RSVP in an agency which does not and cannot have the needs of the elderly as their primary concern-particularly when there is an agency which does have aging as its sole responsibility. Nor are our comments meant to imply criticism of many of ACTION's staff with whom we have worked closely over the years, who we believe have necessarily been limited in their ability to implement what we see as the legislative intent of RSVP. It seems to us that they were understanably restricted by the broad goals and administrative policies of the overall agency. We are convinced that RSVP would be strengthened by being a part of the Administration on Aging's network of services, and this network in turn would be strengthened by the inclusion of RSVP.

We, therefore, respectfully request that as the commitee considers the renewal of the Older Americans Act, it will also consider transferring RSVP back into AOA as a separate title so that it can have its own identity separate from other programs-with an administrative structure similar to the title VII, nutrition program.

One other comment in relation to RSVP. We would like to applaud the recently enacted legislation which provides for ongoing Federal funding for RSVP after the 5th year. This was a major step forward. However, we believe that the present formula which increases local support by 10 percent each year is still unrealistic and we are concerned that many local communities will not be able to continue their RSVP programs under that formula. We therefore urge the Congress to reconsider their mandate that local communities provide 50 percent of the operating costs of the program by the 5th year. Based on what we have heard from communities across the country we urge that a lower level of local support be considered.

This issue of ongoing support for RSVP is closely related to another important concern, that is, the effective implementation of title III programs. Even though the Federal legislation permits funding up to a 90-10 percent formula with no time limitations, the regulations require that funding be discontinued after 3 years unless special approval is given by the Commissioner. This policy tends to reestablish a seed money demonstration approach which implies that local communities can assume full operation costs for program continuation.

All of our experience to date with demonstration programs convinces us that 3 years is too short a period to demonstrate new programs and approaches to alleviate broad social problems. Furthermore, the time-limited seed money approach by the Federal Government is not a viable one for the provision of services to the aging. Congress recognized these facts in the 1973 amendments to the Ölder Americans Act when they completely eliminated the formula of declining grants from the act. In fact, the Committee on Education and Labor declined to accept an administration supported substitute bill in 1973 that would have continued the demonstration and seed money approach.'

We would respect fully suggest that this committee examine the effects of the regulations on the very purpose of title III. We would also suggest that the development of service delivery systems mandated by the area plan approach is dependent on the real existence of services in the community and not on demonstration projects that fade in the wake of withdrawn Federal support.

1 Minority views of Representative Landgrebe on H.R. 71. Older Americans Comprehensive Services Amendments of 1973, Explanation of 1973 Amendments and Selected Background Material. Prepared for use of the Special Committee on Aging. U.S. Senate.

Mr. Chairman, we know that every imaginable service cannot be made available to every older person in every location in the Nation at the same time. But the current pattern of now you see it-now you don't, as has been practiced by the seed money approach must end. It is true that hard priority decisions must be made, but if the intent of the title III legislation is to be fully realized, services must become a permanent reality in local communities. We think those services will have to be fully and permanently supported by public funds as is true in title VII of the Older Americans Act.

Mr. BRADEMAS. Thank you very much.

I must say I find your statement a compelling one in view of the fact you have been a leader in this field, and I think your suggestions merit very close consideration by the subcommittee.

Mr. Jeffords.

Mr. JEFFORDS. Mr. Chairman, I would just like to join in your complimentary remarks about the very fine presentation. It was so fine, I don't have any questions.

Mr. BRADEMAS. Thank you very much indeed, Miss Sainer.

Our next witness is Weldon V. Barton of National Farmers Union, director of Governmental Services.

STATEMENT OF WELDON V. BARTON, DIRECTOR OF GOVERNMENTAL SERVICES, NATIONAL FARMERS UNION

Mr. BARTON. Thank you, Mr. Chairman.

Mr. Chairman and members of the subcommittee, I am Weldon V. Barton, director of Governmental Services, National Farmers Union. Our Washington Office is 1012 14th Street NW., Washington, D.C. 20005, phone 202-628-9774.

While Farmers Union would encourage you to extend all titles of the 1973 Older Americans Comprehensive Services Amendment in a form that will be more serviceable to the elderly, my testimony will focus on title IX because of Farmers Union's particular interest and responsibilities under that title.

Farmers Union, during fiscal 1974-75, contracted with the Department of Labor to carry out an elderly workers employment program under the Community Services Employment for Older Americans Act, title IX of the 1973 act. We are currently employing some 1,331 elderly people under that program.

Farmers Union carries out the title IX program in close cooperation with a similar older workers employment program that we have administered under Department of Labor contract since 1965. Called Farmers Union Green Thumb, this operation mainstream program which is funded under title III of the Comprehensive Employment and Training Act of 1973, employs some 3,739 elderly people during the current fiscal year.

Green Thumb employs older low-income rural persons, 55 years or older, to carry out community betterment and conservation projects, strengthen existing community services, and provide special outreach services to help the aged, shut-ins and handicapped.

Green thumbers carry out a variety of projects and work assignments. Park and recreation facilities are built and improved. Courthouses and community centers are renovated. Green Thumb workers

serve as librarian assistants and teachers aides. They work in senior citizen centers and provide many other outreach services.

Despite the fact that these programs have proven effective for the meaningful employment of persons 55 years or older who otherwise would not have jobs, the Department of Labor on March 5, 1974, sent official notice to Farmers Union and other national contractors of operation mainstream older workers programs that the programs would be terminated on June 30, 1975.

If that decision was allowed to stand, it would mean that over 5,000 older poor people who are now working for their living on Green Thumb projects would lose their jobs and would be forced to find some other way to supplement their meager incomes. When the other operation mainstream contractors are also included, over 9,000 older poor people would have their jobs terminated.

We are appealing to you on this committee, and to the Congress, to prevail upon the Labor Department to continue these employment programs for our elderly people beyond mid-1975, and to prevent the dignity of the presently employed older workers from being trampled upon.

Specifically, we respectfully request that you: (1) Prevail upon the Department of Labor to make available to Green Thumb and the other operation mainstream national contractors the $12 million for title IX that was contained in the fiscal year 1975 Labor-HEW Appropriations Act and that was explicity designated by the Appropriations Committees of both the House and Senate to be allocated primarily to the operation mainstream national contractors; and (2) extend the Community Services Employment for Older Americans Act of 1973 (title IX) as part of an Older Americans Act of 1975, with the necessary changes and money authorizations to make sure that the nationally contracted Green Thumb and other older workers programs will be continued at their full strength in 1976 and beyond. Allow me briefly to review several reasons why the Operation Mainstream programs should be enabled to continue to serve elderly people who are poor and who want meaningful jobs in order to maintain their dignity and to serve their communities."

1. The programs have proven successful. The Kirschner report—prepared by an evaluation group contracted by the Departmentcompared the Operation Mainstream program administered through regional Department of Labor offices and the national contractors, and came to the following conclusion 3 years ago:

It has been demonstrated consistently in Operation Mainstream that by any standard the overall administration and operation of the program has been most effective when the national contractors are involved. It is also apparent that the particular national contractors involved are appropriate for the program and have demonstrated a capability to minister effectively to the needs of both older enrollees and communities served. Thus, it is recommended that: The proposed older worker program be continued to operate under the direction of NCSC, NCOA, NRTS, and the National Farmers Union.

2. A categorical program is required, if older persons who want to work are not to be ignored.

Administrators of the Comprehensive Employment and Training Act of 1973 are manpower people, who tend to think in terms of younger workers, full-time jobs, and career planning-the same type administrators who ran manpower programs in 1973 when enrollees over 55 years represented only 1.7 percent of the total enrollees.

Another major consideration for retaining a separate program for older people administered outside the CETA prime sponsor mechanism is the CETA provision which allows governments to limit enrollment to those people who fit within their particular personnel policies, including their mandatory retirement age policy. This could result in age discrimination, and could, in effect, cut out the neediest of the Operation Mainstream older workers-those who are over 65 years of age and therefore are offered no protection under the Age Discrimination Act.

From the data available from CETA project plans, approximately 4 percent of CETA enrollment positions are supposed to be going to assist older workers. However, this figure is not only much too low in relation to the need, but also may include anyone 45 years or over, since the Department of Labor did not define its term "older worker."

At the request of Mr. William Kolberg, the Labor Assistant Secretary for Manpower, Farmers Union has made every effort to work through the State CETA prime sponsors to secure funding for Green Thumb type projects, and has attempted to monitor the situation regarding involvement of elderly people in CETA-funded employment programs within States with Green Thumb programs.

In a State-by-State report to Assistant Secretary Kolberg, dated August 6, 1974, Farmers Union Green Thumb reported that, to our knowledge, there had been very little enrollment to that date of elderly people in the CETA funded employment programs administered through the prime sponsors.

We have updated that August 6 report with telephone calls last week to each of our States, and we find little change in that situation. Among the 25 States and Puerto Rico in which there are Green Thumb programs, only in Michigan has a CETA prime sponsor made any funds available under workable and acceptable conditions for the operation of a State Green Thumb type program. In Michigan, $60,000 was made available.

Also, insofar as the Green Thumb personnel are aware, CETA prime sponsors have ignored older workers in their employment programs generally to date, and have restricted enrollments almost entirely to younger workers and the recently unemployed. Furthermore, the Governors' State and area councils under CETA, apparently have seldom included persons sensitive to the need to employ elderly people.

Consequently, CETA has not proven to be a workable alternative to the categorical, nationally contracted approach, in making sure that elderly persons who are poor and need to work are able to participate in employment programs.

3. Welfare or other alternatives to meaningful work opportunities for the elderly are more costly.

The average Operation Mainstream enrollee's pay for 1 month is $191 less an approximate $11 deduction for social security. Certainly the services that these older workers provide, if put in dollars and cents values, would more than equal such a cost differential.

Welfare is not a real alternative, in any case, for many of the elderly. who are employed with Green Thumb. These elderly, rural people have a fierce pride, and they need to work to maintain dignity. It is only right in a moral sense that they be afforded work opportunities. 4. There is plenty of meaningful work to be done. Repair, renova

tion, construction, conservation, development, and beautification tasks of the kind that Green Thumb older workers-men and women-are performing abound in rural areas.

For these reasons, we urge you to amend and extend title IX so as to assure the continuation of Green Thumb and other Operation Mainstream programs at their full strength.

Mr. Chairman, with respect to the following specific proposed amendments to title IX, we have agreement among all four of the private nonprofit organizations which are sponsors of Operation Mainstream programs that these specific amendments are required. I do not mean to imply that these will be the only amendments that the national contractors will recommend. The other national contractors will be testifying, and I am sure they may propose some additional changes. Nevertheless, the point that I am making is that all four of the private Operation Mainstream contractors the National Council of Senior Citizens, National Council on Aging, American Association of Retired Persons, and National Farmers Union-have agreed upon the following five amendments:

Specifically, we recommend extension of title IX for a 3-year period, with the following amendments:

1. Section 902(b) (1), delete the comma after the word "organizations" and insert the following: "including national organizations,". Explanation: The additional words would make explicit that national private nonprofit organizations are eligible as program

contractors.

2. Section 903 (b) (1), rewrite as follows:

The Secretary is authorized, where such arrangements are designed to increase job opportunities available to eligible individuals under this title, to coordinate the programs assisted under this title with the Economic Opportunity Act of 1964, the Emergency Employment Act of 1971, the Comprehensive Employment and Training Act of 1973, and the Emergency Jobs and Unemployment Assistance Act of 1974, except that appropriations for programs assisted under this title may not be expended for programs assisted under such acts or other such legislation.

Delete all of section 903 (b) (2).

Explanation: The additions to subsection (1) add the CETA and the 1975 Emergency Jobs Act to the list of legislation already included with which the Secretary is authorized to coordinate title IX programs. The "except that" language of subsection (2) is appended to subsection (1) after that expanded list of acts with which coordination is expected, in order to retain the requirement that the Secretary keep title IX funding separate and not fold it into CETA or any other legislation. The remainder of subsection (2) is deleted, because it now appears superfluous.

3. Section 903 (d), substitute a comma for the period at the end, and add the following: "except that such criteria shall give preference to national organizations with experience in the administration of older workers employment programs."

Explanation: Such an explicit preference in the authorization legislation is deemed essential to assure continuation of nationally contracted programs, in light of the present administration's determination to terminate the same.

4. Section 806 (a) (1), in line 6, delete the words "one-half of"; in line 10, delete the word "one-fourth" and substitute "one-half”.