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Education Commission of the States

300 LINCOLN TOWER 1860 LINCOLN STREET

DENVER, COLORADO 80203 • (303) 893-5200

August 29, 1973

THE STATES AND FEDERAL AID TO ELEMENTARY-SECONDARY EDUCATION

The Education Commission of the States (ECS) supports the concept

of consolidating into block grants to the states most categorical programs of federal aid to elementary and secondary education.

This has been the position of the Commission since shortly after it
Resolutions favoring this approach have been

was founded in 1966.

adopted at every ECS annual meeting since 1968.

Education is constitutionally a state responsibility. While state governments delegate varying degrees of administrative authority to local school districts, and the federal government provides limited financial support in accordance with national needs and priorities, it is the state that is the linchpin of American education.

Unfortunately, the cumulative effect of federal aid programs enacted piecemeal over many years has been to distort traditional and constitutional state-local relationships. Some federal programs require federal

officials to deal directly and exclusively with state officials or agencies. Some involve direct federal-local relationships with little or no state involvement. Some federal funds flow through state agencies to local school districts with varying degrees of state influence or control.

A few federal programs of aid to local school districts, particularly the impacted aid program, even go so far as to disequalize state school finance programs.

Another distortion takes place within education itself. The categorical nature of many federal programs inevitably has led to the creation of specialinterest groups within state and local education agencies, each determined to maintain the narrow focus of its specialty while expanding its influence. These groups compete, not only with one another, but with state and local administrators responsible for coordinating all programs for children.

Some

state and local officials work more closely with federal officials than with people in their own agencies, often managing federal funds in isolation from state and local resources available for the same purposes.

In addition, federal programs have tended to be administratively timeconsuming and expensive in proportion to the return. The delivery system for the existing maze of programs, involving separate schedules, plans, guidelines, regulations, forms and evaluations for each program, is so complex that state and local education agencies find it impossible to coordinate and concentrate federal funds effectively. Most state education agencies and many local school districts have been compelled to hire federal aid experts-specialists in education grantsmanship.

ECS has long maintained that any new or revised federal education program should, as an integral part of the legislation:

Provide forward funding. Funds appropriated in one fiscal year should be for use by the states in the following fiscal year. In this way every state would know the magnitude of federal assistance in time to develop more effective plans for coordinating federal and state programs. Provide adequate transition time. State and local education

agencies--and the U. S. Office of Education (USOE) --need time to plan, time to coordinate new programs with existing programs or, in the case of program

consolidation, time to make the transition from one form of federal aid to another. Thus, while a program consolidation bill enacted in late 1973 could become effective in the 1974-75 school year (fiscal 1975), any such bill enacted in 1974 probably should not take effect until the 1975-76 school year (fiscal 1976). In addition, any major changes in the financial impact on state and local education agencies should be phased over a two-to-threeyear period.

Allocate funds to state-designated agencies. Funds should be re-allocated to local school districts in accordance with state plans. This would eliminate both the distortion in state-local relationships that have developed under existing programs and the disequalizing factor in direct federal aid to local school districts--particularly important as states assume an increasingly larger share of local school costs. Passing funds through state agencies directly to local school districts makes a mockery of federalism by rendering states impotent in fulfilling vital aspects of their constitutional responsibility for education.

Make equitable provisions for territories.

Territories should

receive such funds for education as are consistent with their relative needs, rather than in accordance with an arbitrary set-aside figure based on 2-3% of total appropriations. The long neglected problems of the territories should be dealt with systematically until such time as the educational systems in the territories are comparable with those in the states.

Provide for full state involvement in drafting guidelines and regulations. Too often USOE officials draft guidelines without adequate outside advice and counsel and invite reaction only on an ex post facto basis.

Involving governors, state legislators, and other state

officials from the beginning would help prevent later

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misunderstandings, smooth the transition to new or revised programs and aid annual program administration.

Promote the concept of equal educational opportunity. Encourage states to distribute funds to local school districts on an equalizing basis that includes differentials for programs such as early childhood, compensatory education, the education of exceptional children, career education and for excess-cost programs such as those in urban-impacted or rural-isolated areas (density-sparcity factors). Of course, the states should be free to develop their own equalizing program and to determine their own cost differentials.

Provide for interagency and intergovernmental cooperation. The complications which result from the bureaucratic maze described above can be somewhat eased by provisions which permit states to consolidate funds appropriated for similar types of programs and which promote program consolidation. This kind of coordination can be encouraged both within and between the three levels of government, as well as between governmental units and the numerous kinds of special purpose agencies which exist.

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Following is the ECS position on each of five areas which have been considered for federal program consolidation:

1. Compensatory education.

Transform the existing program of aid for

disadvantaged children under Title I of the Elementary and Secondary

Education Act (ESEA), minus the handicapped set-aside, into a comprehensive compensatory education program. Federal grants to the states should be based

on a Congressionally acceptable revision of the existing poverty-level

formula, using 1970 census data. States should be free to merge federal funds with state compensatory education funds.

The re-allocation of federal funds to local school districts on the basis of either a low-income formula or according to educational needs, as determined by a statewide testing program, should be left to the discretion of the states. States should be required to submit to the U.S. Commissioner of Education a state plan acceptable to the governor and subject to public hearing. The Commissioner should be directed to report to the Congress on the viability of the needs allocation approach after a three-year period.

2. Career education.

Recognize the continuity of career education from

kindergarten through graduate and continuing education by consolidating Parts A to H of the Vocational Education Amendments of 1963 and the Smith-Hughes Act, and insuring cooperative planning with state higher or postsecondary education agencies in implementing Title X-B of the Education Amendments of 1972. Through cooperation of state elementary-secondary and state postsecondary or higher education agencies or commissions, the states should develop a career education plan that involves the cooperative efforts of the various academic and vocational communities including community colleges, vocational technical schools and institutes, elementary-secondary schools and colleges and universities. Emphasis should be on coordinating and articulating vocational or occupational education programs with academic programs as much as possible, including greater emphasis in academic programs on career development.

3. Exceptional children. Consolidate Part B of the Education of the Handicapped Act and the handicapped set-asides from the Vocational Education Act and from Titles I and III of ESEA into a comprehensive program for exceptional children, both the handicapped and the gifted. Emphasis should be on individualized programs within the mainstream of regular schooling as much as possible. States should be assisted in providing appropriate special-education

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