The SEA procedure for approving title I applications was explained thus: The area directors for title I recommend approval of the application; then the assistant to the title I coordinator approves it. The Commissioner of Education serves as a court of last resort for the LEA's who disagree with the title I coordinator's assessment. Nonpublic-school officials were not involved in the review or endorsement of applications on the State level. The title I coordinator is opposed to their involvement because "they (nonpublic officials) have too much of a vested interest in getting proposals approved. The parochial school people have ample opportunity to get into the act at the local level." The procedure for nonpublic participation in planning at the local level was explained thus: The parochial school people suggest the kinds of programs they think they need. Then the public school superintendent tries to work these ideas into the program. The title I coordinator felt that, "the public school superintendents have got the message that they must work with the nonpublic schools." The official policy emanating from the SEA is that parochial schools in disadvantaged areas (target areas) should receive a share of the services proportionate to their ratio of enrollment. Essentially, the SEA relies on the nonpublic-school leaders themselves to insure that the arrangements are equitable. As a member of the title I staff commented, "We (title I staff) are sure that the diocesan superintendent will scream if his schools are not adequately taken care of." In describing nonpublic participation in planning title I programs, the archdiocesan superintendent for Catholic schools explained that the procedure followed was for public officials to plan the programs, and then inform the leaders in nonpublic schools of what they have planned, inviting comment. The general pattern in this area has been to consult leaders in nonpublic schools very little, if at all, while designing the programs. In the fall of 1965 the first area meeting of the SEA was held to explain title I, and many representatives of nonpublic schools attended. Several other meetings on a regional basis were held. The SEA sends memos, directives, and guidelines to nonpublic-school officials on a regular basis. The relationship between the SEA and chief non-public-school officials prior to title I was described by the title I staff as being a situation. in which "they ignored us and we ignored them." After title I, there was a realization "that relationships between the State department and different kinds of schools cannot be avoided." In general the State officials described the current relationship as "fairly cordial." The archdiocesan superintendent stated that prior to title I State officials were very rigid about working with nonpublic schools in any way, interpreting constitutional provisions "supercilliously." Since the advent of title I projects, nonpublic officials feel that cooperation has been much improved. Both the public and nonpublic officials are concerned about legal action relative to title I. The archdiocesan superintendent stated that there has been a marked tendency for public State and local officials to use confusion over title I as an excuse for halfhearted action. "They are afraid some citizen will take them to court and will have them held personally responsible for illegal disbursement of funds." In contrast the State coordinator presented an opinion that the nonpublic personnel "are reluctant to complain. They are afraid to rock the boat, fearing that if someone makes an issue of the arrangement under title I, the whole affair will be held unconstitutional, and they will be out altogether." II. LOCAL CHARACTERISTICS The title I project provided comprehensive reading skills for the school year and a summer enrichment program with available psychological and social services. The fiscal year 1967 title I project was a continuation of the fiscal year 1966 project. TABLE 50.-LEA data, case No. S-5 Number of children eligible.......... Number of public school children participating-- Number of non-public-school children participating. Eligible Participant ratio-- Expenditure per participants- Title I expenditure rank_ State expenditure (1963-64) rank_. 187 264 55 0 1:1.71 $161. 65 4 (14) 1 (3) The title I program was focused on nine schools in the district, including one Catholic elementary school. The remaining Catholic school was not included in the program because it was not in the area of highest concentration. The most pressing educational need of educationally deprived children in these attendance areas was identified as reading. The criteria for judging the needs on both elementary and secondary levels included intelligence and reading tests and teacher observation. The planning and administrative preparation took place between June 1, 1965, and January 1966. The fiscal year 1966 project took place from January 17, 1966, to June 1, 1966, and the fiscal year 1967 project from August 29, 1966, to August 31, 1967. The maximum basic grant (fiscal year 1966) for the LEA for $51,565.25. The maximium basic grant (fiscal year 1967) was $37,400, and $36,400 was the amount approved for the project. The project took place in public and non-public-school facilities, during the regular schoolday. The summer program was held in public facilities during the day. The title I coordinator explained that the nonpublic personnel were "intimately involved in every detail of the planning *** even long before any documents were put together." At least five meetings with the nonpublic officials were held before any program decisions were made. Both the public school principals involved in the title I program and the title I coordinator stated that the nonpublic principal "was involved in the planning all along," but the nonpublic principal_asserted that there was no nonpublic participation at all. "We were asked for reactions far too late to permit real participation." There are two contradictory_opinions evident, relative to the orientation and planning for title I in this LEA. The public school officials identified the needs that they felt were general throughout the district, and then asked for non-public-school officials' reactions. They agreed to the same needs and suggested no changes. In preparing the application the public-school officials claim to have asked about eligible nonpublic children, but a nonpublic principal denied emphatically that this information was requested. In essence, the nonpublic officials were not contacted until the proposal was ready for State approval. Non-public-school officials were not invited to participate in the planning of the summer program. After the program was structured, they were invited to participate. The nonpublic sector was not consulted in determining the needs or the final focus of the summer program. Inservice programs were established for title I remedial teachers, but nonpublic teachers did not participate. The non-public-school principal involved was not aware of the inservice training being conducted. Scheduling, both in time and location, proved to be no problem. The remedial program was located on non-public-school premises, with the schedule controlled by the nonpublic principal. A full-time remedial reading teacher was assigned and the nonpublic principal could "use her pretty well as I wish to do." She is free to decide most of the details of the operation, though the program is formally under the supervision of a public school principal. In the summer program, the non-publicschool students were bussed on the same basis as public school students; the project was located in two centrally located public schools. The nonpublic schools referred a disproportionate number of youngsters to the summer school program. They took greater advantage of the opportunity than did the public schools. The remedial reading instructor is the only individual assigned to the nonpublic schools. A psychologist and social worker were available during the summer. The lack of qualified personnel from the local public-school system proved to be a significant problem in inhibiting full participation of nonpublic students in title I. Since the public-school officials could not locate a qualified psychologist and social worker, the participation of pupils in these services was cut off altogether. The climate of cooperation between public and nonpublic officials has been described as "tremendous" by the title I coordinator, although there have been some difficulties with a priest of one of the parishes. A nonpublic official asserted that "they (public-school officials) work with us only because they have to-because there are many Catholics in the area, or because title I requires it." Since title I, there has been much more contact. Joint meetings of public and nonpublic principals are held. There have been no changes in basic attitudes; it is maintained that they have always been good. Contact is more extensive and frequent. The nonpublic officials find communication very frequent and useful. There are no local pressure groups opposed to title I, but nonpublic officials stated that the superintendent warned of what pressure groups might do if he were too liberal with nonpublic schools. The nonpublic officials were urged not to make an issue out of what they are denied under title I, because pressure groups will become active, and the nonpublic sector, "will end up with less than they would have got if they had kept quiet." Also, other than title I, there are no sharedtime arrangements. The superintendent is, in principle, against shared-time activities not completely supported by title I funds. Otherwise, it would cause a loss of State aid for part-time pupils. Nonpublic school officials point out that just a few miles outside of the district. shared-time programs are common. Non-public-school personnel were not involved in any phase of project evaluations. The public school personnel evaluated in terms of straight testing. The non-public-school personnel were informed of the results and received a copy of the evaluation after it went to the State. It was a consensus of both public and non-public-school officials that the title I project was effective in meeting the needs of both public and nonpublic school children. All considered the remedial reading project as a primary necessity, but non-public-school officials suggested that remedial mathematics, remedial speech, and inservice training for teachers would be helpful. Non-public-school officials, although satisfied with the remedial reading program, expressed reservations relative to the "assumption that public school officials know what we need much more than we do, and the assumption that we should be thankful for any help they feel fit to give us." Criticism was directed toward the public school personnel because "no aspect of the project was planned with any nonpublic pupils in mind, or even with suggestions or information from us concerning the needs of our school." In summary, a nonpublic official commented, "Fortunately, we happened to need a remedial reading teacher." CASE S-6 1. STATE CHARACTERISTICS Case S-6 is based on a small school system of a northern Midwest State. The maximum amount authorized to this State under title I in fiscal year 1966 was $18,030,939.15. Seventy-two percent of the maximum basic grant was expended in fiscal year 1966. In fiscal year 1967 the SEA expects that 98 percent of the total grant will be expended. TABLE 51.-SEA Basic State data, case No. S-6 In fiscal year 1966 the SEA received $262.15 per child (one-half the State average current expenditure 1963-64) for low-income and AFDC children, but the money was allocated to the LEA's on the basis of lowincome children only. In fiscal year 1967 the SEA was ordered to allocate on the basis of both low-income and AFDC children, but the SEA made some adjustments so that some districts would not incur too large a cut in funds in 1 year. During fiscal year 1966, when nonpublic children were not included in the applications, the SEA simply accepted the word of the local public school official that the nonpublic schools did not wish to participate. The title I staff "soon learned that approach was not adequate.” In too many cases the public school personnel had established programs unilaterally and had invited nonpublic schools to participate only after "everything was cut and dried." At present the SEA title I staff is not accepting the statement that nonpublic schools do not want to participate without a written statement from the nonpublic schools. The title I director commented, "Even this does not seem to be adequate." The title I staff is planning to insist that the nonpublic schools be invited into the planning of title I projects. The director found that "the most successful programs, as far as non-public-school participation is concerned, are those which the public and nonpublic schools planned jointly. We have been passing the word around the State that we will insist on this." Also, the title I staff insists "that pupils from present LEA's include non-public-school students on a proportionate basis to public school students in the title I prgram. We (title I staff) are not going to permit this anymore." Every child will have to qualify on the basis of economic deprivation, "even if the approach cuts down. on the proportion coming from nonpublic schools." According to the Attorney General's ruling of July 1966 requested by the SEA, the State constitution prohibits the use of title I funds by nonpublic school children except on the premises of the public schools. No programs may be on the premises of nonpublic schools, and title I funds may not be used to bus pupils from nonpublic schools to the location of title I programs. The SEA approach has been to encourage the LEA's "to provide the services in public schools that are close to the nonpublic schools." In general, no public school personnel have been permitted to provide services on the premises of nonpublic schools. In a very few cases, where the public school has been short of space, and the nonpublic school has been close by, the public school has rented a room in the nonpublic school and established the title I program. To do this is not to provide the services on the premises of nonpublic schools; such rented rooms are public school premises. Professional educators on the staff of the SEA title I director review the LEA applications and they are finally approved by the title I director. Non-public-school officials were not invited by SEA personnel to review or endorse applications prior to final approval. The title I director felt that "the nonpublic schools are sufficiently represented on the title I advisory committee." The title I director described the relationship between the SEA and the chief non-public-school officials as "good all along," but the Catholic diocesan superintendent explained that "relationships have been strained for a period of about 20 years. During the last 6 months, things |