The last sentence of section 4 of the bill should be clarified to indicate whether it is intended to give the Veterans' Administration the authority to withdraw approval from an institution which has been approved by a State agency. There is no antecedent to the words, "If it is found," to indicate by whom the finding may be made. This could refer to either the Administrator or to the State approving agency or to both. The existing law does not specify the authority of the Administrator to withdraw approval from an institution approved by a State agency, although he would, of course, have implied authority to withdraw approval from an institution which had been approved by him but not by a State agency.

The Veterans' Administration believes that, with regard to institutional onfarm courses, it should be given the same authority as is now granted with regard to short, intensive postgraduate courses and correspondence courses; namely, the right to contract with approved institutions for such courses where the Administrator finds that the agreed cost is reasonable and fair and it is suggested that the bill be amended to grant this authority.

At the present time the institutional on-the-farm training programs are being conducted by the various States. The effect of this legislation would be to establish by statute minimum standards governing such programs. It is further believed that it is the intent of the bill to recognize as a full-time program an on-the-farm training program which complies with the standards therein set forth. The Veterans' Administration believes that it is highly important for the Congress to determine whether this program shall be considered as full-time or part-time training. On August 27, 1946, the Veterans' Administration issued an instruction containing the following language:

"For veterans pursuing courses of instruction requiring as part of such course the instructor to come to the veterans' own establishment or farm (as in institutional-on-farm courses), the number of clock-hours of instruction which the trainee receives per week will determine the extent of the part-time course for the purpose of payment of subsistence allowance and tuition."

The effect of this instruction was to announce that the Veterans' Administration considered the institutional on-the-farm program as being a part-time course under the Servicemen's Readjustment Act and, as a result, students would only receive partial subsistence allowances and schools would receive only partial tuition payments. Veterans' subsistence allowances were reduced from $65 per month to $16.25 per month, if they had no dependents and from $90 per month to $22.50 per month, if they had dependents on the theory that 25 clock-hours per week represents, a full-time course which is not on a semester-hour or a quarter-hour basis and the 6 hours per week put in by these trainees is equivalent to one-quarter of that amount. The educational institution would have been paid for tuition on the same basis as any other institution giving the same number of hours of instruction.

Based upon a study of the World War I on-the-farm training rehabilitation program, a policy was developed in 1943 for training disabled veterans under Public Law 16, Seventy-eighth Congress. This policy provided that the veteran could only be put into training where a course of training was written up in such definite terms and consisted of elements so clearly appropriate to the employment objective that the successful completion of the course would indicate satisfactorily employability in the chosen occupation.

The on-the-farm training program was developed to provide:

1. That the veteran to take institutional on-farm course must have complete control of the operation of a farm through ownership, lease, management agreement, or other tenure arrangement.

2. That the farm shall be of sufficient size and suitability for training in all farm-management operations necessary to the particular type of farming.

3. That there should be a veteran's agricultural training committee consisting of representatives of vocational agriculture education and the United States Department of Agriculture agencies which are active in the area. The committee is augmented by adding leading farmers and representatives of other qualified institutions operating in the area. This committee is for the purpose of affording the veteran guidance in technical matters, such as selection of a farm for training, development of the individual training program, and farm practices for the particular arrangement and the particular farm.

4. That the institution shall provide instruction in school for not less than 200 hours per year, not less than 8 hours in any given month.

5. That the institution shall provide instruction on the farm for not less than 100 hours per year, 50 percent of it applicable to the veteran's individual farm, by visits of not less than twice a month.

6. That between the visits of the instructor the veteran will follow instruction, guidance, and assignments of study related to the operation of the farm.

7. That the course of training is to be primarily individual in nature, the teaching concentrated and intensive, the veteran to be taught precisely what he needs to learn to manage and operate his particular farm on the basis of a complete farm and home plan.

8. That the plan should cover one complete livestock cycle and should normally be based upon 12 months of operation. It should include a financial statement, budget of income and expenses, schedule of production and disposal of crops, livestock and livestock products, inventory of livestock, equipment and supplies, statement of family living to be furnished by the farm. It should show clearly and completely the total enterprise in terms of jobs or projects to be accomplished by the operator and his family, what the year's operation will cost, what the family can contribute toward these costs, what income is to be expected, the amount of credit required, and the amount to be repaid at the end of the season. It will be noticed that these are essentially the same criteria as are provided by the proposed bill, expanded somewhat as to detail. The effect of the bill would be to afford courses of a maximum length of 4 years, whereas the period of training under Public Law 16 is generally much shorter, and that for other training on the job is 2 years.

With that kind of farm training plan operating for Public Law 16 trainees, when Public Law 346 was enacted specifically providing for training on the job, it was decided that veterans desiring to train on the farm could do so by enrolling in the same courses which were offered for disabled veterans under Public Law 16 by training institutions which were also approved by the State to give training under Public Law 346.

While the institutional on-farm training may be classified as primarily on-thejob training, on August 27, 1946, the Veterans' Administration's decision, in ffct, classified this training as part-time institutional training because the veteran while on the farm is not under direct instruction or direct supervision except for short periods of approximately 4 hours at intervals of 2 weeks when the instructor calls at the farm to check up on what the student has done on the assignments given at the time of the last preceding visit; to give additional instruction to the veteran and to make further assignments for the next 2-week period.

In contrast to that situation in institutional on-farm training, the veteran training on the job in an employer's establishment is commonly under instruction or supervision by the employer-trainer during each workday. Of course, there are some exceptions to this such as in soliciting or sales work which requires the trainee to operate away from the direct supervision of the employer. However, it must be said that a basic characteristic of all training on the job is that as the trainee progresses he becomes more independent of the instructor or trainer and may properly work away from the presence of the instructor for considerable periods.

Immediately following the issuance of the directive referred to above, opnosition was voiced by persons interested in the program. In line with these objections and with suggestions from some Members of Congress, the directive was rescinded, in this regard, on September 25, 1946, until such time as the particular question might be considered by Congress.

Accordingly, at the present time, the veteran operating his own farm and participating in institutional on-farm training is receiving full subsistence allowance, and the educational institutions involved are receiving their customary tuition charges for the course. Under the rescinded directive, which the Veterans' Administration believed to be a sound administrative measure, such courses would be considered as part-time courses and subsistence allowance and tuition would be paid accordingly.

At the present rate of payment of full subsistence allowance and tuition, it is estimated that the cost of this program for the fiscal year 1948, for each 100,030 veterans in institutional on-farm training, is approximately $117,200,000. If the course had been considered as a part-time course, as determined by the rescinded directive of August 27, 1946, the cost of this training, including tuition and subsistence allowance per 100,000 veterans, would have been $48,345,000.

Averaging this out to unit cost per veteran, it appears that to consider this type of training as full-time training, costs the Government approximately $688.55 more per year per veteran participating in the program. Yet the veteran receives exactly the same amount of training no matter which theory is adopted.

The number of veterans participating in this program has been steadily increasing. On September 30, 1946, there were 54,223 trainees in institutional on-farm training; on January 31, 1947, there were 98,035; on March 31, 1947, it is estimated that there were 130,789.

The amendment intended to be proposed by Senator Lodge is for the purpose of permitting veterans pursuing a farm course under the Department of Education of the State of Massachusetts to pursue such courses under the program outlined by that State, which requires 150 hours of annual instruction, individual or group, plus 250 hours of assigned related home study and a farm-work program equal in time to that customarily considered as full-time employment in farming enterprise (not less than 48 hours per week). Actually, as the amendment is drafted, the standards prescribed by the bill would be advisory only if the amendment were to be adopted, since any regional office of the Veterans' Administration could agree with a State authority to establish an individual on-farm training course and the pattern of uniformity sought to be achieved by the main bill would be destroyed.

It should further be noted that the amendment would recognize in a statute an administrative unit of the Veterans' Administration, the regional office, which unit could be abolished at any time by administrative action. If the Congress should see fit to adopt the proposed amendment, it is suggested that it be changed so that the agreement specified would be between the Administrator of Veterans' Affairs and the State authority, rather than between the State authority and a subordinate office of the Veterans' Administration.

The Veterans' Administration is informed that approximtely 1,650,000 men entered the armed forces from farms. Based on Army surveys it is estimated that from 900,000 to 1,000,000 men intended to be farm operators or to seek farm employment, from 8 to 10 percent of this number indicated a desire for farm employment only. It is believed that 500,000 have a reasonable certainty of having a farm to operate.

In reporting to your committee on the question of ceiling provisions and subsistence allowance rates (May 2, 1947) I pointed out that in the administration of on-the-job training the Veterans' Administration is charged with the conduct of a program designed to help the veteran help himself by acquiring useful and marketable job skills; that we have a double-edged responsibility to the veteran as a recipient of these benefits and to the veteran as part of the taxpaying public. I further pointed out that education and training have not been offered to the veterans simply as rewards but as tools that will enable him to achieve economie and vocational self-sufficiency. I said that in fairness to those other veterans whose circumstances do not permit or require the use of training benefits, and in fairness to all the American people who must pay for their cost, it is our responsibility to safeguard the integrity of the program and make certain that it shall not be diverted from its sound economic objectives and become a windtall. What I said in that report is equally applicable here and it is the position of the Veterans' Administration that to treat courses of instruction involving no more than 6 hours per week as full-time courses would be merely to provide a windfall for those who participate in such programs. I believe that the Congress should also consider in this regard that if this program is determined by statute to be a full-time program calling for the payment of subsistence allowances and tuition, that it will set a precedent whereby State boards of education in the various States could develop similar courses for veterans who operate their own stores or shops, designating such courses as full-time institutional courses. If the proposed legislation is enacted, the Veterans' Administration will be subjected to great pressure to consider such courses as requiring the payment of full subsistence allowance to veteran participants and full tuition to educational institutions offering such courses.

The Veterans' Administration recommends that if consideration be given to this legislation, formal changes herein recommended should be made and that the Congress determine whether this type of training is full-time rather than part-time training for subsistence allowance and tuition purposes.

Due to the urgent request of the committee for a report on this measure, there has not been sufficient time in which to ascertain from the Bureau of the Budget

the relationship of the proposed legislation to the program of the President. A supplemental report will be furnished later in that connection.

Sincerely yours,

OMAR N. BRADLEY, General, United States Army, Administrator.

Senator MORSE. All right, Mr. Stirling. Mr. STIRLING. Mr. Chairman, there are only two problems facing the Veterans' Administration concerning institutional on-farm training for veterans and these have arisen since August 27, 1946, when the Administrator ruled that for veterans pursuing courses of instruction requiring as a part of such course the instructor to come to the veteran's own establishment or farm, as in institutional on-farm courses, the number of clock-hours of instruction which the trainee receives per week will determine the extent of the part-time course for the purpose of payment of subsistence allowance and tuition.

The effect of this instruction was to announce that the Veterans' Administration considered the institutional on-farm program as being a part-time course under the Servicemen's Readjustment Act and, as a result, students would only receive partial subsistence allowances and schools would receive only partial tuition payments.

Veterans' subsistence allowances were reduced from $65 per month to $16.25 per month, if they had no dependents and from $90 per month to $22.50 per month, if they had dependents on the theory that 25 clock-hours per week represents a full-time course which is not on a semester-hour or a quarter-hour basis and the six hours per week put in by these trainees is equivalent to one-quarter of that amount. The educational institution would have been paid for tuition on the same basis as any other institution giving the same number of hours of instruction.

Immediately following the issuance of this instruction, opposition was voiced by persons interested in the program. In line with these objections and with suggestions from some members of Congress, the order was rescinded in this regard, on September 25, 1946, until such time as the particular question might be considered by Congress. Therefore, the two questions before the Congress are:

1. Whether schools ought to be paid tuition based upon all the time which the veteran spends on his farm as well as the time spent in school, or based solely upon the time the veteran spends in school plus the time the school gives instruction to the veteran on his own farm.

2. Whether the veteran, pursuing institutional on-the-farm training on his own farm, shall be entitled to full subsistence allowance, $65 or $90 per month, despite the fact that under the law subsistence allowance is payable only where the veteran is pursuing the course of training in which he is enrolled.

If the bill which is now before your committee becomes a law, the Veterans' Administration would be required to pay tuition for a fulltime course and the full subsistence allowance rate of $65 or $90 per month.

Senator MORSE. Let us take a hypothetical example. Here is veteran A. He decides that he wants to learn something about dairying, so he goes to farmer B and he says, "I want to start in on this farm and I want to learn dairying."

Question No. 1: Can farmer B, without having any connection with any agricultural institution or school of any kind, hire veteran A and then have veteran A petition the Veterans' Administration, being a single veteran, for $65 subsistence?

Mr. STIRLING. If that farmer, Mr. Chairman, is recognized by the approving agency of the State as having a facility which is qualified and equipped to train this boy who leaves his farm to take on dairying, he may elect the course which this farmer offers and while in training he would be considered by the Veterans' Administration as in training on-the-job and would receive $65 or $90 a month, subject to the limitations of $175 and $200.

Senator MORSE. All right; now farmer B has one of the finest and largest dairy farms in the State. He goes to the Veterans' Administration in the State and says, "I want to apply to have my farm approved now by the Veterans' Administration as a training farm."

Mr. STIRLING. He doesn't, Mr. Chairman. He goes to the approving agency of the State, which has nothing to do with the Veterans' Administration.

Senator MORSE. All right, he goes to the approving agency of the State, whatever agency it is that has charge of the on-the-job training program for the State, and says, "I want you to list my farm as a training farm for such veterans as I need to employ," and they do, because it is a very high type of dairy farm, and he trains only those whom he needs to help operate his farm.

Now he needs 20 men to operate it, so he hires 20 veterans, all wanting to learn the dairying business. They get $65 from the Government and he pays the regular wage that he has to pay for dairy men, but it is within the $175 bracket. Is that all right?

Mr. STIRLING. Yes, sir.

Senator MORSE. That is what this bill purports to accomplish?

Mr. STIRLING. No, sir; this bill has to do with a boy who has his own. farm; he has complete control of his own farm.

Senator MORSE. That is my next hypothetical question, but under my first hypothetical question this bill covers that.

Mr. STIRLING. That is correct.

Senator MORSE. Now my second hypothetical question is veteran X. He thinks he wants to go into the dairy business, so he buys a farm and then he goes to the State agency that has charge of the on-the-job training program. He says, "I bought a 160-acre farm out here. I am running 20 Guernsey milk cows on it. I am learning by trial and error, but I have got veteran A, who is going to help me; he is a married veteran, and I want $90 a month and the supervisor of my farm is going to be a next door neighbor." Can he do that?

Mr. STIRLING. I am not so sure, Mr. Chairman. I believe if that boy did what you have said in your hypothetical question, the State approving agency would refer him to that agency in the State which is offering a course of institutional on-the-farm training. He would go to that agency and apply for this course, which is usually a 4-hour a week course, in schooling.

Senator MORSE. But this neighbor happens to be the instructor in this course and he has to do his instructing morning and evening for this veteran who lives next door. This veteran says, "The one thing I don't like is to be enclosed within four walls. I have an obsession