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FROM EDWARD J. KRAMER

MAY 4, 1972. DEAR MR. ED KRAMER: We are a group of Senior Citizens who saw your program on the Phil Donahue Show Thurs., May 4, and we did enjoy it.

What you say sure is true. There is always money to send these Astronauts up or spend plenty of money in Vietnam-where we have lost too many men.

Now, we are a group of elderly people that have found the upkeep of a home is getting too much for us to do. Yet we have our own furniture and do want to stay together. Why can't they work faster to get some reasonably priced senior apartments for us. They sure get them put up fast for the young. We all notice that.

We are not asking for charity, just a place to be with folks our own age and not have the chores of grass cutting and changing windows, etc. We know we are not wanted in the neighborhood with younger folks. They show no respect for us at all. They would just as soon shoot us. We know that the young folks are not responsible for our keep; not like we were for our parents. Everything is considered for the young folks-which is not right. If the Lord permits they will get old also.

Another thing that we older folks do not think at all fair is that if you have up to a certain income you are out of the picture for aid. This is money that we folks have worked plenty hard and saved for years. It is our very own and we should not be limited to what we have. This is what we saved for; to enjoy our older years together.

Why can't the Government see it that way? We just get promises and promises that they will do something. We can all be dead by then.

Hope this will give you an idea of what we are trying for. I will sign my name* but don't pass it on as this is meant for several of us. Would like to hear from you.

Thank you.

*Name retained in committee files.

(332)

Appendix 2.

MATERIAL FROM OTHER THAN WITNESSES

FROM THE NATIONAL COUNCIL ON THE AGING

THE NATIONAL COUNCIL ON THE AGING, INC.,
Washington, D.C., June 13, 1972.

Hon. GEORGE MCGOVERN,
Chairman, Select Committee on Nutrition and Human Needs, U.S. Senate, Wash-
ington, D.C.

DEAR MR. CHAIRMAN: The National Council on the Aging is pleased to have this opportunity to comment on the proposed regulations for Title VII of the Older Americans Act regarding the Nutrition Program for the Elderly. We request that this statement be made a part of the permanent record.

The National Council on the Aging, a private, nonprofit corporation, represents individuals and organizations who are working to achieve a better life for older Americans. We have long been concerned about the nutrition of this population; our concern has been expressed through leadership in the senior center movement, extensive study of home-delivered meals, and several special projects. In one such project, NCOA designed the first program model for providing meals to elderly persons in 1965 on which many of the Administration on Aging's twenty-one demonstration nutrition programs were later based.

Our policies and programs in this field will continue to be directed toward eliminating poverty and the other conditions which contribute to making the elderly the most uniformly malnourished segment of our population. To this end, NCOA would alter several of the proposed nutrition regulations. The changes are listed below with rationale discussed for the major alterations.

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(b) "Minority individuals" are those persons who identify themselves as American Indian, Spanish language, Negro, or Oriental.

Add to read: “Minority individuals" are those persons who identify themselves as American Indian, Spanish language, Negro, or Oriental, or who identify themselves as members of racial, religious, or ethnic minority groups.

§ 909.17 Advisory assistance

Add section (d) The Advisory assistance group shall assist the State Agency in planning all aspects of developing and implementing the standards for nutrition projects which shall include carrying out the provisions of planning prior to the initiation of § 909.33.

We are concerned here about the entire planning process for this program. What are the planning elements? What is the time factor? Where does the planning for Title VII end and the planning for the proposed amendments begin? § 909.21 Project awards

(d) If the applicant agency is not a public agency, the State agency shall secure comments on the proposed project from the appropriate major unit(s) of local general purpose government.

Elimination of entire section (d) is recommended.

The procedure recommended by HEW could provide a major stumbling block for vocal action-oriented groups in the community, such as Community Action Programs and Black power agencies, and should be eliminated.

§ 909.24 Opportunity for hearing

The State plan shall provide that the State agency will provide that any nutrition project applicant, whose application for approval is denied, will be afforded an opportunity for a hearing before the State agency.

Add second sentence, reading: If satisfaction is not obtained by state hearing, the nutrition project applicant shall be afforded the opportunity for a regional HEW/AOA appeal hearing.

State politics may prove to be an insurmountable obstacle to participation by local groups. The appeals process should be extended to the federal level to insure "fair play" in such cases.

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(b) Second sentence now reads: The affirmative action plan will provide for specific action steps and timetables to assure equal employment opportunity.

Add to read: The affirmative action plan will provide for specific action steps and timetables to assure equal employment opportunity for minorities and elderly at least in proportion to their numbers in the State.

§ 909.33 Project councils

(a) Each project shall have a project council. It shall be the responsibility of the council to advise the recipient of a grant or contract on all matters relating to the delivery of nutrition services within the project and to approve all policy decisions related to:

(1) The determination of general menus;

(2) The establishment of suggested fee guidelines;

(3) The hours of operation of the project; and

(4) The decorating and furnishing of the meal setting.

(c) The State agency shall develop formal procedures regarding the tenure of members, responsibilities and operations of the project council prescribed in this section, in keeping with guidelines established by the Social and Rehabilitation Service.

Change (a) and (c) to read:

Governing Council.

(a) Each project shall have a governing council. It shall be the responsibility of the governing council to decide on all matters relating to the delivery of nutrition services and to approve all policy decisions related to:

1. The determination of general menus;

2. The establishment of suggested fee guidelines,'

3. The hours of operation of the project;

4. The decorating and furnishing of the meal setting;

5. The development of formal procedures regarding the tenure and responsibilities of members; and

6. The development of personnel practices and policies for staff.

(c) The State agency shall develop formal procedures regarding the composition and operations of the governing council in keeping with guidelines established by HEW/SRS.

The type of structure set up by HEW, similar to the Parents Council in Headstart programs, is not satisfactory; we have found that it does not give consumers the kind of participation and control necessary for a project to meet the real needs of the community. We strongly advocate a governing board structure.

§ 909.34 Selection of congregate meal sites

(b) First sentence now reads: Such congregate meal sites shall be located as close as possible, preferably within walking distance, to these concentrations of older persons.

Add to read: Such congregate meal sites shall be located as close as possible, preferably within walking distance, to these concentrations of older persons, and, where appropriate, transportation shall be furnished to such site.

§ 909.49 Purchase of goods and services

Add section (d) Preference should be given to minority vendors.

We would also like to share our views with regard to two further areas of concern project size and treatment of Indians. First, the National Council on the Aging would raise serious question with project area size as defined in § 909.3 of the guidelines, especially in terms of city population. What is the Administration's rationale for disallowing project awards for localities with populations of

less than 250,000? Why should the county structure receive the award, instead of the city of 200,000 which falls within it? NCOA is of the belief that two grants should be awarded in this case-one to the county and one to the city-for maximum effectiveness operationally and administratively. Surely a city of this size can meet the minimum standard of 100 meals daily, as outlined by HEW.

Finally, we question the effectiveness of the regulations in dealing with Indian participation in the program. NCOA would recommend, if legally feasible, that monies be earmarked to serve the Indian population and direct federal grants made to the reservations. We are asking, in effect, that they be treated more like a Trust Territory described in § 909.50 for the purposes of this program than a large city or county definied in § 909.3. It seems unrealistic to expect the Navajo Nation, for example, to deal with different state agencies having dissimilar state plans and requirements on such items as matching shares.

The National Council on the Aging stands ready to assist your Committee in implementing these recommendations and to provide any further information you may request.

Sincerely,

JACK OSSOFSKY, Acting Executive Director.

76-300 0-72-pt. 2- -8

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