This study is referred to as Project Renaissance. I suggest to you gentlemen that I have the background experience, and actual operations expertise, to comment with considerable authority on the effective implementation of Title VII and particularly to comment on the proposed guidelines.

Those of us who work with the nutrition programs for the elderly are picking up the ball on the 5-yard line. The clock is running out, but I think we can still score.

Our project personnel must be convinced of the soundness of this premise that through adequate nutrition, a participant will benefit physically, mentally, and emotionally.

We feel the problems that the older people have such as assistance in education, that mental and physical activities, that all of these things help to develop an individual and to keep his vigor at a high level.

COMMENT ON GUIDLINES

My remarks will be addressed to each of the guidelines on which I feel comment is necessary. I will mention each guideline and speak briefly about these.

Section 909.3 addressed to eligible individuals: I suggest that this should read, "The spouses or guardian of such individuals are also considered eligible."

Project area, item B, means the geographic area for which a single award may be made and it goes on to describe those areas, including Indian reservations. I suggest to you an additional statement be added to provide that smaller areas may be designated as project areas upon review, and recommendation of the State agency, with subsequent approval of the Secretary's delegated authority.

Section 909.18 deals with coordination of other agencies. Part 909.83 requires that supporting social services including comprehensive outreach, transportation, information, and referral services, health and welfare counseling services; nutrition education and recreational activities be provided.

Section B of this part provides that no more than 20 percent of a State's allotment for a given fiscal year shall be used for the provision of social services.

I would suggest to you, sir, that the 20 percent support limitation for supporting social services is inadequate to provide the projected demands for social services, particularly that of transportation.

I would suggest that we have a comprehensive review, if you will, of the priorities of Title III programs under the Administration on Aging, as they relate to the operation of the Title VII program, to insure adequate coordination. I would further suggest a task force be set up to study the feasibility of expanding the provisions of Title XVI of the Social Security Amendments of 1967, to include a direct tie-in with the requirements of this section, dealing with this provision of social services.

I am suggesting the following areas in Title XVI be considered:

1. Assurances be made that each of the 50 States has completed its plans for, and has implemented the necessary machinery to

contract with, private and/or public agencies, organizations, and institutions for the purchase of supportive social services.

2. The requirement of third-party funding.

3. The eligibility requirement of former, current, or potential recipient of public assistance be further expanded.

4. The matching requirements be revised to be more consistent with matching requirements of Title VII; Title XVI requires 75– 25 percent matching.

We should also look into the possibility that Title XVI include an in-kind contribution as opposed to cash.

On Section 909.21, projects awards, I would suggest to you that part E of this item, "Each project must serve an average of at least 100 meals daily throughout the project area," be amended to include that, "This provision may be waived in the event that local geographic and/ or population characteristics would make this provision impracticable." Such a waiver would require state and/or SRS approval.

On 909.22, "Strengthening of Existing Programs," I would suggest to you that the words "and expand" be added to line three of this paragraph following the word "strengthen."

On 909.34, "Selection of Congregate Meal Sites," I would suggest to you that either in this section, or part 909.59, "Allowable Costs," that there be a provision for the purchase of equipment and vehicles under the title of capital expenditures.

On 909.40, "Charges to Recipients for Cost of Meals," part E; this section must be reviewed and explained in much greater detail regarding the eligibility of persons using food stamps for home-delivered meals, the USDA guidelines are quite specific regarding the limitation placed on this provision.

On 909.49, "Purchase of Goods and Services"; part C should provide for renewal, options on contractual agreements provided both parties are satisfied with performance of the contracts.

Section 909.59 should provide for the purchase of goods and services. Under the section 909.60, "USDA Donated Foods"; I would suggest that USDA or the Administration on Aging prepare for distribution, a handbook and/or guidelines that would clearly define the type of donated foods available.

The procedure for acquisition of such foods, and periodic equivalent cost charts for accounting purposes, especially when food service is contracted out to a private, profitmaking firm.

REBUTTALS TO NEED FOR MEANS TEST

One other statement I would like to make in response to a question mentioned about the means test. In Dade County, we are serving somewhere in the neighborhood-we have served somewhere in the neighborhood of 800 to 1,000 meals a day. It is probably one of the largest nutrition programs in the country.

In one day, we interviewed 1,000 people without any prior notice whatsoever, to determine what the income level of a person using our services amounted to. Less than 5 percent of those interviewed had incomes exceeding $200 a month. So, we felt that there were a few people who had incomes that were of-more than adequate, that were using

our services, but the majority of our people had extremely low, fixed incomes.

One of the problems we are experiencing with the use of surplus commodities is the type of commodity that is given to us: Cornmeal, rice, butter, peanut butter, cooking oil. Such distribution does not provide sufficient raw foods for significant reduction in raw food costs.

The other area we would like to think about just a moment is the effect, cost analysis, cost benefit we have experienced in Miami with a new program that has been developed in cooperation with the hospitals for the release of geriatric patients earlier with an agreement that senior centers provide food service and supportive social services to these patients.

In many cases, this has meant a release of 5 to 8 days earlier than they normally would have been released.

Talking about the nutrition programs, I think there is a great deal of merit--and, of course, this depends on the size of the community, the volume of the program itself-the use of outside contractors for this type of food service.

I believe there are many, many other methods that can be developed in the delivery of nutrition services to older people and which warrant further investigation. Thank you.

PREPARED STATEMENT OF CLIFFORD W. McLOUD

Mr. Chairman, gentlemen: May I first express my appreciation to you, members of the Select Committee on Nutrition and Human Needs, and members of the Minority Staff for inviting my colleagues and I to testify regarding the proposed regulations leading to the implementation of Title VII of the Older Americans Act, Nutrition Programs for the Elderly. I wish further to particularly thank my Congressman, Representative Claude Pepper for his authorship of the original legislation as presented to the 91st Congress, for his continued interest and perseverance and for his total commitment to Public Law 92-258.

Because of the impact these hearings will have on the implementation of Title VII and because of the millions of Older Americans anxiously awaiting a speedy start up, I feel this statement should be brief, concise and credible. I am currently the Executive Director of the Senior Centers of Dade County, Inc. in Miami, Florida operating one of the largest Nutrition programs for the Elderly in the Nation. During this fiscal year, the Senior Centers will serve approximately 180,000 meals to Older Americans living in Dade County.

Prior to my current position, I was Chief of the Florida Bureau on Aging responsible for the Administration of Title III of the Older Americans Act in the State of Florida.

I have designed, and am currently administering a research project for the Administration on Aging, under provisions of Title IV, to determine the Effect of Nutrition Programs on the Socially Isolated Elderly. This study is referred to as project "Reniassance". I suggest to you gentlemen that I have the background experience, and actual operations expertise to comment with considerable authority of the effective implementation of Title VII and particularly to comment on the proposed guidelines.

My comments will be addressed to each part of the guidelines on which I feel comment is necessary.

909.3 Definitions

A. Eligible Individuals-"The Spouses of such individuals are also considered eligible Individuals."

I would suggest to you that this section should read:

"The Spouses and/or guardian of such individuals are also considered eligible Individuals."

B. "Project area" means the geographic area for which a single project award may be made. This project area may not be less in area than a single

76-300-72-pt. 2- 4

county, a single city with population of at least 250,000, or a single Indian Reservation."

I would suggest to you that an additional statement be added to provide that "Smaller areas may be designated as "Project Areas" upon review and recommendation of the State Agency with subsequent approval of the Secretary or his delegated authority."

909.18 Coordination of other Agencies Part 909.38, A.-requires that Supporting Social Services including: comprehensive outreach, transportation, Information and referral services health and welfare counseling services; Nutrition education and recreational activities be provided.

Section B of this part further provides that, Not more than 20 percent of a State's Allotment for a given fiscal year shall be used for the provision of Social Services prescribed in this section.

I would suggest to you that the 20 percent limitation for Supporting Social Services inadequate to provide the projected demands for Supportive Social Services particularly that of transportation.

A comprehensive review of the priorities of AoA Title III should be completed with the objective of coordinating there priorities with the stated goals and objectives of Title VII.

It is further suggested that a task force be established to study the feasability, on a national level, of expanding the authority of Title VI of the Social Security Amendment of 1967, to include a direct tie in with the requirements of Supportive Social Services as provided for in Title VII.

The following should be reviewed:

1. Assurance that each of the 50 states has completed its plans for, and has implemented the necessary machinery to contract with private and/or public agencies, organizations, and institutions for the purchase of supportive social services.

2. The requirement of third (3rd) party funding.

3. The eligibility requirement of former, current or potential recipient of public assistance.

4. The matching requirements revised to be more consistant with matching requirements of Title VII (Title XVI requires 75/25).

5. To include a provision that Title XVI matching requirements may include "In Kind Contributions."

909.21 Project Awards

I would suggest to you that part E, of this item, "Each project must serve an average of at least 100 meals daily throughout the project area," be amended to include that, "This provision may be waived in the event that Local geographic and/or SRS approval.

909.22 Strengthening of Existing programs

I would suggest to you that you add the words "and expand" be added to line three (3) of this paragraph following the word "strengthen."

909.34 Selection of Congregate Meal sites.

I would suggest to you that either in this section: or Part 909.59, "Allowable Costs, that there be a provision for the purchase of equipment and vehicles under the title of capital expenditures.

909.40 Charges to recipients for cost of meals.-Part E.

This section must be reviewed and explained in much greater detail regarding the eligibility of persons using food stamps for home delivered meals, the USDA guide lines are quite specific regarding the limitation placed on this provision. 909.49 Purchase of goods and services.

Part C should provide for renewal, options on contractual agreements provided both parties are satisfied with performance of the contract,

909.60 USDA Donated Foods

Would suggest that USDA or the Administration on Aging prepare for distribution a handbook and/or guidelines that would clearly define the type of donated foods available, The procedure for acquisition of such foods, and periodic equivalent cost charts for accounting purposes, especially when food service is contracted out to a private profit making firm.

Senator PERCY. Well, I appreciate that very much, indeed.
Mrs. Barnes, would you like to go ahead?

STATEMENT OF MRS. SAN JUAN BARNES, DIRECTOR, SENIOR NEIGHBOR AND COMPANION CLUB, WASHINGTON, D.C.

Mrs. BARNES. Thank you.

I am the director of a 3-year-old program in Washington known as the Washington Urban League.

I am delighted to be allowed to speak about the nutrition program for the elderly.

Although I have seen the project grow from three to 17 clubs serving 348 older Americans a five-course meal 5 days a week in a social setting, I still am concerned about the circumstances surrounding the eating habits of the elderly.

I was very happy to hear you say this morning the Army-the country has found ways of feeding the Army, regardless of where it is and we should do the same for the senior citizens.

I would like to speak to the contributions to the program. I feel that they should be the same. As to the tendency to cheat, the senior citizens of today are so thankful and happy to be able to participate in a program such as this that they are willing to contribute their bit to the project and I think that the cheating is very, very small, if any. If fact, that was their way of life. They know they must pay the way.

Emphasis has been placed on the broad scope of the elderly, but it also includes specifically that forgotten elderly segment of the population, namely the American Indians, the black Americans, the orientals, and the Spanish-speaking people. These are the people who suffer most for they, too often, not only have to go without food, but generally, are not aware of the social services that are theirs for the asking, simply because they have not been exposed to this information.

The needs of the elderly have been analyzed. The results well documented. Now remains the challenge of implementation to reflect the goals spelled out in the nutrition bill. These proposed regulations do so very effectively. For this I am happy and I commend the committee. However, as viable as the nutrition program might be, a question arises in my mind as to the feasibility of some parts of the mandate. For instance, there are presently existing programs of long duration that have become a way of life for some elderly. The structure of these programs is not compatible with the 5-day-week site concept, for in these programs, the elderly meet only once or twice a week. Yet the senior citizens who participate in these programs look forward to that 1-day gathering with their friends and neighbors.

SOCIAL SERVICES CREATE BRIGHTER LIFE

The procedure of dressing up and coming to the congregate feeding station for a hot meal and social services such as nutrition education, counseling and health services, recreation, and may I add one service not included in the regulation listing, consumer education. That is very important. All of this already has given these senior citizens a newer and brighter outlook on life.

I am only saying, gentlemen, that as comprehensive as the goals of the nutrition program are, if the 5-day week, hot-meal onsite-only concept remains the mandate, then there will be senior citizens who unnecessarily will go hungry and will be denied the social services that may help them to lead a better life.