a large urban center. Through research and the recruitment network, the recruiter can often identify the most productive areas to canvass. For example, the recruiter is likely to find migratory children in housing near local farms and in modest apartment complexes or local trailer parks where migratory children have been found in previous years. The recruiter may want to use the State’s migratory student database to print off a list of children along with their previous addresses that have been eligible in the past to look for them as well as any new children who may be residing in the same area.

It can be useful to invite school personnel to participate in recruitment visits to break down barriers between the school system and migratory families. Moreover, it is often preferable for teams of recruiters to canvass together, especially in areas where large numbers of OSY might be found.

A good recruiter is prepared. Recruiters should always have a stocked toolkit on hand containing materials and resources relating to ID&R, such as

• blank COEs and pens (or a laptop computer or tablet with an electronic national COE);
• a local map that can help identify promising areas in which to recruit;
• an online georeferencing map or other directional guide;
• the Child Eligibility Checklist (Chapter 7) and the Sample Interview Script (Appendix VIII);
• business cards or a badge that identifies the recruiter as being employed by the MEP;
• brochures on the MEP;
• local school student handbooks;
• language dictionaries (e.g., English/Spanish);
• important contact information (e.g., names and phone numbers for the recruiter’s supervisor and co-workers, key school personnel, emergency contact information for local hospitals and police, etc.);
• local resource guides (e.g., a list of local schools, social service agencies, adult education materials);
• school information (e.g., school bus schedules, enrollment procedures, school calendars);
• “While-You-Were-Out” doorknob hangers or sticky notes that include the recruiter’s contact information;
• a U.S. atlas and list of state abbreviations to look up the spelling of city names when filling out the COE;
• maps of Mexico and a state/city index to help identify migratory family origins and to help the recruiter look up the spelling of city names in Mexico when filling out the COE;
• a cell phone, walkie-talkie, or other communication device; and
• a whistle or other safety device.

Each of the three main recruitment activities (i.e., employer-based recruitment, school and community-based recruitment, and residence-based recruitment) is effective in certain settings. Therefore, the recruiter should mix and match these approaches, depending upon which will be the most effective and efficient in the local community. For example, K-12 students are usually the easiest to locate, as they are are likely to attend school. Parents bring the children to school to register, and elementary school-aged children, in particular, usually attend regularly. Networking at the school and getting referrals from school staff can be an effective and efficient strategy for recruiting these students. Pre-school children, on the other hand, may not have any connection to the school system unless a local school or other agency operates a daycare or preschool; thus, the recruiter may need to find pre-school children through networking with other service agencies, agricultural employers, or by canvassing in neighborhoods where migratory families often live. Finally, OSY, who are often teenagers, are usually found in the community where they live or work. Promotional activities combined with employer-based recruitment may be the best way to contact this hard-to-reach group.

Dogs have chased me on recruitment visits, so now I always check to be sure that they are chained. If they aren’t chained, I stay in my car and call for someone to come out and get the dog before I get out of the car. I’m required to call my office twice a day so they know I’m safe.

The recruiter should always be alert to the surroundings and be aware of his or her personal safety and security. Driving down a country road after dark, entering a building in a dangerous part of town, coming across threatening dogs guarding a farmhouse, or being female in a camp full of males are just a few situations the recruiter may encounter. Many of these circumstances arise in any outreach job and some occur because of the rural nature of ID&R. Each MEP should have safety policies that are reviewed during the recruiter’s initial training. In addition, many MEPs find it useful to meet annually with local law enforcement officers to review personal safety strategies. Planning, preparation, awareness, and common sense can be the recruiter’s best defense. Experts on safety refer to an individual’s “instincts” or “sixth sense” that warns of danger. If a situation does not “feel” right, the recruiter should rethink the visit and return another time. Safety is always the first priority of the MEP. No student enrollment opportunity is greater than a recruiter’s personal safety. If the recruiter is in a dangerous situation, he or she should leave and return another time with additional support (recruitment team or agricultural employer). Using personal safety strategies such as those described below are important. States may come up with a range of safety measures. For example, some safety strategies may be best practices, others may be part of a safety system and finally, many states enforce safety protocols.

Best practices for recruiters include the following:

• Only enter migratory housing if necessary; most recruitment paperwork can be completed outside regardless of the season.
• Conduct pair or team recruiting visits whenever possible.
• Female recruiters can have a male outgoing message on their voicemail such as,
  “Hi, you’ve reached Jen and Jason, please leave a message,” in order to deter unwelcomed voicemail and text message advances.
• Always have car keys readily accessible.
• Always carry a cell phone; 911 still works without a service provider and in many cases you can still text 911 with no reception.
• Consider carrying mace or pepper spray.
• Pay attention to instincts; recruiters should react appropriately if feeling unsafe.
• Pay attention to personal behavior; sometimes a recruiter’s friendly behavior can
  give the wrong impression, especially if cultural differences are present.
• Notify farm employer or manager upon visiting farm worker housing.
• Consider taking a self-defense course.

Best practices for systems include the following:

• Pre-schedule farm visits whenever possible.
• Use a buddy information system with colleagues to keep everyone informed of when and where the recruiter is going to be while conducting recruitment efforts.
• Provide training on proper responses to uncomfortable advances.
• Provide training on how to report incidents and provide samples of previous reports to make new staff aware of potential situations.

Protocols include the following:

• Do not distribute personal phone numbers of colleagues (or others) without their permission.
• Dress code—recruiters should wear MEP t-shirts and/or MEP vests if possible.
• Maintain a schedule with information on when and where recruitment efforts will be
  taking place.
• Do not recruit after dark unless pre-scheduled and accompanied by a buddy. (University of Vermont Extension, Migrant Education Program, 2011)

The information provided above is intended to be utilized as a guide to help ID&R administrators and recruiters come up with their own safety measures. While serious safety situations are a rarity in the MEP, unfortunately they do occasionally occur. The best defense against danger is being informed, having a proactive safety plan, and knowing what to do if a problem does occur.

Communication. The recruiter should always carry a cell phone with emergency numbers in the speed dial and have a backup plan for rural areas that may not have cell phone reception (recruiters who do not have a cell phone may want to invest in a walkie-talkie or other communication device). Before going on the road, the recruiter should tell a responsible coworker the day’s visitation schedule and an expected time of arrival back at the office or home. When recruiting at a work site, the recruiter should check in with the farmer or crew leader before beginning recruitment activities. The authorities should be notified if the recruiter does not arrive at a particular destination on time and cannot be reached by telephone.

Local Knowledge. The recruiter should plan visits with safety in mind. Knowing which labor camps or neighborhoods may be cause for concern or what apartment complexes should not be visited alone may keep the recruiter from entering a potentially dangerous situation. The recruiter should consider which areas are best visited during daylight hours and whether a team, rather than an individual, should visit a particular apartment building. This type of information, which may be shared by local school personnel or community agency staff, should never be ignored. The recruiter should also be aware of the locations of local police stations, hospitals, and businesses that are open late. It is also important that the local community is aware of the MEP and the recruiter. Wearing a badge that has the recruiter’s name and place of employment can establish credibility and identity in case of an emergency. The recruiter should also be careful not to share too much personal information, particularly his or her home address or home telephone number.

Transportation. Recruiters should make sure that car doors are locked when not in the vehicle and should also keep valuables out of view. The recruiter’s car should be properly maintained and mechanically sound. Having a reliable car with a full tank of gas is a necessity when driving in rural areas. When possible, the recruiter should choose well-traveled roads and avoid shortcuts through isolated areas. The recruiter should have good maps (traditional or those downloaded from the Internet) to avoid getting lost. Many recruiters are issued GPS units or other navigation devices to aid in recruitment safety and efficiency. Emergency items (car jacks, flares, blankets, matches, flashlights, candles, water, a shovel in colder climates, etc.) can help the recruiter stay safe until help arrives in the case of an accident or an emergency.

The most effective recruiters plan their work and follow their plan. Gathering information on the migratory community before beginning recruitment activities and using that information to develop an individual action plan can save both time and effort. Furthermore, individual action plans help recruiters set priorities and manage time efficiently. The recruiter should consider which recruitment strategies are the most likely to be successful when developing his or her own recruitment action plan. Safety factors must always be considered when planning work in the migratory community.

Once the recruiter has identified areas that are likely to have migratory families, the next step is to interview individual families and youth, using the Sample Interview Script provided in Appendix VIII. Chapter 6 provides an interview protocol, discusses the interview process, and provides lessons learned from interviewing.

Recruiting requires a great deal of knowledge, skill, and sensitivity. In particular, the recruiter needs to thoroughly understand the MEP child eligibility requirements and be able to ask probing, yet not leading, questions to make informed decisions about whether a child or youth qualifies to receive MEP services. Furthermore, the recruiter needs to solicit this information without offending the migratory family or youth. This chapter addresses how the recruiter prepares to interview migratory families and youth, as well as how the recruiter should conduct the interview.

Is interviewing a science or an art? Is it the science of understanding rules and regulations, completing paperwork correctly, analyzing data, and making accurate eligibility determinations? Or is it the art of talking to people one-on-one to elicit information that may be very personal? Interviewing is both. The recruiter must strike a balance between having a relaxed conversation and gathering the very specific information needed to determine child eligibility.

Conducting a thorough interview and accurately documenting the information collected is key to determining a child’s eligibility for the MEP. Therefore, in addition to the National COE (or COE), the official record of the state’s eligibility determination for each individual child, many states also utilize a supplemental interview form to gather supporting information. For this purpose, a Sample Interview Script has been provided in Appendix VIII to guide the recruiter through the actual interview process. This chapter will walk the recruiter through the process immediately before visiting prospective families or youth all the way through what to do after completing the interview.

To determine whether a child or youth is eligible for the MEP, the recruiter needs to interview the migratory worker or another responsible adult to obtain information regarding eligibility. Supplemental interview forms guide the recruiter through a series of questions to create a structured, yet comfortable, conversation to draw out the information needed to make a preliminary eligibility determination. It is the recruiter, not the migratory worker, with the help of other MEP staff, who makes the preliminary eligibility determination of whether a child qualifies for the MEP. In many states, it is the ID&R Coordinator or state MEP Director who makes the final eligibility decision. The recruiter should always remember his or her role.

While a supplemental interview form is a useful tool in determining child eligibility, it is not all-inclusive. There are situations where the recruiter may need to ask different questions to address a particular interview situation. However, supplemental forms provide two purposes: a starting point for new recruiters to understand the basic questions to determine child eligibility, and a supporting record of the underlying information the COE is designed to collect. The new recruiter may find a script more useful than a veteran recruiter. However, the veteran recruiter should consider making a script part of the standard interview process to ensure that he or she is asking all of the key questions through the process of the interview.

The Sample Interview Script in Appendix VIII is formatted to guide the new recruiter through an eligibility interview. It is organized into six sections that reflect the interview process. The sections, which are named for the tasks the recruiter should complete, are

1. Lay the Groundwork for the Interview
2. Transition to the Interview
3. Gather Information on Child Eligibility
4. Transition to the Confirmation Process
5. Confirm Responses
6. Close the Interview

The first two sections are introductions and explanations. The third section is what could be referred to as the eligibility interview, where the recruiter asks questions of the family or youth to determine eligibility for the MEP. After gathering information through these questions, the recruiter transitions to a summary and confirmation of the eligibility information. Finally, the recruiter closes the interview and leaves the family or youth.

Each section of the Sample Interview Script has a title and a series of basic statements or questions (written in regular typeface) that the recruiter should ask. Instructions to the recruiter and notes are written in italics or are provided as footnotes at the bottom of the page; the recruiter should not read these aloud since they are meant to guide the recruiter in completing the interview.

Section 3: Gather Information on Child Eligibility includes questions that are used to determine child eligibility. The section is organized by the factors in the Child Eligibility Checklist found in Chapter 7. Section 3 also includes a list of the items in the COE that the questions address. The script also provides space for the recruiter to take notes on the interviewee’s responses.

When using the Sample Interview Script, the recruiter should keep the following in mind:

• If the questions and subquestions do not draw out the information the recruiter needs, the recruiter can ask questions from the “Additional Questions” provided to obtain the same information in a different way or to request additional information, only if needed, to confirm, clarify, or supplement the initial response.
• If a recruiter gets a response to a question that would make a child ineligible for the program, the recruiter should make sure the interviewee understood the question before terminating the interview. The recruiter can restate the question in another way, using one of the additional questions provided, being careful not to lead the interviewee or make it appear as if there is a “right” answer.
• Space is provided on the Sample Interview Script form for notes.

Section 3 of the Sample Interview Script addresses the following Child Eligibility Factors:

• FACTOR 1: CHILD’S AGE: The child is younger than 22 years old on the date of the interview.
• FACTOR 2: CHILD’S SCHOOL COMPLETION STATUS: The child is entitled to a free public education (through grade 12) under state law. For example, the child is not a high school graduate or does not hold a HSED.^[3] OR, the child is not yet at a grade level at which the school district provides a free public education.
• FACTOR 3a: CHILD'S QUALIFYING MOVE: The child moved within the 36 months preceding the date of the interview. The move made by the child was due to economic necessity, AND from one residence to another residence, AND from one school district to another.
• FACTOR 3b: CHILD'S QUALIFYING MOVE RELATIVE TO THE MIGRATORY AGRICULTURAL WORKER OR FISHER: The child’s QUALIFYING MOVE in FACTOR 3a was with, to join, or to precede a parent, guardian, or spouse who is a migratory agricultural worker or a migratory fisher (whose status has been determined in Factors 4a and 4b).
• FACTOR 4a: MIGRATORY AGRICULTURAL WORKER’S OR MIGRATORY FISHER’S (MAW/MF) QUALIFYING MOVE: The parent/guardian/spouse or child (if the child is the worker) moved within the 36 months preceding the date of the interview, AND the move made by the parent/guardian/spouse or child (if the child is the worker) was due to economic necessity, AND from one residence to another residence, AND from one school district to another. ⁴
• FACTOR 4b: QUALIFYING WORK FOR THE MIGRATORY AGRICULTURAL WORKER OR FISHER: After the qualifying move in Factor 4a, the parent/guardian/spouse or child (if the child is the worker) engaged in new qualifying work soon after the move, OR did NOT engage in new qualifying work soon after the move, but he or she actively sought new qualifying work, AND has a recent history of moves for qualifying work. The qualifying work is seasonal employment, OR temporary employment, OR personal subsistence. The qualifying work is agricultural OR fishing.

The eligibility factors are based on the definition of a migratory child, migratory agricultural worker, migratory fisher, and qualifying move found in the statute. Chapter 7, will discuss how to interpret the interviewee’s responses.

Variations of Supplemental Interview Forms. While the Sample Interview Script described above provides a very detailed guide for the new recruiter, other supplemental interview forms may be more condensed for a traditional interview situation. The purpose of supplemental interview forms is to provide a recruiter with the questions needed in order to consistently obtain sufficient information to make an eligibility determination for a migratory child, youth, and family.

While no tool can meet the needs of every state, every recruiter, and every interview, states may wish to adopt a supplemental interview form to address state initiatives or to meet quality assurance goals. In some states, the recruiter may need to collect additional information that is required for the CSPR or for special program services, or may want to collect information on children’s home language, learning skills, or medical history including immunizations. Finally, the state may want to revise a supplemental interview form so it can be used to conduct re-interviews. Although recruiters are not required to use supplemental interview forms, every interview should address all of the child eligibility factors discussed in Chapter 7.

Asking Screening Questions. After the new recruiter has conducted several interviews and has gained experience with the structure and questions, he or she might want to select a few questions, as briefly mentioned above, that can be used to screen families and youth. This practice helps by quickly screening whether anyone in the household meets the primary eligibility criteria, thereby warranting a full interview. Although the most reliable way to determine which children or youth are eligible for the program is to conduct a full interview with every prospect, because of time constraints, the recruiter may decide to focus on those children and youth who are most likely to be eligible. As a word of caution, however, the recruiter must be very careful not to allow his or her implicit biases impact which families or workers he or she selects for interviews after screening. Any decisions on who should not receive a full interview should be based on objective facts, such as any eligibility factors that are obviously not met. The recruiter should recognize that using screening questions will mean that some eligible children are likely to be missed, so the recruiter must weigh the need for efficiency against the importance of identifying all eligible migratory children.

A recruiter may realize during a screening conversation that the circumstances of the family or youth are ambiguous or complex and therefore pose challenges to determine whether the family or youth might be eligible. If the recruiter is unsure whether the family or youth meets eligibility criteria after asking some screening questions, rather than decide not to follow up with a full interview, the recruiter should consult with his or her supervisor. The supervisor may have more experience to help analyze the information obtained from the family or youth or may recommend additional questions to clarify the family’s or youth’s circumstances. The risk in not seeking help and not persisting in getting more information is that the recruiter may miss qualifying an eligible child or youth who needs MEP services.

If the recruiter uses screening questions, he or she should not make a preliminary eligibility determination without asking all of the questions (except for the “Additional Questions”) on the Sample Interview Script. The type of friendly conversation that often occurs during an initial screening will not give the recruiter enough information on each of the child eligibility factors to make a reliable child eligibility determination. During the full interview, the recruiter will need to ask enough follow up questions to gather all needed information. Asking screening questions may help the recruiter use time wisely by only conducting interviews when it is likely that a child or youth will be eligible for the MEP. However, screening questions cannot replace a full interview.

Changing the Order of Questions. Another adaptation or modification that a recruiter might consider is changing the order of the questions on the supplemental interview forms to get at the questions that would be most likely to disqualify a particular child or youth first. For example, if the recruiter is interviewing a mother who has three young children with her, the recruiter might find it more productive to begin the interview by asking whether the family has moved within the last 36 months rather than by asking the ages of the children. If the family has not moved, there is no reason to proceed further with the interview. Also, the recruiter may want to change the phrasing of questions to use language that local families might be more familiar with or may want to translate the questions into the family’s native language. Although recruiters have the flexibility to modify the order of questions, recruiters must examine the child eligibility factors to determine whether a child is eligible for the MEP.

³ The recruiter should find out which older children are still entitled to a free public education in his or her state. If a question arises (e.g., the child has a secondary school degree issued by another country or has received a certificate of completion in lieu of a diploma), the recruiter should find out from state officials whether the child is entitled to continue to pursue a high school diploma in that state. ↑

⁴ In a state that is comprised of a single school district, the child moved from one administrative area to another within such district or resides in a school district of more than 15,000 square miles and migrates a distance of 20 miles or more to a temporary residence. ↑

I don’t jump into a full interview too soon. I let the family see me around before I do a full interview.

Although the interview is the most important interaction in ID&R, there is important preparation work that the recruiter must do to make the interview successful. The state or local program may require the recruiter to complete some or all of the following activities before, during, and after interviewing families and youth.

Before the Visit. When the recruiter makes a home visit, often without an invitation or advance notification, the recruiter is stepping into the world and culture of the migratory family. Therefore, it is important for the recruiter to make a good first impression and respect the dignity of the individuals and families being visited. The following are general steps the recruiter may wish to follow prior to visiting a family:

• Pre-screen families or youth prior to the visit, if possible. For example, follow up with families or youth who have completed either a school or employer survey such as the ones found in Appendix III and appear to be eligible for the program or have a child or spouse who is likely to be eligible. If that is not possible, the recruiter can call the family prior to the visit or get information from others who know the family or youth.
• Develop a schedule of whom to visit each day and get directions to the family or youth’s home or workplace. If interviews will be conducted at a housing unit or work site, contact the housing unit manager, farm owner, plant manager, etc. first to explain the reason for the visit and ideally obtain permission to conduct the interview (see the sections on Identifying Important Information Sources and on Building Relationships and Gathering Data in Chapter 4).
• Determine whether an interpreter is needed and, if so, make suitable arrangements. Bring a copy of the COE that is translated into the family’s native language. Find out as much as possible about the family or youth’s needs prior to the visit so that the recruiter can bring useful resources. For example, if an older child did not complete high school, the recruiter may want to bring information on a local high school equivalency (HSE) program.
• Print out information on the family from the state migratory student database, if available, such as any COE data that is in the system or a list of courses the child has taken that are only partially complete.
• Dress neatly, but not too formally, so that the family feels comfortable.
• Give a colleague a copy of the day’s schedule, complete with locations, approximate times, and when the recruiter expects to return to the office or home (see Safety While Recruiting in Chapter 5). Notify the office or a co-worker if plans change.
• Print a copy of the Sample Interview Script and the child eligibility factors to be addressed during the interview.
• Bring any materials the recruiter will need to complete the COE and any other forms required by the state. For example, some states require the completion of a needs assessment for all families or an OSY profile for every OSY enrolled into the program. Some states use a paper copy of the COE form and require a pen. In other states, tablets, smartphones or laptop computers may be used (see suggestions for what to take on a recruiting visit in the section on Contacting Migratory Families and Youth in Chapter 5).
• Take time to get organized before conducting each interview. Fumbling for promotional materials or COEs makes the recruiter look ill prepared and can reflect poorly on the MEP.

During the Visit. As stated previously, during the interview, the new recruiter should follow the Sample Interview Script. Supplemental forms provide detailed questions that the recruiter should ask; however, the following are additional guidelines to follow when interviewing:

• Observe the surroundings. The recruiter should always be observant about the family or youth’s environment. For interviews that are conducted at the home or workplace, the recruiter should look for clues that may require the recruiter to ask additional questions to help determine if the child is eligible for the MEP. For example, seeing that a migratory family is operating a well-established day care center out of the home might alert the recruiter to ask more questions about whether the family has moved within the last three years. The recruiter should use all available information to ask the right questions to accurately determine the child’s eligibility for the MEP.
• Make introductions and explain the purpose of the visit. The recruiter should begin by introducing himself or herself and explaining the program the recruiter represents and the reason for the visit. It is not necessary to go into great detail about MEP services, but the recruiter should provide enough information to put the interviewee at ease so the recruiter can gather accurate information. A parent or youth may feel less apprehensive and may be more forthcoming if he or she understands the reason for the interview. The recruiter may also want to point out that he or she is not selling anything; the MEP is free for eligible children and the information they provide is confidential.
• Find common ground. The recruiter will need to think about how to build a rapport with migratory families. Saying things such as, “I see we both have three children” or “You’ve lived in Texas; I’ve been to Texas several times and really liked it” may relax the interviewee and keep the conversation going as the recruiter obtains the required information. Making friendly conversation with the children or admiring a pet or a child’s artwork may also make parents feel more comfortable.
• Use a conversational tone. This will help put the interviewee at ease and will make the recruiter more likely to obtain accurate information. Administrators often try to hire recruiters who are friendly, non-threatening, and if possible, from similar cultural backgrounds so families and youth feel comfortable talking with them. Being too “business-like” or asking probing questions too quickly can make a family or youth feel uneasy and unwilling to share information. Having an understanding of possible cross cultural differences will help to set the proper tone of the interview. (Texas Education Agency, 2011)
• Take notes. The recruiter should always take notes during the interview rather than rely on memory. These notes, which can be filed with the completed COE or on a supplemental interview form, become important when an eligibility determination is questioned or when a third party requests additional information on how the decision was made (e.g., as in the case of a quality control re-interview, or in an appeal by a parent).
• Practice active listening. The recruiter only gets the information that is needed when the interviewee is talking. Therefore, the recruiter should be sure not to dominate the conversation. The recruiter should use active listening skills, including techniques like the following:
• Focus on the speaker.
• Sit near the speaker.
• Lean forward in an engaged pose.
• Restate the speaker’s key points.
• Summarize the conversation.
• Ask relevant questions.
• Show interest through facial expressions and gestures like nodding.
• Let the speaker rest after talking.

Interrupting speakers, dominating the conversation, or even coaching answers from a parent or youth is not only a sign of disrespect, but it can lead to faulty eligibility determinations.

• Repeat or reword questions. The recruiter should feel comfortable asking a question a second time or approaching it from a different angle. For example, a recruiter might ask, “Has your oldest daughter graduated from high school?” “Has she received a HSED?” “Did she take a test and receive a certificate that said she passed high school?” Rewording a question may help the interviewee understand what information the recruiter is seeking.
• Answer questions or make a note to follow up. If the family or youth asks a question that the recruiter cannot answer, the recruiter should not be afraid to say, “I do not know the answer to that, but I’ll be glad to find out for you.” It is much better for the recruiter to admit not knowing something than to give the wrong answer. Writing down any questions or concerns the family or youth might have and following up with them later will help build the recruiter’s credibility within the migratory community.
• Ask for additional information or documentation. Following are several common scenarios in which the recruiter is advised to ask more questions or to get additional documentation:
• The facts are unclear. An interviewee may give conflicting or unclear answers because of fear or stress, an inability to recall specific information, language issues, or other unintentional reasons. In particular, it is critical to gather enough information to be able to develop a timeline to chart moves, qualifying moves, dates of engagement with qualifying work, QAD, etc. because these dates determine if a child or youth is eligible for MEP services and on what date eligibility begins. For example, one family member may say the family moved in the spring, and another family member may say they moved in the summer. The recruiter should ask for more information to clarify the date of the move. Another example is where language issues prevent the recruiter from getting clear responses to eligibility questions (e.g., the person being interviewed speaks a language that is not typically spoken in that area and the local project is unable to find a good translator). Again, the child should not be enrolled until the MEP has enough information to determine if he or she is eligible.
• It is not clear that the employment the worker is engaged in or actively sought is qualifying work. If the worker moved to find work that the state has not qualified previously, it may not be clear whether the work meets the definition of being agricultural or fishing or of being temporary or seasonal employment. In this case, the recruiter would need to collect enough information to allow the state to determine if the work qualifies for purposes of the MEP.
• The worker did not engage in qualifying work soon after the move, information (1) on the ways in which the worker actively sought such employment and (2) the recent history of the worker’s moves for qualifying work is not evident. (These moves do not have to be qualifying moves.) For workers who did not engage in qualifying work soon after the move, the recruiter needs information on both (1) and (2). The recruiter should ask the worker about where he or she applied for work and how many potential employers he or she contacted within 60 days after the move. See the NRG for a recommended interpretation of “soon after the move” (NRG, Ch. II, C5). Also, the recruiter should review information on family moves that may be available in the state MEP student database or Migrant Student Information Exchange (MSIX).
• The recruiter suspects that the family has not been truthful. In some cases, parents may say whatever they need to say to get their child a desired MEP service (e.g., extra tutoring). For example, a worker may claim to have moved to another state for qualifying employment during a specific time period. However, the recruiter may have viewed records that show the children in attendance at the local school or seen the worker in town during that time. In this case, the recruiter should ask for additional information such as proof of employment that may include verbal confirmation from the employer, a copy of a pay stub, or a copy of an employment application. The recruiter might also speak with school personnel to find out if the child missed any school during the time the worker claimed to have moved to another state.
• The family made a short duration move. If a move was of an extremely short duration of time, for example a few days or less than one week, it may be questionable whether the move was a change in residence. In situations such as short duration moves the recruiter should ask the State for its written policy for determining and documenting when and why these moves qualify for the MEP. In cases where change of residence may be questioned, the recruiter should clearly document on the COE why he or she believes that a move of such short duration would be considered a qualifying move.
• It is not clear that the move was made due to economic necessity. The MEP is premised on the Federal government’s understanding that migratory children have unique needs in view of their mobility, and generally are in low-income families. However, the statutory requirement that a qualifying move be made due to economic necessity clarifies that, under the ESEA, economic necessity is integral to a move that makes a child a “migratory” child. Thus, a person who leaves from the place where he or she lives to, for example, (1) visit family or friends, (2) attend a wedding or other event, (3) take a vacation, (4) have an educational or recreational experience, or (5) take care of a legal matter, would not have “changed residence due to economic necessity” because the person did not go to the new place because of financial need. Similarly, this person would not have “changed residence due to an economic necessity” upon returning home from one of these visits. The recruiter may want to ask additional questions if it is not evident that the move was due to economic necessity, as defined above.

Additional documentation should only be requested when the information is needed to o determine a child’s eligibility for the MEP, since parents may view these requests as unnecessary and intrusive. The recruiter should talk with a supervisor to decide if additional documentation is needed and, if so, what type of documentation to request (more information on documentation is provided in Chapter 7). If the recruiter and supervisor are not able to determine if a child is eligible for the MEP because the parent is unwilling to provide additional documentation or there are still questions about the child’s eligibility after the recruiter reviews the additional documentation, the child should not be enrolled in the MEP.

• Confirm the information on the COE and get the form signed. The recruiter should review the COE with the person who was interviewed to make sure that everything recorded on the form is accurate. When you review the information, the interviewee may make corrections or remember additional details; the recruiter should take the time to get it right. The recruiter should summarize the information gathered from the interview and repeat it back to allow the interviewee to make corrections if necessary. Once any needed corrections have been made to the COE, the recruiter can then ask the interviewee to sign the form to verify that he or she provided the information and that it is true to the best of his or her knowledge. The recruiter may have permission slips or other forms that need to be signed as well.
• Thank the interviewee and ask for referrals. The recruiter should thank the interviewee for his or her time and ask whether there are other farmworkers or fishers who live in the local community who might be eligible for the program or have additional family members or co-workers who might be eligible.

  I’m careful not to promise the family that their child will receive services because my state doesn’t get enough money to serve every child. I’d rather tell the family that I will find out whether their child can get extra services so I don’t promise something I can’t deliver. I want migratory families to be able to trust me.

After the Visit. After the recruiter has completed the interview portion of the visit, he or she should do the following:

• Check the COE to make sure it is complete, clear, signed, and correct (see the sample COE Review Checklist in Appendix XII).
• If needed, consult with the translator to verify the information on the national COE and observations regarding the interview.
• Make a note of any observations about the family or youth that may assist in making the final eligibility determination.
• If appropriate, thank the housing unit manager, farm owner, or employer for being cooperative.
• Follow up on any promises made to the family during the interview.
• With the interviewee’s permission, contact community agencies and provide them with referral information so they can help address any needs the family may have that are outside of the scope of the MEP.
• Where required by the state or local program, record the interview in an activity log (i.e., a record of how the recruiter uses his or her time) and complete any other required paperwork.
• If the recruiter gathered any new or updated information from the family or youth, enter that information in the state or local migratory student database.
• Avoid sharing private information about the family that came out of the visit. Respecting confidences is a way of gaining the respect and trust of the family. Much of this information is also protected by privacy laws.

The recruiter may encounter any number of difficulties during an interview. While it is impossible to anticipate every possible issue a recruiter might encounter, some of the most common are discussed below.

Resistance. Migratory family members or youth may refuse to be interviewed or may not want to disclose information about their employment, particularly if the family or youth is not familiar with the program. While there are many reasons why a recruiter could face resistance, one reason is that a number of recent immigrants and farmworkers are uneasy about providing information to a government representative for privacy or other reasons. It is important that the recruiter assure the interviewee that the COE will only be used to document the child’s eligibility for the MEP and that the MEP does not collect information on immigration status of a family or individual. By explaining the MEP’s basic purpose, the recruiter may be able to persuade the family member to allow the recruiter to interview him or her. The recruiter may also ask a family who has been served by the MEP to talk with the new family. Many times a resistant migratory family or youth will become more cooperative after talking with a satisfied parent or other OSY. Another strategy is to give the family time to think about the request and come back later.

To overcome resistance, it might be helpful for the recruiter to make the following points:

• A family or worker’s immigration status is not a factor in determining eligibility for the MEP.
• In the U.S., all children are entitled to receive a K-12 education, regardless of their immigration status. In fact, each state has compulsory school attendance for children who are within a specific age range^[5].
• The state is required to look for all children who are eligible for MEP services.
• The MEP is a supplemental educational program that helps migratory children who are struggling to keep up in school due to factors such as a lack of educational continuity, lost instructional time, difficulty adjusting to a new school, lack of educational support in the home, health issues, and access to services.
• Even if a child does not need help at this time, the family should know about the MEP for future reference.

The recruiter does not need to mention all of these points if the family is comfortable with sharing information or already knows about the program.

Assumptions and Judgments. The recruiter is susceptible to making assumptions and judgments about people he or she encounters that may make interviewing difficult. Some common assumptions the recruiter may unintentionally make include those found in Table 1.

Table 1. Eligibility Interviewing Assumptions and Facts

The recruiter may unconsciously make judgments about individual families or youth that affect the outcome of the interview. For example, over time the recruiter may become aware that some families are more or less respected by other members of the local migratory community. The recruiter should be careful not to base eligibility decisions on assumptions or judgments formed by others, but rather look objectively at the facts. Even if the recruiter is uncomfortable with a particular family or youth’s lifestyle or behavior, the recruiter cannot factor these feelings into the eligibility decision. The recruiter’s role is not to judge a family or youth, but rather to make objective eligibility determinations for the MEP.

Language and Culture. The recruiter may come in contact with unfamiliar languages or cultural norms. If the recruiter does not speak the family’s language, he or she may overcome linguistic differences with the use of an interpreter. When using an interpreter, the recruiter should remember to communicate with the family, not just the interpreter. Avoiding slang and long statements can make interpretation easier. The interviewee should be reminded that talking slowly and pausing when responding will help the interpreter. Cultural challenges can be more difficult to overcome. However, most people generally appreciate sincere attempts to be cordial and respectful. Having sincere concern for the welfare of the family and children will also help to avoid awkward cultural misunderstandings.

Distractions. The recruiter should be aware that distractions can diminish the quality of an eligibility interview. To increase the reliability of the interview, the family or youth should be in a comfortable environment with limited distractions. For example, a recruiter that interviews a worker at the doorstep of the home—with cars passing, children playing, and dogs barking—may not get accurate information or may not record the information accurately. The recruiter should be aware of the surroundings, and if there are too many distractions, the recruiter could ask screening questions, but wait to do the full interview at a more convenient time. If appropriate, the recruiter could also suggest moving the interview to a more accommodating space.

Leading Questions. Because the interview is critical to determining the child or youth’s eligibility for the MEP, the recruiter should avoid asking questions that lead families to give vague or untruthful answers. Leading questions can often be answered by “yes” or “no” responses and prompt the interviewee to give a particular answer. On the other hand, open-ended questions prompt the interviewee to provide more information than simply yes or no. In the first example below, “you moved here to work in agriculture, right?” the phrasing makes it appear that “yes” is the correct response. Rephrasing the question to “why did you move here?” allows the interviewee to provide various reasons without having a predetermined answer in mind. Below are several examples of leading questions that the recruiter should avoid, along with suggestions on how to rephrase them to be open-ended.

Table 2. Comparison of Open-Ended vs. Leading Questions

The recruiter should not tell the interviewee the MEP eligibility requirements before the interview begins as this might inadvertently affect the interviewee’s responses. Instead, the recruiter should ask questions similar to those in the Sample Interview Script in order to obtain accurate information.

Chronological Confusion.. Experienced recruiters often report that it is easier to get a worker to tell what was done than when it was done. For example, a worker may recall having worked at a chicken processing plant, but may have trouble remembering the exact start date. Many people have trouble remembering specific dates; this can be even more difficult for migratory families who move frequently. Because the SEA must approve the COE on or before the parent’s status of a migratory agricultural worker expires, it is critical that the recruiter establish the most recent date that the children made a qualifying move with the parent/guardian who is a migratory worker.

To help the worker place the event in time, the recruiter may wish to

• review a calendar with the worker and ask the worker to point to the date of the move;
• ask about the weather during the time the worker moved or obtained the agricultural or fishing work;
• help the worker recall important news, school, or family events and try to determine if the move happened before or after that event;
• ask the worker to recall the ages or grade levels of the children at the time of the move;
• check with other family members; or
• ask to see pay stubs or school records.

If the family has previously qualified for MEP services, information in the MEP student database or MSIX may help place the family or youth’s move.

Contradictions. During an interview, a family may give answers that appear to be contradictory or inconsistent with what the recruiter has observed. For instance, the recruiter may observe that the family runs a thriving construction business even though the parent says he moves frequently for agricultural work. If a situation is unclear or if the recruiter is not satisfied with the answers that the interviewee provided, the recruiter should tell the interviewee that he or she has to consult with a supervisor before determining if the child or youth is eligible and that he or she will inform the family of the supervisor’s decision. A family or interviewee may feel pressure to give false or exaggerated information for a variety of reasons: to qualify for services, to please a friendly recruiter, to appease another family member, or to compensate for not knowing or remembering the answers to certain questions. The recruiter should be aware of these motivations and clarify any information that does not appear to be accurate. More information on this topic is found earlier in this chapter; material on falsification of information by the recruiter is found in the next chapter.

Premature Determinations. The recruiter should avoid telling the interviewee whether the child or youth is eligible for the MEP during the initial visit. There may be circumstances or issues that the recruiter did not consider during the interview that may later affect the eligibility determination. For example, the MEP staff person who reviews the COE may question whether the work that the family does is temporary or may know something about the family that might affect the child’s eligibility (e.g., the child did not move with the parents to do agricultural work). This additional information could change the recruiter’s initial eligibility determination.

Similarly, the recruiter should avoid telling the interviewee that the child or youth will receive MEP services. The MEP is not required to serve every eligible migratory child. In some areas, there may not be enough migratory children to justify the cost of starting a program. In others, an eligible child may not be served because there are other eligible children who have greater needs. Funds are limited and local programs are often forced to make tough decisions. Families often ask what kind of services their children will receive, and the recruiter may be tempted to list all the services the local program provides. However, the recruiter should keep in mind that not all eligible children will receive all services. Therefore, while most programs assess migratory children and do their best to deliver the most appropriate services, there is no guarantee that every child will be served.

The recruiter should avoid the uncomfortable and unpleasant position of having to return to a family to inform them that there has been a mistake and their child is not eligible for the MEP and will not receive promised services. The recruiter should inform the family that others need to review the COE before a final eligibility determination is made, and that someone from the MEP will notify the family of the outcome.

⁵ For information on age range for compulsory school attendance and special education services, and policies on year-round schools and kindergarten programs, by state, as of 2015, visit: https://nces.ed.gov/programs/statereform/tab5_1.asp. This information is also available from each SEA. ↑

In the fall of 2004, most states re-interviewed a sample of children who had been determined to be eligible for the MEP as part of a National Re-Interview Initiative. Through this initiative, there were a number of lessons that were learned about interviewing migratory families and youth. Some of those lessons are listed below.

The Role of the Recruiter. The recruiter may encounter families who are living far below the poverty level and who have great needs. Regardless of the level of poverty the recruiter finds in a home or shelter, the recruiter cannot confuse empathy for the family with the duties of the job. The recruiter should be careful not to perceive himself or herself as having the power to decide which children are eligible to receive services and which ones are not. Furthermore, the recruiter cannot use the MEP as a way to “level the playing field” by occasionally making a questionable eligibility determination to help a particularly deserving family. While it might feel good to be able to help a deserving family, the role of the MEP recruiter is to identify and recruit eligible migratory children, not children in need.

Moreover, for families that have domestic problems, there are social organizations that can help them with issues like domestic violence, drug abuse, child abuse, or neglect. The recruiter may not feel comfortable giving unsolicited information about these services to a family, but he or she should be aware that these services exist and should provide the information if necessary. In addition, the recruiter should learn the local, district, and/or state policy with regard to when and how to report suspected cases of child abuse and neglect.

Quality Control Procedures. Routine quality control checks are important for catching eligibility determination errors. The 2004 National Re-Interview Initiative resulted in ED’s issuance of regulations that mandate quality control procedures nationwide. Annual prospective re-interviews are designed to catch errors prior to reporting the number of migratory children in the state. An ongoing random sampling of students allows concrete training opportunities when errors are found. It also leaves less room for intentional inaccuracies from recruiters when they know ahead of time a family may be called for a random re-interview.

Double check dates. Dates for qualifying moves are critical. For that reason the recruiter must make the extra effort to ensure that the dates recorded on the COE are as accurate as possible. The qualifying move date for the children establishes the QAD, which determines the length of time the child is eligible for the MEP. The qualifying move date for the worker establishes the timeframe for the individual’s status as a migratory agricultural worker/migratory fisher. This date is also critical because the SEA must approve the COE on or before the parent’s status of a migratory agricultural worker expires.

Services Vary. States and school districts offer a variety of different types of services through the MEP. A child may receive a service in one state that is not available in another state. Moreover, services may even vary within a state from one local project to another. Therefore, the recruiter should inform the family that services can vary from one MEP to the next.

Referring Families and Youth to Appropriate Services. The recruiter, with the family’s consent, should feel free to refer a family to other suitable service providers. When the recruiter is able to accurately identify the family’s needs and provide complete information on the referral source, the family is more likely to get the services they need. In making a referral, the recruiter should provide the family with the

• name of organization,
• location and hours of operation,
• name of contact person and telephone number,
• eligibility criteria, and
• services provided.

To increase the likelihood that the family will actually receive services, the recruiter should follow-up by

• contacting the person to whom the migratory family was referred—after receiving the family’s consent to do so—and providing the following information:
  (1) the name of the family, (2) the service(s) needed, (3) the date the referral was made, and (4) contact information for the recruiter (or the family) if the family does not make contact; and
• following up with the family to see if they received the service(s) they needed.

Youth who qualify for the migratory program may be eligible for a variety of other services, including

• ESL classes,
• Adult Basic Education classes,
• referrals to health and other community services (e.g., legal, housing, clothing),
• “reconnection” to high school programs,
• semi-independent study courses, and
• local volunteer or student group contacts.

Do Not Set Recruitment Quotas. At times, the recruiter may use techniques that are similar to the strategies used in sales and promotion to find and recruit migratory children; however, the recruiter is not a salesperson. The recruiter should never feel compelled to meet specific recruitment targets or quotas. Instead, the recruiter should concentrate on finding all of the eligible children in the recruitment area to the best of his or her ability. Agricultural and fishing jobs may change over time due to factors such as development, farm consolidation, changing weather patterns etc., which can affect the number of migratory families and youth who move into a particular area to work. All the recruiter can do is find the eligible children who reside in the recruitment area. The recruiter should never feel pressured to make questionable eligibility determinations to increase the number of identified migratory children.

Do Not Give Families Recruitment Incentives. Never give families gifts like jackets or backpacks to entice them to enroll their children in the MEP. Giving gifts may encourage a family or youth to say what the recruiter wants to hear to get the gift. It can also cause hard feelings if one child receives a gift and another one does not. Once enrolled into the program, some programs may offer small “welcome bags” to eligible students as a means of reminding them about the MEP and preparing them for school, but this is not appropriate as a recruitment tool.

When conducting an eligibility interview, the recruiter should be prepared to do the following: introduce himself or herself, explain the reason for the visit, find common ground with the family to build rapport, screen the interviewee using the child eligibility factors to determine whether the child qualifies for the MEP, and use a supplemental interview form to obtain the supporting information needed to determine whether the child is eligible for the MEP and to fill out the COE. The new recruiter may rely heavily on the more in-depth Sample Interview Script when conducting an interview, while a seasoned recruiter will learn how to draw out the information that is needed to determine eligibility using a more conversational approach or a more condensed supplemental interview form.

Interviewing skills develop and improve over time. With solid research, a good individual ID&R action plan, working knowledge of eligibility requirements, and practice, the recruiter will gain confidence and proficiency as an interviewer. The next chapter provides tools that will help the recruiter make accurate preliminary eligibility determinations.

The recruiter’s job is not complete until the eligibility determination has been documented.

The recruiter should now know how to find migratory workers and families and understand the rules and regulations regarding eligibility. In particular, the recruiter should know how to ask basic eligibility questions and conduct interviews, and then be able to make preliminary eligibility determinations. The next step in the process is to document each child’s eligibility on the national Certificate of Eligibility (COE) form.

States are required to use the COE template issued by ED. (34 CFR § 200.89(c)). The form and accompanying instructions establish the minimum requirements the SEA must meet to document its eligibility determinations under the MEP. States may add requirements in addition to the minimum requirements established by the National COE, but they may not remove any of the minimum requirements. The COE is comprised of three parts:

• Required data elements, which states can organize according to state preference and need
• Required data sections, which states can place according to state preference and need, but must be maintained in whole and unaltered
• State required/requested information, where space is available, for states to use if they choose to collect other data (ED, 2017, National COE Instructions)

The instructions for completing a COE in this chapter are based on the national COE form. This chapter outlines all required data elements in addition to offering instruction for the most common state required information. The chapter notes when data elements are not federally required.

You should be able to read a COE like a storybook that tells the story of a migratory family.

The SEA is ultimately responsible for documenting every migratory child’s eligibility for the MEP on the national COE form. The COE serves as the official record of why the recruiter and state believe the child is eligible for the MEP. Because the COE establishes the basis for a particular child’s eligibility, it is crucial that the information on the COE be adequate, accurate, and reliable. As such, it is important that the COE be properly reviewed, filed, secured, and maintained so it is available for review at any time.

The recruiter obtains the information needed to complete the COE by conducting a personal interview with a migratory worker or credible family member and collects supporting documentation, where needed. As stated in previous chapters, states may require recruiters to complete other forms to provide additional information on why the child is eligible or to gather additional information needed by the state (e.g., parental permission for the child to participate on field trips, a supplemental interview form). The recruiter should only enter data on a COE if the recruiter finds the source to be credible and believable since the COE serves as the primary record of eligibility when an auditor or reviewer checks the child’s eligibility. States often use the information from the COE to determine the number of migratory children who live in the state each year and to compile demographic information about these migratory children. States are required to complete a COE before the MEP provides services to a child. For these reasons, the COE is the most important document generated by the MEP, and it is vital that it is completed adequately and accurately.

NATIONAL CERTIFICATE OF ELIGIBILITY

Click below to open a high-res version of the National COE.

The National COE template and corresponding instructions are available on the RESULTS website. For convenience, the instructions are also provided, in full, in this chapter of the National ID&R Manual.

General Instructions

• A COE must be completed every time a child makes a new qualifying move that would renew the child’s eligibility for the MEP.
• All attempts should be made to complete all data elements and sections of the COE. In cases where a response may not be required or does not apply, flexibility has been built into the instructions. In these cases, the recruiter must write a dash (-) or “N/A” in the appropriate blank. All other information must be provided.
• With the exception of the “Qualifying Move and Work” section, if the instructions ask for additional information in the Comments section and the state has required this information as a state data element, the recruiter does not need to provide the information again in the Comments section. For example, the instructions recommend that recruiters record the first and last names of the child’s legal parent/guardian(s) in the Comments section if different from the current parent/guardian(s). However, if the state includes data elements for legal parent information, the recruiter would not have to repeat this information in the Comments section.
• If the recruiter completes a COE for a family, the recruiter must fill out a separate COE for any child who has a different qualifying arrival date (QAD) or for any child who has different eligibility criteria than the rest of the children in the family, such as an OSY who may have moved as the worker. The QAD is the date that both the child and worker completed moves to the same school district (listed in #1 of the Qualifying Moves and Work section.) There are special cases that are described in the instructions for the section titled “Qualifying Move and Work Section.” If more than one COE is necessary, the recruiter must complete all sections on each form.
• The recruiter must not include any child who:
• Was born after the qualifying move described on the COE in #1 of the Qualifying Moves and Work section.
• Is not eligible to receive a free public school education through grade 12 under state law; or
• Did not make the qualifying move described on the COE in #1 of the Qualifying moves and Work section.

• Family Data. In this section of the COE, the recruiter will record the contact information for the child(ren) and name of the child(ren)’s parent(s)/guardian(s).
• The recruiter may have to pay special attention to ensure that the family’s last name is accurate. A parent or guardian may have different last names or hyphenated names, or the use of last names may vary by culture or ethnic group. It is important that the recruiter become familiar with the naming customs of the various groups that the local MEP serves.
• Parent/Guardian 1 [Last Name(s), First Name]. Record the name of the individual (if any) currently responsible for the child(ren). Record this individual’s legal last name (or names) and legal first name. If the parent/guardian has two last names or a hyphenated last name, record the individual’s last name(s) as it legally exists. The term “parent/guardian” on this form and in other sections of these instructions includes a legal guardian or other person who is standing in the place of the parent (in loco parentis), such as a grandparent or stepparent with whom the child lives. If the child(ren)’s legal parent/guardian is different from the current parent/guardian, ED recommends providing the name of the child(ren)’s legal parent/guardian in the Comments section. If there is no parent/guardian information disclosed, or if the child is responsible for his or her own welfare (e.g., emancipated youth), write a dash (-) or “N/A.”
• Parent/Guardian 2 [Last Name(s), First Name]. Record the name of the second individual (if any) currently responsible for the child(ren). Record this individual’s legal last name (or names) and legal first name. If the parent/guardian has two last names or a hyphenated last name, record the individual’s last name(s) as it legally exists. The term “parent/guardian” on this form and in other sections of these instructions includes a legal guardian or other person who is standing in the place of the parent (in loco parentis), such as a grandparent or stepparent with whom the child lives. If the child(ren)’s legal parent/guardian is different from the current parent/guardian, ED recommends providing the name of the child(ren)’s legal parent/guardian in the Comments section. If there is no parent information disclosed, or if the child is responsible for his or her own welfare, (e.g., emancipated youth), write a dash (-) or “N/A.”
• Current Address. Record the physical address, including the complete name of the street or road where the child(ren) currently resides. In cases where a formal physical address is not available, include as much other identifying information as possible (e.g., trailer number, rural route, migrant camp, landmark). If the physical address is different from the mailing address, ED recommends providing the mailing address in the Comments section of the COE.
• City. Record the name of the city or town where the child(ren) currently resides.
• State. Record the postal abbreviation used by the U.S. Postal Service for the state where the child(ren) currently resides.
• Zip. Record the five or nine-digit zip code where the child(ren) currently resides. The U.S. Postal Service has an online zip code directory service (http://zip4.usps.com/zip4/welcome.jsp).
• Telephone. Record the telephone number, including area code, of the family. If no telephone number is available, write a dash (-) or “N/A.”

Child Data. Child data includes the name, sex, birth date, etc. of each child. A recruiter should include all children with the same family and eligibility data on the same COE. Any child who has different (1) current family [see “Family Data” above for additional definition] or (2) eligibility data—including a different QAD—must be documented on a separate COE.

• Residency Date. Record the date (MM/DD/YY) that the child(ren) moved to (i.e., arrived in) the present school district. Use the two-digit number that refers to the month and day, and the last two digits of the year. For example, May 20, 2016, would be written as 05/20/16. If the child(ren) qualified for the MEP on a move prior to the move to the present school district, the residency date will be later than the QAD. If the child(ren) moved prior to the worker’s move, the residency date would precede the QAD. Note, although it is possible to record a residency date that precedes the QAD, a COE cannot be filled out and a child cannot be enrolled in the MEP until after the child and worker each make a qualifying move.
• Last name 1. Record the legal last name of each eligible child in the family. If the child has a multiple or hyphenated last name (e.g., Ramírez-García), record the first part of the name (i.e., Ramírez).
• Last name 2. If the child has a multiple or hyphenated last name (e.g., Ramírez-García), record the second part of the name (i.e., García). If the child does not have a multiple or hyphenated name, write a dash (-) or “N/A.”
• Suffix. Where applicable, record the child’s generation in the family (e.g., Jr., Sr., III, 3^rd). Otherwise, write a dash (-) or “N/A.”
• First name. Record the legal first name of each eligible child in the family. This is the name given to the child at birth, baptism, or during another naming ceremony, or through a legal name change. Do not record nicknames or shortened names (e.g., Ale or Alex for Alejandra).
• Middle name. Record the legal middle name of each eligible child in the family. This is the secondary name given to the child at birth, baptism, or during another naming ceremony, or through a legal name change. Do not record nicknames or shortened names (e.g., Ale or Alex for Alejandra). If the child does not have a middle name, write a dash (-) or “N/A.”
• Sex. Record the child’s sex: “Male” or “Female”. States may abbreviate these responses as “M” or “F”, respectively.
• Birth Date. Record the month, day and year the child was born. Use the two-digit number that refers to the month and day, and the last two digits of the year. For example, September 20, 2003, would be written as 09/20/03.
• Multiple Birth Flag (MB). Record “Yes” if the child is a twin, triplet, etc. Write “No” if the child is not a twin, triplet, etc.). States may abbreviate these responses as “Y” or “N,” respectively.
• Birth Date Verification Code (Code). Record the four numbers that correspond to the evidence used to confirm each child’s birth date (see the codes and corresponding evidence listed below). States may choose to abbreviate the codes listed below by recording only the last two digits.

A birth certificate is the best evidence of the child’s birth date, if available. If a birth certificate is not available, the interviewer may use another document to confirm the child’s birth date, including any of those listed below.

If written evidence is not available, the interviewer may rely on the interviewee’s verbal statement. In such cases, the interviewer should record “1007” – the number that corresponds to “parent’s affidavit.”

Qualifying Move & Work Section.

In this section, record the qualifying move and qualifying work information which the state believes documents the child’s eligibility for the program. Note that exceptions apply for moves within states comprised of a single school district and school districts of more than 15,000 square miles. See #1 (immediately below) for how to document these exceptions.

Throughout this section, the term “worker” refers to the child(ren)’s parent/guardian or spouse who is a migratory agricultural worker or migratory fisher. The term “qualifying work” as used in this section refers to the new temporary or seasonal employment (or personal subsistence) in agriculture or fishing. The “qualifying moves” documented in this section are the qualifying moves that meet the MEP-eligibility criteria [i.e., #4 documents the move soon after which the worker engaged in qualifying work (or after which he or she actively sought qualifying work), and #1 documents the child(ren)’s moves as, or with or to join, the worker].

1. The child(ren) listed on this form moved due to economic necessity from a residence in _________ (School District/City/State/Country) to a residence in __________ (School District/City/State).
   • from a residence in _________ (School District/City/State/Country). This location is the child(ren)’s last place of residency immediately prior to the qualifying move. Note that the child(ren) might have made subsequent non-qualifying moves.
   • to a residence in __________ (School District/City/State). This location is where the child(ren) resided immediately following the qualifying move as the worker, or with or to join, the worker. A qualifying move can never be made to a country outside of the United States. As mentioned previously, the child(ren) might have made subsequent non-qualifying moves.
     • Exception. If the child(ren) migrated a distance of 20 miles or more to a temporary residence in a school district of more than 15,000 square miles:
       • Record the name of the school district where the child(ren) resided immediately prior to and immediately following the qualifying move, in order to identify this move as one that meets the 20 miles criterion.
     • Exception. If the child(ren) moved from a residence in one administrative area to a residence in another administrative area within a U.S. state that is comprised of a single school district:
       • Record the full legal or commonly used name of the administrative area where the child(ren) listed resided immediately prior to and immediately following the qualifying move.

   Provide as much of this information in these blanks as available. At a minimum (with the exception of states comprised of single school districts or school districts of more than 15,000 square miles), the state must be able to document that the child moved from one school district to another and changed residences in the process. In the case of states comprised of a single school district, the state must be able to document that the child moved from one administrative area to another and changed residences in the process. In the case of school districts of more than 15,000 square miles, the state must be able to document that the child migrated a distance of 20 miles or more and changed residences in the process.

   If the child and worker moved from different previous residences, record the child’s prior residence in response to #1 and record the worker’s prior residence in the Comments section.

2. The child(ren) moved (complete both a. and b.):
   1. as the worker, OR with the worker, OR to join or precede the worker. [Mark only one box]
   • Mark the box “ as a worker” if the child moved as the worker.
   • Mark the box “with the worker” if the child(ren) moved with the worker.
   • Mark the box “to join or precede the worker” if the child(ren) moved either before or after the date the worker moved. If this box is marked, also complete “i” under 2b.
   2. The worker, ______________ (First and Last Name of Worker),
      • Record the first and last name of the individual who is a migratory agricultural worker or migratory fisher (i.e., the child(ren)’s parent/guardian or spouse, or the child – if the worker).

      is the child or the child(ren)’s parent/guardian spouse. [Mark only one box]

      • Mark the box that indicates whether the worker is the child or the child(ren)’s relationship to the worker (i.e., parent/guardian or spouse).

      (Complete 2bi if “to join or precede” is checked in 2a.)

      • The child(ren) moved on _________(MM/DD/YY). The worker moved on _________(MM/DD/YY). (provide comment)
      • If the worker moved separately from the child(ren), record the date that the child(ren) moved to the school district listed in #1, and record the date the worker moved to the school district listed in #1. Also record the reason for the different move dates, and whether the worker moved from a different location than the child(ren), in the Comments section.
3. The Qualifying Arrival Date (QAD) was ___________ (MM/DD/YY). Record the QAD, using the two-digit numbers that refer to the month and day, and the last two digits of the year. For example, May 20, 2016, would be written as 05/20/16.

The QAD is the date that both the child and worker completed the move to the school district listed in #1. The child must have moved as a worker, or with or to join a parent/guardian or spouse who is a migratory agricultural worker or migratory fisher. As referenced in #2a, the child and worker will not always move together, in which case the QAD would be the date the child joins the worker who has already moved, or the date when the worker joins the child who has already moved. (For more on “to join” moves, see the NRG, Ch. II, E2.) The QAD is the date that the child’s eligibility for the MEP begins. The QAD is not affected by subsequent non-qualifying moves. For more information on determining the QAD, see the chart below.

Type of Qualifying Move The child. . .	Qualifying Arrival Date (QAD)--Eligibility Begins The QAD is. . .
. . .moved with the worker.	. . .the date the child and worker both arrived in the district.
. . .moved before the worker moved.	. . .the date the worker arrived in the district where the child was residing.
. . .moved to join the worker after the worker moved.	. . .the date the child arrived to join the worker.

4. The worker moved due to economic necessity on _________(MM/DD/YY), from a residence in _______(School District/City/State/Country) to a residence in _______(School District/City/State), and: [Mark only one of the following boxes: either a or b.]
1. engaged in new qualifying work soon after the move (provide comment if worker engaged in qualifying work more than 60 days after the move), OR
   • Mark this box if the individual listed as the worker in #2b moved due to economic necessity from a residence in one school district to another, and, soon after doing so, engaged in new temporary or seasonal employment (or personal subsistence) in agriculture or fishing.
   • Explain in the Comments section if the worker is determined to be a migratory agricultural worker or migratory fisher based on his or her engagement in new qualifying work more than 60 days after the qualifying move described in #4.
2. actively sought new qualifying work, AND has a recent history of moves for qualifying work (provide comment)
• Mark this box if the individual listed as the worker in #2b moved due to economic necessity from a residence on one school district to another and actively sought new qualifying work before or after the qualifying move described in #4, and has a recent history of moves for qualifying work.
• Explain in the Comments section how and when the worker actively sought new qualifying work. For example, the individual stated that he or she (or someone on his or her behalf) applied for qualifying work at a particular agricultural or fishing job site, or applied at a center that coordinates available qualifying work.
• Explain in the Comments section the worker’s recent history. For example, the recruiter could write, “worker moved from Brownsville, Texas, to Decatur, Michigan, and planted tomatoes in May 2016, and moved from Decatur, Michigan to Presque Isle, ME, and picked potatoes in October 2016.”
5. The qualifying work*, _____________ (describe agricultural or fishing work),
   
   • Describe agricultural or fishing work. When describing the specific agricultural or fishing work, the recruiter should use an action verb (e.g., “picking”) and a noun (e.g., “strawberries”). In other words, the recruiter should describe the worker’s action (e.g., “picking”) and the crop, livestock, or seafood (e.g., “strawberries”). For example: picking strawberries; thinning sugar beets; pruning grapes; detasseling corn; catching chickens; planting oysters; walking (weeding) soybeans; and harvesting crabs.

was (make a selection in both a. and b.):

1. seasonal OR temporary employment
   • Mark the box for “seasonal employment” if the employment occurs only during a certain period of the year because of the cycles of nature and that, by its nature, may not be continuous or carried on throughout the year. Examples include planting, cultivating, pruning, harvesting, and related food processing in agriculture. Also, planting and harvesting clams and oysters, fishing during seasonal runs of fish, and related food processing in commercial fishing [34 CFR § 200.81(o)].
   • Mark the box for “temporary employment” if the employment lasts for a limited period of time, usually a few months, but not longer than 12 months. It typically includes employment where the worker states that the worker does not intend to remain in that employment indefinitely, the employer states that the worker was hired for a limited time frame, or the SEA has determined on some other reasonable basis that the employment is temporary. [34 CFR § 200.81(p)].
2. agricultural OR fishing work.
   • Mark the box for “agricultural work” if the work involves the production or initial processing of raw agricultural products such as crops, poultry, or livestock, dairy work, as well as the cultivation or harvesting of trees (Section 1309(2) of the ESEA; and 34 CFR § 200.81(a)). The work may be performed either for wages or personal subsistence.
   • Mark the box for “fishing work” if the work involves the catching or initial processing of fish or shellfish or the raising or harvesting of fish or shellfish at fish farms. [Section 1309(4) of the ESEA; 34 CFR § 200.81(c)]. The work may be performed either for wages or personal subsistence.

   *If applicable, check:
   personal subsistence (provide comment)

   • (*) Mark the box for “personal subsistence” if “…the worker and the worker’s family, as a matter of economic necessity, consume, as a substantial portion of their food intake, the crops, dairy products, or livestock they produce or the fish they catch” [34 CFR § 200.81(m)]. Also provide a comment in the Comments section.
6. (Only complete if “temporary” is checked in #5a) The work was determined to be temporary employment based on:
   1. worker’s statement (provide comment), OR
      • Mark this box if the work was determined to be temporary employment based on a statement by the worker or the worker’s family (e.g., spouse) if the worker is unavailable (provide comment). For example, the worker states that he or she only plans to remain at the job for a few months. Provide explanatory comments in Comments section.
   2. employer’s statement (provide comment), OR
      • Mark this box if the work was determined to be temporary employment based on a statement by the employer or documentation obtained from the employer. For example, the employer states that he or she hired the worker for a specific time period (e.g., 3 months) or until a specific task is completed and the work is not one of a series of activities that is typical of permanent employment. Provide explanatory comments in Comments section. Attach supporting documentation if available.
   3. state documentation for ______________ (employer).
      • Mark this box upon verification that the state has current documentation to support that the work described in #5 is temporary employment for this particular employer.
      • Employer. Identify the employer, whether it is the name of or code for a farmer, a grower, a business, or a corporation, where the worker engaged in qualifying work.

Comments Section. (Must include 2bi, 4a, 4b, 5, 6a and 6b of the Qualifying Moves & Work Section, if applicable.) The “Comments section” of the COE allows the recruiter to provide additional information or details that clarify the reasons for the recruiter’s eligibility determination. The recruiter should write clear and detailed comments so an independent party who has no prior knowledge of the eligibility determination can understand the recruiter’s reasoning for determining that the child(ren) is eligible. At a minimum, the recruiter must provide comments that clearly explain items 2bi, 4a, 4b, 5, 6a, and 6b of the Qualifying Moves & Work Section, if applicable. The Comments section must be self-contained and include at a minimum, the required comments, but states may choose to divide the required comments into subsections. As mentioned previously, these items include the following scenarios documented in the Qualifying Moves and Work Section:

• #2bi: The child(ren) and worker moved separately. If the child(ren) joined or preceded the worker, record the reason for the child’s later move or the worker’s later move. If the worker moved from a different school district than the child(ren), record the name of the school district in which the worker resided immediately prior to the move.
• #4a: The worker engaged in new qualifying work more than 60 days after the qualifying move.
• #4b: The worker did not engage in new qualifying work soon after the qualifying move. In this case, the recruiter must document that:
  • The worker actively sought new qualifying work; AND
  • The worker has a recent history of moves for qualifying work.
• #5: The worker is a migratory agricultural worker or migratory fisher on the basis of “personal subsistence,” meaning “that the worker and the worker’s family, as a matter of economic necessity, consume, as a substantial portion of their food intake, the crops, dairy products, or livestock they produce or the fish they catch.” (34 CFR § 200.81(m)).
• #6a or 6b: The employment is temporary based on the worker’s statement or the employer’s statement. In particular, record the information provided by the worker or employer regarding how long they expect the employment to last. The comment should be of sufficient length to adequately document how the recruiter came to the eligibility decision.

ED recommends that the recruiter provide additional comments on the COE in the following circumstances and in any other circumstances in which a third party may question the eligibility determination:

• The information on the COE needs additional explanation to be clearly understood by an independent outside reviewer.
• The basis for the preliminary eligibility determination is not obvious. For example, the work is unusual enough that an independent reviewer is unlikely to understand that it is qualifying work. An explanation is needed to enable a reviewer to understand how the preliminary eligibility determination was made.
• The work could be part of a “series of activities” that, viewed together, would constitute year-round employment (e.g., mending fences on a dairy farm and bailing hay could be two parts of year-round ranching with one employer).
• The work may be viewed by an independent reviewer as either temporary or year-round employment (e.g., collecting eggs or milking cows).
• A "move" is of such brief duration that one could question whether it was a move from one residence to another residence, due to economic necessity.
• An interviewee uses a symbol such as an “X” or other valid mark as a signature.
• The person who provided the information on the COE form (interviewee) is not the worker.
• The mailing address is different from the child(ren)’s physical residence.
• The child(ren)’s legal parent/guardian(s) differ from the current parent/guardian(s) listed.

Interviewee Signature Section. The interviewee signs and dates the COE on the day the interview is conducted. The interviewee must also write his or her relationship to the child.

I understand the purpose of this form is to help the state determine if the child(ren)/youth listed on this form is/are eligible for the Title I, Part C, Migrant Education Program. To the best of my knowledge, all of the information I provided to the interviewer is true.

Signature, Relationship to the child(ren), Date

The person who signs the COE must be the source of the information contained in the document and should verify any information provided by another source. If the interviewee is unable to sign his or her name, he or she must mark an “X” in the signature section and the recruiter must print the parent’s name and relationship to the child in the Comments section. If the interviewee refuses to sign his or her name, the recruiter must document the interviewee’s refusal in the Comments section and print the interviewee’s name and relationship to the child.

If a state chooses to include other statements that require, for example, a parent/guardian signature specifically, the state can include those statements separately from the Interviewee Signature. ED strongly recommends that states obtain the approval of their legal counsel to ensure that additional statements they add to this section comply with the applicable federal, state, and local laws and policies.

The recruiter should make sure the interviewee understands what he or she is signing. The recruiter can do this by reviewing every line of the COE and confirming with the parent that the information is correct. If the interviewee can read, the recruiter should give the interviewee a blank copy of the COE form in his or her native language (if available) so the interviewee can follow along. Once the SEA-designated reviewer reviews, signs, and dates, the COE, the MEP should send a copy of the COE by mail or hand-deliver it at a later date.

Eligibility Data Certification. The recruiter signs and dates the COE on the day the interview is conducted.

I certify that based on the information provided to me, which in all relevant aspects is reflected above, I am satisfied that these children are migratory children as defined in 20 USC 6399 and implementing regulations, and thus eligible as such for MEP services. I hereby certify that, to the best of my knowledge, the information is true, reliable, and valid and I understand that any false statement provided herein that I have made is subject to fine or imprisonment pursuant to 18 USC 1001.

Signature of Interviewer, Date

Signature of Designated SEA Reviewer, Date

At least one SEA-designated reviewer must check each completed COE to ensure that the written documentation is sufficient and that, based on the recorded data, the child(ren) may be enrolled in the MEP. The SEA-designated reviewer must sign and date the COE on the day it was reviewed.

NOTE: If an SEA wishes to add to any portion of the Eligibility Certification Section, it must submit its proposed statement to OME for approval.

These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level. ↑

After the recruiter completes the COE, the SEA or LOA is responsible for reviewing the information on the document, and then storing and securing it appropriately. This process varies by state, but there are some basic guidelines for the recruiter and other ID&R staff. After the recruiter completes the COE and before it is forwarded to the next person for review, the recruiter should

• Check the COE for accuracy. Are all the items filled in? Are the dates of birth, QAD, and residency date correct? Are the names spelled properly? Are the recruiter’s and the interviewee’s signatures included? Is the writing legible?
• Review the eligibility determination. Were all of the applicable eligible factors met? Is it clear from the information on the COE that the child is eligible for the MEP? Were comments provided? If so, would they be clear to an independent reviewer?

After the recruiter completes these checks, the recruiter must forward the COE to at least one SEA-designated reviewer, usually a recruitment supervisor, local administrator, or other trained recruiter, who reviews the form. If the reviewer finds errors, the reviewer will return the form to the recruiter for corrections. If the form is complete and error-free, the reviewer signs and dates the COE to certify that, based on the information provided, each child listed is eligible for the MEP. Some states require additional reviews. Once the COE has the recruiter’s and the reviewer’s signatures, and it has gone through any other reviews the SEA requires, the COE is entered in the state MEP database. States that use electronic COEs generally have a comparable review process. These quality control checks help ensure that every COE is completed and that the information contained on the COE establishes eligibility under the MEP. States cannot provide services or include a child in the annual child counts reported to ED until the SEA (or its designee) has certified each child is eligible for the MEP.

COEs contain personal information that, under FERPA and some state laws, is not authorized for public disclosure. For this reason, the recruiter should check with a supervisor about policies and procedures for storing and securing COEs.

Generally, records must be maintained for three years after the date the grantee or local operating agency submits its last expenditure report for the period in question (Uniform Guidance, Subpart D, 2 CFR § 200.333). If any litigation, claim, negotiation, audit, or other action involving the records has been started before the expiration of the three-year period, the records must be retained until completion of the action and resolution of all issues which arise from it, or until the end of the regular three-year period, whichever is later.

In practical terms, the length of time that an SEA/LOA must keep a COE to meet this three-year retention period depends on whether the child makes subsequent qualifying moves which result in new QADs, which will increase the amount of time. For example, a COE that indicates that a child made a qualifying move in October 2012 means that the child will remain eligible, without another qualifying move, until October 2015. A child eligible in October 2015 would be included in the Category 1 child count for the period September 1, 2015 – August 31, 2016, and would generate funding for the state through fiscal year (FY) 2019. FY 2019 funds may be used, with carryover, until September 30, 2021. The SEA does not need to submit the final expenditure report for these funds to ED until as late as December 31, 2021. The three-year record retention period begins in December 2021 when the SEA submits the final expenditure report and runs until December 31, 2024. Therefore, the SEA would have to keep this particular COE until December 31, 2024. (NRG, Ch. XI, C3). Of course, the SEA might have to keep this COE longer if there is any litigation, claim, negotiation, audit, or other action involving the record.

The SEA/LOA should ensure that records are stored in an orderly fashion and readily available if needed. By carefully maintaining and preserving MEP records, the SEA

• satisfies regulatory requirements,^[6]
• increases efficiency and saves administrative costs (both time and storage) by making it easy to locate and retrieve records,
• makes current data readily available to decision makers,
• helps document the demographic characteristics of migratory children and achievement of the MEP performance targets and measurable objectives,
• demonstrates accountability for the use of federal funds, and
• protects the confidentiality and interests of migratory children.

Individual State Requirements: Depending on state procedures or data-entry systems, additional instructions might apply. The recruiter should speak with his or her supervisor if additional instructions are required. Common ones include

• The COE should be completed legibly in blue ink to show that it is an original document, not a photocopy.
• Corrections that are made after the original interview should (1) be made in an ink color other than blue to distinguish from the original text, (2) provide the name or initials of the person making the correction, (3) provide the date the correction was made, and (4) indicate the source of all new or corrected information (e.g., the parent, the school).
• Additional comments in the Comments section of the COE may be requested such as, last grade completed in home country for OSY, additional children not eligible for MEP services but who reside in the household or any safety concerns that service providers should be aware of.

Electronic COEs. States may use paper or electronic versions of the COE. For purposes of the MEP an electronic COE is one for which information is entered by the recruiter/interviewer at the time of the interview using an electronic device (e.g., tablet). COEs that are completed on paper at the local level and entered electronically for transmission to the state, are not electronic COEs for the purposes of the MEP. States must collect the required information, including required signatures, in a manner that follows the COE instructions, regardless of whether they use paper or electronic COEs. States should also be able to print the COE according to the requirements outlined in the instructions.

Each state has its own procedures for ensuring that electronic signatures are valid and authentic. ED would consider an electronic signature captured via stylus or PIN code to be equally acceptable for audit purposes, and would hold states accountable for any failure to implement its own procedures. States should

• consult with the state’s auditors, Attorney General, or other appropriate state personnel who know and understand electronic signatures, to validate that the state will be able to rely on such signatures for purposes of identifying the person signing the document; and
• keep the assurance referenced above on file for audit purposes. (ED, 2017, National COE Instructions, p. 2)

Historically, the MEP has made efforts to incorporate technology into all aspects of the program and the area of ID&R has been no exception. The use of technology for documenting child eligibility is an emerging trend that states may wish to explore.

Some of the advantages of using laptops, tablets, or other hardware that can be loaded with an electronic COE include

• Electronic COEs are more likely to be completed in a standardized way. In particular, electronic COEs can be designed with drop down lists and option buttons that help how the data is received.
• The SEA can build edit and logic checks into an electronic COE that will help to identify inconsistent or illogical data relationships (e.g., comparing date of birth to grade level).
• Electronic COEs can be used for data analysis that could ultimately improve the quality of the data (e.g., the program could flag families who move north to do agricultural work in the middle of winter).
• Some recruiters can fill out an electronic COE faster than a paper COE, thus reducing the amount of time needed to complete the COE and freeing up time for other recruitment activities.
• Completing an electronic COE reduces the extra step of filling out a paper COE and then typing the same data into an electronic system.
• Electronic COEs can be linked to other data sources such as postal abbreviations for states, zip codes, lists of cities in other countries, etc.
• Having an electronic COE with a parent signature or even scanning a paper COE can reduce the number of paper files the MEP is required to maintain.
• Some people find electronic files easier to retrieve than paper files.

Some disadvantages and considerations around using an electronic COE include

• For audit and quality control purposes, it is important for states to be able to produce a version of the COE that has all the original data (including signatures) and to track any subsequent changes, corrections, and/or updates (by date and source). Therefore, the state must ensure that even if the most current information is displayed in the electronic database, users are able to examine the history of the COE.
• The information that is collected on the COE has to reflect the information on the national COE and has to print out in the same format (i.e., a one page document with all required data elements and sections).
• States need to be sure that parents can see what they are signing on the COE form and should make provisions for the parent to receive a copy.
• Some migratory parents may be more apprehensive about signing an electronic COE versus a paper document.
• States need to make security provisions to guard against identity theft and the release of personally identifiable information.

States should carefully weigh the advantages and disadvantages of anything new before deciding whether to adopt it, including performing a cost-benefit analysis of new technology and piloting the technology to work out any technical problems before it is fully implemented.

⁶ The Uniform Guidance requires that records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award (Uniform Guidance, Subpart D, 2 CFR § 200.302). ↑

Do Things Right the First Time. It is very important that preliminary child eligibility determinations are clearly documented. If the recruiter makes errors or does not submit complete paperwork, the work will have to be re-done. Having to re-do work delays services to children in need and costs the local MEP additional expenses which could otherwise be spent on educational services. When a recruiter does things right the first time, this saves time and money. The recruiter should always double check work before it is turned in.

Do Not Hide Mistakes. We are all human, and we all make mistakes. If the recruiter finds mistakes when checking the COE, he or she should either fix them or find someone else who can fix them. The recruiter should use this experience to find ways of avoiding and/or catching mistakes in the future.

The COE is both a legal document and the most important document the recruiter will generate for the MEP, and it should be treated as such. The recruiter should complete the COE with care so that it is easy to read and understand and serves as a clear basis for the determination of a child’s eligibility. The COE tells a very private story about a family’s movement and employment. The family shares this information with the recruiter with the understanding that the information will remain confidential and that the recruiter will use it to determine whether their child is eligible to obtain needed services. Moreover, federal law requires the recruiter and other federal program staff, as well as SEA staff, to maintain the privacy of this information.

The next chapter will provide information for administrators of ID&R systems.