We are hopeful that major welfare reform will resolve this issue in the near future. However, being realtistic, we also designed a number of "interim reforms" that would simplify and cut costs in AFDC and food stamps on a short-term basis. We support a standardized deduction for both AFDC earnings and food stamp income. The AFDC deduction should be a flat 35 percent of the gross income, and should be tied to an income ceiling, adjusted for family size, at which families would no longer be eligible. This provides for gradual reduction of the AFDC benefit as income rises. I thank you for this opportunity to present the counties' views. I will be glad to answer questions. Mr. CORMAN. Thank you for presenting Ms. Cutler's testimony to the subcommittee. You filled in for her exceedingly well, and I am sure you are making a worthwhile contribution to the National Association of Counties and to Los Angeles County in particular. Mr. JENSEN. Just one question; you suggest that there be Federal standards such as regulations and through administrative review. You also indicate that there not be a whole series of regulations, proposed requirements for the use of additional funds and it should be examined to make sure that one requirement does not eat up all the money. Now, what is the middle ground between those two? Mrs. JOHNSON. Well, I would like to see some very sound solid Federal standards that would be guidelines for the States and counties about the nature of foster care. While I think a lot of research has been done in the area of child abuse not very much leadership has been taken by the Federal Government in terms of saying what an adequate public welfare program should consist of. So, those are the guidelines I think should be established. Not something as specific as how many cases may be carried and not as specific as how many days or months of placement before the review comes, but basically some standards setting. I do believe across the Nation that there is need for leadership. If I could speak on behalf of Los Angeles County for a moment. We have a very fine, solid child welfare program there and it would be a detriment to us to have some very heavy reporting requirements and some rather strenuous, detailed kinds of things coming down but we would like to see general guidelines and leadership. One of the things I spoke about, a single requirement eating up all the money, is in reference to court review. If you use a great deal of available funds to have court review then it leaves very little for preventive services. Mr. BOWLER. I just want to state for the record the concern that exists with regard to the proposal to eliminate judicial determination. It seems to be the only third party protection that a family has. You may contend that they do not need that protection, but it does provide a third party protection that would be eliminated under your proposal. What you are proposing is to let the people who work with the family review their own decisions. I think that the elimination of judicial determination in AFDC foster care is a serious matter. Maybe we can find a better alternative to judicial determinations. I think that the third party review is a critical element and an important protection for the family. Ms. JOHNSON. Ken, could I speak in a specific and a general way to that. First of all, that would not preclude ever going into court for protection of children who do require the court's intervention and this is done now. Those children are the ones whose families fail to cooperate. When social services are offered, by and large most families do cooperate. They want someone to stop the cycle of problems going on in their households. As a matter of fact, many of these parents request that the child be temporarily removed to a safer setting. So, it is not necessary when all of the reasonable persons involved can agree to services, that the child needs to have the court sign off on him. I agree thoroughly that there needs to be a third party review. But this is not necessarily through the court official whose knowledge of the circumstances and the family is no greater than what he gets in a written report, as a rule. So, I simply disagree with involving the court in those cases where the child's welfare is not threatened in any way. I do not feel that lawyers and judges have any better knowledge of family circumstances and certainly with their different responsibilities they can be less intimately involved with what a child needs. So, third party review can be but there are a number of ways short of going to court, to have third party review. In our view the solution is administrative review. Usually we have team decisionmaking about when the child goes into placement and what the plans will be. The team decision is usually made between one or two supervisors and the caseworker involved with the child and of course, the family itself. Then after a period of time we have administrative review in which a high department official is assigned to sign off on whether a child remains in placement. Again, this is on the basis of considered casework plans. We do have children who go to court and we use our court resources freely because they are very responsive to us. When their involvement is needed we will no doubt use it and, of course, we do get Federal reimbursement for those children. Mr. CORMAN. Just for the record let me tell you what disturbs me about this. You painted a picture of a child who needs temporary care. Why doesn't the State just decide to take care of the child for that temporary period? Until the States are willing to assume responsibility for that for which they do not receive Federal money, I do not think we should distribute Federal funds. Ms. JOHNSON. I think that is a very sound, logical point, Mr. Chairman. I can only put it in the context of fiscal problems at the local level. Now there is a rather extreme pressure at the local level to secure as much as Federal funds as possible because these children in foster care are currently 100 percent locally funded and there is no State shares in that cost and as we know local property taxpayers have to pay that. Mr. CORMAN. I am acutely aware of that. I hear it from my constituents and I share in their burden, but revenue sharing is such a farce. To my knowledge, no one in Government who is connected with any program using some Federal funds has ever said, "We don't need money now. We have general revenue sharing." If we are going to go to federalized welfare we at least have to get out of the system. We burden you with regulations and you burden us with requests for more money. How do we get out of it? Ms. JOHNSON. Well, if I could push one little point further, the reason I talked about the child that was ineligible while his mother was in the hospital is because it seems like it is some kind of a discriminatory policy when obviously it was not intended to be that way. Mr. CORMAN. The Federal policy almost seems to me to be one that says: "If a program is very expensive the Federal Government will participate in it. If it is inexpensive, we'll let some other governmental entity do it." Suddenly, local governments, so intent on getting Federal dollars, are not concerning themselves with anything inexpensive. But, I suspect they spend more of their own funds trying to get Federal dollars than if they initiated a program without Federal participation. Ms. JOHNSON. That is absolutely true. Mr. Chairman, I submit, on behalf of Supervisor Cutler, for the record, a brief statement from her staff in Black Hawk. They have a very strong opinion on earmarking. Mr. CORMAN. We will be pleased to make that part of the record. [The document follows:] BLACK HAWK COUNTY DEPARTMENT OF SOCIAL SERVICES, Re Public Law 94-401-national day care bill. Ms. LYNN CUTLER Black Hawk County Board of Supervisors, DEAR LYNN: Thank you for this opportunity to express our concerns and opinions in regard to the rules, regulations, concerns and opinions and actual end results for local implementation of these monies created by this bill. As you are aware, this bill, commonly known as the "Child Care Bill" was signed into law on September 7, 1976 (H.R. 12455 which amended Title XX of the Social Security Act). The time period for the law was October, 1975 to September 30, 1977. Under this law, each State received an allocation of monies. In Iowa, a state task force for the Department of Social Services was named to review the regulations and make recommendations on the utilization of those funds. Due to a delay in publishing the regulations, there was much confusion in regard to the rules and a delay in actual implementation for not only Iowa, but for many States. It was not until December, 1976, that the work of the Iowa task force was completed and recommendations made to the local districts. The following recommendations were made: 1. To use these monies to maintain child care services at their present level. 2. Increase the opportunity for low-income families to place their children in day care situations to enable the parents to pursue employment and/or training for future employment through additional purchase of service contracts for units of care in the following ways: (a) Increase slots in existing POS centers, (b) provide individual contracts for family day care home providers, (c) develop additional family day care systems, (d) add slots in day care centers which previously did not have a POS agreement. 3. Upgrade child day care services by increasing staff/child ratios to move toward meeting Federal Inter-agency Day Care Requirements by means of hiring ADC recipients and through additional training opportunities. These recommendations by the Iowa State Task Force did comply, I believe, with the intent of the Public Law. However, problems occur with rules and regulations when the intent is attempted to be implemented! It still remains a mystery what rules and regulations do exist and how in fact these monies can be implemented to meet the community needs in day care. Specific problems incurred are as follows: 1. A certain amount of the allocation to the local level was earmarked for the employment of ADC recipients in day care centers. This employment of the ADC recipient has proven to be an uneconomical move for not only the day care center but also for the client. In regard to the center, one of the problems lies with the time period of funding. Employment would have to end September 30, 1977 unless a vacancy occurred in the regular staff since the day care center generally would not have the funds after September 30th to hire the client. A second problem in regard to hiring the ADC recipient with these special monies is the fact that the center would have to pay unemployment insurance on that client. This financial obligation is one that the centers cannot afford to absorb in their current financial budgets. Thus, hiring a client for a specified time period and having to absorb financial costs is economically unsound. For the ADC client, the money gained from employment would lower the ADC grant for a period of time and when employment ended, the client would once again be at the same status as before employment. This short-term employment is not seen as a beneficial move by many clients. Accordingly, the earmarked use of funds for hiring ADC recipients has proven to be useless to us. 2. It was not until January, 1977 that it was made clear to the local districts that the special day care monies could be used to pay current day care costs and thus shift regular Title XX from day care to other needed areas of service funding. Due to the time factor and the amount of money already allocated to various services under Title XX, it was found to be impossible by the local area to utilize this special money to its full extent. Had we known this method of funding was open, we could have prepared our agencies for this opportunity by possibly gaining adidtional day care facilities under Purchase of Service agreements. However, due to the time limitedness of the funds, it is impossible to do such. 3. It was felt that this special day care money was an opportunity to provide for specal day care related projects that had the support and enthusiasm of local communities. An example of how this local generated support for day care is seriously threatened is by describing a local project that has incurred problem after problem. The project involved the training of ADC recipients to become a pool of substitute workers to hire while regular day care staff was receiving training or were ill or on vacation. This proposal ran into trouble with rules and regulations and varied interpretations of such. The training proposal was intended to comply with and utilize the intent of the bill. The day care provider agenices recognize the need to meet Federal standards. They have, however, met these standards through the extensive use of volunteer staff. The goal of the project has two objectives: (1) to train ADC recipients in the many aspects of child care so they could become a member of a substitute pool to be available to hire in day care facilities, (2) the trainig program for the ADC recipient would also be made available to train local day care personnel toward the goal of increasing the quality of service to all children in day care settings. The frustrations and difficulties in obtaining approval of this project have been extensive. It was recently learned that rules and regulations do not allow for the implementation of the project. This indeed has been a bitter outcome for many community people who have a desire to aid in providing quality child care. 4. It is impossible to add day care to POS day care centers that are already to their licensed capacity. We see this suggestion as meaningless unless the rules and regulations actually mean that we are not to regard licensing standards as being important! 5. It has been nearly impossible to enter into POS agreement with centers who did not previously have such an agreement. This is due to the fact that it is economically unsound for many centers to enter into an agreement for a relatively few children, especially when you consider that the funding for these children would end September 30, 1977. We see this child care bill as a tremendous failure in regard to actually aiding local communities and states in their efforts to provide quality day care services to children. This earmarked day care money is not reaching the goals it was supposedly meant to reach and in actuality has created more problems than what it was to solve. The rules and regulations and the fact that it is an earmarked time specified grant have tied up the implementation of the funding to the extent that it has proven to be extremely frustrating and disappointing to the people on the local level in their attempts to utilize this money toward the goals for which it was intended. Sincerely, (Miss) MARLYS KASEMEIER, Purchase of Service Supervisor, District Title XX Coordinator. Mr. CORMAN. Please extend to Ms. Cutler our appreciation for this. We are sorry that the plane schedule did not permit her to be here. However, I am pleased you were here to testify. The next witness is Joseph Jenkins. You have a written statement. You may summarize or you may proceed however you wish. STATEMENT OF JOSEPH E. JENKINS, EXECUTIVE DIRECTOR UNITED NEIGHBORHOOD HOUSES OF NEW YORK, INC. Mr. JENKINS. Mr. Chairman and members of the committee, I am pleased to have this opportunity to discuss some of the legislative recommendations of the committee concerning public assistance programs. My name is Joseph E. Jenkins. I am executive director of United Neighborhood House of New York, Inc., the federation of 35 multiservice settlement houses and neighborhood centers operating in 70 low-income neighborhoods in New York City. I am speaking on behalf of the board of directors of UNH and of its affiliated settlement houses. My testimony reflects both the citywide experience of a large voluntary organization and the problems raised in administering and implementing programs in the poverty areas of New York City. 1. IMPLEMENTATION OF TITLE XX I should like to speak first to the problems arising in a city like ours in implementing the social services programs under title XX and to our concern with respect to the use of the additional funds made available in 1977 as a result of the enactment of Public Law 94-401. My organization has, over the past 5 years, sponsored and administered a home management program funded initially under title I-A and subsequently under title XX. Indeed, at the present time, our program is the only home management program in New York State that is funded under title XX and operated in 22 sites by a multiservice voluntary federation. The current funding in the amount of $844,699 is on the basis of 75 percent from Federal funds with a 12.5 percent State and 12.5 percent city match. In some of |