areas with a high concentration. That means they get less administrative money, fewer other agencies to help them, and considerably more difficulty in doing any real planning.

In some of the urban areas, city aging offices had allocated funds for planning prior to the area agency funding, thus allowing for additional planning staff with the title III funds. This additional commitment from the rural area agencies has not occurred, not because it wasn't needed, but because there just wasn't enough money for staff.

We wonder if it would not be possible for a study to be made of the overall difference in costs per unit of serving elderly in the rural areas v. serving those who live in urban areas. Such a study could then document the need on the part of Federal and State governments to develop new allocation formulas that would take into consideration these differences.

As the evaluations and reports from the area agencies begin to come in, it may be that there will be obvious remedies for dealing with the rural elderly.

I appreciate the opportunity to comment on this issue and am glad to know that you are looking into the special problems of the rural elderly.

Very truly yours,

HARRY F. WALKER.

ITEM 19. LETTER AND ENCLOSURE FROM JOSEPH A. GAIDA, EXECUTIVE DIRECTOR, STATE OF NEBRASKA COMMISSION ON AGING; TO SENATOR FRANK CHURCH, DATED MAY 13, 1975

DEAR SENATOR CHURCH: Thank you for your letter of April 14, 1975, and your request for information from the Nebraska Commission on Aging relative to the Older Americans Act and the rural elderly.

The Nebraska Commission on Aging prepared some remarks for presentation to Senator Dick Clark of Iowa at his recently scheduled hearing in the Midwest. These were presented to Dr. Woodrow Morris of the University of Iowa for inclusion in his testimony to Senator Clark.

Because I have only recently learned that there is a possibility that our comments were not included in Dr. Morris' testimony, I am hereby furnishing you with a copy for your review.

Thank you for this opportunity to comment. Best wishes.

Sincerely

Dr. W. W. MORRIS,

[Enclosure]

Chairman, College of Medicine, University of Iowa,
Iowa City, Iowa

JOSEPH A. GAIDA.

DEAR WOODY: Thank you for your memorandum of April 11, 1975, and the opportunity to comment through you before the U.S. Senate Special Committee on Aging regarding programs in rural States and areas. I will try to specifically direct my comments to your numbered points for consideration.

1. The $160,000 State administrative level is much too small for effective administration of very sparsely populated areas which contain a large percentage of population aged 60 and over. Although it is quite fair to allocate the funds according to the number of individuals over a certain age; the impact of the programs on the State should be of equal consideration. Because Iowa and Nebraska are basically tied for second place in the country-on population over the age of 60 per total population-it contributes to a rather high dependency ratio. Therefore, it is the impact of the elderly on the State's population which should be of consideration, not only the number of individual heads. Additionally, the mere geography of a large State requires a rather large outlay in terms of travel expenditures. For example, it is much faster, easier, and economical for an individual from our central office in Lincoln to reach Chicago, Ill. some two States distance than to reach the other end of our State. These considerations are of importance when we are forced to go to the legislature for administrative funds because the Federal Government cannot provide enough administrative money to manage title III, much less title VII programs.

2. Nebraska is in the process of trying to consolidate its transportation programs in the department of roads and consequently will be in a much better position to deal with the transportation needs of the elderly citizens through legislated presignoff on rules, regulations, and amounts issued by that department.

3. The Nebraska Commission on Aging has had considerable difficulty explaining to State officials the necessity for using State moneys to administer the title VII program. We find that a large share of our evaluation and management time is spent in the administration of title VII activities for which we receive not one penny.

4. This particular problem of service personnel migration is not unique to Iowa or Nebraska. Unfortunately, the impact which the commissions on aging can have in this regard is rather minimal. I firmly believe, that these must be dealt with on a multiagency State level basis, with great help from the national scene. Only through such considered effort can services remain in the microcities or be brought to them.

Thank you for this opportunity to comment. Should there be any questions, please do not hesitate to contact me personally, Best wishes.

Sincerely,

JOSEPH A. GAIDA.

ITEM 20. LETTER FROM L. E. RADER, DIRECTOR, INSTITUTIONS, SOCIAL AND REHABILITATIVE SERVICES, PUBLIC WELFARE COMMISSION, STATE OF OKLAHOMA; TO SENATOR FRANK CHURCH, DATED MAY 16, 1975

DEAR SENATOR CHURCH: Reference is made to your communication inviting comments on how the Older Americans Act is operating in rural areas.

The services available under the act in rural areas is providing very needy services on a limited basis. There is just not sufficient funding to provide any significant impact. The AoA allotment process used during the past 2 fiscal years has directed funds to larger populated States. The intent of the act is good, however, designating other agencies as area agencies does provide for many problems and loss of dedication and interest in the real job to be done.

We would recommend that manpower programs such as Green Thumb should come through area agencies. Home repair is desperately needed. The matching requirement for Federal funds is difficult to develop in many instances. We have found that in administering the program since it began in fiscal year 1966 that bookkeeping to document the use of in-kind resources is a very time consuming and expensive job. It would seem more logical to require cash match on a lower matchpercentage basis. Consideration should also be given to remove 3-year limit on funding individual programs without approval of AoA. Thank you for the opportunity to comment.

Very truly yours,

L. E. RADER.

ITEM 21. LETTER AND ENCLOSURE FROM DAVID C. CROWLEY, EXECUTIVE DIRECTOR, OHIO COMMISSION ON AGING; TO SENATOR FRANK CHURCH, DATED MAY 20, 1975

DEAR SENATOR CHURCH: We are pleased to respond to your memorandum of April 14, 1975, and we apologize for our late reply.

Since Ohio represents a State which has both large rural and large urban areas, we concur with your committee's concern relating to the special needs of the rural

area.

Our agency has attempted to respond to the rural areas of Ohio through various issues. First, the formula utilized by the OCOA in allocating title III funds to area agencies has an established minimum of $125,000. While this amount is obviously insufficient for our rural areas with an average of nine counties, it is significantly above the amount rural areas would receive if Ohio's funds were allocated solely on the basis of the 60-plus population. Secondly, the funding formula in Ohio provides for a greater weight to areas with higher poverty level 60-plus populations. Again rural areas benefit from this aspect of the allocation formula.

In addition to the title III funds, the OCOA reserves the majority of our State subsidy funds to be utilized for the local match of our rural area agencies and services. We are presently working with our State legislators to increase our State subsidy as it is inadequate for our needs for local match.

Thus at the State level our agency is continually seeking resources to assist the rural areas match the title III funds, but our success as well as our realistic predictions for the future, has not begun to alleviate the problem. We do support

your committee's investigation into the Older Americans Act's effectiveness in the rural areas in hopes that alterations may be recommended to complement our efforts at the State level.

The following aspects of the Older Americans Act are deserving of your careful review:

(a) Federal funding sources.-Rural areas have been left out of the major Federal grant-in-aid programs that are allocated to local jurisdictions on the basis of population. General revenue sharing, CETA, and the Housing and Community Development Act, are relevant examples. Thus where urban areas are able to tap these funding sources in concert with title III programs, the same process is not possible in rural areas. This issue relates to the 3-year limit for title III funds in support of any one program. Title III funds do succeed in making citizens aware of the need for aging programs but the "fourth-year spinoff" aspect cannot result if only the awareness exists and not the resources for continuation.

(b) Local match.-Again, lack of resources to supply the increasing need for local matching funds is a critical issue. Tax base funds are low, with tremendous physical and social needs pressing on a small amount of local public funds. Other sources of local match are scarce in rural Ohio as there are few philanthropic or service agencies who generate so much of the local match in our urban areas. We suggest that rural areas who show conscientious efforts to raise local match but are yet unsuccessful be allowed to waive existing matching regulations.

Please note that we've attached a memo from a rural area agency that responds further to the above issues.

As the State agency, we are all too aware that the greatest need for essential programs are in our rural areas, and that the most difficult and expensive services to implement are also in the rural areas. We will continue to assume major responsibilities for these concerns at the State level and will continue to encourage those at the Federal level to join and assist us in our endeavors.

We are anxious to be of further assistance to your committee and wish you success in your deliberations.

Sincerely,

[Enclosure.] MEMORANDUM

DAVID C. CROWLEY.

To: Caddie Riegel

From: John R. Allen, Acting Director

Re: Title III of Older Americans Act

Date: May 5, 1975

In our rural area there are four areas of concern in dealing with title III of Older Americans Act: (1) Lack of sufficient resources for local funding of relevant program for the elderly, (2) lack of rural mass transportation, (3) lack of services geared to rural area, and (4) oppressive Federal regulations that inhibit Federal programs ease in coordination/cooperation.

(1) The lack of sufficient resources for local funding of Older Americans Act programs is acute in our rural area. The needs for match have been met through some use of general revenue funds in some counties and primarily by fundraising drives by the elderly themselves. The elderly in four of our counties have worked very hard to get local match money for title III. They have held dinners, radiothons, auctions, sales, and nearly every imaginable means of getting local funds has been attempted.

In our rural areas, the scarce resources are pressured from all sides. Each Federal program requires local match, therefore each program must beg, borrow, or steal from the counties' or cities' general funds. Also there are many problems of other natures throughout rural areas. These problems, such as water supply, sewage, roads, adequate police force, etc., are real also. When all of these problems are confronted, the tax base in our area is not sufficient to attempt to solve all of them. Federal revenue sharing has been a partial answer but the access to these funds by programs for the elderly has been limited by the use of the Federal revenue sharing money for "more pressing" problems of a building nature. Federal revenue cannot match other Federal programs, this should be changed. Threeyear-and-off provision to indefinite funding to rural area under title III would help immensely. I would further urge that funds be available under title III to continue match at a 50-50 ratio for the fourth year through the authorization of the program. This would enable these rural counties to continue programs for the elderly as long as the Older Americans Act is in force. I urge the committee to consider this vital issue for the continued success of the programs for the elderly in rural areas. This concern is of number one priority throughout our area.

(2) The lack of rural mass transportation means that access to existing social services for the elderly is severely limited. With Older Americans Act moneys several local programs have been able to alleviate some of the transportation problems of the elderly, but only a few can be served and only a small amount of the need can be met. The need for rural mass transportation is great in our area. If such services could be developed throughout the entire 10-county area, then the title III moneys could be spent to put in place special vehicles to accommodate the handicapped and severely isolated elderly. This would enhance the rural mass transportation system and give access to transportation the elderly who are denied the service because of their isolation or handicaps.

My suggestion for the Older Americans Act, title III, would be to allow the matching of certain amounts of title III dollars and FHWA or UMTA funds in rural areas. This would enable local programs to secure access to rural mass transit. This is necessary to guarantee a truly coordinated effort for alleviating this problem.

(3) The services that have been developed with title III funds in our area have been patterned around senior citizen centers of a multipurpose nature. This is a pattern that exists in urban areas where transportation is less a problem. There is the need to shift emphasis to a full range of home-based health, nutritional, outreach, home-aides system while maintaining the multiservice centers for those elderly who can avail themselves of this service. Home-based services could be coordinated with local welfare departments of parts of title III could match title XX or vice-versa in our rural area. Again this calls for the use of title III funds as incentives to attract other Federal dollars. This could be set up as with ARC funding or model cities funding. The rural areas have been suffering from lack of adequate social service delivery and this could enhance the use of title XX moneys in our area by contributing to the match necessary. It would entail a switch in concept from seed money to incentive money. I urge the committee of Senator Church to investigate this possibility for the adequate provision of homebased services in rural areas.

(4) The lack of coordination of various Federal programs is due in large part to Federal regulations which are ludicrous for use in a rural area. Current issues are in the area of title III regulations on transportation vehicle purchase v. UMTA-FHWA regulations on various transportation programs. These regulations create gaps in service in delivery of transportation and other services in regard to match and eligibility requirements for service. If any coordinated comprehensive service delivery system is to be developed in rural area then restrictive Federal regulations that only inhibit this goal of cooperation must be taken down. The role of the area agency itself is to develop, coordinate, pool untapped resources, and monitor all programs for the elderly in a given area. If other Federal, State regulations are not written with this in mind, then the Older American's Act must reflect the need for this coordination in all of its programs, i.e., title VII, volunteer programs, etc. I urge the committee to look at conflicting rules and regulations and make the Older Americans Act a fair vehicle of the development of coordinated comprehensive service delivery for the elderly in rural areas.

These problems are those which are vital to our rural area of Ohio. There must be input to the committee of these pressing problems to make the Older Americans Act programs a viable segment of service to the elderly in our area, the State, and the United States.