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From the perspective of educational management,

comprehensive educational planning and effective delivery of educational services, this proposal has a great deal of merit. Anyone experienced in working with Federal education programs at the state and local levels would readily admit that the proliferation of such programs places a near impossible burden of paper work and red tape on school administrators. This is especially true in school districts which have limited resources with which to pursue and administer federally-funded projects.

Virtually all nonpublic school "systems" find themselves

in this latter category because of their limited administrative budgets. This is exacerbated by the fact that none of the monies allocated for the administration of presently authorized programs is used to alleviate the nonpublic school administrators' added burdens resulting from involvement in such programs. In short, it costs the nonpublic schools money to participate in these programs.

I do not think that the main question before this Committee should be whether or not consolidation of existing categorical programs is desirable. Rather the question should be how can this best be accomplished without undermining the purposes of previously enacted legislation.

The history of the Federal government's role in

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elementary and secondary education indicates that its involvement has been consistently restricted to those areas of need which were not being adequately met by state and local efforts. The inherent weakness of Education Revenue Sharing, moreover, is that it is based on the assumption that state and local educational authorities now stand ready to meet their responsibilities in fulfilling these needs once they are freed from the morass of red tape inherent in these Federal programs.

This leads me to a much broader concern I have with the concept of Education Revenue Sharing as an appropriate way for the Federal government to help solve the problems of American

elementary and secondary education.

What evidence there is, does

not indicate that the most serious problems of education are a result of over-dominance by the Federal government. If anything, these problems persist and have worsened partially because of the Federal government's inability to have a significant impact on education at the state and local levels. An identical conclusion could be drawn of the states vis-a-vis local school districts.

This point may be demonstrated by examining some of the problems encountered in implementing compensatory education programs funded through ESEA Title I. This program has not had the educational impact which many educators had anticipated.

There

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are many reasons for this not the least of which is the inability of the Federal government to nsure compliancy with the intent of this legislation.

Let me cite one example which illustrates this point.

In the first years of this program, school districts spread the Title I funding so thin that less than $100.00 per child was expended. This problem is treated in the Fourth Annual Report of the National Advisory Council on the Education of Disadvantaged Children as follows: "...many school administrators have spread their limited funds over very large groups; the average Title I expenditure per child during 1965-66 and 1966-67 was $96.00 and $99.00 respectively hardly enough to make a significant difference." This problem is

being overcome only after a vigorous effort by the United States Office of Education in the past three years to effect an adequate concentration of services on the most needy children so that the program would begin to show significant educational results.

A weak Federal role in the implementation of Title I is further highlighted in the conclusions of a study conducted by Washington Research Project and NAACP Legal Defense and Educational Fund, Title I of ESEA: Is It Helping Poor Children? I would like to quote in part one paragraph from the summary of that report.

"In this report we have tried to spell out Title I
requirements and match them against what is actually happening
in many districts. We found that although Title I is not
general aid to education but categorical aid for children
from poor families who have educational handicaps, funds

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appropriated under the Act are being used for

general school purposes; to initiate system-wide programs;

to buy books and supplies for all school children in the system; to pay general overhead and operating expenses ..."

Additionally, Mr. Chairman, it should be noted that the

last two Annual Reports of the National Advisory Council on the Education of Disadvantaged Children recognize these problems and call for a strengthening of the Federal role in the implementation of this program.

Two of the most serious problems currently confronting education are the inequitable distribution of education funds among and within school districts as well as those related to racial discrimin tion. Partially, at least, both of these problem areas are rooted in the decentralized nature of the American school system. Recent state supreme court rulings in California have dramatized the inequitable nature of our present system of school financing. A Federal district court ruling on September 27 concerning segregation problems in the public schools of the city of Detroit followed by the same courts' order to the Michigan Board of Education to develop a metropolitan school district to create an integrated school system demonstrate the relationship between local autonomy in education and the problems of racial discrimination. I find it difficult to understand how a legislative proposal which encourages further decentralization relative to the Federal role can be a viable answer to such problems.

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Finally, Mr. Chairman, I would like to call the

Committee's attention to a recent study by the Harvard Graduate
School of Education, The Effects of Revenue Sharing and Block

Grants on Education, which treats these matters in depth.

I would now like to address myself to the effect of S.1669 on the nonpublic school sector of American education. The history of nonpublic school efforts to obtain public assistance for the performance of a public service to over five million American school children would indicate that Federal involvement in education has been beneficial to their cause. As a minority on the American educational scene, it is interesting that we share this feeling with minority groups within public education. Consequently, we are very wary of any weakening of Federal control over programs authorized by Congress.

1.

The following facts are offered in evidence of our concern:
Throughout most of the twenty-five year history of

the National School Lunch Program more than half of
the states were unable to administer the program for
the nonpublic schools. The Federal government had to
assume this responsibility.

2.

Until the 1970 ESEA amendments consolidating the

NDEA V-A testing program with Title III of ESEA, forty

one states were unable to administer the testing

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