individualized care plans for foster children, and periodic review of the appropriateness of the foster care placement. In each of these instances, in our view, it is vital that other State agencies which deliver services to the target population be involved, particularly in the case of disabled children. To cite just one example of why this involvement is so vital, consider the fact that Federal law currently mandates individualized care plans for disabled children served under the Education for All Handicapped Children Act, the Developmental Disabilities Act, the Vocational Rehabilitation Act, and the Child Referral provisions of the SSI program. One child may very easily be receiving services under two or even three of these programs. It is vital that they be coordinated.

We, therefore, recommend that the State plan be required to identify other interested agencies and specify appropriate mechanisms to assure that interagency cooperative efforts are undertaken.

6. Limitations

In order to assure that the dramatic expansion of Title IV-B funding recommended by the Committee serves to expand services, rather than refinance currently state-supported activities, a number of statutory limitations are required.

First, there must be a prohibition against using any new Title IV-B funds to pay for basic foster care maintenance-room, board, clothing, etc. Further, States now using only a portion of their Title IV-B allotment for maintenance payments should be prohibited from increasing those payments.

Second, there must be a carefully drawn requirement that States maintain their level of fiscal effort for child welfare services at a level of at least equal to the States' expenditures for such services in fiscal year 1977, adjusted annually by a cost-of-living factor.

Medical or remedial care, unless it is an integral but subordinate part of a child welfare service, should not be eligible for Title IV-B support.

Room and board, except for emergency shelter or respite care for 30 days or less, should be excluded from payment under Title IV-B.

Finally, payment for educational services which the public schools are obligated to provide under State or Federal law to all children should be prohibited under Title IV-B.

7. Maintenance payments in public group homes and child care facilities The bill introduced by Representative Miller of California would allow payment of Title IV-A foster care maintenance funds to publicly-operated facilities which care for twenty-five or fewer children. Such facilities, provided they have twenty-five or fewer children, are termed "group homes" under the bill.

While we have no serious quarrel with an extension of Title IV-A eligibility to children in small, public facilities, we must object in the strongest terms to calling twenty-five-bed facilities "group homes." A facility for twentyfive children can only be considered an institution.

The Keys amendment, sponsored by Ms. Keys and Mr. Brodhead, and enacted by the 94th Congress, defined public community residences and group homes for purposes of SSI as facilities with sixteen or fewer residents. This is the same number which the Medicaid program utilizes.

It is the largest possible number which can be considered a group home. To establish a larger limit of twenty-five in another Title of the Social Security Act strikes us as a dangerous precedent.

8. Voluntary foster care placement

We would support an elimination of the current requirement in Title IV-A that foster care placement be adjudicated.

Given appropriate administrative due process, the involvement of the courts can be both unnecessary and counter-productive.

9. Adoption subsidies

We would like to see a program of adoption subsidies for handicapped and other hard-to-place children authorized under Title IV-A. There are a sig

nificant number of children who are needlessly institutionalized or who continue to reside in foster care settings who are technically available for adoption but who are difficult to place because of a handicapping condition, behavioral problem, age, etc. State agencies should have the ability, supported by Federal funds, to move such children into adoptive homes by providing prospective adopted parents with the assurance that an adoption subsidy will be available to assist them in meeting the additional expenses of these hard-to-place children.

Thank you again for the opportunity to present this statement.

Mr. BRODHEAD. Thank you very much, Mrs. Everitt.

Mr. Coughlin?

Mr. COUGHLIN. I have a full statement. I would like it entered in the record and I will summarize it.

Mr. BRODHEAD. Without objection, so ordered.

STATEMENT OF THOMAS COUGHLIN

Mr. COUGHLIN. My name is Thomas Coughlin. I appear before you to present the views of the National Association of Coordinators of State Programs for the Mentally Retarded on proposed amendments to legislation authorizing the Federal/State social services program, Title XX: Supplementary Security Income Benefits, title XVI, and the child welfare program, title IV-B.

The membership of our association consists of the designated officials in the 50 States and territories who are directly responsible for the provisions of residential and community services to a total of over one-half million mentally retarded children and adults.

As a result, we have a vital stake in a variety of Federal health, education, and social welfare programs. In recent years, as States have begun to emphasize the development of a wide range of residential and daytime alternatives to large, public operated institutions, the number, scope, and complexity of Federal assistance programs impacting on State mental retardation agencies has increased tremendously.

Of particular relevance to the subcommittee's interests is the fact that roughly 91 percent of HEW's anticipated expenditures on behalf of mentally retarded citizens in fiscal year 1977 will be obligated for income maintenance, social service, and medical assistance payments authorized under the various titles of the Social Security Act.

This afternoon, I would like to discuss several critical problems facing State mental retardation officials as they attempt to appropriately utilize existing Federal resources.

In addition, I plan to briefly outline some of the steps which this subcommittee might take to assist States which are seeking to develop community-based alternatives to large, congregate care facilities for mentally retarded children and adults.

In its recommendations on the First Concurrent Budget Resolution for fiscal year 1978, the House Ways and Means Committee recommended that the funding for child welfare services under title IV-B of the Social Security Act be increased to $209.5 million.

The committee explained that it intends to give serious consideration to reporting legislation which would convert title IV-B into an open-ended, entitlement program with a statutory spending ceiling, similar to title XX.

Subsequently, Congressman George Miller introoduced a bill, 5893, which is intended to accomplish this purpose.

H.R.

The association would like to offer several general comments on family care programs for the mentally retarded and suggest some specific approaches to expanding and reshaping the existing Federal/State child welfare program so that is is compatible with the States' goal of minimizing the need for institutional services.

In recent years, more and more States have developed specialized family support and foster placement programs for the mentally retarded in an attempt to prevent unnecessary institutionalization and provide a normal living environment for retarded children and adults.

In the State of New York, for example, the department of mental hygiene is currently engaged in an effort to reduce the number of mentally retarded residents in State-operated institutions from 19,284 to 10,500 over a 5-year period.

One of the most important elements in our current plans is to expand the number of children and adults in the department's family care program by approximately 3,500 persons.

In 1970, the New York Department of Mental Hygiene had 1,259 mentally retarded persons placed in family care homes. Today, we have approximately 4,500 enrolled at an annual cost to the State of $7.9 million, excluding all SSI entitlements and reimbursements for out-of-home services and transportation.

By 1981, we plan to have 8,000 retarded persons placed in family care homes across the State at an annual cost of roughly $20 million.

New York State is not alone in its efforts to expand and strengthen services to mentally retarded persons living in either the home of their natural family or in foster homes. Michigan, Pennsylvania, and the State of Washington also have developed creative programs to provide more appropriate, homelike living situations for the retarded.

The single State agency designated to administer the title IV-B program should be permitted to contract with other public and private, nonprofit agencies for the provision of specified child welfare services.

In many States, including New York, responsibility for furnishing specialized family support and foster care services on behalf of mentally retarded persons rests with the State mental retardation

agency.

Unless provision is made in the legislation for an effective authority, mentally retarded individuals, especially those with severe handicapping conditions, will be excluded from the benefits of increased Federal support for child welfare services.

Not only would retarded persons and their families be denied access to much-needed services, but a major opportunity to reduce. the demand for institutional care would be missed.

The inclusion of contractural authority in title IV-B would be entirely compatible with the present purchase of service arrangement under title XX of the Social Security Act.

Such a provision simply recognizes the complexity involved in delivering family support and foster family services and the resultant

need to give the States considerable flexibility in how they organize to accomplish this mission.

Another issue we would like to touch on-and this may sound different from many of the other speakers today-is that we would strongly support revised title IV-B language which would make clear that services to the severely handicapped and their families is one of the statutory goals of the expanded child welfare program. We believe that Congress should begin by drafting a clear set of goals for the revised IV-B program. These goals should then be reflected throughout the remainder of the legislation.

The revised title IV-B language should make it clear that services to severely handicapped persons and their families is one of the statutory goals of the expanded child welfare program.

Past experience with Federal legislation indicates to us that human service programs frequently are not made available to severely handicapped persons unless explicit provisions are incorporated in the basic statutory authority.

For this reason, we urge members of the subcommittee to critically examine the provisions of existing law and the proposed amendments to assure that services to the mentally retarded and other severely handicapped individuals are allowable under the expanded child welfare authority.

I think I would just as soon stop now without taking up too much time. My statement will stand on its own.

[The prepared statement follows:]

PREPARED STATEMENT OF THOMAS A. COUGHLIN, DEPUTY COMMISSIONER, NEW YORK DEPARTMENT OF MENTAL HYGIENE FOR THE NATIONAL ASSOCIATION OF COORDINATORS OF STATE PROGRAMS FOR THE MENTALLY RETARDED, INC.

Mr. Chairman, and distinguished members of the Subcommittee, I appreciate this opportunity to appear before you to present the views of the National Association of Coordinators of State Programs for the Mentally Retarded on proposed amendments to legislation authorizing the federal/state social services program (Title XX), Supplementary Security Income benefits (Title XVI), and the child welfare program (Title IV-B).

The membership of our Association consists of the designated officials in the fifty states and territories who are directly responsible for the provision of residential and community services to a total of over 2 million mentally retarded children and adults. As a result, we have a vital stake in a variety of federal health, education and social welfare programs. In recent years, as states have begun to emphasize the development of a wide range of residential and daytime alternatives to large, publicly-operated institutions, the number, scope and complexity of federal assistance programs impacting on state mental retardation agencies has increased tremendously. Of particular relevance to the Subcommitte's interests is the fact that roughly 91 percent of the HEW's anticipated expenditures on behalf of mentally retarded citizens in FY 1977 will be obligated for income maintenance, social service and medical assistance payments authorized under the various titles of the Social Security Act.

This morning I would like to discuss several critical problems facing state mental retardation officials as they attempt to appropriately utilize existing federal resourcees. In addition, I plan to briefly outline some of the steps which this Subcommittee might take to assist states which are seeking to develop community-based alternatives to large, congregate care facilities for mentally retarded children and adults.

A. CHILD WELFARE SERVICES

In its recommendations on the first concurrent budget resolution for FY 1978, the House Ways and Means Committee recommended that the funding

for child welfare services under Title IV-B of the Social Security Act be increased to $209.5 million. The Committee explained that it intends to give serious consideration to reporting legislation which would convert Title IV-B into an open-ended, entitlement program with a statutory spending ceiling, similar to Title XX. Subsequently, Congressman George Miller (D-Calif.) introduced a bill (H.R. 5893) which is intended to accomplish this purpose. The Association would like to offer several general comments on family care programs for the mentally retarded and suggest some specific approaches to expanding and reshaping the existing federal/state child welfare program so that it is compatible with the state's goal of minimizing the need for institutional services.

In recent years, more and more states have developed specialized family support and foster placement programs for the mentally retarded in an attempt to prevent unnecessary institutionalization and provide a normal living environment for retarded children and adults. In the State of New in an effort to reduce the number of mentally retarded residents in state operated institutions from 19,184 to 10,500 over a five year period. One of the most important elements in our current plans is to expand the number of children and adults in the Department's Family Care Program by approximately 3,500 persons.

In 1970, the New York Department of Mental Hygiene had 1,259 mentally retarded persons placed in Family Care Homes. Today, we have approximately 4,500 enrolled at an annual cost to the state of $7.9 million (excluding all SSI entitlements and reimbursements for out-of-home services and transportation). By 1981, we plan to have 8,000 retarded persons placed in Family Care Homes across the state at an annual cost of roughly $20 million.

New York State is not alone in its efforts to expand and strengthen services to mentally retarded persons living in either the home of their natural family or in foster homes. A few brief illustrations may help to underline this fact: Michigan supports a network of specially licensed Family Care Training Homes for the mentally retarded. The basic costs of room and board for most. retarded foster home residents are met through supplementary Security Income payments, while the extraordinary costs of providing the in-home training and habilitation services required by these severely handicapped clients is paid for out of state mental health funds.

In Pennsylvania the Office of Mental Retardation's Family Resource Service Program provides a comprehensive array of services to assist families to maintain their retarded child at home. Among the services provided are respite care, baby sitter and homemaker services, recreation programs for the retarded, transportation, in-home therapy and parent training and counseling. Washington State has recently launched a Home Aid Program which is similar in many respects to the Pennsylvania Family Resource Service Program. Physical, occupational and recreational therapy, transportation and in-home care on an emergency of respite basis are all provided.

These and similar efforts in other states to provide stable family living environments for mentally retarded individuals who might otherwise require institutional placement are a highly encouraging trend in our field. Within the context of an expanded and revised child welfare program, which aims at strengthening and reinforcing the role of the family unit and improving the quality of foster care placements, the specialized needs of the mentally retarded and other severely handicapped individuals needs to be considered. In particular, we recommend that the following provisions be incorporated in any legislation to amend Title IV-B of the Social Security Act:

1. The single state agency designated to administer the Title IV-B program should be permitted to contract with other public and private, non-profit agencies for the provision of specified child welfare services. In many states, including New York, responsibility for furnishing specialized family support and foster care services on behalf of mentally retarded persons rests with the state mental retardation agency. Unless provision is made in the legislation for an effective authority, mentally retarded individuals-espeecially those with severe handicapping conditions-will be excluded from the benefits of increased federal support for child welfare services. Not only would retarded persons and their families be denied access to much needed services but a major opportunity to reduce the demand for institutional care would be missed.