In order to provide the State agencies with the planning capacity necessary to lay the groundwork for this program, we announced in April that AoA would award $4 million in area wide model project discretionary grants to the States for initiation of local planning for their nutrition programs. By the end of the fiscal year, June 30, we expect 85 of these awards in 46 States. We also have commitments from States to use a like amount of Title III supplemental money for the same purpose in other parts of the State than from those areas funded with the area wide model project awards.

The result of this early groundwork will be approximately 185 planning efforts by States before July 1. Thus, many States will be prepared to begin implementing their nutrition programs shortly after State plans are filed and funds become available.

In many cases, programs that are currently operating can expand and improve if they meet the requirements in the regulations. This is important because there are some 150 nutrition programs under Title III and under the area wide program and under our Title IV program, which are already in existence, as well as the 185 or so programs funded by the OEO.

So there are substantial numbers of programs which are in operation, many of which, we believe, can be adapted to meet the standards of our regulations.

On June 6, State agencies and regional offices were informed of specific key requirements of the nutrition program that they should begin working on immediately. These activities include:

1. State agency staffing for the nutrition program;

2. Initiation of a system for obtaining advisory assistance for this program;

3. Identification of target groups of elderly within the State, who are in greatest need of the services to be provided under Title VIII;

4. The identification of potential project areas to receive Title VII awards.

Mr. Chairman, from the activities I have just outlined, I am sure you will agree that AoA has compressed a great deal of work into a very short period of time. We have done this expressly for the purpose of assuring that the nutrition program becomes operational in the shortest possible time.

With the same purpose in mind, we have asked for comments from the State agencies on aging, plus more than 150 other agencies and organizations, on the nutrition regulations in 15 working days from the date of publication. We will, of course, accept comments on the regulations up until the last moment that they remain in draft form. Now I want to discuss what I regard as the major elements of the proposed regulations. I believe that the key elements of the proposed nutrition regulations are:

CONSUMER PARTICIPATION

A. STATE LEVEL

The State agency will obtain advice from nutrition experts, and consumers of service, including members of minority groups, in the development of the program throughout the State. The State agencies

can add members to their present advisory councils, from these groups to provide specific input in the area of nutrition services, or they can establish a separate advisory group on nutrition.

This kind of assistance is mandatory and must exist at an early stage before the programs are in operation.

B. PROJECT LEVEL

We are also proposed that each nutrition project have a project council, whose members would consist primarily of elderly participants from the major project sites.

We contemplate there will be numerous sites within each project. The council would also include other persons competent in the fields of nutrition and related services provided by the project, and persons who understand the problems and needs of the elderly.

The project council would advise the project director on all matters relating to the delivery of nutrition services, and approve all policy decisions related to:

1. The determination of general menus;

2. The establishment of a suggested fee or fees;

3. The hours of operation of the project; and

4. The decorating and furnishing of the meal setting.

By delegating these responsibilities to a project council, we will insure the involvement of older persons in decisions about those components of the project most important to them.

Participants in nutrition projects will have the opportunity to pay all or part of the cost of the meals served at the project site. Each project will develop, with the approval of the project council, a suggested fee or fees for participants in the nutrition project. However, each participant will determine for himself the amount of any payment he is able to make.

Senator PERCY. From a practical standpoint, how will that be implemented? Let us say the 25-cent fee for a meal costing $1.75. If a person is able to pay more, how do they go about paying more; and if a person is not able to pay that, how does that work out?

Mr. MARTIN. Well, as we have set it up in our regulations, people would be advised—if a single fee was set by the project council, people would be advised as to what the fee was; and if they were not able to pay it, they would not have to pay it.

They would also be advised at the same time that if they were able to pay more, if they were in a higher economic bracket, it would be hoped they would pay more, but they would not be forced.

We have bent over backwards to avoid what might be referred to as a means test. A means test normally relates to eligibility to get in or out of the program entirely, but I think it has been given a rather broader connotation in the discussion here today.

We are not going to sit down and interrogate each person as to exactly what their range is. They might well be advised, if the council decides on more than one fee, that is a higher fee for a certain higher range of income, they would be advised as to what that range was and what would be applicable to their particular income level.

From there on, we are depending upon the honor and integrity of the individuals who participate in the program, frankly, and that is

the way we have done it in the Title IV projects with which you are very familiar.

Senator PERCY. I presume there is enough flexibility so that if the local council decides that in their particular area, if the program is going to be more successful, that they must have a more expensive meal to compensate by charging a higher fee, they can decide so.

In other ethnic areas where, say, Spanish speaking, there may be a lot of lower cost foods, rice, chicken, beans, where the fee could be substantially lower and the cost of the meal could be lower.

Mr. MARTIN. If the cost were substantially lower, they might have a little more money to spend on more meals for more people and it would be permissible to use their money that way.

Senator PERCY. The regulation seems to require a schedule of suggested fees for different income levels in a project area. Your testimony seems to indicate a single fee is permissible. Is this true?

Mr. MARTIN. It is true, Senator. If the project council decided that a single fee would be more usable or suitable than a range, there would be no reason why they should not settle on that.

Senator PERCY. Who do you feel should set the fee, a site, or an area? Mr. MARTIN. I think the fee should be set by the project if the project is, as we hope it would be, a relatively sizable project, 100 or more meals per day. It might run, of course, much more than that in the case of Chicago, but I do not think we can set a fee nationally. I do not think we can even set it statewide, but I think it should be set projectwide.

Senator PERCY. All right. Why don't you go right ahead?

COORDINATION WITH OTHER AGENCIES

Mr. MARTIN. The State agency will consult with and utilize to the maximum extent feasible the resources of health, mental health, social service, rehabilitation, education, economic opportunity, and food and agricultural agencies, in the development and implementation of its program. This will help assure that the participants of the nutrition programs will have available a range of comprehensive and coordinated social services, in addition to the nutrition and related services specified in the law; but will provide these additional services wherever possible, without cost to the Title VII program.

In the regulations, we have set a maximum of 20 percent for social services. We do that because it is our feeling that although the bill specifies that social services may be included, nonetheless there needs to be some limit, because the emphasis is on nutrition, and that has seemed to us to be a reasonable limitation.

But, it could be-there could be an exception for that in the case of transportation if it could be shown that that was a necessary addition to the program.

Transportation is not considered a cost in the home-delivered meals program so that improves that situation.

In any event, social services would be coordinated with the Title III services.

IDENTIFICATION OF TARGET GROUPS TO BE SERVED

The State agency will identify the groups of persons eligible for this program on a statewide basis in order to assure that the Title VII

funds are targeted at primarily those older individuals determined to be in greatest need of such services throughout the State.

The criteria for the identification of such groups are based on the language in the Findings and Purposes statement set forth in the law.

SELECTION OF AREAS FOR PROJECT AWARDS

The States will make Title VII nutrition awards to project areas which include major concentrations of low-income individuals as required by the statute. Such projects would serve low-income and minority groups, at least in proportion to their numbers in the State as required by law.

We have defined minority to include the four largest minority groups, but it would be assumed if there were more minority groups within a particular jurisdiction that the State agency and the local project program or management would take account of their presence also.

The phrase is general and it is difficult for us to interpret it any more than we have in the regulations. On the other hand, if we get into every conceivable kind of minority we would fragment the program so far that it might not serve the purposes of the act at all.

SIZE OF AREAS FOR PROJECT AWARDS

Each project area selected by the State agency to receive funds under Title VII would have a single nutrition program. We propose this approach in order to assure that each of the nutrition services funded within any project area will be coordinated and mutually supportive of one another; and that no older person needing nutrition services in any given program area will be overlooked.

This is especially true where you have a mixed urban and rural population where the rural population might well be overlooked. Numerous local and neighborhood nutrition delivery sites could be operated within any project area as part of such a project.

It should be noted that this concept was developed as a result of our experience with the Title IV nutrition demonstrations.

The city of Chicago, as you know, Senator, operates a citywide Title IV nutrition project with 35 neighborhood sites. In rural Olive Hill, Ky., a single Title IV nutrition project provides meals through six outlying community sites.

We believe that making a single award to a community results in the following benefits:

1. Avoiding the need for multiple project directors and duplication of staff;

2. Minimum overhead and expenditures for general administrative support through consolidated operations;

3. The ability to purchase food, equipment, and supplies on a largescale, economical basis;

4. Provide a focal point for the stimulation of the provision of related services by public and private agencies in cooperation with the nutrition program; and

5. Assure that older persons in need, wherever they may live throughout the project area, would have the opportunity to participate in the nutrition program.

76-300-72-pt. 2- -5

Therefore, the regulations we have developed propose a strategy that would avoid overlap, duplication, and unnecessary competition for funds in the implementation of this program.

We have suggested that, in making awards, only one public or private nonprofit agency within a given county should receive a nutrition award.

We discussed this the last time we were before a similar committee, and we have listened to the discussion today. We were not fixed on any formula as being final and irrevocable.

We have examined several possible options in this connection. We have not found one that we thought was better than the one we originally came up with, but we are continuing research, and I would hope that we can find a formula which will be satisfactory for all those who are concerned about it.

Any such award could provide for the operation of the program at a number of neighborhood or community sites throughout the county. We have also provided for projects to give special attention to subcontracting, especially to low-income, minority, or other groups having special needs. Such subcontracts could provide for full control by these groups over that portion of the program.

A major reason for the development of this strategy was our concern that many small communities that have older persons in considerable need of nutrition services would not be able to support a nutrition project alone.

Thus, these older persons might be overlooked in the provision of the services provided under Title VII. Our strategy is designed to assure that their needs will be met, no matter where they lived within any given project area.

PREFERENCES FOR STAFFING OF NUTRITION PROJECTS

In the staffing of nutrition projects, we provide that preference be given to persons aged 60 years or over. Part-time positions will be considered for those older persons for whom full-time work would be difficult or economically unfeasible due to Social Security benefit restrictions.

Project staff would also be, to the extent feasible, representative of minority group individuals participating in the project.

CONFIDENTIALITY

Finally, we have assured that all personal information about the participants will be kept in strictest confidence.

One other item I might call your attention to has to do with what is known as Project FIND. We are not directly responsible for this project, but since it has impact on the matter of nutrition, you might

be interested in it.

ADDITIONAL FEDERAL NUTRITIONAL EFFORTS

As you will recall from the President's Message on Aging, the President has committed the Federal Government to a special effort to make all persons over 65 years of age aware of the eligibility requirements for Federal food assistance programs, and to aid those who wish help in filing an application for this assistance.