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munity in Oregon, and assurance that the cost of the child's return cannot be readily and promptly secured from his parents, guardian, agency responsible for his care, or the agency in the State where the child is found. In cases in which parents or the responsible agency are able only to pay a part of the costs involved in returning the child to Oregon, such funds are to be obtained by the juvenile court or the county public welfare department assuming responsibility for the social investigation and forwarded to the State public welfare commission. Such funds will then be applied as reimbursement to the Federal funds expended by the State public welfare commission for the cost of the child's return. Such checks, money orders, or bank drafts are to be made payable to the Oregon State Public Welfare Commission. Receipts should be provided to the individual or agency advancing such funds with a copy retained by the county public welfare departments or the juvenile court, and a copy of the receipt with the money sent to the State public welfare commission. From the time a case which appears to come under this program is referred to a juvenile court or a county public welfare department in Oregon by a juvenile court or agency in another State, all correspondence and the necessary social-work activities should be carried out between the two agencies in both States. The State public welfare commission will not enter into the case until such time as an application form is received for funds for return of the child and at that point the State public welfare commission, if the case is found eligible, will take responsibility for giving authorization to the agency in the other State to return the child to Oregon and will make the necessary transportation arrangements and commitment for reimbursement of costs. giving such authorization to the agency in the other State to return the child to Oregon under this program, the State public welfare commission will notify the agency of the maximum amounts which will be approved for travel and incidental expenses incurred in the return of the child, and the costs of an attendant, when needed. The maximum amounts for such items as meals and overnight lodging will be in accordance with out-of-State travel expenses currently allowed in the State service. The State public welfare commission will not pay for salary or wages of an attendant. Authorization will be given only for the use of common carrier in the return of children to Oregon.

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Federal funds under this program will not be used to pay for temporary foster care costs or other costs which may be incurred for the care of the children in the other State. Such costs are considered to be the responsibility of the State where the child is found to be in need of care and services.

County public welfare departments and juvenile courts in Oregon are encouraged to send adequate and prompt social information regarding the child to the agency in the other State making the inquiry regarding return. There should also be a request for the agency who plans on returning the child to Oregon to provide adequate information regarding the circumstances surrounding the individual child coming to the attention of that agency, any contacts the child has had with law-enforcement agencies or social-service agencies, the type of care the child is receiving pending decision regarding authorization for his return to Oregon, health and behavior status, the sending agency's recommendation regarding need for an attendant, and the sending agency's willingness to provide an attendant. In those cases in which the agency in the other State is of the opinion that an attendant is not necessary to return the child to Oregon, but the juvenile court or the county public welfare department in Oregon that has had experience with the individual child recommends that an attendant is necessary, the State public welfare commission will tend to accept the recommendation of the Oregon agency. It will be necessary for the Oregon agency to indicate its ability to send an attendant to the other State to return the child. The Oregon agency is requested to notify the State public welfare commission on the application form of the type of common-carrier transportation recommended. It will be necessary for an attendant from Oregon to pay for his own expenses other than transportation, which the State public welfare commission will provide, and to submit a bill of actual expenditures incurred for reimbursement.

A supply of application forms with instructions is enclosed for your use. Additional forms may be requested through the child welfare division.

As this is a new program, the State public welfare commission will welcome additional help and suggestions in the operation of this plan. Please address such communications to Mr. Juras. The State public welfare commission is interested in extending the fullest cooperation of its staff and county public

welfare departments to the juvenile courts in Oregon in developing this as a workable program and the plan set forth can be revised as experience indicates. Yours very truly,

Hon. HERBERT H. LEHMAN,

STATE PUBLIC WELFARE COMMISSION, (Miss) LOA HOWARD, Administrator.

STATE OF ALABAMA,

DEPARTMENT OF PUBLIC WELFARE,
Montgomery, Ala., July 6, 1955.

Chairman, Special Subcommittee on Juvenile Delinquency,

Washington, D. C.

MY DEAR SENATOR LEHMAN: This is in response to your letter of June 29 about legislative hearings before your subcommittee July 6 and 7 on four bills pertaining to some problems of our Nation's youth. I appreciate your giving me an opportunity to give you my thinking on this whole matter of juvenile delinquency.

Over a period of years this agency has been on record both with congressional committees and the Department of Health, Education, and Welfare about the need for additional Federal funds to strengthen and improve overall child welfare services. We have, therefore, urged that appropriations be made for the full authorization contained in title 5 part III of the Social Security Act. We still believe that is the best way to insure that prevention and treatment of delinquency can be attained.

Under Alabama statutes, public welfare workers are responsible in 64 counties for providing probation and parole services to the juvenile courts in behalf of delinquent children. The great need, therefore, is for additional child welfare workers who are concerned with both the prevention and treatment of juvenile delinquency.

We, of course, would not wish in any way to jeopardize any additional Federal funds which might become available and could be infiltrated into our total child welfare program in behalf of delinquent children. We would, therefore, hope that any funds which might be available under the presently proposed legislation could be so infiltrated that delinquent children could be better served. We believe that the sponsors of the four bills are interested in providing better services to and in behalf of delinquent children, each however approaching it in a different way. We would, therefore, hope that any compromise legislation which might be considered would take into account the already existing facilities for the prevention and treatment of juvenile delinquency.

Sincerely yours,

J. S. SNODDY, Commissioner.

THE NORTH CAROLINA STATE BOARD OF PUBLIC WELFARE,
Raleigh, N. C., July 1, 1955.

Senator HERBERT H. LEHMAN,

Senate Office Building, Washington, D. C. DEAR SENATOR LEHMAN: I am writing you with regard to the hearings on juvenile delinquency bills S. 728 and S. 894 scheduled for July 6 and 7. Representing a State which is deeply concerned with regard to all needs of children, and a State in which the approach to child welfare is on a well-integrated basis, including the problems of children with behavior difficulties, I would like to suggest the following points for consideration by the special subcommittee.

We believe that the question of any reorganization with respect to the location of the Children's Bureau within the Department of Health, Education, and Welfare, or with respect to its basic functions is an entirely separate issue and should not be considered along with measures relating to juvenile delinquency prevention and control. The entire question of the best planning for programs directed toward prevention and control of juvenile delinquency represents a special area quite apart from the administrative structure of the Federal agency. Among specialists in the child welfare field, there is wide agreement that the soundest approach is toward the strengthening of all child welfare services, including services to delinquents. Children have many special needs. A comprehensive program to deal with those needs through public programs will be

more effective than segregating out special groups of children in terms of a particular type of problem.

At the present time, the Federal appropriation for child welfare services under the Social Security Act is increasingly less adequate as the number of children in this country increases. A major need at this time is additional funds for States in order to strengthen the total child welfare program, including delinquency prevention and control.

From the point of view of State administration, it is important to have clear lines of responsibility between any Federal agency and the State agency handling child welfare matters. Any steps which might create overlapping of services among several agencies dealing with child welfare problems would be confusing and uneconomical. It is for such reasons that we believe in the importance of strengthening basic child welfare services, which in the end is the most effective method of preventing juvenile delinquency.

We hope that any action in this field may be deferred until the next session of Congress. That will give opportunity to study the testimony presented during your hearings in relation to the more effective integration of programs of juvenile delinquency prevention and control into the total child welfare programs of the various States. I appreciate the opportunity of filing these comments with regard to the hearings scheduled for July 6 and 7 and request that they be included in your consideration of juvenile delinquency problems.

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Chairman, Special Subcommittee on Juvenile Delinquency,

Committee on Labor and Public Welfare,

Senate Office Building, Washington, D. C.

DEAR Mr. LEHMAN: In response to your notice of the hearings on four bills dealing with the problem of juvenile delinquency, to be held in Washington July 6 and 7, the Iowa State Welfare Board had the bills reviewed, and would like to comment on them.

S. 894 and S. 728 have many similar features which commend them to agencies working in the field of delinquency prevention and treatment. However, Iowa department favors S. 894 for the following reasons:

1. It provides for advisory committees, both Federal and State, which have responsibility only for coordinated planning. We believe this is more feasible, than a large interprofessional, interorganizational supervisory body with statutory administrative duties. It would eliminate the problem of another State administrative agency, while still bringing together the same varied interests for coordinated planning as an essential requirement for submission of a State plan. It is very doubtful if States could set up a new administrative and supervisory body without legislative enactment. Most of the States' legislatures have adjourned for 2 years, and thus the States would not be able to start on a coordinated program except with a nonstatutory advisory committee. We hope that administrative funds for the strengthening of programs may be used to pay expenses of committee meetings where State funds are not available without specific legislative appropriation.

2. While there is definite merit in the proposal in S. 728 to elevate the Children's Bureau to a top position in the Department of Health, Education, and Welfare, and make the Chief an Assistant Secretary of HEW, it seems to us that this is premature. It would be better to permit the Children's Bureau to complete the building of its staff in the new juvenile delinquency division and bring its services to the States than to go through a major reshuffling of divisions and bureaus in the Federal department now. As proposed in S. 728 the reshuffling might run into considerable interprofessional and/or political difficulty in that services of several major divisions do and can overlap where would those be placed? For instance, education has a very close relationship to children and youth-would the Office of Education be shifted to the Office of Children and Youth? The functions assigned to the Children's Bureau by the organic act are sufficiently broad and well understood now to permit it to give strong leadership

in the delinquency prevention field immediately. range consideration.

It is, however, a valuable long

3. We approve of the proposal that a single, and evidently already established, State agency will be administratively responsible for the execution of the plans made under S. 894, with other agencies assisting in making the plans, and some taking assigned responsibility for particular areas of the program.

We question the phrase "Provides for coordination of State and local programs for the control of juvenile delinquency and" in section 203 (b) of S. 894. This would include not only services which might be set up under the provisions of the bill, but also all ongoing programs. These exist in most States under separate laws with different requirements and standards, under different supervision, etc. To make a single State agency responsible for coordinating ("bringing into common action") all State and local programs for the control of delinquency, is to invite defeat before starting. In some instances, there could not be effective coordination without changes in the State laws, and State legislatures would be apt to take a dim view of accepting a Federal program which would require them as a prerequisite to change some of their fundamental laws and agencies. Furthermore, a plan could not be made in the next 2 years in the face of such a restriction because many legislatures are not in session. It would seem to us that a demonstration program should be possible on an administrative basis, without the necessity for general changes in State laws, or for an immediate appropriation of State funds.

We note the bill permits a flat unmatched grant of $25,000 to each State, but the balance of the proposed Federal appropriation cannot become available until there are matching State funds. Would it be permissible under the bill for the Secretary of Health, Education, and Welfare to consider funds already appropriated for State functions in this area to be considered as matching funds? Or are specific State appropriations expected?

We commend the provision in S. 894 as to hearings on State plans if they have been rejected by the Federal department. This review is a sound procedure. The provision for including youths up to 21 years of age in the coverage of the act also deserves mention. This makes possible the same kind of coordinated planning for older youth as for those who are still under juvenile court age (in our State 18). The 18-21 year-old group presents more of a crime problem than the younger children and is a fertile source of adult recidivists.

S. 1088, to assist States to return runaway children to their own communities in another State, has real merit. We would like to suggest that the Children's Bureau be mentioned as the division of the Department of Health, Education, and Welfare which shall administer the details of the program. All is left in the hands of the Secretary as the bill is written. However, the bill calls for only one State agency, either the department of public welfare or another agency with primary responsibility for child welfare to administer the provisions locally. The Secretary would have general direction of the program, but the statutory tie-up between Federal and State services would logically fall into the branch of HEW which is directly concerned with child welfare or with financial aid.

Some States will not be in a position to set up surveys immediately for the development of plans for return of children to other States. Would the apportioned funds for this purpose be carried over or would a State lose them and not be able to complete a survey which might be started a year after the provision goes into effect?

Paying one-half of the cost of maintenance of children for a period of not more than 7 days (sec. 201) is probably not adequate on an overall basis. Often plans cannot be completed that rapidly, especially when holidays intervene. Agency practices vary so much over the country that a particular State cannot control the planning down to a fine point. We are not certain from the text of this section if the bill would allow 100 percent reimbursement for transportation and administrative expenses or one-half.

There needs to be careful evaluation of the proposed fiscal arrangements to be sure that States can take advantage of the plan. The program should probably be specifically set up with a small advance grant for expenditures which, when reimbursed, do not revert to the State's general fund without the possibility of reimbursing the particular departmental fund from which the expenses were originally paid. There are some practical realities relating to State appropriations and refunds and the existence or not of revolving funds which would affect State participation in this program.

The proposal in S. 1832 to establish a National Youth Rehabilitation Corps is new to many State agencies concerned with the problem of juvenile corrections.

It is our opinion that States should study this closely in connection with their plans for strengthening programs for youth and report to the Congress later. We do not feel that we are ready for this yet. Perhaps in the next session of the 84th Congress, action could be taken. Considerable change might be needed in some State laws to permit them to release their committed delinquents to a federally supervised conservation work camp program. Many aspects of this cooperative plan should be studied.

Thank you for giving us an opportunity to express our opinions about this legislation. The intensive analysis of the nationwide problem of juvenile delinquency made by the Senate and the bills submitted for Federal aid to the States in meeting the problem are appreciated.

Respectfully yours,

L. L. CAFFREY,

Chairman, State Board of Social Welfare.

P. S.-S. 728 lists among the organizations to be included on the supervisory committee the American Association of Social Workers. This organization is changing its name as of October 1, 1955, to the National Association of Social Workers.

DEPARTMENT OF PUBLIC WELFARE,

STATE OF MISSISSIPPI, Jackson 5, Miss., July 1, 1955.

Re S. 728; S. 894; S. 1088; S. 1832.

Hon. HERBERT H. LEHMAN,

Chairman, Special Subcommittee on Juvenile Delinquency,
Committee on Labor and Public Welfare,

United States Senate, Washington, D. C.

DEAR SENATOR LEHMAN: In response to your June 29 letter regarding legislative hearings July 6 and 7, we wish to present our views and suggestions in reference to S. 728; S. 894; S. 1088; S. 1832.

We are in complete agreement with the intent and purpose of S. 728 and S. 894, to provide for assistance to and cooperation with States in strengthening and improving State and local programs for the control of juvenile delinquency. Such a step by Congress would be welcomed in Mississippi. It would provide funds very much needed for programs which should be in operation at this moment.

It is our opinion that S. 894 is a superior bill to S. 728 from the standpoint of administering a program at the State level. The provision in S. 728, section 303, concerning the State plan for administration would lend itself to a chaotic condition with no single agency being pinpointed as responsible for carrying out the provisions of the act. The provision lends itself to compelling a State to create a new agency in order to secure funds.

In reference to raising the Children's Bureau to the level of an office, it would seem more appropriate to separate the service programs from the insurance programs, combining the Children's Bureau and the Public Assistance Bureau with other service programs into a single coordinated office.

We strongly wish to call attention to both S. 728 and S. 894 providing for an advisory council or committee to advise the Secretary concerning the administration of the act. If the intent and purpose of the act is to strengthen and improve State and local programs for the control of juvenile delinquency, then it would be far more practical to provide that each of the several States shall be represented on an advisory council or committee to assist the Secretary concerning the administration of the act. Representation could come from each "designated State agency," or a person in the field of juvenile delinquency appointed by the governor. We believe the national organizations could help advise the Secretary on a technical committee, but that these organizations are in no position to advise the Secretary concerning individual States' local and State conditions. One example is the matter of drafting policy which would apply to rural areas as well as to urban areas. From the standpoint of Mississippi, had the Children's Bureau and Congress in turn been properly advised at the time we would not today have to deal with an almost impossible administration of Federal child welfare services fund regarding "areas of special need." This is but one example, yet a major one where proper advice from the States might have prevented such type of legislation and policy at the Federal level.

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