Inadequate LEA participation in titles III and IV. Some States reported that LEA's did not submit title III projects because they lacked the expertise to mount effective ones. Several States reported that LEA's failed to see the relevance of title IV activites to their own problems.

Suggestions from the State reports

The major administrative suggestion made by the States called for the incorporation of all titles under one approval agency. Many States recommended that the application forms of titles I and II be combined, thus minimizing paperwork. Some speculated that perhaps giving approval authority over title I and title III projects to the same agency would stimulate greater interrelationship between the two programs.

Finally, many States felt that title IV funds should be more clearly related to the needs of the title I program and that more research should be sponsored in the field of the disadvantaged. Specifically, in view of the overwhelming number of programs involving reading and language arts, they suggested broader research in the areas of communication, perception, and thinking.

3. State assistance in evaluation

In title J, for the first time in the history of Federal grant-in-aid programs for education, evaluation was mandated as a condition for participation.

Section 205(a) (5) of Public Law 89-10 directs SEA's to insure that "effective procedures, including provision for appropriate objective measurements of educational achievement, will be adopted for evaluating at least annually the effectiveness of the programs in meeting the special educational needs of educationally deprived children * Reports of these evaluations must be submitted to the Commissioner of Education under section 206(a)(3), which states that "the State Educational Agency will make to the Commissioner * * periodic reports (including the results of objective measurements required by section 205(a)(5))

*

Most school systems of moderate size and most education departments of universities have conducted curriculum and program evaluation for many years. Nevertheless, for most of the educational community, the title I evaluation requirement presented a new and difficult task.

The States' general difficulties were well illustrated in the report from Connecticut, which said in part:

Most school personnel do not have background experiences in evaluation procedures of the scope required for sophisticated Title I evaluation procedures. For the most part, school efforts have been directed toward determining the progress individuals have made in school subjects. Demands for needs analyses, determination of objectives based on needs, activity descriptions, group data, evaluation instruments related to levels of design, and evaluation in terms of changes found in title I youth are measurement procedures uncommon to most school personnel.

One State identified a further difficulty. After noting that, traditionally, educators "had not in the past been required by outside agencies to establish a formal research design that would lend itself to statistical analysis at the conclusion of the project," it reported that

it was faced with an early backlog of unapproved projects that threatened to hinder the title I program for the majority of 250,000 eligible pupils.

The U.S. Office of Education recognized that "tooling up" for evaluation would present considerable difficulty to SEA's, LEA's, and the Office itself. With the advice and concurrence of the various State educational agencies, the Office therefore developed a reporting form which was adopted by most States and, after modification, was forwarded to the LEA's as a guide for their evaluation efforts (see app. C).

The SEA's launched programs of evaluation assistance to LEA's, the most commonly reported method being the development and dissemination of guides, instructions, and evaluation reporting forms. New Hampshire, for example, developed a workbook that "would be of benefit to educators working with title I projects to assist them in selecting effective instruments for evaluation as well as methods of evaluation." Initial documents were later revised as the needs in evaluation were further clarified and defined. A number of SEA's developed their evaluation guidelines earlier than the Office of Education and revised them as they learned of Federal needs in the evaluation effort.

In order to meet the many difficulties in developing and implementing effective evaluation plans, most SEA's encouraged and in some cases sponsored- workshops, seminars, conferences, and university courses dealing with evaluation and its relationship to title I programs. Many SEA's encouraged members of their own staffs and representatives of LEA's to attend workshops conducted by private research and evaluation organizations. Universities offered special courses in evaluation to title I personnel at the request of LEA's and SEA's.

SEA staff personnel also played a key role in interpreting, designing, and implementing programs with a built-in evaluation strategy. A total of 621 consultants or consulting groups were used by SEA's in providing assistance to LEA's; these ranged from one consultant in one State to 21 in another. The total number of SEA personnel offering similar assistance was 413 in 49 States, with a range from 1 to 14 and an average of 7 to a State.

Telephone calls, letters, memorandums, and publications were the most widely used methods of providing evaluation assistance to LEA's. Regional and local meetings also were frequently used for this purpose. A number of States reported holding a series of 1- or 2-day meetings with followup meetings on a regular basis for LEA and project personnel.

An important (but infrequently reported) type of evaluation assistance was the processing of achievement, attitude, and aptitude test results for the LEA by the SEA. A few SEA's reported assistance to LEA's in determining appropriate tests and test forms to be used and the appropriate time to administer the measures.

4. Information dissemination

Dissemination of ideas and information was described as vital in many State reports, in view of the need to keep teachers, adminis trators, and the community informed and involved and of the partic

ular need to spread ideas for new, effective curriculums and techniques for educating the disadvantaged.

State and local methods of dissemination (present or planned) reported by SEA's are summarized as follows:

1 Details represent the number of SEA's mentioning some form of the methods. 4 SEA's provided no information on SEA methods; 8 provided none on LEA methods.

SEA's, serving as clearinghouses of title I information, distributed news releases and articles, State correspondence and mailings, and local pamphlets and brochures. Most SEA's also said they had distributed, or planned to distribute, publications describing types of title I programs-both ineffective and outstanding-that had been developed.

The Kansas SEA published a booklet entitled "Information Concerning Projects Under P.L. 89-10, Title I," which was distributed to all LEA's and other interested parties and which included a résumé of a cross section of Kansas projects.

Many SEA's used various forms of direct communication to bring information to their LEA's. One SEA said that it "has depended largely upon workshops and consultative visits" and that "these were supplemented by suggestions made by consultants to local school officials through letter, telephone conversations, and office conferences."

LEA's used similar means to communicate with teachers, administrators, and parents (e.g., through PTA's) about title I programs and practices. The use of person-to-person methods, such as conferences, speeches, and home visits, was reported more widely by LEA's than by SEA's. In North Dakota, some schools exchanged proposals and sent teachers to visit neighboring projects. Several LEA's allowed their coordinators to assist other districts with their title I projects.

Some States sponsored inservice training and workshops conducted at colleges and universities. Employing consultants and specialists to disseminate information was a widespread practice. For example, West Virginia reported that:

Regional Title I curriculum specialists are analyzing programs *** with special attention to innovative and promising practices. These specialists have the opportunity to carry, from one county system to another, information on successful programs as well as the practices that have not been successful and need to be modified or discontinued."

For the most part, local dissemination of information was restricted to an explanation of legal requirements, procedures needed to initiate

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title I programs, evaluation methods, and other preparations necessary to submit title I projects. As one respondent explained:

Since money was made available so late in the year *** local districts had difficulty planning and implementing projects without having to concern themselves with providing information to other schools. The projects have not been in operation long enough to provide information worth disseminating.

Michigan, while reporting that more than 90 percent of its 497 responding LEA's disseminated data or information to other school districts, went on to note:

Although the variety of methods of dissemination appears extensive, the percentage of local education agencies that disseminated data and shared information other than by informal discussions and news releases is small. The lack of preparation and exchange of brochures, films, and tapes between local agencies is a regrettable condition, but understandable when consideration is given to the factor of time and of heavy demands made upon teaching personnel, especially Title I teachers. More specific direction and encouragement of such activity should be included in future guidance to local agencies.

5. Participation of nonpublic school children

Congress specifically provided in the ESEA that nonpublic school children are to participate in title I programs The law stipulates that educationally deprived children residing in project areas, whether they attend public or nonpublic schools, are eligible for services provided under title I.

Many arrangements for providing services to nonpublic school children are permissible under Federal regulations, e.g., dual enrollment, shared services, and participation by nonpublic school children in activities on public school grounds. Equipment purchased under title I may be placed in nonpublic schools on a temporary basis for use in project activities. However, several State constitutions and statutes forbid one or more of these arrangements.

State laws and existing legal interpretations of those laws are sufficiently restrictive in at least eight States to seriously limit nonpublic participation. One State, for example, permits only dual enrollment Another prohibits dual enrollment and the establishment of special classes by public school officials in nonpublic schools (although it allows public school officials to provide special services such as guidance in nonpublic schools).

Several States have also ruled against using public funds to transport children from a nonpublic school to a project in a public school. În a number of States, participation of nonpublic school children would not have been possible if the Attorney General had not ruled that restrictive State laws and court decisions did not apply to the use of Federal funds.

Procedures to encourage participation of nonpublic school children

States encouraged nonpublic participation most frequently through publications and guidelines. Thirteen States cited the circulation of publications describing the types of services LEA's could provide for nonpublic school children. Eight States reported that their guidelines required LEA's to contact nonpublic school authorities when planning programs. Other SEA's mailed information on title I-rules, regulations, approvable activities, and services-to both public and nonpublic authorities (see exhibit III-2).

In three instances, SEA's arranged joint conferences devoted specifically to the techniques of joint program planning by public and nonpublic school officials. Several cities also arranged conferences for public and nonpublic school representatives. The purposes of these conferences ranged from disseminating basic title I information to actual program planning.

A number of SEA's required that LEA's clearly designate in their title I application forms the nonpublic school activities they proposed (or the reason for lack of such provision) and cited this as an important procedure for insuring participation by nonpublic school children. Six States required statements from nonpublic school officials that they had foreknowledge of the program and opportunity to participate; seven required a description of the efforts taken to coordinate projects with nonpublic authorities. In Montana and Pennsylvania, for instance, a letter from a nonpublic school official concerning project participation was made a basic requirement for project approval.

EXHIBIT III-2.-Steps taken by SEA's to encourage participation of nonpublic school children in title I programs

WRITTEN GUIDELINES AND CONFERENCES MOST PREVALENT STEPS TAKEN BY SEA'S TO ENCOURAGE PARTICIPATION BY NONPUBLIC SCHOOL CHILDREN

Sixteen SEA's said they had strongly urged LEA administrators through conversations, memorandums, or correspondence to provide adequate services to nonpublic school students. Field visits were conducted by five States to assist LEA's in the development of projects involving nonpublic school children and to insure that the LEA's were fulfilling their responsibilities in that area. A number of States said that through informal conversations they were able to suggest suitable project arrangements for nonpublic school children.