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Mr. Chairman and members of the sub-committee:

I want to thank you on behalf of the American Vocational Association for the opportunity to present a statement concerning H.R.3437, a bill to amend the Education Amendments of 1976. We recognize the interest you have in perfecting Title II, the Vocational Education Amendments, of PL 94-482 and appreciate your sincere support

for vocational education.

When the Education Amendments of 1976 (PL 94-482) were being considered by the Congress, there was considerable discussion regarding the purpose of federal assistance for vocational education. It was recognized that one of the primary purposes of federal assistance historically has been to improve the quality and quantity of vocational education programs available to the people of this nation. Federal assistance to vocational education has stimulated state and local interest and has provided a means whereby programs could utilize all resources to the best advantage. Federal assistance has stimulated innovation; it has also provided a means for state and local governments to monitor the quality of vocational education and it has provided assistance to local education agencies who would expand and improve programs of vocational education.

In line with this, the Congress in PL 94-482 stated that it was the purpose of federal assistance to vocational education to improve planning in the use of all resources available to them for vocational education and manpower training; to extend, improve and where necessary maintain existing programs; to develop new programs; to overcome sex discrimination and sex stereotyping in vocational education; to provide part-time employment for youth who need the earnings to continue their vocational training, so that persons of all ages can have ready access to training and re-training which is of high quality.

The purpose of the law as stated is well written and it is appropriate to the situation facing vocational education in the late 1970s. I do, however, share with

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you some concerns that certain provisions of the law will not allow the state and local governmental agencies to fulfill the objectives and the purposes as written. For this reason, I am pleased, Mr. Chairman, that you and Mr. Quie have introduced amendments to PL 94-482. I will address these amendments and other areas of concern that the American Vocational Association has identified which are:

1) Provisions for federal funds for state administration of vocational

education.

2) Provisions for federal funds for local administration of vocational

education.

3) The allocation of a percentage (20%) of the basic state grant for

program improvement and supportive services.

4) The need to clarify the date of implementation of the new law.

I hope we can discuss in depth the state and local administration today. Since

I am not sure whether the other two issues require amendments to the law or not,

I will simply place them before you for consideration.

State Administration

Under the provisions of PL 94-482, Section 102(d), state administrative costs are to be taken from a separate authorization of $25 million annually. The purpose of this section is to authorize funds for preparing the five year comprehensive state plan, preparing the annual program plan and accountability report including necessary data; conducting evaluations and funding state administration of vocational education. In addition, it is to be remembered that the law requires states to match federal expenditures for administration at the rate of 80%-20% for FY 78, 60%-40% for FY 79 and 50%-50% thereafter.

Since enactment of the law, we have identified several problems that will drastically hinder the delivery of vocational education in many states unless adjustments

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are made to the law. One of these problems is that the $25 million which is the total authorization in Section 102(d), even if fully funded, would not adequately meet the current requirements for the federal share of expenditures for state administration. In response to a survey conducted by the National Association of State Directors of Vocational Education, approximately $51 million of federal funds are used to match approximately $81 million of state funds for administration. This means that 62.6% of the total administrative expenses during FY 76 were taken from the federal dollar leaving 37.4% funded by state monies. The state share of administrative cost in FY 76 more than met the requirements outlined in PL 94-482 for FY 78 and while it will not meet the requirements mandated for FY 80 and beyond, it is an indication that most states are prepared to assume their fair share of the responsibility for administering vocational education.

The new vocational education amendments call for comprehensive planning to meet the vocational education needs in each state. Great responsibilities are placed upon the State Board for Vocational Education to coordinate this planning and administer federal and state funds in accordance with the plan. Strong leadership will be required at the state level during the development of these plans and to follow through with quality programs in each and every community within the state. In addition to the greatly expanded planning requirements, PL 94-482 calls for each state to evaluate each program within the state during the period covered by the five year plan. The ability to stimulate data collection and accurate evaluations will depend upon the leadership coming from the State Board for Vocational Education.

Extensive new requirements are placed upon this leadership. The innovative concept of PL 94-482 was built around these requirements and it is my belief that the new vocational education amendments will accomplish their purpose only if strong state and local leadership is encouraged.

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With this in mind, it appears restrictive, therefore, for federal legislation

to require both a matching provision for state administration and a limitation on the amount of funds that are to be available from the federal government. The 50-50 state-federal match required by law ensures state participation. Further, in a time when funds are scarce and priorities must be established it should not be mandated that vocational education seek increased funds specifically to provide administrative technical assistance and state leadership for programs both desired by Congress and supported with federal funds.

This sub-committee and other members of Congress have a strong interest in providing vocational education for all people. The mandates contained in the vocational education amendments seek new direction and a new thrust for vocational education. There are requirements that state and local programs better serve the disadvantaged, unemployed and underemployed youth and adult. In addition, there are requirements that whatever sex biases may be found in vocational education are to be eliminated; that improved guidance and counseling programs are necessary and that the total supportive and program improvement services are to be expanded in order to assure vocational education that addresses the economic and social needs of people. These mandates of Congress will be seriously curtailed without full implementation of the concepts of comprehensive planning based upon data gathered and evaluations made that are contained in the law. These concepts cannot be enacted with limitations on state and local leadership as currently written.

Recommendations

In light of the above statements, it is recommended that federal funding for state administration be removed from the purposes of Section 102(d) and be placed under the uses of basic state grant funds, Subpart 2, Section 120(b)(1). It is understood that this is one of the purposes of H.R.3437. I support this wholeheartedly.

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Prior to the passage of the Education Amendments of 1976, 38 states utilized federal funds to pay some portion of the expenditures incurred in providing local administration for vocational education. Because of this, I was pleased when the original bill considered by this sub-committee (H.R.12835, which eventually led to the enactment of PL 94-482) contained language permitting the use of federal funds for local administration. In addition, we watched closely the corresponding Senate bill (S.2657) and I was pleased that it contained local administration in the definition of vocational education. With this as background, I believe it would be fair to say that Congress recognized the need for qualified local administrators and was interested in providing initiative in the form of federal funds to assure quality leadership at the local level.

The Senate-House conference between the two documents leading up to PL 94-482 eliminated the provision for utilizing federal funds for local administration. I am sure that Congress will want to pursue their intent and amend the law to provide incentives for qualified local leadership.

There currently appears to be no established pattern within the states for utilizing federal funds to support local administration. Many states have assumed responsibility for funding a portion of the local administrators salary while others look to the local education agency. My own personal experience addresses this issue as one of maintaining quality programs of vocational education through quality leadership. In the past, the State Board for Vocational Education has, in many states, provided state and federal funds to local school districts who identify and employ qualified vocational administrators. This has been used as a temporary incentive in some states while in others, it has been used to assure a quality program when the local school district could not afford the total financial responsibility of

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