should take greater care and do more consultation in preparing these papers. The States and AAAS cannot be held accountable when AoA directives, memos, and guidelines regulation, and statements are in conflict or ambiguous. Too often information memos and podium policies seem inconsistent with the law and regulations.

Present law, and particularly AoA policy, does not permit the flexibility for the states or AAAS to work cooperatively with integrated services or program efforts which causes conflict with other federal and State policies and priorities. The States and AAAs are restricted in contraction, sharing staff, and integrating efforts or projects.

The States and AAAS cannot be held accountable when AoA directives and memos give inadequate time for planning and implementation (for example 75-11, Affirmative Action).

AoA should be giving more leadership in policy formation and less in detailed administration. There is currently "over detailed" AoA administrative direction in such areas as Information and Referral, escort S.S.I. and energy.

There are important national policy areas that are seemingly neglected by AoA including maintenance of effort, prevention of problems, pension planning, evaluation, long range financing (after 3 years) of projects, interfacing Older American Program efforts with human resources and services integration programs, SSI, SSA, COG and district planning councils.

The 15% limitation on planning and administrative funds for AAAS is unreal and creates administrative headaches and should be removed as well as the percentage of funds going to AAAS. The States and AAAs must realistically face the difficult task of how much to invest in administration, planning, and coordination with a simple administrative process which can be justified to the public. Calling "coordination" and "tapping untapped resources" direct services is unreal. The single area plan States need approximately 8% for the additional administrative and program costs involved in carrying out the area plan.

The States should clearly have the right to determine the criteria for the selection of AAA over and above the federal laws and official regulation.

AoA and/or the Federal Council should set an example of advocacy at the federal level. The States and AAAS have trouble with the advocacy role when AoA is silent on critical aging issues at the federal level and isn't providing leadership on legislation.

Regardless of the formula for State allocations in the 1975 Older American Act, the law, the regulations, and policy statements should clearly spell out that the mission of the Older American Act is to serve all older people on an equitable basis.

The State administrative funds should be in one budget and not separate line items for each program it has to administer and should be increased in proportion to the funds under all Titles it must administer.

The States find that the system of monthly "draw down" of AoA funds is unrealistic not allowing sufficient turn around time and strongly urge return to the "quarterly draw down". The administrative and program cost is disruption not worth the interest lost to the Federal Government.

The States need to take a greater role in Older American Act policy formation and the States and AoA should do more to insure better communication and consultation before policies are established.

ADDENDUM TO THE COLUMBUS, OHIO, STATEMENT

I. The states are supportive of substate planning and administration of the Older Americans Act. This process has contributed to improved policies and services for older citizens through:

The more active involvement of older citizens in policy development.
The increased involvement and support of local elected officials.

The development of a broader policy and leadership role for state agencies on aging.

In order to further strengthen this process, AOA should develop policies to provide the state increased flexibility in the designation of AAA's to meet particular state needs. Specific attention should be given to amending Sec. 903.66 to permit AAA's to purchase planning and other functions, when they are available from established multi-purpose agencies.

II. In order to provide state and area agencies with an opportunity to know and to reflect national policy for services to older citizens, prior to the initia

tion of each fiscal year, the AOA should develop a federal plan including three (3) to five (5) year's goals and one (1) year measurable operational objectives. This plan should be transmitted to state agencies for review and comment. In addition the Federal Council on the Aging should hold public hearings on the annual plan within each federal region.

III. Item 1c of Commissioner Flemming's letter to Mr. David Crowley states that AOA regards program instructions as binding. Given this interpretation, clarification is needed on the following points:

A. What is the legal basis for the development of binding policies without using established procedures such as promulgation of rules?

B. What is the legal basis for developing policies which deviate from or extend beyond existing statistics and rules? (i.e., policy requiring the destruction of information and referral identifiable records after 30 days).

C. What is the process for state agencies to appeal policies transmitted by program instructions?

IV. The Older Americans Act assigns the AOA prime responsibility for advocating the needs of older citizens in federal administrative and legislative decisions. While it is recognized that some of the federal interagency agreements have been developed with the objective of improving services for older citizens from existing resources, it is important that the needs of older citizens be actively advocated in the development of new or revised legislative and administrative policies.

A. What is the AOA position on the proposed budget reductions in food stamps, Medicaid and Medicare? Has AOA prepared an analysis of the impact of these reductions on older citizens?

B. Has AOA prepared a budget request for Title V appropriations since 1973? Has there been an analysis of the need for Title V funds?

C. What was the initial AOA budget request to OMB for the 1974-75 Title VII appropriations?

D. Did AOA actively support the inclusion of half for seniors in the Transportation Assistance Act?

E. Has AOA taken a position on Title XX? Does the AOA analysis of Title XX propose any amendments to provide increased benefits for seniors?

F. Are AOA legislative analyses available for distribution to state and area agencies?

Mr. CARSTENSON. During this past 2 years in implementing the Older Americans Act and particularly title III, a number of complaints have come to the fore as to things that need to be altered in the Older Americans Act in order to help the States function more effectively.

I work as a consultant to a number of States: Ohio, Rhode Island, South Dakota, and Minnesota. This testimony is based on experience in working with these States and trying to cope with a number of the problems that have emerged.

Certainly one of the things which has been touched upon by earlier witnesses today and yesterday is the need for some tools for the State unit on aging and the area agency on aging and the Federal Government, the Administration on Aging, to deal with other agencies, to help make it an effective tool in working with other State and Federal agencies.

For this reason I would like to suggest that there be some flexibility, limited flexibility to negotiate and work out agreements with other State and Federal agencies, to work on joint projects, that this would greatly strengthen the ability to work with agencies such as the SSI program, such as social security, such as the employment service, and other State and Federal agencies.

The suggested changes, specifically on title III, are spelled out on pages 8 and 9 and 10, on through 11. I would like to call attention to two points. One is the problem of the A-95 review. It is being abused in certain States and in certain planning districts to use to coerce States and area agencies into providing contracts or arrangements.

I would like to suggest that some safeguards be put into protect the area agencies and State units on aging from this coercion.

I would like to in general commend the Administration on Aging not only for moving ahead in putting into operation a nutrition program in title III. Commissioner Flemming is an aggressive forceful champion of older people even if he is a bit of a hard taskmaster for State agencies and local area agencies on aging to try to reach older people.

I have been discouraged from the reports I have heard on the budget about the administration systemmatically cutting every single program in the field of aging without exception, or perhaps without exception. I am not sure about the SSI program. But every program whether it is senior transportation, senior aids, green thumb, RSVP, foster grandparents, title III, title IV, title VII, social security, food stamps, housing, every single program that affects older people by the Federal Government has been cut in the proposed rescinding of the budget items.

I urge that the whole thing be thrown out and you ask the President to come up with a budget that is not going to cut back on programs and services for older people.

I would like to suggest that perhaps the location of the older American volunteer programs should be changed back to the way that this committee had originally set the program up, mainly in the Administration on Aging or in HEW. I would strongly urge that this not be put through the traditional area agency-State agency channel, but rather worked out on an individual contract basis with the States, because of the problem of disallocation and because, frankly, I think the area agencies have a lot to chew on and a lot to do and a lot of things to work out, and so I would urge that it be put over in a family and a cooperative arrangement and relationship developed as it did in the past when the foster grandparents was in the Administration on Aging.

One other major area I would like you to consider is the problem of realistic financing of the title III projects on an ongoing basis. First of all, I think that because of our current economic situation that a 1year freeze on reduction or increasing the local share should be undertaken. We are in a very difficult situation where many local programs will not be able to raise additional programs will not be able to raise additional funds this year, and I would like to suggest this:

I would also like to suggest that certain kinds of projects, transportation, outreach, and information referral, do have a difficult time in getting local funding. I would like to suggest that the 309, the McGovern-Schweiker program, be continued, but that the program not go below 60 percent Federal funding on an ongoing basis.

I heard the testimony yesterday about the great skills of the Department of Transportation and I am afraid in terms of having worked a good deal in the area of transportation with Congressman Beard and others in Rhode Island, it was a great experience in working with their senior transportation program, but AOA has a lot more skill and ability in senior transportation than does the Department of Transportation.

I am afraid that we are going to see a situation in the next 2 weeks or so where the Department of Transportation is going to come out

with a regulation requiring all businesses be equipped with hydraulic lifts for wheelchairs and this is going to, by itself, cause such a reaction that the Biaggi amendment which provides, for access for handicapped and the elderly be thrown out by Congress because everybody will go up in outery that this can't be done with the money that transit systems have.

I think we do need to move to producing senior transportation. This is the most critical area of concern to the area agencies and State agencies and the fact that in the last 2 years well over a thousand projects or systems have been set up throughout the country on senior transportation under the Older Americans Act indicates that this is a high priority. Thousands of people have been involved. State and local governments have put up funds and it is a critical problem which I am glad this committee has moved ahead on, the McGovernSchweiker 309 transportation money.

I would like to comment in one other area which has to do with the employment programs. As most of you are aware, I used to be Director of Green Thumb and have appeared many times before this committee concerning the employment problems of older people.

In the last section of testimony in this report I have some new information from the Labor Department which clearly indicates that its manpower program discriminates on a very serious basis against older people. By the best count we have 1.2 million people out of the 6.5 million people over age 45 who are unemployed. When you add the hidden unemployed it goes up to 2 million unemployed people over 45. When you look at the percentage of the services of the Manpower Administration which serves older people, the best you can come up with is less than 6 percent. When you analyze as I did in the case of Rhode Island, the long-term unemployed, what I am really concerned about, and I think you are concerned about, is the person who is employed 10 or 13 weeks, then you find that approximately a third of the people who are unemployed long term are older workers and yet practically a very small proportion of the services now go to older workers.

You in this committee have worked hard to try to instruct the Labor Department in the intent. I am afraid they haven't listened. I hope that you will look seriously at the middle aged and older worker program that was enacted in the Senate in 1973, and look at it from the point of view if the Labor Department cannot hear what you have tried to instruct so patiently, and I know, Mr. Chairman, that you have on a number of occasions talked with them and have tried to insist that the Labor Department work on the problems of the older workers, they simply have not heard you, and the evidence is here. The Administration on Aging has tried mightily as well, and I think it does call for some specific action at this time.

I would like to share my time with David Crowley, who is director of the Ohio Commission on Aging.

Mr. BRADEMAS. Thank you.

Mr. Crowley?

Mr. CROWLEY. Thank you very much for giving me the opportu nity to talk with the committee this morning.

am a State director in the western part of Ohio. I helped prepare the testimony that my colleagues gave earlier so I will not go on too

long except I did want to say and highlight a few points that I felt might best be said by one individual State director.

First of all, I would like to emphasize and say very emphatically that Ohio endorses the philosophy and goals of the Older Americans Act, and that this approach to a Federal, State, and community level arrangement of planning and coordination at all three levels in my mind greatly raises the public consciousness about both the problems and the potentials of the elderly and allows for a lot more citizen input. Ohio, I have to admit, is certainly not a leader in the field of programs for the aging. I would like to comment and inform you about some things that are happening. I think in view of the fact that Ohio, as I have to admit, is not a leader, the kind of things that are happening in Ohio are probably not uncommon but they are a frequent result I believe of the new awareness and the new push that this committee and the Congress has given to programs for the elderly.

I would like to begin by saying first of all there was created in Ohio a Commission on Aging at the highest level of State government with the director and the Commission members being appointed directly by the Governor, and reporting directly to him. For the first time in Ohio the State has appropriated reduced fares for elderly citizens. A coalition of 10 statewide elderly groups has been formed and they are prepared to deal in their initial effort with the high cost of utility bills as one of their first projects. There has been significant liberalization of the amendment to the supplemental security income as a result of some citizen input and effort from Ohio as well as other States across the Nation. For the first time there is a House and a Senate standing committee concerned primarily with the needs of the elderly.

I mention these things and there are others because I believe these are direct tangible results again of the impact that the Older Americans Act has made at least in one State.

In regard to the renewal of the Older Americans Act, I believe you will hear if you have not already heard that there have been conflicts between the area agencies and the State units in some States. I believe that there is a certain amount of creative tension that can be helpful.

I do believe that the responsibilities and the roles of these various units, both the State and the area agencies, can be more clearly defined so that there is not the bureaucratic infighting that seems to take place.

I would make a few concrete suggestions. I would suggest that the 15-percent limit on area agency administration be liberalized. I know there is an argument about higher cost for administration versus more funds for services. When I talk about administration I include in that the very significant role of advocacy. Many of the area agencies around the State are multicounty. They are staffed with minimal staff. I believe that we have to recognize there are great other sources of funds and, of course, this is one of the premises of the Older Americans Act.

There are other sources of funds that can be available for older people's programs but it takes a strong, dedicated, hard-working area agency staff to secure those funds and do the planning, coordination, and advocacy that will free up those funds for older people.