The extension of the teacher institute program to include health and physical education is also necessary in order that teachers in these subjects have the opportunity for up-dating their training. There is a continuing shortage of girls' physical education teachers. There is increasing recognition of the value of physical education for young children, especially those in urban areas yet there is little attention given to training personnel to meet these needs.

Institutes for school librarians, at one time covered by the NDEA institute title, were dropped from this title when the greatly expanded library program was enacted. We believe that the institutes for school librarians should be restored to the NDEA institute program. The emphasis under the Library Services and Construction Act is on college, community, and technical library training. School librarians require a different type of training program, with more emphasis on child relations perhaps, than is normally required of technical or college librarians.

The suggestion has been made that all categories listed under Titles IV and XI be eliminated. We feel this is unwise since then there would be no Congressional directive to the U.S. Office of Education as to the variety of institutes which should be provided with the appropriated funds. We believe leaving the choice of institutes to be funded entirely to the discretion of the Commissioner is a dangerous form of potential federal bureaucratic influence on the curriculum that is most undesirable.

REPRESENTATIVE MEEDS AMENDMENT

Legislation to accomplish the objectives of the NDEA amendments herein proposed, plus authorization of additional funds for Titles III and XI, has been introduced by Representative Lloyd Meeds (D-Wash.) and several other members of the House of Representatives. A great many members of both the Senate and the House have written to members of the Association for Health, Physical Education and Recreation pledging their support for the amendments. We do not believe that there is any opposition to them.

Again, thank you for the opportunity to express the position of the National Education Association on the bills relating to the Higher Education Act and the National Defense Education Act.

PREPARED STATEMENTS OF WILLARD B. SPALDING, DIRECTOR, COORDINATION COUNCIL FOR HIGHER EDUCATION, STATE OF CALIFORNIA

The Coordinating Council for Higher Education has not examined S. 3047 or H.R. 14644 in detail. The following comments should be viewed as my personal opinions in respect to the Higher Education Amendments Act of 1966.

First, and here I am confident that my opinions coincide with those of the Council, the general intent of providing federal funds to support public and private higher education is wholly laudable. National needs will continue to be met most satisfactorily as more well educated manpower is available.

Second, providing funds to enable State Commissions to carry on "comprehensive planning to determine the construction needs of institutions," as proposed by Section 102, Part A, Title I, of S. 3047, is the key to wise use of all resources available in each state for capital outlay in higher education. On the basis of experience in California, future revisions of the Higher Education Act could profitably include comprehensive planning in other areas. I question strongly, however, whether the $4,000,000 authorized by S. 3047 is enough to achieve the goal sought.

California has had considerable experience in long range planning of capital outlay for our 18 California State Colleges and the 9 Campuses of University of California; extremely limited experience in such planning for our 77 junior colleges and our over 80 private colleges and universities. We know that comprehensive planning requires accurate projections of enrollments at all levels and at all campuses. Developing sophisticated procedures to do this is costly and this would be one of the first places the Coordinating Council would use such federal planning funds.

We also know that orderly comprehensive planning requires accurate anticipation of what will be taught on each campus, for buildings are constructed for specific purposes. Space utilization standards are required, so that each institution's needs are appraised on the same basis as those of any other institution.

I suggest at least $10,000,000 for comprehensive planning, a modest sum when compared with the total expenditures proposed for higher education.

Third, I question the desirability of reducing authorizations for funds for the construction of graduate academic facilities. When the California Master Plan for Higher Education was written in 1960, 28,000 graduate students were predicted for 1965–66. The actual number was 61,000, an over enrollment of 120%. The tremendous surge toward graduate education is sure to continue. More, rather than less, funds are needed here.

Fourth, the Higher Education Facilities Act of 1963 contained a statement regarding the maintenance of current effort. I note that S. 3047 and H.R. 14644 make no provisions for changing this section.

Since 1957, the State of California has constructed almost all of its higher education construction from bond funds voted by the people. Well over a billion dollars has been voted to construct facilities at State Colleges and the University of California. In addition, junior college districts have voted local bond issues for construction purposes. An exact figure is not available, but I would estimate that it is over $500,000,000. Thus the total state and local debt for higher education is quite great. A State bond issue for $230,000,000 more will be on the ballot this November. Overall annual cost (both state and local) for interest and principal payments are substantial and will increase.

Since 1957, the State of California has constructed almost all of its higher education which omits current costs, for interest and principal payments, works severe hardships on those states which have endeavored to anticipate their needs through the use of bonds, for it calls upon them to carry past and present burdens at the same time.

Further, since each public institution or each private one must provide a major share of the cost of each facility, I cannot understand what good is served by a maintenance of effort requirement. The sharing formula represents a true partnership in higher education and recognizes the responsibilities and the gains which each partner shares in this important enterprise.

I suggest that current maintenance of effort be defined as the sum of current expenditures for capital outlay for higher education, current expenditures for interest on bonds for capital outlay for higher education and current expenditures for principal payments on bonds for capital outlay for higher education. Fifth, I do not believe that the policy of shifting more of the burden of financing higher education to the student is in the national interest. Loan programs are designed to require students to pay at a time in life when they will also be paying for new families, new homes, and new public services and the costs of all seem likely to increase substantially, if present trends continue. If trends become deflationary, the student will be in worse shape, for he will be paying off an inflated loan with deflated dollars.

I suggest strongly that grants be used in place of loans. State plans can be developed so that each college or university can use its existing procedures to make grants.

California has a long history of tuition free public higher education. It was among the early states to establish a scholarship program for graduates of its high schools. Continued national policy to shift the burden of support of higher education to the student can erode what has been accomplished here.

Sixth, I suggest you examine the extent to which present policies in respect to guaranteed loans are accomplishing the goals desired. Cheap money is becoming harder to get as interest rates rise. For what purposes are funds secured from loans actually used? To what extent does the use of private organizations to administer the state's loan program actually increase the costs to the college and/or the student?

I recognize that my fifth and sixth comments come too late to affect action this year, but I hope that they can be considered fully when the Higher Education Act of 1967 is being prepared.

PREPARED STATEMENT OF CLARENCE A. PHILLIPS, CHAIRMAN OF THE BOARD, HEALD'S COLLEGE, SAN FRANCISCO, CALIF.; PRESIDENT, UNITED BUSINESS SCHOOLS ASSOCIATION, WASHINGTON, D.C.

Mr. Chairman and members of the subcommittee, my name is Clarence A. Phillips. I am chairman of the board of Heald's College, San Francisco, Calif. For more than forty-five years I have been associated with business education.

Also, I am President of the United Business Schools Association to which belong nearly 500 of the quality post-secondary independent business schools and junior colleges of business. UBSA itself was founded in 1912 but many member institutions, including Heald's College, have been serving students for more than 100 years.

UBSA itself is an affiliate of the American Council on Education. At least one administrator in every UBSA school is a member of the American Vocational Association.

STATEMENT OF POSITION

1. We endorse and urge favorable consideration of the provisions extending grants and loans under the Higher Education Facilities Act of 1963.

2. We endorse and urge favorable consideration of the extension of the National Defense Education Act.

3. We wish to express our concern for what might be the inadvertent noninclusion of the National Vocational Student Loan Insurance Act of 1965 (P.L. 89-287) with respect to certain proposals in Title II dealing with teacher incentive forgiveness proposals.

4. We respectfully point out to the Committee the array of Federal programs of student financial aid or benefit which include students enrolled in accredited, proprietary institutions.

EXTENSION OF THE HIGHER EDUCATION FACILITIES ACT

Although only slightly more than 10 per cent of the institutions holding membership in UBSA are nonprofit institutions we are pleased to report that a number of these institutions are now participating in and have received grants and loans pursuant to the Higher Education Facilities Act of 1963. One of the requirements of this Act is that the institution be accredited by a “nationally recognized accrediting agency."

We feel that it is indeed a tribute to the efficacy of accreditation by the Accrediting Commission for Business Schools which has had such recognition from the USOE for more than ten years that these schools have been able to qualify for grants and loans under HEFA. We feel the trust reposed in ACBS by the USOE has been justified. The responsibilities of ACBS as the recognized accrediting agency for independent business schools will continue to expand in the light of the host of Federal programs of student financial assistance which have been recently enacted or expanded.

EXTENSION OF NDEA

It is our position that the National Defense Education Act has a very special place in the total structure of student assistance. It is geared to student need and, thus, should be distinguished from the two newer loan guarantee programs enacted by the Congress last year.

In support of our position we offer as Exhibit "A" a letter from the President of McKenzie College in Chattanooga, Tennessee, urging continuation of the NDEA student loan program. This letter was published at page 5896 in the Congressional Record of March 17, 1966. It tells how the NDEA student loan program is providing realistic assistance to needy students from the Appalachia region so they can attend McKenzie College, which is accredited by the Accrediting Commission for Business Schools.

NONINCLUSION OF NATIONAL VOCATIONAL STUDENT LOAN INSURANCE ACT OF 1965 In three separate instances this year there has been what might be an inadvertent omission of any reference to the National Vocational Student Loan Insurance Act. In each case there was a specific reference to the Title IV B guarantee loans of the Higher Education Act of 1965. As the Committee knows, the Vocational Student Loan program has language almost identical with the Title IV B language.

Thus, when amendments are proposed for Title IV B loans or reference is made to them we respectfully submit that the same should apply to vocational student loans. The three instances are

(1) The loan reimbursement payments for teachers under Title II of S. 3047.

(2) The loan moratorium amendment for VISTA volunteers under Title VII of the Economic Opportunity Act of 1964 as proposed in H.R. 15111 which would amend Section 427 of the Higher Education Act of 1965.

(3) Omission of the vocational student loan program from the list of those acts making specific reference to Peace Corps volunteers contained in the section by section analysis accompanying S. 3418 appearing in the Congressional Record of May 26, 1966, at page 11004.

We are fearful that these examples point out the possibility that the parallel language of the two student loan programs which was the intent of Congress at the time of enactment will not be preserved. We therefore, urge the Committee to reflect in its report concern for this problem and that the Committee recommend in such proposals that the two acts be kept in parallel.

We submit as Exhibit "B" letter dated June 17, 1966, to R. A. Fulton from the Deputy General Counsel of the Peace Corps.

In the event that the NDEA is amended as proposed in Title II of S. 3047 we feel it would indeed be an unfair and unjustified omission to exclude a student with a vocational student loan from the benefits of loan reimbursement payments for teachers.

As the Committee knows, there is a growing articulation and transition between proprietary business schools and the four-year degree granting colleges. There is also an alarming shortage of business education teachers. Programs of transfer with credit hour recognition for courses completed in accredited proprietary business schools are now underway. Thus, it is possible for a student who originally enrolled in a business school and who later expanded his vocational and professional aspirations to transfer with credit to a bachelor degree program including certification as a business teacher.

It would be unfair to deny such a teacher the benefits of loan reimbursement payments merely because such a teacher began his education with a loan bearing the label of "Vocational Loan" instead of a Title IV B or NDEA loan.

We sincerely hope that the omissions referred to were inadvertent and not deliberate. We also hope that future inadvertencies can be avoided.

FEDERAL FINANCIAL BENEFITS FOR STUDENTS IN PROPRIETARY SCHOOLS

We respectfully list eight Federal programs of student financial aid and benefit which include students in proprietary educational institutions. In all of these programs it is the need of the student combined with the quality of the educational program (usually accreditation) which governs and not the corporate structure of the institution. It is no bar to student benefits that the institution is proprietary under the following Federal programs:

(1) War Orphans' Educational Assistance; 38 U.S.C. 1701 et seq.

(2) Veterans' Readjustment Benefits Act of 1966; P.L. 89-358 [See Sec. 1652 (c)].

(3) Social Security Amendments of 1965; P.L. 89-97 [See Sec. 202 (d) (8) (C)].

(4) Federal Employees' Compensation Act; P.L. 89-488.

(5) Income Tax Deduction for Student Dependents; 26 U.S.C. 151 (e) (4). (6) National Vocational Student Loan Insurance Act; P.L. 89-287. (7) Survivorship Annuities under Civil Service Retirement Program; 5 U.S.C. 2251-2268 [See Sec. 2251 (j) definition educational institution] [See Sec. 2260 (d) dependent student].

(8) Indian Loans for Vocational School Tuition; 25 U.S.C. 471. Therefore, while we agree with Commissioner of Education Harold Howe II that the NDEA should be extended, we most respectfully disagree with the completeness of his statement in his testimony to this Subcommittee on July 12, 1966, when he said the objective of the new financing proposal "is to provide a NDEA loan to every needy student who requires it.”

There are approximately 100,000 students enrolled in independent business schools accredited by the Accrediting Commission for Business Schools. Less than 20 per cent of the accredited business schools are nonprofit in corporate structure. Thus, students enrolled in the remaining 80 per cent of accredited independent business schools are excluded from access to the NDEA student loan program.

This exclusion is not related to the need of the student or of the quality of the institution's program. It merely is on the basis of corporate structure of the institution; that is, the institution is proprietary in form.

Thus, it can be seen that there are needy students enrolled in accredited institutions but who do not have access to the NDEA student loan program. Committee in its Report No. 1275 of July 31, 1964, said:

This "Approximately 20 per cent of the students in accredited business schools have enrolled after having one or more semesters of study in four-year colleges or universities." Page 3.

According to a report by the American Council on Education, Volume XV, No. 23 of July 14, 1966, 65 per cent of students finish a four-year college program. What about the other 35 per cent?

As the Committee has noted, accredited business schools offer a realistic quality program for students who drop out of a four-year college program. Very likely these college dropouts or transfers are very much in need of financial assistance for this "second chance." It is realistic to point out that certainly a representative percentage of the 100,000 students enrolled in accredited proprietary business schools are "needy." Yet, the bulk of these students are denied access to the NDEA loan program. Not because of the quality of the educational program and not because of student need, but merely on the grounds that the institution itself is organized as a proprietary rather than a nonprofit corporation.

Such a bar does not exist in the other specialized Federal programs of student assistance listed above nor has it prevented such institutions from contributing to the success of other educational programs for many years. Among the many programs through which "under contract training" is conducted by proprietary business schools are

(1) Indian Adult Vocational Education; 25 U.S.C, 309.

(2) Vocational Rehabilitation Act of June 2, 1920, as amended 29 U.S.C. 31 et seq.

(3) Manpower Act of 1965; P. L. 89-15 [See Secs. 102(6) and 231]. (4) Economic Development Administration; P. L. 89-15 [See Sec. 241]. (5) Economic Opportunity Act of 1964; P. L. 88-452 [See Secs. 103 and 207].

(6) Government Employee's Training Program (P. L. 85-507) 5 U.S.C. 2201-2319: [See Sec. 2302(7)]. [See also P. L. 89-478 authorizing variation in Federal Employees 40-hour work week.]

(7) Vocational Education Act of 1963; P. L. 88-210, Sec. 8(1).

It is our understanding that there are not now before the Committee any proposals which would amend the terms of student eligibility. We, therefore, point out the above facts to the Committee for future consideration. We look forward to the day when such proposals may be considered and to such time when we can testify more fully and completely at this point.

At such time that there is a re-examination of the terms of student eligibility we feel that a commentary by the present Secretary of Health, Education, and Welfare the Honorable John W. Gardner is pertinent. Secretary Gardner pointed out in 1960 that:

"All the organizational arrangements, all the methods and procedures that characterize American education today were originally devised to help us accomplish our purposes. If they no longer help us, we must revise them. The arrangements and methods must serve us and not control us." Goals for Americans, page 88.

As a general proposition we feel that there is a justifiable distinction between necessary organizational arrangements defining present public policy on grants and subsidies to public and nonprofit institutions for institutional support and procedures governing eligibility of students for personal financial assistance.

CONCLUSION

We sincerely urge the Committee to consider favorably:

1. Extension of the Higher Education Facilities Act of 1963.

2. Extension of the National Defense Education Act.

We also hope that the Committee shares with us the view that there is a need to maintain parallel statutory language in the Title IV B student loans of P. L.. 89-329 and the Vocational loans of P. L. 89-287. Additionally, we look forward at the appropriate time to the opportunity of contributing to any considerations for amending arrangements and methods governing the terms of student eligibility for any programs of student assistance from which students in accredited proprietary business schools are now excluded.

We thank the Committee for this opportunity to express our views.