Some States (for example, California) have included nonpublic school representatives on State advisory committees and have encouraged LEA's to include nonpublic school representatives on their title I program development committees. Colorado, in reporting that only four of 184 LEA's encountered any difficulty whatsoever in providing services to nonpublic schoolchildren, related:

In May, 1965, Colorado held its initial meeting to discuss the Elementary and Secondary Education Act. At that time we charged both public and nonpublic schools with their responsibilities of working together to ensure successful operations under Title I.

A State Advisory Committee was formed which included representatives from the nonpublic schools. This committee frankly discussed the situation and set up channels for further discussion of ways of communicating and cooperation. Our approval of projects required the inclusion of evidence of real contacts and the effects of working together. We did not accept statements that merely said nonpublic school [children] are or will be invited to participate. We checked to see if in fact these programs were arrived at cooperatively or that the programs were in fact meeting some of the needs of nonpublic school [children] *** [Some] nonpublic schools set up committees and appointed persons who were responsible for working with the public schools and have diligently functioned to see that programs have worked for both school systems * *

Our State has had no serious problems regarding this matter. Once the guidelines were set up and understood, both sides went to work to improve the educational opportunities for the educationally deprived students.

Extent of participation of nonpublic school children

The SEA reports indicated that 526,600 (or approximately 6 percent) of the total children participating in title I were enrolled in nonpublic schools. Exhibit III-3 designates the reported frequency, location, and scheduling of projects for nonpublic school children. Projects involving nonpublic school children were reported as taking place most often on public school grounds and during the regular school day and/or summertime.

EXHIBIT III-3.—Projects involving nonpublic schoolchildren by location and schedule NONPUBLIC SCHOOLCHILDREN PARTICIPATED MOST OFTEN IN SUMMER PROGRAMS ON PUBLIC SCHOOL GROUNDS

Participation of nonpublic school children: successes and difficulties

One-fourth of the State responses referred to successful cooperative program planning and implementation. Twelve SEA's mentioned joint planning of title I projects by public and nonpublic school officials. Kansas, for example, reported that "the cooperation between public and nonpublic schools, with very few exceptions, has been excellent during the planning period of title I projects. Representatives from both schools meet regularly, working together to plan a project to meet the most important needs of the community.' Ten SEA's reported favorably on joint project implementation by public and nonpublic school authorities (see exhibit ÎII-4).

Rhode Island praised the relationships that evolved during both the planning and implementation stages. "Public school officials," it said, "have enthusiastically described this relationship as 'excellent.' 'outstanding,' 'positive and enthusiastic,' 'most cooperative'

Only one community reported any problems whatsoever in implementing" projects with public and nonpublic school participation. Florida reported that, "in light of the fact that a dialog between the two groups had not existed in a consistently cooperative manner prior to the implementation of the Elementary and Secondary Education Act, LEA's have accomplished much toward opening channels of communication."

The evaluation reports of the big cities indicated similar success. Several cities emphasized the importance of establishing communications with private school administrators prior to project implementation. Two city reports stated that the majority of nonpublic school parents responded positively to the cooperation between the two school systems and wanted continuation of the program.

One-fifth of the successes reported by SEA's fell into the category of provision of special services to nonpublic school children. Services mentioned most often were either auxiliary benefits (health, guidance. food, and transportation) or the sharing of equipment and materials. California's statement is typical: "The most successful activities were those which Federal regulations allowed to be implemented on nonpublic school facilities. These were auxiliary services where the ESEA title I teachers traveled to the nonpublic school for a specified time each day or week."

Many LEA's loaned reading equipment and mobile educational equipment to nonpublic schools for use by educationally deprived children. A few cities considered the broadcasting of educational television programs and the sharing of curriculum materials to be useful arrangements.

Inevitably, along with success there were difficulties too. While some SEA's described efforts to develop dialog, cooperation, and understanding between public and nonpublic school officials as highly successful, others considered them their greatest problem areas.

Misconceptions as to the rules, regulations, and intent of title I constituted the most conspicuous difficulties. Ten States reported that nonpublic school officials sometimes were not fully acquainted with the categorical nature of title I, the requirements on ownership and use of equipment, and the assignment of legal responsibility for program administration. Some nonpublic school authorities declined to participate in title I-for the most part objecting on grounds of

separation of church and State or opposition to the concept of Federal aid. Six SEA's reported lack of cooperation among administrative personnel.

The big cities reported fewer, but similar, communication problems. Public school officials sometimes complained of inadequate academic, personal, or attendance records on nonpublic students. In some cases, nonpublic school officials reputedly did not convince parents, staff, or children of the merits of the program. Lack of proper information about programs and objectives on the part of title I staff presented additional difficulties.

Planning and implementing projects for nonpublic school children presented difficulties for a number of LEA's. One SEA stated:

In a few instances it has been rather difficult to get public school officials to actively involve nonpublic school officials in the planning stage rather than to inform them what has been done after much of the planning has been completed. Sixteen States reported difficulties in scheduling title I activities; seven cited the distance between schools as a major problem. Seven also referred to the problems inherent in designing projects that would adequately meet the differing needs of nonpublic and public school students.

A number of States explained the difficulties of providing services to nonpublic school children who resided in target areas but attended nonpublic schools located outside the target area. Two SEA's reported that the nonpublic school students residing in target areas were sometimes not educationally deprived.

Certain States experienced two or more common difficulties. For instance, of the 27 States which reported difficulties in the category of determining relative needs of nonpublic school children and coordinating and planning programs for them, 14 also experienced difficulties in the category of selection and eligibility of students. The total pattern of responses indicates that many States experienced compound problems in providing services to nonpublic school children. A number of the problems appear to be a result of the newness of the program and are expected by the States to diminish during the second year. Recommendations

Thirty-three States submitted recommendations to improve present legislation governing participation of nonpublic schoolchildren in title I programs. Nine urged that appropriate arrangements for including educationally deprived children enrolled in nonpublic schools be further clarified in the law and guidelines. More than a third of the recommendations related to the way in which nonpublic school children should participate in title I programs, Three SEA's recommended direct grants to nonpublic schools, or, as Rhode Island stated: "Remove the back-door approach to nonpublic school participation in title I." Another SEA suggested that nonpublic school authorities work directly with the SEA; yet another proposed separate and distinct legislation for public and nonpublic children (see exhibit III-5).

California stated:

There should be some provision to allow nonpublic school children in poverty areas to participate in Title I programs even though the public school district chooses not to apply for its entitlement.

Two States declared that it should be mandatory for nonpublic school administrators to furnish public school officials with the names, addresses, and special educational needs of eligible nonpublic school children. The big city reports more or less reinforced the State reports in the above areas.

Also received were recommendations to improve the procedures for nonpublic pupil selection and participation: (1) the number of nonpublic children eligible to participate in title I programs should be established on a percentage basis; and (2) educationally deprived children attending nonpublic schools outside target areas should be able to participate in title I projects in their own schools.

EXHIBIT III-5.-SEA and LEA recommendations for revising title I legislation regarding participation of children enrolled in nonpublic schools

ABOUT 60 PERCENT OF THE SEA's RECOMMENDED REVISIONS IN THE LEGIS LATION REGARDING PARTICIPATION OF CHILDREN ENROLLED IN NONPUBLIC SCHOOLS

Reports from local educational agencies told of many successes and frustrations, the need for cooperative planning, big city operations. and hundreds of creative new approaches to educating children of poverty.