First, title I, or whatever it ends up being called when a final decision is made, should continue as a categorical program with very clear guidelines for States, local educational agencies, and schools, covering distribution and service objectives.

While title I has served as an effective tool over the past 8 years and, as noted earlier, has made educators and citizens more aware of the possibilities of providing more effective educational opportunities for the disadvantaged, the long-range goal of allocating services to pupils on the basis of their educational needs is, I would submit, far from being achieved.

Indeed, as we noted before in dealing with the question "Where would our schools be today without title I?" In terms of serving the educationally disadvantaged and providing additional funds to hardpressed urban and rural districts for that purpose, it has been an eminently successful mechanism.

If annual appropriations of $1.5 billion had been distributed as general aid since 1965 instead of as categorical aid focused on the disadvantaged, would those resources have accomplished what title I has achieved?

I am persuaded that the answer to that question has to be "no" and that the Nation clearly requires a strong Federal continuation of compensatory aid.

Strong Federal initiative in this area is necessary for two reasons. First, as noted already, those districts that benefited most from title I would probably not get the help they needed from their States. The studies at Syracuse have clearly demonstrated that fact.

Second, the immense problems facing core cities in particular are not local or even State-generated conditions. The degenerating fiscal plight of older cities and the character of their urban populations are problems created by national economic conditions and the mobility patterns of the general population, and as such they deserve national responses and not simply State and local responses.

Recommendation No. 2: Title I should be fully funded. I am sure you have heard that one before. Nevertheless, if we look at the marginal increases in resources that have been placed upon disadvantaged youngsters, those resources fall far short of the need.

Title I has certainly not been a failure, it has succeeded admirably to serve one of the legislative purposes set forth in the act; namely, to assist school districts in meeting those extra costs that are brought on by heavy concentrations of educationally disadvantaged students.

Recommendation No. 3: Title I should be used as a lever to insure wide participation in planning at the local level. Specifically, this means that parent advisory councils should continue to be required and comparability reports should occur annually and be readily available to parents and other citizens.

As Professor Kirst has eloquently stated, the implementation strategy of Federal aid has been essentially top-down. Federal and State standards supposedly were designed to assure that local education agencies responded to Federal categorical priorities.

Program negotiations were conducted among professional administrators at all three levels with little involvement of parents, teacher organizations, students, and community agencies. This top-down strategy of regulations and guidelines contains neither the sanctions nor incentives sufficient to accomplish the categorical purposes of Federal aid in general and title I in particular in all 50 States.

Moreover, the top-down strategy does not have sufficient leverage to reorient classroom practice or to insure that money always reaches the intended targets.

A potentially more effective system would be to reverse the flow of sanctions and incentives substantially so that students, parents, and teachers with the desire to effect changes would be provided with access to the means to accomplish national purposes.

For example, the difficulty of determining and assessing comparability over the past few years has become one of the knottiest problems associated with the administration of title I. Neither the typical State nor the USOE has the way and often not the will to really determine and enforce comparability standards that both fulfill Federal guidelines and yet remain flexible enough to adjust to local conditions.

A potentially more effective method of auditing school district behavior in terms of comparability requirements would be to place responsibility for the auditing function in the hands of local citizens. To accomplish that approach, data such as that contained in the current comparability reports would have to be compiled annually and made available.

Indeed, it should be a routine part of a comprehensive management information system and should be readily available for examination and analysis by parent groups and other interested citizens.

Recommendation No. 4: State level and school district level administration of title I should be governed by flexible administrative patterns designed to meet guidelines and objectives through a variety of means. The Federal role should be used as a lever to get States and local districts to plan more effectively for the allocation of resources and the educational experiences of disadvantaged pupils.

One of the clearest conclusions drawn from Professors Berke and Kirst's analysis in "Federal Aid to Education: Who Benefits? Who Governs?" is that States and local school districts differ markedly in their ability and willingness to plan effectively to meet the educational needs of their citizens.

The Federal role in dealing with States and local education agencies should reflect those differences. Considerable latitude should be given to those States and local districts that engage in some form of comprehensive planning or priority setting.

States might be permitted, for example, to define high need pupils in a manner different from the Federal Government, say, by the use of achievement test scores. Similarly, the Federal Government might require that States move toward systems of assessment of performance of their educational programs in order to enjoy greater latitude in allocating resources.

States might also be permitted to merge title I funds with State compensatory funds and distribute them as one package. Local districts might be permitted to develop a system to insure comparability that is different from the USOE comparability report as long as the general intent of the legislation is clearly followed:

For example, one of the clearest observations we found made after talking with administrators and teachers at the local level is that it makes very little difference to them what the source of funding is for resources; as a matter of fact, very often they don't know.

It was a striking finding to us when we got into elementary schools in New York City, for example, to find that very often even principals

didn't know whether a particular program had been funded by New York State or by title I. More often than not, they had submitted the same proposal to two or three different funding sources, but what is important to them is that they get the resources from someplace to do what they wanted to do.

In other words, what counts is the total resources and not the mix, and it seems that it can be handled that way in some districts and some States.

On the other hand, States and districts that do not engage in a planning process approved by the USOE should have allocations to individual districts and perhaps even schools determined by the USOE. In short, if local districts and States want local control over decisionmaking concerning resource allocations to the disadvantaged, they must indicate their willingness and ability to exercise that control in terms of national as well as local objectives.

Now those four recommendations, I think, conclude my statement this morning, and I certainly hope it has been useful to you.

Chairman PERKINS. Thank you, Doctor, for an outstanding state

ment.

We will now hear from Dr. Michael Kirst so that those members who will be joining us very shortly will have an opportunity to question both of you gentlemen.

Go ahead, Dr. Kirst.

STATEMENT OF DR. MICHAEL W. KIRST, PROFESSOR OF EDUCATION AND BUSINESS ADMINISTRATION, STANFORD UNIVERSITY

Dr. KIRST. Thank you.

My statement is based in part on our extensive study on Federal aid to education.

Chairman PERKINS. Identify yourself, please.

Dr. KIRST. I am Michael W. Kirst, assistant professor of education and business administration at Stanford University.

I want to move from Dr. Goettel's general findings to my own views of some recommendations. I want to make five points in brief, and then I will go back over them in some detail.

Chairman PERKINS. Without objection, your prepared statement will be inserted in the record.

[The statement referred to follows:]

STATEMENT OF MICHAEL W. KIRST, STANFORD UNIVERSITY

REVISIONS IN FEDERAL COMPENSATORY EDUCATION: A STRATEGIC VIEW

Mr. Chairman, I am pleased to testify on your bill (H.R. 69). I support the objectives of your entire bill. I would like to start by going into detail on ESEA revisions. The preceding testimony by Dr. Goettel summarizes the findings in the book "Federal Aid to Education: Who Benefits, Who Governs." I want to move from these findings to some specific recommendations.

The Administration's theory of "New Federalism" has some good components but should not be adopted in toto in education. I favor a mix of grant consolidation (or special revenue sharing) and the present categorical approach. Our studies indicate that neither extreme is desirable-total reliance on bloc grants with no federal strings or the present federal maze of categories. Let me begin with the largest program-Title I ESEA.

A reform of federal compensatory education should begin with the original objectives of Title I ESEA and consider whether these objectives are: a) still in the federal interest, b) can be accomplished and implemented. c) interrelated with other federal compensatory programs that are now directed at the same

objectives as Title I. Much of the current discussion mixes up strategic thinking (especially about "propor and priority" objectives) with tactical mechanisms (such a grant consolidation) to accomplish the objectives. So let us go back to the beginning and list the objectives. If one believes these original objectives still apply, then some continued categorical restrictions are necessary to implement them. On the other hand, if most of the original objectives are no longer desirable or considered possible to implement, then a bloc grant mechanism with few federal strings is appropriate.

The original objectives were a result of the political bargaining and coalition process. Many of them were added as political concessions so that ESEA I could appeal to as many interest groups as possible. It should be remembered that up to 1965 large scale federal aid had been defeated in Congress and reputable political scientists predicted a decade of political deadlock. Moreover, the Congress scrutinized Title I carefully, but let the rest of ESEA pass with only cursory review.

As it emerged from the political process Title I embodied the following objectives:

1. A fiscal redistribution device to channel more money to the most financially needy schools and school districts. A recent book by the writer shows Title I has succeeded on the school district level. We do not know the situation at the school level because of the inadequacy of education accounting systems. School by school data is not kept.

2. Increased academic attainment of disadvantaged children through reforms in school processes. In 1956 USOE contended that if Title I regulations prevented schools from using "more of the same" instructional techniques or merely increasing teacher salaries it could improve academic attainment.

3. Support for nonpublic schools to slow down their fiscal collapse and enrollment declines. This objective was crucial in gaining Congressional support through the "child benefit" theory.

4. Improvement of the "capital embodiment" of disadvantaged children through better health clothing nutrition programs. In effect Title I could make up for some of the deficiencies of the federal-state welfare system. The schools were envisaged as a one stop comprehensive social service delivery mechanism.

5. Provision of so much federal aid that it would be a "sugar solvent" to foster desegregation. School districts would rather integrate than lose the federal largesse.

6. A national symbol of the national awareness and priority for disadvantaged and minority children. In this way, Title I would galvanize state compensatory programs and a rethinking of local priorities, so that the disadvantaged received special assistance in the basic as well as the compensatory program.

It is possible to construct a case that most of these objectives are now irrelevant to Title I or could be discarded without any undesirable consequences. The symbolic value of Title I (No. 6) could give way to the new symbolism of "benign neglect." Integration is now enforced by civil rights laws and as a Southerner once remarked, "You can take the black kids and the federal money or you can just desegregate the kids." Objective No. 4 might be handled by welfare reform and such things as enlarged school lunch/breakfast appropriations. Aid to nonpublic schools (Objective No. 3) might be accomplished by federal tax credits to individuals. The present categorical constraint would no longer be needed to attract Congressmen with large nonpublic school constituencies.

This leaves objectives 1 and 2. We could argue that objective 2 is impossible to attain through federal aid. The federal/state administrative system inherently lacks sufficient federal sanctions/incentives to bring about school reform. Moreover, we are just as uncertain about what instructional and related services are effective with the disadvaantaged child in 1973 as 1963. In effect, the age of school reform is in limbo anyway. Maybe the best we can do is restrict Title I to a fiscal weighting factor and let the rest of the objective fade away. The only objective would be No. 1.

Such a view would lead one to fine tuning the distribution formula for bloc grants so that it stressed equity and to expunging compensatory education from the statute books and federal lexicon. If ESEA's various titles were merged with vocational education, handicapped, impact aid, etc., one would want to be sure the bloc grants were directed in the same relative amounts at the school districts and states with large numbers of disadvantaged children as Title I now does. A slightly more aggressive federal stance would be to preserve comparability among schools. An even more aggressive stance would be to use this "pot of consolidated categories" as part of the incentive for reorienting state aid

systems to meet the Serrano criterion. However, if we focus on objective 1, we can sidestep most of the complexities and inadequacies of the delivery mechanisms for targeting aid to the special education needs of disadvantaged children.

A PREFERRED STRATEGY

My own values lead me in a different direction. Our study demonstrates that we can make a federal compensatory program reach its intended beneficiaries and provide comprehensive programs. I favor the retention of objectives 1, 2, 4, and 6. Integration (objective 5) need not be tied explicitly to Title I given the existing court decisions and federal civil rights laws. The problems of parochial schools are best dealt with through federal tax credits or perhaps not at all.* Although I want to retain many of the original objectives of Title I, I also favor large scale federal grant consolidation. Indeed such a consolidation will provide a more effective mechanism for making compensatory education effective. Consequently, ESEA should not be renewed in its present form.

But let me start by justifying the "proper" objectives for Title I ESEA and then move to the subsidiary issues of categorical mechanisms and coordination of all federal funds. An explicit focus on compensatory education is probably needed to justify school by school comparability as part of objective 1. Other fiscal formulas could get the same amount of money to the district level as does Title I, but the basic rationale of compensatory education requires school by school comparability. You cannot have compensation without having an equal base at each school so that federal funds provide "more than equal" for the disadvantaged. All our studies reveal that the schools with the greatest needs have the least amount of money allocated to them by the central office.

While we have little established technical knowledge on specific instructional approaches that "work," we do have indications of what doesn't work. For instance, merely increasing teachers' salaries, adding more professional personnel, and diluting funds through general aid is probably ineffective. Consequently, on objective 2 I would preserve such current categorical restrictions as: Concentration of funds at the level of 1⁄2 state average on disadvantaged children (as distinct from not following the money after it reaches the school system); parent participation through councils at each Title I school; availability of information on local compensatory strategies including performance data for each Title I school; comprehensive programs for each child that are more than piecemeal remedial efforts; school comparability mentioned obove.

Many of the other categorical restrictions and guidelines could be eliminated from Title I. This would simplify the statute and strengthen enforcement of the crucial restrictions.

I would leave objective 4 permissive with school districts-they can use compensatory money for capital embodiment if there is a local need. I remain distressed by the inadequate health, clothing, and food services provided to children in many of our states. I see no indication that the administration's 1973 proposals will do anything to reform welfare. Title I will still need to be used in some districts for the basic necessities of a child's life.

I also believe objective 6 is still important. Recently, several states have started compensatory programs and several others are contemplating them. One of those in the latter category is Florida where I have recently assisted in a school finance revision. The existence of an explicit federal compensatory program is crucial for giving legitimacy and momentum to the political forces supporting such a Florida initiative. Repeal of Title I with no replacement at the federal level would give an enormous boost to the opposition. A federal incentive for complementary state programs would even be better. As of now Federal compensatory money does not reward states that reinforce the limited federal effort with their own compensatory funds. This would be part of a differential state strategy I will stress later.

A REVISED DELIVERY SYSTEM

Given the strategy above, grant consolidation or some form of special revenue sharing would be useful as an adjunct to a streamlined Title I. Currently very limited federal auditing, enforcement, and monitoring resources are spread thinly over too many complex categorical programs. Moreover, the information requirements are stupendous for parents, legislators, lawyers, and state governors to oversee and to understand the present system. A single state bloc grant

Any Congressional desire to preserve aid to nonpublic schools through federal grant mechanisms will require categorical restrictions. Our studies clearly indicate this.