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gram consolidation is not new; in fact, on February 3, 1968, in Chicago, tho Council of Chief State School Officers endorsed the concept and agreed to make every effort to implement the program in fiscal year 1969. Thu program consolidation mission was aborted shortly after July 1, 1968 and the concept quietly faded away only to appear again this March under the misguided title of Special Revenue Sharing.

Revenue Sharing and Program Consolidation Are Not The Same

The concept of revenue sharing for education recognizes that state and local governmental agencies do not have access to sufficient fiscal resources to sustain programs and confront the pressing problems and priorities to which they must respond in order to best meet the needs of their constituencies. The intent to provide additional fiscal resources through revenue sharing precludes the identification of categories, priorities, restrictive regulations, etc., at the national level. This concept of revenue sharing could come reasonably close to the "General Aid" program which educators have been seeking from the Congress.

Thus, the distinction between Revenue Sharing and Program Consolidation clearly indicates that they are entirely separate programs designed to respond to completely different sets of circumstances and any effort to suggest that the programs are synonymous, or intended to replace one another, is simply

fraudulent.

Is The Proposed Consolidation Appropriate?

If program consolidation is to be resurrected, and if the resurrection is an expression of genuine intent to reduce the duplication, fragmentation, and administrivia associated with categorical grant-in-aid programs, then the substance of the Special Educational Revenue Sharing Act bears closer examin

ation. First, the name of the Act must be changed to the "Program Consolidation Aot" beuntiae it does not have any relationship to ravonuo sharing. Tho intent to consolidate the administration of compatible programs to simplify application, management and reporting requirements remains a very worthwhile objective; however, caution must be exercised in protecting the fiscal resource and categorical purpose of each program to be included in the consolidation package. The Special Educational Revenue Sharing Aot (Program Consolidation Act) proposed by the U. S. Office of Education contains a rather illogical hodgepodge of programs which do not afford promise of reducing administrative overburden nor the protection of the fiscal and program integrity of each of the parts. The most glaring example of inappropriate consolidation is the inclusion of parts of Public Law 874 (School Assistance in Federally Affected Areas) in the proposed Act. In view of the attitudes expressed by the National Administration and the Congress in recent years toward P. L. 874, the fact that the states have never administered nor received support funds to administer P. L. 874 and the fact that P. L. 874 does not contain categorical constraints for special programs, must cause many to wonder why P. L. 874 was ever considered for consolidation in the proposed Special Educational Revenue Sharing Act (Program Consolidation Act). It does seem much more logical, keeping in mind the purpose of program consolidation, to package those existing categorical programs which have similar educational purposes or objectives.

Will The Proposed Consolidation Be Complete?

Since the expected outcome of program consolidation is improved efficiency and effectiveness in directing resources to problems, some consideration must be given to programs such as those for vocational education which are presently administered by innumerable federal and state agencies. The consolidation of

similar programs and placing them under appropriate administrative authority, that is, educational, egénutes when the purpose is educational, in in kapping with the basic intent of program consolidation. As it now stands, the Special Education Revenue Sharing Act (Program Consolidation Act) includes only a portion of the categorical aid presently set aside for occupational programs.

Proposed Matching Requirements and Plans for Advanced Funding

The provision for the removal of matching requirements in program consolidation is very desirable, as it will remove some difficult, non-productive accounting nightmares and will not require state and local educational agencies to sacrifice priorities in order to redirect needed resources just to have access to federal funds. The provisions for advanced funding and the removal of arbitrary time constraints from the expenditure period for appropriated federal funds are both very constructive and will solve many problems in planning, program development and program operation for state and local education agencies. The need for timely and sufficient appropriations ahs been fervently requested for many years and the removal of expenditure time constraints is certainly more in keeping with the educational intent of categorical legislation. Arbitrary fiscal year and grant period time constraints for expenditures all too often prevent the recipient of funds from being able to mobilize and sustain resources for a long enough period of time to really make substantial progress in resolving a problem. The advantage is that problem solving, not time, becomes the most important focal point.

Who Shall Administer This Act?

The Special Revenue Sharing Act (Program Consolidation Act) contains a provision which would have the Governor in each state decide which of the state agencies shall administer funds under the proposed Act. The rationale for this provision is not provided, although the same language seems to be

included in what has come to be called the "General Revenue Sharing Act" proposed by the President. It is incongruous that an Act which purports to reduce bureaucratic entanglements would ignore agencies established by state government for the precise purpose of achieving the intent of the legislation! Why would the U. S. Office of Education and the U. S. Congress choose to circumvent a State Department of Education which is governed by a State Board, duly elected by the citizens of the State, and a State Superintendent who serves at the pleasure of the elected Board? This particular provision is difficult to analyze because no apparent method of reason produced it; however, the potentially undesirable consequences of such a provision are evident and should be sufficient to cause it to be changed to the extent that State Educational Agencies become responsible for the administration of educational grants.

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Conclusion

In conclusion, Program Consolidation and Revenue Sharing are two entirely seperate programs. The financial plight of education becomes more severe each year and it behooves all governmental agencies to very seriously confront the problem and develop programs that can realistically offer promise of relief instead of merely redesigning administrative procedures to manage existing programs which have never been funded at the level needed to get the job done. The emphasis on both "Program Consolidation" and "Revenue Sharing" is intended to emphasize, and re-emphasize, the need for continued federal support in the form of categorical aid and the need for new federal revenue support in the form of general aid to education. Revenue sharing is still in the formative stages and many questions remain to be answered regarding apportionment formulae, methods of allocation, administrative policies, etc., before we can be assured that it is the appropriate vehicle for providing

the relief so badly needed in education.

Basic concerns about Revenue Sharing

Include the ponabble discrimination against atatos with mall populations, vast areas of government-owned lands and tax structures which do not include state income, ostate, corporate, etc. taxes. The federal government should not be permitted to pass discriminatory legislation which could force state and local governments to alter their methods of taxation nor impose penalties because of per capita wealth and size of population. It is imperative that

State Education Agencies have the opportunity to review more information about Revenue Sharing as the legislation is being prepared. In the interim, we must be cautious of those proposals which are offered as the panacea lest we discover the same inadequate programs brilliantly bound with a new ribbon.

RAVELL LARSON

„Oprema e tantas of 2012, Nstruction
Nevada State Department of Education
Jason Co, Nevada

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