The American Personnel and Guidance Association appreciates the opportunity, given by the President's National Advisory Council, to present the recommendations of our membership concerning proposed changes in Title III of the Elementary and Secondary Education Act. The Association is particularly appreciative of the leadership exerted by your Chairperson, Mrs. Dorothy S. Robinson, and your Executive Secretary, Mr. Gerald J. Klucmpke, for the kind invitation extended to us. Our Association is acutely aware of the dedication of all of the PNAC members in reviewing the administration, evaluating the programs and recommending improvements in the operation of Title III. We know that each Council member recognizes the legal responsibilities he has for both educational innovation on the one hand and guidance, counseling and testing on the other, as found under ESEA III. It is in this spirit that the American Personnel and Guidance Association makes its recommendations to you at this time.

However, before doing so, I would like to point out how these recommendations have been generated. Our recommendations are the synthesis of several separate thrusts. We have solicited reaction from our general membership and leaders by means of the APGA Legislative Flier and our national newsletter, The Guidepost. Responses are coming in daily. Additionally, we have just completed a comprehensive 2-1/2 day meeting in St. Louis, Missouri in which our seven member national federal relations committee; our Association President, Donna Chiles; and representative guidance leaders from six states and two large city school systems, have met and offered their recommendations for changes in the existing provisions of ESEA III. As a further point, let me say we used the PNÁC staff-developed worksheet as a guide, and were therefore very much aware of the suggestions for change, existent therein, as well as the PNAC

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Recommendations, made in your annual reports, over the past three years.

The recommendations which we now wish to make have been given careful thought and are representative of our 28,000 national membership. The Association expects to give this subject continued consideration up to Spring of 1973 when it plans to offer testimony concerning this legislation, when hearings should be scheduled by the 93rd Congress.

Major Recommendations

The major points that the Association feels are most important to the improved operation of the Elcinentary and Secondary Education Act, Title III, Supplementary Educational Centers and Services; Guidance, Counseling and Testing, are as follows:

Recommendation No. 1

The Association agrees with the recommendation of the President's National Advisory Council that the current name of Title III should be changed in the interest of better communication to legislators and the general public and as a more descriptive explanation of the role that Title III has in American education. The Association therefore recommends that the name of Title II of the Elementary and Secondary Education

Act be changed to "Educational Innovation and Guidance".

Recommendation No. 2

Federal funds may be used for the same

The Association is adamantly opposed to the elimination of the words in Section 303, part (a) which are as follow purposes and the finding of the same types of programs previously authorized by those Titles." The elimination of these words would be a frustration of the intent of Congress as the original provisions of PACE programs found under Title III, and guidance, counseling and testing programs found under NDEA, V-A, were intended to be preserved.

Further, the Association has some specific recommendations which identify ways that

the language of Title III can be updated, especially as it affects guidance, counseling and testing. This language will be offered in the subsequent section dealing with

"Specific Recommendations".

Recommendation No. 3

Since the Elementary and Secondary Education Act, Title III represents both the educational benefits derived from innovation as well as those derived from guidance, counseling and testing, the Association recommends that in every State Advisory Council there should be a specific provision that representatives of the areas of professional

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competence in elementary and secondary school counseling and guidance services be

appointed to cach State's Advisory Council.

Recommendation No. 4

The Association has been deeply appreciative of the work, efforts and the dedication of the National Advisory Council and its individual members. The Association has been particularly appreciative of the efforts expended by Council member Dallas H. Smith, Consultant from the Career and Personal Counseling Service of the Presbyterian Church of the United States. However, the Association views Mr. Smith's appointment as fortuitous rather than one resulting from the language of Section 309, which deals with membership on the President's National Advisory Council. It seems important to us because of the unique way in which innovative programs and guidance, counseling and testing programs were linked in Title III that appropriate représentation be given to both aspects of this Title as found on the President's National Advisory Council. Therefore, the American Personel and Guidance Association recommends that at least one person be appointed by the President to the Council who has professional competence in

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the area of guidance and counseling, and that this inclusion be made a part of Section

309b) as a perfection of this Section under the National Advisory Council.

Recommendation No. 5

One of the particularly troublesome aspects of administration of the guidance and counseling provision of Title III has been the indefiniteness of amounts of money to he allocated in each State for the purposes of guidance, counseling and testing when an over all allocation of money was forthcoming to cach State resulting from annual appropriations to Elementary and Secondary Education Act, Title III, Supplementary Educational Centers and Services; Guidance, Counseling and Testing. This troublesome provision is found in that Section of 309 which deals with the amount of money that each State shall receive for the purposes of Title V-A. In many instances, State Title III Directors have viewed the language in Sub-section 4 as a ceiling for funding, not a floor in allocating amounts of money to those State administrators responsible for the guidance, counseling and testing provisions of this Title. Therefore, the Association recommends the following perfection in sub-section 4: "(4) of Section 303(b) of sucli Title III an amount at least equal to the amount expended by the State for the purposes of Title V-A of the National Defense Education Act of 1958 from funds appropriated pursuant to such Title V-A for fiscal year ending June 30, 1970." The intent of this change is.that funds reserved for guidance and counseling programs in 1972 should be appropriated at least at the same level as those funds appropriated for NDEA, V-A, in fiscal 1970, to insure that guidance and counseling is an integral part of our educational

system.

Recommendation No. (

United States Office of Education shall appoint and actively involve a representative

committee of State Directors of Guidance in the formulation and drafting of comprehensive guidelines for the administration of guidance and counseling under Title III. The intent of this recommendation is that in many instances State leaders in guidance feel they are called upon to review or comment on regulations after the fact. These leaders because of their unique position in administration of the Guidance, Counseling and Testing provisions of Title III, wish to be consulted and involved prior to the drafting of guidelines and in the drafting process.

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Specific Recommendations

In Title III there should be a name change from Supplementary Educational Centers and Services; Guidance, Counseling and Testing to "Educational Innovation and

Guidance".

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Section 301(a), in the first paragraph this should read "the Commissioner shall carry out a program for making supplemental grants for vitally needed educational services not available in sufficient quantity or quality (i) which stimulate and assist in the development and establishment of exemplary elementary and secondary school educational programs to serve as models for regular school programs, and (ii) assist the States in establishing and maintaining programs of guidance and counseling.

Section 301(b), APGA agrees with the appropriations levels recommended by

the Council in its worksheet.

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Section 302(a)(2), the first sentence should read "from sums appropriated for making grants under this Title for any fiscal year, pursuant to Section 301(b), the Commissioner shall allot $400,000 to cach State and shall allot the remainder of such sums among the States as follows:" The Association feels that the past allotment to each State is too low and should be raised to a much higher level.