By telephone and correspondence, the LEA coordinator advised the non-public-school principal of available programs and indicated his willingness to help as much as possible. The non-public-school principal seemed to feel that the LEA coordinator and his staff had been cordial and cooperative at all times. There seemed to be no evidence of antagonism or bigotry. Sporadic availability of funds and hesitation on the part of non-public-school officials to challenge State constitutional provisions or to request the Attorney General's opinion are factors which restrict non-public-school children's participation in title I

programs.

Ideally, title I projects should be suggested and planned by school personnel from the target schools. In practice, while suggestions may come from the public school principals and their staffs, the superintendent and the LEA coordinator decide on the final focus and plan the projects. Both sectors agree that at no time was the pastor or the principal of the nonpublic school involved in the planning of the projects. The non-public-school principal voiced dissatisfaction when she learned that the LEA coordinator had filed her requests in a separate folder, thereby relegating them to a lower priority.

During fiscal year 1966, the LEA coordinator offered the non-publicschool principal the services of teacher aides and of a nurse, audiovisual equipment, films, and free lunches. As of the date of the field. survey coordinator's contact, only one aide had come to the non-public school, and that for only 4 days. The excuse given was that the aide had resigned and that others were being trained. An overhead projector and five slide projectors were made available to the nonpublic school. Each teacher was allowed a quota of three films a week. The school nurse gave the children immunization shots. The free lunch offer had to be declined. This would have necessitated busing the children to public elementary schools to eat lunch there. This cumbersome and time-consuming restriction would have placed an additional expense on the non-public school, since it is unconstitutional to provide free bus service for non-public-school children.

In fiscal year 1967 one-fourth of the maximum LEA allotment was spent on equipment and materials. Eight projects were funded, but the eligible nonpublic school children shared less. "Due to provisions of ESEA which prohibits assignment of staff and personnel to nonpublic schools on a full-time basis, no teacher aides will be assigned to nonpublic schools." Unfortunately the question of shared services on a part-time basis was never investigated by the nonpublic school. Once again the nonpublic school had to settle for less than token participation.

The 10-page fiscal year 1966 LEA evaluation of the entire title I program was very sketchy and noncommittal. The usual meaningless generalities contributed little. The nonpublic sector was completely

ignored in the writing of this phase of the project. No records or data were interchanged because the eligible nonpublic school children could not afford, in terms of time and money, to be bussed to the public schools to participate in title I activities during the regular schoolday. A few nonpublic school children participated in the summer projects. The hazy, vague, almost private interpretation of ESEA title I at the State and local levels needs to be probed and clarified, and the question of shared services be investigated.

Three interested citizens were interviewed. This group consisted of a member of the local board of education and a practicing lawyer, an M.D. who was a civil rights leader, and the assistant editor of a political party newspaper. All three confessed ignorance of the specifics of title I.

The lawyer knew of no State law forbidding the disbursal of title I funds to the nonpublic schools. He gave the interviewer the impression that he intended to look into this matter. "The community should be grateful for the presence of the parochial schools. They lessen the burden placed on the local public school system.”

The physician expressed dissatisfaction with religious leaders, especially members of the clergy, because they failed "to stand up and be counted" in the civil rights movement. He believed that this fear or apathy accounted for the minimal nonpublic participation in this district.

The board member pointed out that the present legislation discriminates against the needy student attending a nonpublic school located in in a nontarget area.

Judging from the comments made by these three community leaders, a little more initiative on the part of nonpublic school leaders and increased communications between both sectors at the local level would result in a more equitable sharing of title I funds.

CASE S-4

I. STATE CHARACTERISTICS

This small school system is located in an eastern-central State. The State's maximum allotment for fiscal year 1966 was $16,991,225.28 for ESEA title I programs. The amount for approved projects was $16,383,765.62. Half the State average expenditure per pupil for 1963-64 amounted to $159.56. The economy of this State has been affected significantly in recent years by the decline of mining and coal industries.

TABLE 47.-SEA Basic State data, case No. S-4

The State evaluation for fiscal year 1966 includes the following meaningful comments: "During title I operation in 1966, participation of non-public-school children was limited. This was especially true for

academic year programs. Summer school programs operating in June, July, and August showed much greater participation of children from nonpublic schools."

A principal limitation during early operation was found in the difficulty of establishing open communication between representatives of public schools and nonpublic schools. Such communication had not existed over past years. A special effort has been made in this State to improve communication at the local level between public school and private school representatives. Title I program specialists are visiting nonpublic schools to talk with principals and teachers on program activity and services available under title I, and to explore ways and means of making these programs available to non-public-school children.

Teachers employed by public school boards of education are assigned to remedial programs in private schools. Non-public-school children are participating in title I activity in the public school on a sharedtime basis as well as in activity conducted outside the normal school day, i.e., before school, after school, and on Saturday. Further, nonpublic-school teachers are participating in in-service training programs provided by title I funds. When the SEA official was asked to describe any suggestions or recommendations for revising the legislation he declared: "Federal legislation seems to be adequate."

This State has county school districts. County allocations were determined by the U.S. Office of Education. No suballocations were involved since there are no subdistricts. A public school official at the State level said that title I expenditure for fiscal year 1966 was 83.6 percent of the maximum basic grant to the State. This same official also indicated that non-public-school officials did not participate in the review and approval of title I projects on the State level, but they generally participated on the local level, including the endorsement of proposed programs.

When title I project applications did not provide for participation of non-public-school children, some of the reasons offered were

(1) No financially and educationally deprived children in nonpublic schools;

(2) Difficulties involved in participating on a shared-time basis because of the demands of the non-public-school program; and (3) Too few eligible pupils to justify the establishment of a title I program activity in a nonpublic school.

It was the perception of a public school State official that, prior to title I, there was little or no communication between the public and private sectors. Certainly there was no working relationship. Since title I, however, communication has been established between the two separate school systems, and public and nonpublic school representatives are working together to plan and develop programs for disadvantaged children. In his opinion communication was initiated by public school representatives.

A non-public-school official at the dioceson level has made the following observations: "Orientation for title I at the State level was in most instances satisfactory; at the local levels, it left much to be desired. Representatives from the nonpublic sector were involved in planning projects only to a very limited and unsatisfactory degree.

The needs of the non-public-school students are not necessarily the needs of the public school students. With very rare exceptions, the needs of the public school students have been assessed, found, and pinpointed; and then remedies for these needs have been made available to both public and nonpublic students whether or not, in the case of the latter group, their needs were the same. Involvement in title I has caused a change in adminstrative relationships on the State level from very apathetic or detached to involved and cooperative. Communications appear to have improved progressively, but contrary to the opinion of public school officials at the State level, non-publicschool officials believe this is due to the initiative of the non-publicschool personnel."

II. LOCAL CHARACTERISTICS

Public school officials at the local level made the following observations:

1. Non-public-school personnel participated in all in-service meetings in the county and in regional meetings pertaining to title I. 2. Non-public-school officials seem highly interested in their involvement in title I projects and were extremely cooperative.

3. All preliminary plans were cooperatively discussed and opinions consulted.

4. Non-public-school officials were consulted concerning the needs of non-public-school children and their needs were determined to be the same as public school children's.

5. All programs were conducted within geographical proximity to the parochial school.

6. Summer programs had excellent participation by children from both private and public schools. Percentagewise, there was better participation from non-public-school students than from the public school students.

7. Communication between officials of both sectors takes place as needed and is highly desirable.

8. Non-public-school officials received the evaluation reports of nonpublic-school children who participated in title I programs.

A non-public-school official at the local level made statements which agree in substance with the perceptions of the public school officials.

The perceptions of the field survey coordinator included the following: There were no nonprofessional persons involved in either planning or evaluationing of title I projects; and, thus, no interviews were conducted with interested citizens. There is only one nonpublic school in this county and its students were involved in title I projects. There is evidence that a genuine respect for personnel from both public and non

public school systems was present. School principals appeared to have only a very general knowledge of the intent and purpose of title I. There also seemed to be an agreement of sorts which implied that the needs of the nonpublic and the public school children were the same. It is the opinion of the field survey coordinator that the county school system was attempting to follow the intent and purposes of title I.

It was a recommendation from the nonpublic sector that the State superintendent and/or county school board deal directly with the diocesan superintendent who, in the case of the Catholic schools in this State, occupies a position equal to the chief State education officer. A public school official recommended that teacher aides be made available to private schools. Further, non-public-school personnel recommended that there be more articulation between all community agencies which are concerned with the welfare of the children. Finally, a nonpublic representative called for more parent involvement in title I activities.

CASE S-5

I. STATE CHARACTERISTICS

In this midwest State the maximum amount authorized was $24,509,211.50, based on a per-pupil figure of $275.75.

The LEA's were allocated a stated amount for each eligible child in the district as determined by the USOE criteria. The SEA started planning in terms of $265.10 per pupil; the amount finally allocated was $184.70. About 64 percent of the maximum basic grant was expended by the SEA during fiscal year 1966.

There were no major constitutional problems pertaining to title I. The only restriction is that public personnel going into nonpublic schools under title I must be supervised by public personnel.

Also, the State has a quasi-arrangement for some title I programs. The public school districts may get some money from the State to help with these programs, money to add to title I money. This money is available for the programs that are in public schools. It is even available to help bus pupils to public schools from nonpublic schools. It is not available when the services are provided on the premises of the nonpublic schools. It is legal to send people to nonpublic schools to provide "remedial" and "therapeutic" services.

The Attorney General has not given the SEA any formal rulings. "He sat down and advised us informally." His position was not to raise the constitutional issues publicly. Thus far he has avoided any rulings regarding title I. The Attorney General informed the title I staff to "quietly go ahead on the assumption that the State constitution would not prevent channeling Federal moneys to benefit children."