PAGENO="0001"
PART 2: PAPERWORK PROBLEMS IN ELE..
MENTARY AND SECONDARY EDUCATION
~ ~
I(tt
HEARINGS
BEFORE THE
SUBCOMMITTEE ON ELEMENTARY, SECONDARY,
AND VOCATIONAL EDUCATION
OF THE
COMMITTEE ON EDUCATION AND LABOR
HOUSE OF REPRESENTATIVES
NINETY-FIFTH CONGRESS
FIRST SESSION
ON
H.R. 15
TO EXTEND FOR FIVE YEARS CERTAIN ELEMENTARY,
SECONDARY, AND OTHER EDUCATION PROGRAMS
HEARINGS HELD IN WASHINGTON, D.C.
MAY 24, 25, AND 26, 1977
Printed for the use of the Committee on Education and Labor
CARL D. PERKINS, Chairman
U.S. GOVERNMENT PRINTING OFFICE
91-8600 WASHINGTON: 1977 ~2(!j /~ ~
PAGENO="0002"
COMMITTEE ON EDUCATION AND LABOR
CARL D. PERKINS, Kentucky, Chairman
FRANK THOMPSON, Ja., New Jersey ALBERT H. QUIE, Minnesota
JOHN H. DENT, Pennsylvania JOHN M. ASHB ROOK, Ohio
JOHN BRADEMAS, Indiana JOHN N. ERLENBORN, Illinois
AUGUSTUS F. HAWKINS, California RONALD A. SARASIN, Connecticut
WILLIAM D. FORD, Michigan JOHN BUCHANAN, Alabama
PHILLIP BURTON, California JAMES M. JEFFORDS, Vermont
JOSEPH M. GAYDOS, Pennsylvania LARRY PRESSLER, South Dakota
WILLIAM "BILL" CLAY, Missouri WILLIAM F. GOODLING, Pennsylvania
MARIO BIAGGI, New York BUD SHUSTER, Pennsylvania
IKE ANDREWS, North Carolina .SHIRLEY N. PETTIS, California
MICHAEL T. BLOUIN, Iowa CARL D. PURSELL, Michigan
ROBERT J. CORNELL, Wisconsin MICKEY EDWARDS, Oklahoma
PAUL SIMON, Illinois
EDWARD P. BEARD, Rhode Island
LEO C. ZEFERETTI, New York
GEORGE MILLER, California
RONALD M. MOTTL, Ohio
MICHAEL 0. MYERS, Pennsylvania
AUSTIN J. MURPHY, Pennsylvania
JOSEPH A. LE FANTE, New Jersey
TED WEISS, New York
CEC HEFTEL, Hawaii
BALTASAR CORRADA, Puerto Rico
DALE E. KILDEE, Michigan
SUBCOMMITTEE ON ELEMENTARY, SECONDARY, AND VOCATIONAL EDUCATION
WILLIAM D. FORD, Michigan
IKE ANDREWS, North Carolina
MICHAEL T. BLOUIN, Iowa
PAUL SIMON, Illinois
LEO C. ZEFERETTI, New York
RONALD M. MOTTL, Ohio
AUSTIN J. MURPHY, Pennsylvania
JOSEPH A. LE FANTE, New Jersey
TED WEISS, New York
CRC HEFTEL, Hawaii
`BALTASAR CORRADA, Puerto Rico
DALE E. KILDEE, Michigan
GEORGE MILLER, California
CARL D. PERKINS, Kentucky, Chairman
ALBERT H. QUIE, Minnesota
JOHN BUCHANAN, Alabama
LARRY PRESSLER, South Dakota
WILLIAM F. GOODLING, Pennsylvania
SHIRLEY N. PETTIS, California
CARL D. PURSELL, Michigan
(I')
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CONTENTS
Hearings held in Washington, D.C.: Page
May 24, 1977 1
May 25, 1977 315
May 26, 1977 387
Statement of-
Eldridge, Marie, administrator, National Center for Education Sta-
tistics, accompanied by Darwin Stoizenbach, executive director,
Education Data Acquisition Council, National Center for Educa-
tion Statistics 324
Frazier, Calvin, commissioner, Colorado State Department of Edu-
cation, representing the Council of Chief State School Officers,
accompanied by George Rush, director of the joint data project,
Council of Chief State School Officers 330
Gluckman, Ivan, legal and legislative counsel, National Association
of Secondary School Principals 463
Horton, Hon. Frank, a Representative in Congress from the State of
New York, accompanied by Warren Buhier, Director, Commission
on Federal Paperwork, Peter Franklin, Assistant Director, Paper-
work Commission, and Howard E. Holcomb, Study Group on
Education 2
Levitas, Hon. Effiott H., a Representative in Congress from the State
of Georgia, accompanied by Ellis Bateman 387
McClure, Ms. Phyllis, NAACP Legal Defense Fund 521
Peek, William, assistant to the State superintendent, North Carolina
Department of Public Instruction 349
Smith, Paul, research director, Children's Defense Fund 521
Warner, Mrs. Carolyn, superintendent, Arizona State Department of
Education 293
Prepared statements, letters, supplem~ntal materials, etc.-
Edelman, Marian Wright, director, Children's Defense Fund, testi-
monyof ~- 477
Eldridge, Marie, administrator, National Center for Education Sta-
tistics:
Testimony of 316
Information requested (tables) 372
Forbes, Roy H., director, Education Commission of the States, Denver,
Colorado, letter to Hon. Frank Horton, chairman, Commission on
Federal Paperwork, dated June 27, 1977 578
Frazier, Dr. Calvin, commissioner, Colorado State Department of
Education, representing the Council of Chief State School Officers:
Testimony 331
"The paperwork disaster," newspaper article from Rocky Moun-
tain News 344
Frenzel, Hon. Bill, a Representative in Congress from the State of
Minnesota:
Letter from Bruce R. Anderson, superintendent, Richfield Public
Schools, Richfield Minn 532
Letter to Chairman l~erkins, dated May 26, 1977 526
Testimony of Vincent C. Carison, Independent School District
281, Robbinsdale, Minn 527
Horton, Hon. Frank, a Representative in Congress from the State of
New~ York:
The Commission on Federal Paperwork, report on education 3
The report on education makes 41 recommendations 203
Ladd, Frank, superintendent, Holly Springs Public Schools, Holly
Springs, Miss., letter to Chairman Perkins dated May 2, 1977, en-
closing several articles 309
(III)
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Iv
Prepared statements, letters, etc.-Continued
Levitas, Hon. Elliott H., a Representative in Congress from the State
of Georgia: Page
Appendix A 396
Appendix B 413
Appendix C
McClure, Phyllis, division of legal information and community service,
NAACP Legal Defense and Educational Fund, statement of 471
National School Boards Association, statement on behalf of 533
Nyquist, Ewald B., president, The University of the State of New
York and Commissioner of Education, statement by 552
Peek, William, assistant to the State superintendent, North Carolina
Department of Public Instruction, statement of 350
Thompson, Dr. Barbara, superintendent of public instruction, Wis
consin Department of Education, testimony of 302
Warner, Carolyn (Mrs.), superintendent, department of education,
Phoenix, Ariz.:
A Systems Approach to Forms Management for Arizona De-
partment of Education, article entitled 223
Data Collection and Form Clearance, article entitled 229
Data Reduction Achievements, Cutting the Paperwork, article
entitled 216
Definitions and criteria for forms approval by data acquisition
advisory committee 235
Letter to Chairman Perkins, dated May 24, 1977, enclosing a
statement 212
Memorandum enclosing "Third Annual Data Acquisition P1an"~. 238
Whitehead, David, superintendent, Paducah Public Schools~ Paducah,
Kentucky, letter to Chairman Perkins, dated June 27, 1977 577
PAGENO="0005"
PART 2: PAPERWORK PROBLEMS IN ELEMEN-
TARY AND SECONDARY EDUCATION
TUESDAY, MAY 24, 1977
HOUSE OF REPRESENTATIVES,
SUBCOMMITTEE ON ELEMENTARY, SECONDARY,
AND VOCATIONAL EDUCATION,
COMMITTEE ON EDUCATION AND LABOR,
Washington, D.C.
The subcommittee met, pursuant to notice, at 9:20 a.m. in Room
2175, Rayburn House Office Building, Hon. Carl D. Perkins, chair-
man of the subcommittee, presiding.
Members Present: Representatives Perkins, Simon, LeFante,
Kildee, and Quie.
Chairman PERKINS. The Subcommittee on Elementary, Secon-
dary, and Vocational Education is beginning hearings today on
paperwork problems in elementary and secondary education. These
hearings are a continuation of our hearings this year on elementary
and secondary education in general and on Federal programs in
particular.
We have scheduled these hearings on the subject of paperwork
because many of us have come to believe that undue paperwork is
harming the effectiveness of Federal programs arid that it is an
issue which must be addressed broadly apart from any particular
Federal program.
Over the last decade Congress has greatly increased the amount
of Federal aid, the number of programs providing this aid, and the
requirements necessary to receive this aid. Our purposes have
generally been to improve the overall quality of education in the
nation, to aid specific groups of needy students, and to promote
equality of educational opportunity.
In the process of seeking these objectives though, the paperwork
involved in administering these programs has become enormous.
The Office of Education estimates that in 1973 it required partici-
pants in Federal programs to complete 43.4 million separate data
items and to spend 2.2 million staff hours in this work. State and
local educational agencies had to supply 11.2 million data items,
using about 700,000 staff hours.
I am sure that none of us would dispute the principle that the
Federal government must request and receive sufficient data to
assure that its program objectives are being met and that state and
(1)
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2
local agencies are held responsible for these funds. But we must
find out whether the enormous amount of data now being required
is in fact what is needed to achieve accountability. It seems that
there are at least some instances where data items are required and
the information is never complied with.
It also seems that in some instances instructions for filling out
forms are several pages longer than the forms themselves. It seems
that redundant requests for the same information are made by
different Federal agencies from the same recipient of funds.
What I am saying is that we must fmd a better balance between
the data needs on the Federal level and the amount of time now
being spent to supply that data. I hope that through these hearings,
and further hearings this year, we will find the legislative or
administrative changes which must be made and that we will act on
them.
This committee made some initial efforts to this end in the
Education Amendments of 1976. That law includes amendments
requiring the National Center for Education Statistics to coordinate
the collection of information involved in Federal education pro-
grams within the Education Division of the Department of Health,
Education, and Welfare. Our purpose was to have a coordinating
body which would cut back on redundant requests and unnecessary
requests for data. Tomorrow we will hear from the National Center
on their progress in implementing those amendments.
Today. we have with us our colleague, Congressman Frank Horton
from New York, who chairs the Commission on Federal Paperwork.
I know that his testimony today will be invaluable to us.
Our second witness is Superintendent Carolyn Warner from the
State of Arizona, one of the nation's foremost advocates of cutting
back on unnecessary paperwork in education. She has done an
outstanding job in this regard, and we look forward to her testimo-
ny and to her suggestions for improvements.
At this time it is a great pleasure to introduce one of our most
outstanding colleagues in the House of Representatives, a gentle-
man who always has been constructive ever since he has been in
the United States Congress, insofar as improving the quality of
education and improving educational programs.
It is a great pleasure for me to introduce you, Mr. Horton.
Procceed in any manner you prefer.
STATEMENT OF HON. FRANK HORTON, A REPRESENTATIVE IN
CONGRESS FROM THE STATE OF NEW YORK, ACCOMPANIED BY
WARREN BUHLER, DIRECTOR, COMMISS~N ON FEDERAL
PAPERWORK; PETER FRANKLIN, ASSISTANT DIRECTOR,
PAPERWORK COMMISSION, AND HOWARD E. HOLCOMB, STUDY
GROUP ON EDUCATION
Mr. HORTON. Thank you kindly, Mr. Chairman.
First of all, I would like to introduce those who are with me. On
my immediate right is Mr. Warren Buhler, who is the Director of
the Commission on Federal Paperwork. To his immediate right is
Pete Franklin, Assistant Director for the Paperwork Commission,
and on my immediate left is Mr. Howard Holcomb, who is the
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3
person who headed up this Study Group on Education. He was
formerly, the last five years before he came with the commission,
with the Association of American Colleges. Mr. Franklin was Spe-
cial Assistant to the Secretary of HEW before he joined the
Paperwork Commission, and Mr. Buhier was one of the counsel
with the Government Operations Committee before he joined.
The study report we have furnished to the committee, and I hope
each of you has a copy of it.
Chairman. PERKINS. Without objection, it will be submitted for
the record.
[The document referred to follows:]
DRAFT
THE COMMISSION ON FEDERAL PAPERWORK
REPORT ON
EDUCATI ON
APRIL 18 1977 ~
THIS STAFF REPORT IS SUBMITTED TO THE COMMISSION ON
FEDERAL PAPERWORK FOR ITS REVIEW, AND IS NOT AN OFFICIAL
REPORT OF THE COMMISSION.
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4
FOREWORD
The Commission on Federal Paperwork was established by
Public Law 93-556 Operating for two years ending in
October, 1977, the Commission's mandate is to develop ways
of reducing paperwork associated with Federal information
demands while recognizing legitimate program planning and
administration data needs Section 3 (c) of the legisla-
tion directs the Commission to make a final report to
Congress and the President upon completing its work, and
* authorizes such jnterim reports and recommendations as it
deems advisable. Section 3 (d) requires the Office of
Management and Budget to report to the Congress and the
President at least once every six months, and make a
final report within two years, on the status of actions
taken upon submission of the Commission's final report.
This is the Commission's interim report on Federal
paperwork in the area of education.
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5
TABLE OF CONTENTS
SECTION PAGE
I INTRODUCTION
Education in Our Society
* Growth: in Federal Legislation
Scope of the Study
Major Themes
* Overview of Reôommendatjons~
II GRANTS ~ND CONTRACTS
Documentation of Personal Services
* : on Government Projects at Colleges
and Universities
Accounting for Nonexpendable
Property Purchased by Grantees
DHEW Federal Assistance Financing
System
Office of Nan~gement and Budget
Circular A-l],O
The Protection of Human Subjects.
Single Agency Cognizance
III. STUDENT AID
* Guaranteed Student Loan Program.
Campus-based Programs
* Coordination of Student Aid:
Toward a Single Application
IV. NONDISCRIMINATION REQUIREMENTS
Cognizant Agency
* The Emergency School Aid Act
The Elementary and Secondary School
Civil Rights Survey
The Higher Education
General Information Survey
V. MANAGEMENT CONTROLS
Coordination of Education
Data Collection
Standardizing Terminology
Development of Indexing
(Catalogue) System
Reducing the Burden by the *
Education Division
The Role of Congress
Respondent Group Participation
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6
GLOSSARY OF
ABBREVIATED TERMS
ACT American College Testing Program
BEOG Basic Educational Opportunity Grant
BOB Bureau of the Budget, predecessor of the Office of
Management and Budget
CCD Common Core of Data
CCSSO Council of Chief State School Officers
C El S Corrinittee on Evaluation and Information Systems, Council of Chief
State School Ofticers
CSS College Scholarship Service
CWS College Work-Study Program
DFAFS Departmental Fèderal Assistant Financing System
of the Department of ~Health, Education, and Welfare
EDAC Education Data Acquisition Council
ERDA Energy Research and Development Administration
ESAA Emergency School Aid Act
FISL Federally Insured Student Loans
GAO *General Accounting Office
GSLP Guaranteed Student Loan Program
HEGIS Higher Education General Information Survey
HE~7 Department of Health, Education, and Welfare
IRS Internal Revenue Service
LEA Local Education Agency
NACUBO National Association of College and University
Business Officers
NASFAA National Association of Student Financial Aid
Administrators
NCES National Center for Education Statistics
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7
GLOSSARY CON'T.
NDSL National Direct Student Loan Program
NIH National Institutes of Health
OCR Office for Civil Rights of the Department of
Health, Education, and Welfare
OE Office of Education
OFCCP Office of Federal Contract Compliance Programs
of the Department of Labor
0MB Office of Management and Budget
PBS Public Health Service
P L Public Law
SEA State Education Agency
SEOG Supplementary Educational Opportunity Grant
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8
I. Introduction
Our Nation holds the opportunity for learning among
its primary requirements for a free and productive society.
The early colonists had hardly settled before they initiated
the first public Latin school in 1635, the first private
college in 1636, and the first school supported by direct
taxation in 1639. Cultivation and financial support of
education were continued and increased through the years
until, at the time of our Bicentennial, three of ten
citizens in a population of 214 million were directly in-
1
valved with education. Approximately 59 million of these
citizens were students, over 3 million were teachers, and
another 300,000 were administrators or other staff members.
No other nation has gone so far in advancing education.
The control of education thus far has remained at
the State and local levels whether under public or private
auspices. In the last two decades, however, the Federal
Government has increased its policy making and financial
roles. It has sought, for example, to end various kinds
of discrimination and has funded special categorical
programs such as aid to disadvantaged and handicapped
children. During this period State and local financial
support for elementary and secondary education increased at
a greater rate as did State support for institutions of
higher education (see Figure 1).
Estimated expenditures of education institutions
for 1975-76 reached $75.1 billion, for elementary and
secondary schools and $44.9 billion for institutions
1-1
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9
of higher education, for a total of $120 billion, a sharp
increase of approximately $100 billion in the last 20
years. The Federal share of these expenditures reached
a high of 11.9 percent in 1967-68 but declined to 11.1
percent in 1975-76. The State share has increased
meanwhile from 29.1 percent in 1959-60 to 34.7 percent
in 1975-76 (see Figure 2).
The exact cost of Federal paperwork to educational
institutions is illusive. In fact, the most severe costs nay
not be measurable in dollars at all. Educators complain that
the rapid growth of educational bureaucracies at all levels
has led. to an increased concentration on the regulatory and
administrative processes and the diversion of faculty
from their primary responsibility -- teaching. One result
has been the creation of an atmosphere of hostility within
the institution bringing with it very real, though intangible
costs.
Testimony of educators also demonstrates that substantial
reallocation of institutional resources has often resulted
from the steady and continuing impositionof intricate
regulations and demands for increasing esoteric information.
What makes the problem particularly acute is that these
requirements are increasing precisely at the tine
when institutional resources and outside funding, in
constant dollar terms, are generally on the decline.
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10
Growth in Federal Interest
World War II marked a watershed in enactment of
Federal laws and promulgation of accompanying admini-
strative regulations affecting education. In the early
years of our Nation Congress provided, first in 1787
with the Northwest Ordiance and later in 1862 and 1890
with the Morrill Acts, land and money grants for the
establishment and support of education. Beyond that,
until World War II, only an occasional Federal statute
on some vocational education subject was enacted.
Then, in 1944, before the first serviceman invaded
Europe, a grateful Nation provided in advance of their
return hone the promise of assistance for education to
veterans in the Servicemen's Readjustment Act (P.L. 78-346),
better remembered as the first GI Bill. This law, plus
the greater mobility of our citizens caused by the war and
its related technologies, transformed higher education from
a promise open to only a few to a seeming entitlement for
many. Wartime needs for technological development, research
and specialized training also brought the Federal Government
into much closer contact with colleges and universities.
1-3
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11
The `baby boom" following World \~ar II had a significant
effect on education because more schools and more teachers
were subsequently required. As the world of educational
opportunity widened Congress manifested greater interest
in covering some of the costs of programs to provide the
buildings, staffs, and programs needed to assure equal
opportunity for all. Many pieces of education legislation
enacted since the 1940's demonstrate the expanded Federal
interest and role. They have transformed the Federal
relationship with the States and local education agencies
(LEAs) as well as with educational institutions in the
private or proprietary sectors. Among the enactments.
which demonstrate the growing role of the Federal Government
in education are:
o 1944 Surplus Property Act (P.L. 78-457).
Donation of Federal property to education
institutions.
o 1946 National School Lunch Act (P.L. 79-396).
Assistance to States for school lunch programs.
o 1950 Financial Assistance for Schools in Areas
Affected by Federal Activity (P.L. 81-815 and
874. "Impact aid."
o 1950 Housing Act (P.L. 81-475). Loans for college
housing.
o 1958 National Defense Education Act (P.L. 85-765).
Assistance to States to strengthen instruction
in mathematics, science and modern foreign
languages; National Defense Student Loans (NDSL).
1-4
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12
~ ?
Figure 1 shows expenditures of educational institutions
by source of funds. Figure 2 illustrates expenditures for
elementary and secondary schools and institutions of higher
education.
Figure 1
U.S. Department of Health, Education, and Welfare, National
Center for Education Statistics. The Condition_of Educa-
tion:_ 1976, by Mary A. Golladay (Washington, D.C.: Govern-
rnent Printing Office, 1976), p.27.
Figure 2
U.S. Department of Health, Education, and Welfare, The
Condition of Education: 1976, pp. 28-29.
1-5
1-6
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13
o 1963 Higher Education Facilities Act (P.L.
88-204). Grants and loans for undergraduate
and graduate academic facilities.
o .1965 Elementary and Secondary Education Act
(P.L. 89-10). Grants for schools enrolling
children of low income families, books,
strengthening State departments of education,
etc.
o 1965 Higher Education Act (P.L. 89-329).
Grants for community service by colleges,
library assistance, and student grants and
insured loans.
Much of this basic legislation has been amended
by Congress repeatedly since 1968. Interspersed with
these legislative initiatives have been important
enactments affecting education with respect to civil
rights, economic opportunity, refugee assistance,
drug abuse, environmental education, juvenile justice
and delinquency, Indian self-determination, and special
consideration for deaf, handicapped, mentally retarded,
and older persons.
Congress has included education in a lengthy list of
legislation dealing with, among other issues, non-
discrimination, occupational safety and health, privacy,
and pensions. These four topics are the subjects of
other reports of the Commission, but certain educational
aspects of nondiscrimination are discussed in Section
IV of this report.
1-7
91-8600-77--2
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14
Forms of Federal Funding
Many of the laws affecting education are administered
in the Office of Education (OE). The Commissioner of
Education recently told a Senate subcommittee that he
administered approximately 120 programs in Fiscal Year
1976 compared to fewer than 35 prior to Fiscal Year
2
1965. During that period, appropriations for OE in-
creased from $l.55l to $7,270 billion, an increase of
369 percent. While the number of programs grew by 243
percent, staff had been increased only 87 percent.
Created by Congress in 1867 to gather statistics
on education, OE has become a program agency, essentially
in the last 15 years. With each new law one or more sets
of regulations must be issued by the unit of the executive
branch that administers the program. In Section V this
report discusses the role of Congress and suggests manage-
ment controls for paperwork problems caused primarily by
the rapid growth in size and number of Federal education
programs.
Federal funding for education, in total approximately
$22 billion in Fiscal Year 1976, is awarded to individuals,
institutions and States. For individuals it may take the form
of grants, loans, interest subsidies on loans, work-study
stipende fellowships or scholarships, or a combination
of these. For institutions it may take tile form of grants
or contracts for a specific program, loans or donation
1-8
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15
property. States receive assistance primarily through
categorical or formula grants-in-aid and donable property.
Whatever the form of assistance, regardless of the
amount or the source, a degree of reporting and account-
ability is necessary to ensure that the statutory objectives
are being met and the Federal, State or private interest
is accounted for. It is at this point that most paperwork
burdens come between the provider and~ the recipient.
Several funded programs supporting individuals and in-
stitutions are analyzed from this perspective in the follow-
ing sections of this report.
Scope of_this Study
To assess paperwork requirements placed on States,
elementary and secondary schools, postsecondary in~titut-
ions, and students, the Commission looked also at the
originators of paperwork, Congress and the executive branch.
To identify specific examples of unnecessary, redundant, and
excessively burdensome paperwork, the Commission examined
the testimony of many witnesses at its hearings (See
Appendix A.), reviewed letters it received complaining
about the paperwork burden, and sought evidence to sub-
stantiate many media reports on the problems of paperwork.
Congressional committee and agency staffs were
interviewed for their perspectives on information and
reporting requirements, and a substantial number of hearing
records, Government reports, and special studies were
analyzed. The Commission observed also a wide range of
1-9
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16
advisory council meetings, seminars on data reporting
and agency reviews of survey instruments.
As a preliminary step in its research, the Commission
conducted a quick survey of all OE programs to identify
likely targets there for in-depth study. In the course
of this survey, the Commission interviewed a sample of
officers and analyzed the application and reporting
process for selected OE programs.
The Commission then utilized the assistance of two
major respondent groups which devoted special efforts
to supply information about current reporting require-
ments. The Council of Chief State School Officers
(CCSSO) through its Committee on Evaluation and In-
formation System (CEIS) conducted a survey of its members
to identify specific examples of paperwork probre~ns that
are especially burdensome in time and dollars. In higher
education, the American CounciL on Education designated
the National Association of College and University
Business Officers (NACUBO) to coordinate production of
information from institutional membership associations
and three specialized organizations of registars, personnel,
and financial aid administrators. In addition., the Commission
was in contact with the entire range of Washington-based education,
associations, including student groups.
Through coordinators in each State and several terri-
torial jurisdictions, CEIS monitors agencies that collect
data from elementary and secondary schools and State Ed-
ucation Agencies (SEAs). CEIS has given high priority in
1-10
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17
recent years to the timing of and amount of data collected
in civil rights surveys, the *need for coordination of
collection of data among Federal and State agencies,
and multiple uses of data. These priorities and the roles
of respondent groups are discussed in Sections IV and V
of this report.
NACUBO appointed a paperwork committee in higher
education and identified several areas of concern, in-
cluding:
o The Employee Retirement Income Security Act
of 1974 (ERISA),
o The Higher Education General Information Survey
(HEGIS),
o Nondiscrimination requirements,
o Student financial assistance, and
o Grants and contracts.
ERISA is the subject of a separate Commission report;
the other concerns are analyzed in this report.
The Commission concluded early that a broad approach
to a large number of institutions would be more productive
if it were preceded by studies in greater depth at one or
more institutions. Accordingly, such studies were made
at the George Washington University and at the University
of Maryland at College Park. These institutions, one
public and one independent, deal with a large number of
Federal agencies because of their location and the variety
of their expertise. Although the studies centered upon
Federal contracts and grants for research, instruction, and
I-li
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18
public service, they inevitably involved other areas as
well.
Inter-A~n~ Task Force
The Secretary of Health, Education, and Welfare,
at the President's request and with the support of the
Council of Economic Advisers, convened a work group to
study Federal reporting requirements for institutions
of higher education and to make recommendations for their
consolidation and simplification. This work group of
ten people included representatives of the Commission. It met
for two weeks in October, 1976, and presented 15 recommenda-
tions. These were referred by the Secretary of HEW to the
heads of 15 Federal departments and agencies, including
the Commission on Federal Paperwork. They were asked to
delegate one or more responsible officials to form an inter-
agency task force.
The Task Force, which consisted of 30 members including
two representatives from the Commission, met regularly during
November, 1976. The 15 recommendations of the earlier
work group were expanded, supplemented, and revised.
The final report of the Task Force, submitted December 14,
1976, included 19 specific recommendations for the re-
duction of the paperwork burden on higher education.
(See Appendix B.) The Commission representatives were able to
contribute regularly to the Task Force deliberations, and
several of the 19 recommendations coincide with and reinforce
1-12
PAGENO="0023"
19
recommendations of the Commission in this report.
~ Themes of the~~ort
As the Commission analyzed the information it
obtained from the sources indicated above, the complaints
and criticism could be grouped into six general categories.
These are discussed below.
Late Feedback of Results. Education respondents
complain frequently about the lateness or absence of
feedback on information supplied Federal agencies. They
indicate also that some of the feedback they do receive
is not useful. Some of the complaints relate to affirmative
action plans submitted that are not acknowledged or re-
viewed for periods of three or four years and others to
certified letters requesting clarification of instructions
for civil rights surveys tht go unanswered before the
filing deadline is at hand.
Many comments about late feedback relate to general
information surveys in either higher or elementary and
secondary education where publications of data are
frequently four years late. A library survey of elementary
and secondary schools was conducted in 1974, according
to CEIS, and no feedback had been received by early 1977
when plans were announced for another survey.
NCES recognizes this problem and does make available
to researchers and others computer tapes and other forms
of data compilation for their early use. It also hasbegun
providing earlier, briefer analyses of much of its collected
1-13
PAGENO="0024"
20
data. The late feedback problem is a significant element
in several of the recommendations in this report, particu-
larly in Section IV.
Insufficient Lead Time. A univeral problem in Federal
paperwork is the absence of sufficient lead time to respond
to a survey, study, reporting form, application or proposal.
Frequently, insufficient lead time is due to a legislative
mandate, agency tardiness, a decision to await funding,
or an independent agency activity.
Some examples of insufficient lead time are:
o An eastern State department of education stated that
four vocational education program report forms were
received two weeks after the reports were due; that
a program outlay form by geographical districts was
received 15 days after the due date of the report;
that evaluation report forms for Titles IV and IX
were received one week before due date for completion;
that an application for a handicapped education
program was received less than one month before
the date for completion; and that an application
under Title III was received only two weeks before
it was due to be completed.
o A higher education survey of information on re-
cipients of degrees conferred, requiring in-
formation not collected earlier, was received
after the graduation and departure of awardees
from the campus.
o A private university in the midwest received
an application on June 8 for the continuation
of a Federally-funded child development program,
with a notice of a related workshop for applicants
to be held June 10 and 11, and a completed
application due date of June 14.
o A biennial civil rights survey of elementary
and secondary schools, administered primarily
through State departments of education, was
issued almost three months after the start
of the school year.
1-14
PAGENO="0025"
21
The concept of sufficient lead time for surveys,
specifically at least nine months prior to the start of
a school year, has been advanced in recent years both by
the American Association of Collegiate Registrars and
Admissions Officers and by the CCSSO Whether surveys
are directed to colleges, schools, or States, the in-
stitutions and States contend they need that much time
to build their annual data acquisition plans in order to
collect the data during matriculation or registration
and then prepare the response. Information requests
arriving after that planning and collecting cycle in-
volve a second collection of data and usually require
a manual compilation. Specific examples are found in
Section IV of this report where school civil rights
surveys and REGIS are discussed.
If Federal agencies would develop annual data
acquisition plans before sending out their requests,
as a few have recently begun to do, the announcement
nine months in advance of their intention to collect
data would materially enhance the quality of data
received. Without sufficient advance notice, data must
often be estimated because they are not available.
Discussion of and specific recommendations for lead time
of this kind are included in Section V of this report
Duplication of Collection Duplication is frequently
a matter of interpretation The Federal or State program
manager, the staff person in a statistical agency, or the
I-~l5
PAGENO="0026"
22
researcher under contract or in a private organization
may not consider the problem of duplication unless that
person is required to determine whether the data are
available elsewhere Even then, duplication may not be
deemed to exist unless the data are found in the identical
form the collector requires, after which, the collector
may decide it is easier to collect them again than to use
the alternate source
To the education respondent duplication exists when
data are required by more than one agency, whether or not
the requirements are in precisely the same form. To the
respondent, the Federal Government is unitary and its
agencies are expected to make common and multiple uses
of information in the interest of efficiency and economy.
Some examples to the contrary cited by respondents are:
o Students file family financial information in
different formats at least twice, and often
three times, in applying for grants, work-
study stipends or direct loans.
o Students provide much of the same or similar
data when completing as many three applications
for Federally Insured Student Loans.
o Higher education enrollment surveys by Federal
agencies, and some State agencies or regional
bodies, request similar data.
o Employment reporting forms Of the Equal
Employment Opportunity Commission and the
National Center for Education Statistics (NCES)
require similar information by different .
classifications.
* o Pupil, annual, and performance report forms for
* Title I of the Elementary and Secondary Education
Act require similar data. *
1-16
PAGENO="0027"
23
o Four separate migrant student surveys by the
same agency involve duplicate information.
o Application and fiscal operations report forms
for Federal campus-based student aid programs
contain duplicate data requests.
o Financial reports for fiscal control and
reports for program monitoring of grants and
contracts involve duplicate data requests.
o School districts awarded grants provide much
of the same data quarterly to program and
finance offices and annually both in final
programs reports and statutorily mandated reports to
the Commissioner of Education.
Duplication is difficult to track or analyze
except on a form-by-form basis as questions are raised
by respondents, agency clearance officers, or 0MB final
clearance staff. Collection of data is not coordinated
by a central agency, and there is no automated index
of data elements collected by statutory authority, subject
or purpose. Duplication of data collection can be checked
only after first examining HE~Ps Annual Data Acquisition
Plan, which is a computer printout of descriptions of forms
for the Education Division of HEW or OMB's Inventory of
Active Repetitive Public Use Reports approved under the
Federal Reports Act, which is a computer printout of
titles, agency report numbers, and descriptive infor-
mation by agency.
In Section V if this report, the Commission makes a
series of recommendations intended to reduce unnecessary
duplication. Several other recommendations elsewhere
in this report are directed also toward this problem.
1-17
PAGENO="0028"
24
Unrealistic Data Requests. Education respondents are
unnecessarily burdened when faced with requests for data
that are not reasonably available, excessive, or not used.
A major souce of these complaints in the last three years
relates to civil rights surveys of elementary and secondary
schools and to affirmative action plans of institutions
of higher education. A limited review of the agency
administering these programs by the General accounting
Office in 1976 indicated that the agency did not know and
could not ascertain for fiscal years 1970-1976 how many
complaints had been received by type and authority and how
many compliance reviews, by type of discrimination, had
been initiated--yet more data had been collected each year.
Other examples include institutional applications
for campus-based student aid, where approximately one
dozen of 680 data elements collected are computerized for
general use, the balance being stored. In the following
sections these complaints are analyzed and recommendations
are made. for reducing the burdens associated with them.
Inconsistent Terminoloa~ The problems of insufficient
lead time are exacerbated when terminology and definition
are changed from one year to another. Examples of changes
of this sort in the past few years include racial and
ethnic classifications, the definition of residence in
migration studies, and the determination of attendance
for the purpose of allocating funds in certain programs.
~18
PAGENO="0029"
25
During the last 20 years NCES has developed a
series of handbooks on terminology, definitions, and
classifications of data items that provide, in effect,
a common language of communication These handbooks,
however, have not been used faithfully by the Federal
agencies or States NCES is currently developing a
common core of education data which could become the
data base for purposes of reporting for compliance,
evaluation and program management, as well as for
statistical analyses. Until developments such as these are
put into use, the problems of inconsistent terminology
will continue to plague agencies and respondents alike
The problem is implicit in the recommendations in this
report on HEGIS and protection of human subjects, among
others, and is the central theme of one of the recommenda-
tions in Section V
Costs of Data and_~formation Reliable evidence
on the costs of providing data and information has not
yet been developed Only in recent years, as data and
information have come to be regarded as a resource to
be managed, have education researchers and business
officers been impelled to start looking at the mounting
costs of responding to more requests for more information
School systems say they are drowning in paperwork,
that time spent filling out forms takes time and resources
away from classroom activities Testimony at a Commission
hearing in Knoxville, Tennessee on January 9, 1976 by
1-19
PAGENO="0030"
26
John C Carter, director of the Food Service Department
of the Knoxville city schools, provided an example. He
said `ti~ne was being taken away from other school duties
and many teachers are asking whether they are to teach
or handle welfare programs In a system of over 30,000
students, he stated, approximately 20,000 person-hours
are required to adriinister the school lunch program,
using 200 reams of paper each year, not including daily
food tickets
* A large western school system estimated conservatively
that the time required to complete a recent civil rights
survey was 1,960 hours Another large southwestern
community school estimated its costs for the same
fc~rm to be $67,000, no part of which had been budgeted.
States speak of costs in terms of the balance be-
tween State and Federal information requirements as compared
to their respective funding levels. A western State says
the Federal Government imposes 40 percent of its data
collection requirements yet provides only 10 percent of
the funds. A mountain State shows that 39 percent of the
data it collects is required by the Federal Government which
provides only five percent* of its funds. A midwestern farm
State says that 30 to 50 percent of its reporting time
is due to Federal requirements, yet it receives only four
percent of its funds from Federal sources. Another ;
1-20
PAGENO="0031"
27
midwestern State estimates it may cost $3 50 per data
item per school to provide data not readily available
Determining the cost of providing education data
is a complex problem Elementary and secondary educa-
tion includes over 90,000 schools in 16, 000 districts,
so the determination of cost of data is itself costly,
according to CEIS. For example, depending upon the
size of. the school or district, the `following, questions
must be answered to ascertain cost:
o Who is involved in collecting the data and for'
how long? Certified administrative staff,
research personnel, students, individual, school
staff, district staff or State staff?: . `
o How is the data collected and reported? By
hand, or ~
o How is the system designed? .
o Is the developmental cost charged to the
original activity or prorated over several
years, and for'how many years? . .
o Is the data to be reported exactly as it is
collected?
o How many times will data be reported'
o In what format will it be reported~
o Will data affect'decision-making, and if so,
to what degree and how much money is made
available as a result? ` .
o Can it be understood without explanation?
o How will it be ~
Measuring.accurately information specific enough
to provide good cost data has not yet been accomplished
by CEIS, but in its opinion the question of "how much it
will cost" is becoming so important that techniques must
1-21 `
PAGENO="0032"
28
be developed soon to determine costs of data production
and collection.
Colleges and universities expend from one to four
percent of their operating budgets to meet the costs of
implementing federally mandated social programs, accord-
3
ing to a recent American Council on Education study.
The report states that these costs have increased from
ten to 20 times in less than a decade.
A large midwestern public university indicates
it responds to 275-300 governmental agencies and bureaus
at a cost of several million dollars annually. Smaller
independent colleges, which receive the major portion
of their income from students, fear that additional costs
of paperwork will require increases in tuition. A
consortium of 20 independent colleges in.a southern State~
suggests Federal paperwork cost them $668,727 last year,
or $47.09 for every full-time equivalent student.
A small eastern independent college president
testified at a Commission hearing that his institution
could not consider applying for certain grants of less than
$50,000 because of the high cost of the requisite paper-
work. Another midwestern public university officer
testified that institutions sometimes forego responding
to requests for proposals to help solve national problems
because of the excessive paperwork involved. He said his~
university could increase its participation in Federal
programs by 50 percent if less paperwork were required.
1-22
PAGENO="0033"
29
Costs of education at any institutional level are
supported typically by taxes, tuition charges and private
philanthropy. As costs increase for whatever reason,
including paperwork, support from these sources must
increase also. These are rarely profit-making enter-
prises where increased costs can be met by increasing
the price to the consumer. The burden of cost in
supplying data is implicit in the rationale for most
of the recommendations in this report.
Review of Recommendations
Time and resources permitted only the examination of
selected paperwork burdens. In selecting those to be
studied, the Commission considered the information
developed through methods and from sources described
in earlier pages with respect to the following criteria:
o What was the impact of programs in terms of
level of funding, numbers of persons and in-
stitutions affected?
o How burdensome was collection of information in
terms of availability, effort required, and
whether repetitive or single-time?
o Was the burden exacerbated by multiple laws and
regulations?
o Would a generic solution relieve similar burdens
elsewhere?
o Would solutions provide long term control as well
as immediate relief?
Problems selected are discussed from the standpoint
of grants and contracts, student financial aid, non-
discrimination, and management controls. Each subsequent
section of this report considers several programs, in each
1-23
91-8600-77--3
PAGENO="0034"
30
of which the salient problems are stated and analyzed and
recommendations are made.
Grants and Contracts. The grants and contracts category
was selected because more than 2,500 colleges and universities,
through the efforts of an undetermined number of thousands
of researchers, administer approximately $4.5 billion in
Federal projects that contribute significantlyto the
national interest. Faculty members and administrators in
these colleges and universities are required to complete
overlapping forms, meet multiple compliance requirements
from many agencies, and keep records, at an enormous cost,
that have little use or validity. The grants and contracts
area is discussed in Section II.
This section deals with reporting faculty and other
professional time and effort; eliminating mandatory cost
sharing in research and development projects; raising the
threshold for nonexpendable property reporting; streamlining
the payment process; extending to contracts standard
administrative requirements similar to those applying to
grants; establishing single agency cognizance for the
protection of human subjects; and generalizing the concept
of single agency cognizance.
Student_Financial Aid. The largest programs in HEW's
Education Division, in terms both of dollars and of in-
dividual applicants, are those in student financial aid,
where over $3 billion is awarded annually to almost two
million students. These awards are supplemented, when
1-24
PAGENO="0035"
31
additional need exists, by State, institutional, and private
sources which combine to *provide $1.5 billion annually
for assistance to students not receiving Federal funds
as well as for additional aid to those who do. Students
may complete up to seven application forms and three
financial information forms, all using similar data
and frequently with separate fees. This hodgepodge of
programs, forms, and fees, involving duplication of
data and resulting burdens upon students and their
families as well as upon institutions, became an almost
automatic selection for Commission study.
Selected student financial aid programs are discussed
in Section III, where recommendations are made to combine
applications in the Federally Insured Loan Program; to
shorten and simplify institutional applications for campus-
based programs; and to produce a single financial aid
application for Federal, State, institutional, and private
sources.
Nondiscrimination Initiatives in the last dozen years to
eliminate discrimination and provide equal educational
opportunity, especially in Federal programs, have been
augmented and intensified in more recent years by additional
laws and regulations which have forced educational in-
stitutions into meeting a variety of compliance require-
ments from many agencies. As employers and Federal con-
tractors, in admissions and financial aid policies,
1-25
PAGENO="0036"
32
educational institutions and agencies are committed to
nondiscrimination. But this reporting and enforcement
requirements of Federal agencies in administering
these necessary programs are uncoordinated and overlapping,
causing unnecessary expense and burden. For these reasons,
nondiscrimination was selected as a topic for study and
comprises Section IV of this report.
In that section, the Commission recommends a single
cognizant agency for equal opportunity and civil rights
recordkeeping, reporting, and compliance in the field
of education.
Management Controls. States and territories and their 91,000
elementary and secondary schools face special reporting
problems, in part because of the number of categorical programs,
each requiring appropriate accountability for Federal funds
and each requiring compliance with equal opportunity mandates.
CEIS monitors effectively the individual data collection
activities, but there remains the necessity for better
management of the overall Federal collection to improve
the value of the data submitted. On this basis, the manage-
ment of data gathering was chosen as a topic for study and
is treated as a part of the management controls discussed
in Section V.
Management solutions to generic paperwork problems
are proposed there which can provide for the central
coordination of data collection, a common language of
communication in that collection, and automated processing
1-26
PAGENO="0037"
33
of data elements by purpose and subject to imorove clearance
procedures and reduce duplication These management solutions
can also improve the ability to make multiole uses of
data
The final analyses in Section V discuss the roles
of Congress and of education respondent groups in con-
trolling excessive and burdensome recordkeeping and
reporting in the future.
FOOTNOTES
Section I
1. U.S. Department of Health, Education, and Welfare,
Annual Report of the Commissioner ~f Education~
~I~äI~ Year 1975 (washington; D.~: Government
Printing Office, 1976) p. 199.
U.S. Congress, Senate, Committee on Governmental
Affairs, Guaranteed Loa.p9~ before
the Permanent Subcommittee on Investigations,
U.S. Senate, 94th Congress, 1st session, 1975,
pp. 464-508.
3. Carol Van Alstyne, The Costs to Colleges and
Universities of Implëirienting Federally Mi~ited
social Programs, Policy Analysis Service Special
ReportTWä~Shington, D.C.: American Council on
Education, 1976), p.4.
1-27
I- 28
PAGENO="0038"
34
II GRANTS AND CONTRACTS
Federal grants and contracts were identified early
in the Commission's study as major sources of concern to
higher education (see page 11). Federal~rants and con-
tracts awarded to colleges and universities amounted to
more than $4 5 billion in fiscal year 1975, according to
the National Science Foundation's Surveys of Science Re-
*sources. These awards were shared by 2,517 institutions.
Colleges and universities are labor-intensive, sal-
aries and wages constituting their largest item of expen-~
diture. A major source of difficulty for these institu-
* tions is the paperwork required to document the portion
of salaries and wages that is appliedto Federal grants
and contracts. Another is the administration of property
acquired in the course of these programs, and a third el-
ement is the manner in which payment for these projects
is made by Federal agencies to the institutuions These
three topics are discussed first in this section
The Commission noted progress made by 0MB in estab-
lishing consistent policies and procedures among Federal.
agencies in the administration of grants and contracts
It noted also the leadership exercised by HEW in developing
effective and responsive regulations for the protection
of human subjects involved in Federally supported research
and urged that HEW be assigned sole responsibility for
11-1
PAGENO="0039"
35
regulations in this area as the "cognizant agency." Fi-
nally, the Commission investigated the cognizant agency
concept as a potential solution in other areas, perhaps
including those where critical problems may not yet have
emerged. Discussion of these three steps concludes this
section
Documentation of Personal Services
The process of reporting and documenting theefforts
devoted to Government-sponsored programs by faculty mem-
bers and other professionals at colleges and universities
has been an abrasive one for many years The issue in-
volved in effort reporting, simply stated, is this How
can the Government be assured that faculty and profes-
sional services offered by the universities under the
terms of their grants and contracts have been delivered
and are properly chargeable to programs financed by public
funds~'
The process involves some form of monthly data for
each professional involved in Government-sponsored programs
at every college and university These data are prepared
on forms designed by each institution and are made avail-
able to Federal auditors as needed
The Way and Navy Departments jointly issued in 1947,
an "Explanation of Principles for Determination of Costs
Under Government Research and Development Contracts With
11-2
PAGENO="0040"
36
Educational Institutions." This document stated (para-
graph 8) that:
Where faculty members paid on a salary basis
work part-time on a government research and!
or development project, reasonable estimates
of such time may be used in lieu of exact time
records, it being recognized that such members
of educational institutions cannot be expected
to keep time records in the manner common to
industrial oganizations.
Bureau of the Budget Circular A-213-, first published
in 1958, sets forth cost principles for educational in-
stitutions with respect to all Federal agencies. On this
point, it specified (paragraph I.C.l.a.) that:
Where professional staff paid on a salary basis
work directly part-time on a research agreement,
current and reasonable estimates of time spent
may be used in the absence of actual time records.
These estimates were typically expressed as `percent
of effort," since a flat number of hours would have no
translatable value.
Faculty Resistance. In most institutions faculty members
have consistently held effort reports to be incompatible
with the creative processes of academic activity. The
effort report system is, to them, fallacious and meaningless
in that it rests on the assumption that it is possible to
partition, for purposes of record, an individual's intel-
lectual effort. A report, "The Effort Reporting Issue,"
prepared at Harvard University in March 1967, stated that
the phrase "percent of effort" is itself illogical when
one considers the question "percent of what?" "Within the
academic world," the Harvard report continued, "the con-
11-3
PAGENO="0041"
37
ception of an eight hour day and 40 hour week are as in-
congruous as a 40 hour day and an eight day week."
In addition, the academic environment particularly is
affected by the "joint product" phenomenon, under which two
separate benefits flow from the same effort. The most com-
mon example of this is a faculty member who simultaneously
is conducting research while guiding the activities of grad-
uate students engaged in that research as part of their
thesis requirements. Teaching and research duties are highly
interrelated, and their separation can be accomplished only
by an arbitrary and subjective process.
The Council of the American Mathematical Society enacted
a resolution at its meeting on August 29, 1967, urging re-
sponsible university officers to take action "to have Time
and Effort Reports and similar documents pertaining to fac-
ultymembers' time eliminated, because it considers that such
documents are incompatible with academic life and work. The
Council reiterates the traditional view that teaching and
research are inseparable, and that accounting procedures in
universities must take account of their unitary character."
Such faculty resistance could not be ignored, since in the
last analysis any documentation of effort devoted to a pro-
ject must originate with the individual.
Cost Sharing. The effort reporting problem was exacerbated
by the imposition of mandatory cost sharing, which requires
that the performer of a research grant or contract participate
"-4
PAGENO="0042"
38
in the cost of its performance. There had always been cost
sharing on a voluntary basis by universities, ever since
sponsored projects appeared there, primarily in the form of
direct faculty effort applied to such projects for which no
reimbursement was claimed. This practice arose from the con-
cept that faculty workloads customarily left some unscheduled
time to be used, at the individual's discretion, for purposes
of professional advancement -- writing, study, research, or
whatever. Such unscheduled time was devoted without charge
to sponsored projects. Voluntary cost sharing of this type
continues on a large scale today, even though the volume of
sponsored projects has grown dramatically. The resultant
demands upon faculty effort far exceed the unscheduled time,
however, and individuals must therefore be released from
other academic duties in order to accommodate the excess of
sponsored projects.
In 1965, cost sharing on research grants became a stat-
utory requirement, set forth in appropriation acts for several
agencies. Bureau of the Budget Circular A-74, issued in
December of that year to implement these statutory provisions,
instructed the agencies to require institutions to maintain
records demonstrating their participation in the costs of
each project. This necessitated effort reports even from
those faculty members who, since all of their salaries came
from institutional funds, had not had to prepare them prior
to the imposition of cost sharing.
11-5
PAGENO="0043"
39
At present, cost sharing requirements may arise either
from statutory provisions or agency regulations. The stat-
utory provisions have appeared each year in two appropria-
tions bills, one for the Labor-HEW Departments and the other
for the Independent Offices and the Department of Housing
and Urban Development, which includes.the National Science
Foundation and the National Aeronautics and Space Administra-
tion. The agency regulations are largely based upon 0MB
Circular A-lOO, `Cost sharing on research supported by Fed-
eral agencies," which replaced the earlier Circular A-74.
Circular A-lOO states in paragraph 5.b. that when cost
sharing is not required by statute, "agencies shall encourage
organizations to contribute to the cost of performing re-
search under Federal research agreements" under certain con-
ditions. The Department of Defense appropriation bills for
fiscal years 1966 through 1969 carried the same cost sharing
requirement as the Labor-HEW bill. This was dropped in
fiscal year 1970, and no statutory cost sharing has applied
to DOD since that time. However, that Department has con-
tinued to require cost sharing on research grants.
Interagency Task Force. Faculty resentment against effort
reports, aggravated by the cost sharing requirement, was
reinforced in many instances by Federal agency personnel.
Objections were sufficient to persuade the Budget Bureau in
late 1967, to designate an interagency taks force to review
the problem. Under the chairmanship of Cecil E. Goode of
11-6
PAGENO="0044"
40
BOB, the task force included members from the Defense Con-
tract Audit Agency, the General Accounting Office, the Na-
tional Institutes of Health, and the National Science Foun-
dation. Its report, issued February 23, 1968, followed
briefings by the Federal agencies, interviews on 21 campuses
with faculty and with academic and business administrators,
and subsequent discussion of findings with Federal officials
and university representatives.
The task force conclusions contain the following
(page 38 of the report):
Time or effort reports now required of faculty
/ members are meaningless and a waste of time.
They have engendered an emotional reaction in
the academic community that will endanger
university-Federal relations if relief is not
provided. They foster a cynical attitude
toward the requirements of government and take
valuable effort away from more important activi-
ties, not the least of which is the research in-
volved. We need to go to a system that does not
require documentary support of faculty time de-
voted to government-sponsored research. No real
evidence of faculty effort is provided anyway
under the present system, and there is no way
other than the research results themselves to
prove how much effort was in fact expended.
The task force report describes the negative attitudes
toward effort reporting (page 21), expressed not only by the
academic community as being impossible, meaningless, and a
disincentive, but also by the Federal agencies as being un-
realistic, unnecessary red tape, arid needlessly complicating
relations.
The task force recommendations included the following
(pages 39-43), which were largely adopted in a revision of
11-7
PAGENO="0045"
41
Circular A-21 in June 1968:
1. Adoption of an optional device known as stipulated
salary support, for use by faculty members and
any others engaged in part-time research and
part-time instruction. Under this procedure,
agreement is reached between the sponsoring a-
gency and the institution, during the proposal
and award process, as to the monetary value of
the contribution that the individual is expected
to make to the particular project. This amount,
once agreed upon, requires no subsequent documen-
tation and remains fixed unless there is a major
change in the individual's performance.
2. For those not using the stipulated salary sup-
port method, replacement of the effort reporting
system by one based upon institutional payrolls.
These payrolls must be supported by either (1) an
adequate appointment and workload distribution
system accompanied by periodic reviews by re-
sponsible.officials or (2) a monthly certification
system under which deans, department heads, or
supervisors would report any significant and
long-term changes in the workload distribution
of any professional. (As adopted in A-21, the
periodic reviews specified in (1) above were
prescribed as monthly, and the certifications
specified in (2) were to be made by one with
first-hand knowledge of the services performed
on each research agreement.)
Subsequent Developments. The stipulated salary procedure
has found virtually no acceptance in the academic community.
No explanation can be found for this. The only tenable theory
is the inflexibility of the procedure. Circular A-21 states
(section J.7.e.): "The stipulated salary for the academic year
will be prorated equally over the duration of the. grant or
contract period during the academic year, unless other arrange-
ments have been made in the grant or contract instrument." This
means that minor variations cannot be reflected in the charges.
Accordingly, the alternative payroll-based system has
11-8
PAGENO="0046"
42
been used, which involves monthly after-the-fact reviews or
certifications that have all of the defects of the original
effort reporting system. Although the payroll-based system
does not require effort reports as such, the resulting pro-
cedures were tantamount to effort reports, and for this rea-
son a number of institutions have continued the effort re-
porting system. A proposal was made in January 1977, by the
Department of Health, Education, and Welfare to the Office
of Management and Budget that the effort report system be
revived.
The Commission analyzed a 1976 survey made by NACUBO
of universities heavily involved in sponsored programs. Of
53 responses, 37 stipulated the documentation of personal
service charges, including cost sharing, as among the most
burdensome of recordkeeping requirements because of the con-
siderable internal paperwork generated by this process. The
extreme decentralization within the institution of the effort
reporting procedure makes it difficult to obtain estimates
of costs in dollars or in hours. The University of Iowa
estimates an annual requirement of 2,400 man hours. Another
estimate, 1,800 hours including 500 on the part of faculty
members, was made by a State university in the Rocky Moun-
tain area.
The Commission finds that:
o The stipulated salary support method has not
been found to be in use at any institution
with a sizable involvement in sponsored programs.
11-9
PAGENO="0047"
43
o The institutional payroll system, with monthly
after-the-fact reviews or certifications, is
producing results that are laborious to the
institutions and unsatisfactory to the agencies.
o The requirement for demonstrating cost sharing,
to the extent that cost sharing is in the form
of contributed professional salaries -- which
is the most common form -- is an added diff i-
culty. Cost sharing by definition is not a
payroll allocation, so that the required doc-
umentation must be outside the payroll system.
o The Commission on Government Procurement, in its
Recommendation B-8, proposed the elimination of
cost sharing on research and development pro-
jects except in cases where the performer would
clearly benefit, for example, through economic
benefits from commercial sales. The arguments
in favor of this recommendation (B-8) appear on
pages 26-28 of Volume II of that Commission's
final report. A special task group, charged
with proposing an executive branch position on
the recommendation, submitted a report in Jan-
uary 1976, affirming the recommendation for the
elimination of cost sharing.
Recommendation No. 1
With respect to serviOes for which charges
are made against the grants or contracts
involved, the Director of the Office of
Management and Budget should:
o Inquire into the reasons for the
failure of colleges and universities
to use the stipulated salary support
option set forth in 0MB Circular A-21;
o Determine whether it is feasible to
revise the terms of the option to
accommodate these reasons; and
o Confer with the Cost Accounting Stand-
ards Board to assure consistency with
the Board's requirements.
11-10
PAGENO="0048"
44
Recommendation No.2
With respect to services for which no charge
is made but which nevertheless must be doc-
umented in order to demonstrate cost sharing,
the Commission endorses the position of the
Commission on Government Procurement, in its
Recommendation B-8, concerning the elimina-
tion of mandatory cost sharing on research
and development projects, except in cases
where the performer would clearly benefit.
These recommendations were adopted by the Commission
December 3, 1976. In response, the Director of 0MB replied
to the Commission February 2, 1977, agreeing that the stip-
ulated salary support option would result in a considerable
paperwork reduction and stating that his Office would inquire
into the matter. "If, as a result of that inquiry," wrote
the Director, "it appears feasible to revise the terms of
the option to assure its more frequent use, we would be
glad to consider such a revision." The Director further
pointed out that cooperation and coordination with the Cost
Accounting Standards Board had been regularly maintained
and would continue with respect to any changes in Circular
A-2l.
The Acting Administrator of the Office of Federal Pro-
curement Policy replied to the Commission on March 3, 1977.
He stated that a "policy document which would implement a
number of the Commission on Government Procurement recom-
mendations, including. B-8 on cost sharing, is under consid-
eration."
11-11
PAGENO="0049"
45
Accounting for Nonexpendable Property Purchased by Grantees
Administration of Federal grants usually entails the
use of equipment or other nonexpendable personal property.
For property on hand, grantees are normally reimbursed
through depreciation allowances or use charges generally
treated as indirect costs. However, it is sometimes neces-
sary for a grantee to acquire equipment for a specific pur-
pose as part of the direct cost, particularly in the case
of scientific research. In this event, with the prior ap-
proval of the grant-making agency, the full acquisition
cost can be treated as an allowable direct cost.
Once the property is acquired, the grantee must account
to the Federal Government for its use and, when the property
can no longer be used in connection with Federal awards,
must reimburse the Government for its share of the fair
market value or proceeds from sale. During the period of
time in which there is a Federal interest in the property,
the grantee has to maintain prescribed property management
standards including property records.
These regulations impose a substantial reporting and
recordkeeping burden on colleges and universities. In a
1976 survey by NACUBO of 53 institutions heavily involved
in Federally-sponsored research, 30 rated the mangement and
control of property as among the most burdensome Federal
recordkeeping requirements. Although the Commission focused
on higher education, our recommendations, below, are pertinent
to apply to other grantees as well.
11-12
91-8600-77--4
PAGENO="0050"
46
Grantees contend that the rules to carry out account-
ability provisions are complex and budensome. For. example,
a grantee or subgrantee is required to:
o Maintain property records including a descrip-
non of the property, manufacturer's number,
acquisition date and cost, percentage of Fed-
eral participation, location, use and condition,
etc;
o Conduct a physical inventory at least biennially,
investigate differences between the inventory
and accounting records, and verifycurrent utili-
zation and continued need for the property;
o Maintain a control system to prevent loss, damage
or theft;
o Implement adequate maintenance procedures;
o Use property in accordance with Federal regu-
lations and priorities;
o Establish proper sales procedures to assure
competition when property must be sold.
These rules are cited from Attachment N of 0MB Cir-
cular A-lb1 which is discussed later in this section. In
its Attachment N, which sets forth property management stand-
ares, the Circular establishes a standard definition of non-
expendable property (equipment costing $300 or more with a
useful life of more than one year) in place of the welter
of definitions previously used by different agencies..
Equally significant, the Circular raises to $1,000 the thresh-
old of nonexpendable property which grantees are permitted
to use for other activities without reimbursement to the
Federal Government, after that property is no longer needed
for Federal grant programs.
11-13
PAGENO="0051"
47
Although the rules in A-hO are a distinct improvement
over previous regulations, they are still burdensome and
costly for grantees. Furthermore, some Federal adrninistra-
tors are of the opinion that Attachment N of the Circular
is in some respects overly simplistic, and that even more
elaborate rules will have to be worked out to implement cer-
tam provisions. For instance, the regulations in A-llO ex-
tend to the entire universe of non-governmental recipients,
subgrantees, and cost-contractors as well as to the original
grantee. But the Circular does not explain how the account-
ability provisions are to be applied to subgrantees. If
the property is sold, for example, how is the Federal share
to be computed when title vests conditionally with the sub-
grantee? According to knowledgeable Government officials,
an even more complex body of rules will be required to deal
with this problem and others.
Burdens on Grantees. Compliance with the property mangement
requirements frequently imposes substantial administrative
costs on grantees. For instance, the University of Rochester*
estimates that it requires a minimum of two man-years annually
merely to maintain equipment listings and report thereon.
Another estimate of three man-years annually was supplied
by the University of Washington.
A study by the University of California, San Diego,
reveals the futility of much of the paperwork resulting from
Federal regulations. The study found that a substantial per-
11-14
PAGENO="0052"
48
centage of property at the University was either Government
property or property acquired with Federal grant~ and con-
tracts and subject to Federal regulations. According to
the study:
The resulting administrative burden is
significant. Title to almost all this
equipment (University officials estimate
99 percent) will eventually be vested
in the University or the property will
be used exclusively by the University
during the life of the property. During
these years, the cost and other burdens
on the University are substantial. These
are reflected in unnecessary records, un-
productive and expensive reports and re-
strictions which prohibit full utiliza-
tion of the property.2
Particularly onerous was the requirement for the physical
inventory.
There is also some evidence that Federal regulations
actually interfere with what is normally considered good
property management. For example, Circular A-lb does not
address the question of "trade-ins,t' and the issue is sub-
ject to different interpretations by the various agencies.
Some Government officials and grantees believe that colleges
and universities are inhibited by the regulations from
trading in equipment for newer or more recent models while
the original equipment still has commercial value -- some-
thing they would normally do under good property management
standards. They are reluctant to do it because of the paper-
work involved and the requirement to reimburse the Government
for its share. The University would have to return to the
11-15
PAGENO="0053"
49
Government a percentage based on the Government's original
contribution while itself absorbing the price differential.
Level of Accountability. There is convincing evidence that
the present threshold for accountability, that is, the mini-
mum value of property subject to Federal recordkeeping require-
ments, is unrealistic. NACUBO, commenting on the record-
keeping responsibilities set forth in Attachment N of 0MB
Circular A-llO, asked for certain data from constituent in-
stitutions that are heavily involved in Federally sponsored
projects. The brackets suggested were $300 to $1,000, $1,000
to $5,000, and more than $5,000 of unit cost. The $300 min-
imum was chosen because that is the minimum unit cost of
property that Circular A-lb defines as nonexpendabie and
thus subject to recordkeeping requirements.
Twenty-four institutions were able to report such
studies. They indicated that, if such recordkeeping re-
sponsibilities were limited to property with a unit cost
of $5,000 or more, the number of items would drop by more
than 90 percent while more than 55 percent of the total
dollar value would remain on the list. If the accountability
level were increased only to $1,000, the number of items on
which recordkeeping was required would drop by 63 percent,
while more than 82 percent of the dollar value would be re-
tained.
The Question of Accountability. Raising the level of ac-
countability from $300 to $1,000 would be an improvement over
existing requirements and would substantially reduce the
11-16
PAGENO="0054"
50
recordkeeping burden on colleges and university. Logic and
evidence, though, compel the Commission to raise a more
fundamental question: do the regulations serve a useful
national purpose? Regardless of the level of accountability,
the paperwork burden resulting from the regulations can be
justified only if the accountability serves a useful pur-
pose.
The major argument advanced by Government officials3 in
support of accountability, briefly stated, is:
Since property may have a useful life beyond
the immediate objectives of the grant, the
Federal Government has a responsibility to
see that it is used for appropriate public
purposes and to recover the value of any re-
maining useful life when the property can
no longer be used for authorized purposes.
This argument treats the unused life of the property,
its remaining value, as the residue of grant funds or, in
other words, unspent money from the grant. However, it can
be shown that the accountability provisions for grants are
not an absolute necessity and that they do not always serve
a useful national purpose.
Waiver of accountability can be justified as consistent
with proper accounting practices for Federal funds. To
treat property as the residue of a grant is a fully acceptable
accounting approach, but it is only one approach. It is
equally correct to take another approach that treats property
as the residual benefit, not residual funds, from the grant.
Under one recognized accounting approach, the full acquisi-
tion cost of the property is part of the cost of the grant
11-17
PAGENO="0055"
51
and allocable to the grant period in which acquired. (In
other words, the cost of the property is charged in full to
the grant, and is therefore justified and accounted for
during the life of the grant itself.4 Federal responsibility
ends when it is determined that the cost of the property is
necessary and reasonable to achieve the purposes for which
the grant is being made.)
Therefore, there is no residue of the grant, but rather
a residualbenefit to the grantee from the grant, analogous
to other long-term benefits resulting from a grant. For
example, curriculum development projects supported with Fed-
eral grants often confer additional benefits on the grantee,
but no one claims that the Government is. owed any money for
these increased benefits. Similarly, most agencies waive
their right to royalties resulting from copyrights that have
been developed under Federal grants.
To extend to the grantee the long-term benefits of
property is consistent with Federal policy for grants. This
is intended to provide (financial) assistance for programs
or projects in the national interest, many of which continue
after Federal funding ends. One must also add that Circular
A-llO now extends to grantees the right to use property ac-
quired under one grant on other Federally-assisted projects
and even on projects no longer supported with Federal funds.
Since the Government has already extended the rules so far,
giving grantees some benefits, there appears to be little,
11-18
PAGENO="0056"
52
if any, justification for the existing restrictions.
Furthermore, Congress has already recognized situations
when the accountability provisions are not in the public in-
terest, and it has waived accountability for a large category
of programs in several important classes. The Grants Act,
P.L. 85-934, gives agencies discretionary authority to vest
title to equipment purchased with grant or contract funds
without further obligation to the Federal Government, for
the conduct of basic or. applied scientific research at non-
profit institutions of higher education or at nonprofit
organizations whose primary purpose is the conduct of
scientific research. The General Education Provisions Act,
P.L. 91-230, permits the Commissioner of Education discre-
tionary authority to vest title to equipment purchased with
grant or contract funds at local educational agencies and
State educational agencies, without further obligation to
the Federal government.
The rationale for waiving accountability in the Grants
Act was twofold: to increase U.S. scientific research cap-
ability by developing the resources of institutions and
organizations, and to reduce Federal costs for accounting,
shipping and disposition of equipment, on the grounds that
such costs would far exceed the use value to the Government
of much of that property. Similar arguments were advanced
for the waiver of accountability in the General Education
Provisions Act.
11-19
PAGENO="0057"
53
In those cases where accountability has not been waived,
the Commission has not been able to find hard evidence that
the property provisions are being enforced. For example,
no one on the staff of the Finance Offices of the Office of
Education and the Office of Human Development (HEW) can cite
for any recent time period how much money, if any, had been
returned to the Federal Government representing the Federal
share of equipment acquired under its grants, or even the
total dollar value of equipment purchased under its grants.
The lack of response to these questions indicates that there
is a large body of rules that are extremely difficult to
enforce.
Furthermore, some Federal officials believe that any
attempt to enforce the regulations, given their other re-
sponsibilities and the complexity of the rules, would be
extremely difficult, perhaps impossible. For instance, the
HEW Audit agency acknowledged that it was very difficult to
determine whether a grantee was in compliance with the
property regulations, that is, whether the property was
being used for authorized purposes, particularly at larger
institutions with multiple research projects.
Agency Burdens. The Commission has attempted *to discover
how the Government monitors compliance with property regu-
lations. No cost data are available, but discussions with
agency staffs indicate that implementation of property regu-
lations is costly and burdensome and produces little, if
any, appreciable return to the Government.
11-20
PAGENO="0058"
54
For instance to effect disposition of property when
the grantee can no longer use it for authorized purposes,
the agency must first describe the item and put it on an
excess property list which is then sent to .every Government
agency for screening An OE official estimates the cost of
the entire screening process to be.$55 per line item. If
no agency can use the property, the General Services Admin-
istration declares it surplus and makes it available for do-
nation. Some officials question whether the returns to the
Government, often negligible since the property has depre-
ciated in value, justify the cost of these procedures
The same point was the principal reason for an unsec-
cessful HEW attempt to extend the Grants Act in 1969, an
effort supported by six other agencies. In the draft of a
cover letter to Congress, the Secretary said, in part,
The additional administrative workload and
cost of such procedures (governing property)
contribute nothing to furthering the research
and training program purposes of the Depart-
ment and result in no appreciable economy.
Equipment which grantees or contractors pur-
chase with Federal funds is equipment they
need to carry out their Department-supported
research and training program operations,
which are usually only a part of their con-
tinuing research and training functions.
Since the continuing functions are almost
always in the same general program area as
the Department-supported activity, such
equipment.should normally continue to be
available for use in program areas of in-
terest to the Department without imposing
an obligation on the institution to estab-
lish and maintain records and to undertake
* other procedures that serve little useful:
purpose
11-21
PAGENO="0059"
55
Recommendation No. 3
The Director of the Office of Management and
Budget should consider changing from $300 to
$1,000 the minimum value of property acquired
under grants that is subject to accountability
provisions.
Recommendation No. 4
The Director of the Office of Management and
Budget should undertake further study to de-
termine if the burden on grantees and agencies
associated with accounting for nonexpendable
property is indeed excessive, whether the re-
turns to the Government are commensurate with
the costs of enforcing the regulations, and
whether other, more efficient means can be
devised to protect the Federalinterest.
These recommendations were adopted by the Commission on
rebruary 25, 1977. In response, the Director of 0MB replied
to the Commission cn March 28, 1977, that the study specified
in Recommendation No. 4 would be undertaken as part of OMB's
continuing program to update its Circulars. This study,
wrote the Director, will consider whether the $300 criteria
should be changed.
*DHEW Federal Assistance Financing System
In recent years, the Federal Government has attempted
to simplify and standardize payment procedures for Federal
grants and contracts. One such effort, the HEW Departmental
Federal Assistance Financing System (DFAFS), represents a
significant advance in fiscal reporting and management which
substantially reduces the paperwork burden on recipients of
Federal awards. The advantages of the system have not been
I 1-22
PAGENO="0060"
56
seriously explored by other agencies or departments. If
extended in some form to other Federal agencies, substantial
financial and paperwork savings could be realized by both
the Government and recipients
DFAFS is a computerized system that provides to a re-
cipient organization a consolidated payment on all its HEW
programs, rather than individual payments for each grant or
contract. As of October 1975, DFAFS was handling approxi-
mately 80 percent of HEW grants and "assistance-like con-
tracts," or approximately 53,000 awards with funding in ex-
cess of $8 5 billion
The system is designed to facilitate the payment pro-
cess by standardizing expenditure reports and providing a.
single central location in HEW for award payments --a
significant advance for a department as highly decentralized
as HEW. In effect, DFAFS functions as a fiscal intermediary
between the agencies and recipient organizations; that is,
it provides .cash as needed to recipients and collects sum-
mary expenditure data from them. This is fed into the ac-
counting offices of the various agencies for the fiscal
management of programs and for updating records.
As an advance funding system, DFAFS utilizes two basic
payment mechanisms -- the letter of credit and the monthly
cash request. Criteria for determining the method of pay-
ment are governed by Treasury regulations, specifically
Treasury Circular 1075. To qualify for a letter of credit
11-23
PAGENO="0061"
57
under these regulations, a recipient must have continuing
business transactions with HEW aggregating at least $250,000
annually. Of the approximately 14,000 recipients in DFAFS,
68 -- primarily larger universities, but also including
seven States and one territory -- receive letters of credit.
For instance, New York State has one letter of credit
for all State agencies (health, welfare, etc.) and the Uni-
versity of the State of New York has a separate one for its*
64 campuses. The letter of credit operates through the U.S.
Treasury, a Federal Reserve Bank, and the recipient's bank.
An authorization is established in an amount based on the
recipients's average monthly expenditures for all HEW pro-
grams, and recipients can draw on this amount as needed
simply by presenting a payment voucher at their local bank.
The monthly cash request -- a procedure used by the
majority of DFAFS recipients, approximately 13,900, whose
business relationships with HEW do not exceed $250,000 per
year -- provides cash in advance to cover anticipated ex-
penditures for the succeeding month. To obtain payment,
one form is submitted for all HEW programs indicating, in
summary form, available cash on hand and anticipated ex-
penditures for the coming month. Normally, it takes the
Treasury seven to ten days to honor the request. Thus, if
the form reaches DFAFS by the 25th of the month, a Treasury
check should be in the hands of the grantee or contractor
early the following month.
11-24
PAGENO="0062"
58
Each quarter, DFAFS furnishes recipients a report show-
ing the authorized amount for each award and a listing of
both active and expired awards held by the recipient. The~
recipient compares this report with its records and corrects
and completes the form showing cumulative expenditures to
date for each award The Commission finds that
o DFAFS provides recipients a single point of
contact within HEW for cash~ matters. Even
in a small agency, grantees frequently deal
with several different offices (program,
grants, finance) on matters relating to
award payments. Obviously, the situation
becomes more complex when an institution
has multiple grants and contracts from
different offices within an agency as large
and widespread as HEW. Merely identifying
the appropriate official who can handle the
problem frequently results in delays and
unnecessary paperwork for the grantee.
o DFAFS significantly cuts paperwork by re-.
ducing the bookkeeping and reporting on
grants and contracts. One can best il-
lustrate this by comparing the billing
and reporting requirements for DFAFS with
those for other Federal agencies.
One major university currently has 175
awards under DFAFS and 22 from all other
agencies. The latter represents only 8
percent of the institution's total Federal
funding. Four full-time staff are required
for billing on the 22 awards; no full-time
person is needed for the DFAFS account.
Each month staff must submit a separate cash
request for each of the 22 awards not granted
by HEW and an additional form summarizing all
cash transactions with each agency. The
forms themselves are relatively simple; how-
ever, the bookkeeping required to collect the
data is extremely burdensome and time-consuming
because 22 different accounts are involved.
For instance, staff must complete a monthly
cash reconciliation for each account, martipu-
late that data to fit the different reporting
* requirements of each agency, then estimate the
* 11-25
PAGENO="0063"
59
next month's expenditures for each award,
and reconcile these figures with the pre-
vious month's. Since DFAFS, on the other
hand, requires only total anticipated ex-
penditures.for all programs, far less
bookkeeping is required.
Additional paperwork is created when the.
Treasury checks are received at the insti-
tution. Since neither the funding source
nor the award number is always clearly in-
dicated on the checks, considerable time is
spent matching the check to the appropriate
award. Here again, the contrast with DFAFS
is striking. A single check is received
for all DFAFS awards and assigned to a single
cash account.
o DFAFS enables recipients to gauge their needs
and manage funds better by making available
one lump sum each month. Officials at George-
town University and Johns Hopkins report
that, since the system was introduced, their
accounts for Federal funds are balanced for
the first time. Knowing the total Federal
funds unexpended and the exact amount due
them at any one time, recipients can plan
and manage their funds more. efficiently.
o `Consolidation of payments under DFAFS helps
minimize cash flow from the Treasury and thus
reduces the amount of interest the Treasury
must pay on borrowed funds. A conservative
estimate from the Treasury is that in fiscal
year 1975 DFAFS provided interest savings of
approximately $20 million.
These savings result from DFAFS' more efficient
use of Federal funds. Treasury regulations
require grantees to time their payment requests
or draw-downs as closely as possible to aàtual
expenditure needs. However, where payments
are not consolidated, grantees frequently
do not draw on a needs basis, but rather
reserve a small residue of Federal funds
from each award to cover any unforeseen
expenses, because they cannot use money from
one account to cover expenditures on another.
In contrast, DFAFS creates a single cash pool
11-26
PAGENO="0064"
60
for recipients which permits them to use
those funds as needed for any DFAFS award.
Recipients are thus able to monitor and
control cash flow better while keeping the
balance of Federal funds at the institution
to a minimum.
Although DFAFS offers distinct advantages to both recipients
and the Federal Government, one problem with the system must
be acknowledged. That~is the inaccuracy of data often supplied
to DFAFS by the HEW agencies, which creates difficulties for
the institutions in reconciling their DFAFS accounts. The
DFAFS staff is fully aware of the problem and has initiated
efforts to correct this deficiency.
For instance, DFAFS and, agency staff have been working to
standardize financial data elements on award letters, the
initial amd crucial source of information for both DFAFS and
recipients. Literally hundreds of different award forms are
currently being used by HEW. These often have confusing entries
such as two different locations in HEW for payment. Standardiza-
tion of the data elements is expected to alleviate many of the
problems involved in reconciling DFAFS accounts with the
recipients' own records, thus promoting a closer relationship
between DFAFS and its 14,000 recipients.
Despite this problem, universities approached by the
Commission are still enthusiastic about DFAFS. Their chief
complaint is that more Federal programs are not covered by the
system. The Commission also found an enthusiastic endorsement
of DFAFS among officials at Treasury and 0MB, although there
is no consensus on precisely how the model might be expanded
11-27
PAGENO="0065"
61
or adapted to other Federal programs. Some officials believe
that other agencies and departments., particularly larger
ones with different components and offices dealing with the
same kinds of recipients, night establish comparable systems--
paralleling DFAS--with the same standardization. of concepts,
reporting levels, and procedures. Another option is to expand
DFAFS eventually into a single centralized payment system for
the entire Federal Government.
Whatever the merits of these proposals, the Commission's
research confirms that the system has a potential that should
be explored more fully to the advantage of both recipients
and other agencies of the Federal Government.
Recommendation No. 5
The Commission on Federal Paper~ork endorses
the concept of DFAFS as an effective way of
streamlining the payment process and reducing
paperwork in one important area of grants and
contracts administration.
Recommendation No. 6
The Office of Management and Budget and the
Department of Treasury should systematically
evaluate DFAFS and explore ways of expanding
the system to other Federal programs.
11-28
91-8600-77--5
PAGENO="0066"
N\1
62
These recommendations were adopted by the Commission on
December 3, 1976. In response, the Director of ÔMB replied
on February 2, 1977 that "We endorse the concept of a con-
solidated payment system such as the one used by HEW. It is
our understanding that Treasury is systematically evaluating
the HEW system, and exploring ways of expanding the system
to other Federal programs."
0MB Circular A-llO
On July 1, 1976, 0MB issued Circular A-lb establishing
"uniform administrative requirements for grants and other
agreements with institutions of higher education, hospitals.,
and other nonprofit organizations." This Circular, whose
initial implementation process will have been completed early
in 1977, will reduce substantially the paperwork burden on
the nonprofit sector to which it applies.
Although Circular A-llO applies to virtually all grants
awarded to the nonprofit sector, it covers only a small fraction
of the contracts performed by these organizations. The sub-
stantial contribution that the Circular makes to the reduction
of recordkeeping,-~reporting, and other burdens could be
enhanced considerably if the standards set forth in the
Circular could be made applicable, where appropriate, to the
majority of Federal contracts for~-research, training, demonstra-
tion, and public service that are performed by nonprofit
institutions and organizations. In the absence of expanded
11-29
PAGENO="0067"
63
coverage, there will be only partial realization of the poten-
tial benefits of Circular A-ll0.
Histoi~y. The Circular is the outcome of aneffort originated in
September, 1970, by an interagency task force established by 0MB.
Between that date and February, 1975, when it was published
in the Federal Register in proposed form, drafts were subject
to circulation, review, discussion, and comment by interested
parties in and outside the Government. Further comments on
the published material were numerous, and the Circular was
issued in its present form July 1, 1976.
The original intention of the task force had been to embrace
both grants and contracts, excluding only such specialized
concerns as systems development or hardware production, ser-
vices to Federal employees or their beneficiaries, operation
of federally-funded research and development centers, the
Reserve Officers Training Corps, the Medicare program, and any
awards providing for a fee or profit or based primarily on
cost competition. To obtain agreement from the agencies,
however, and to provide consistency in the grants area, 0MB
limited the Circular's initial coverage to awards that are
not required to conform to procurement regulations.
Circular A-ll0 includes 15 Attachments, each establishing
standards in a given area. These are:
11-30
PAGENO="0068"
64
A. Cash Depositories
B. Bonding and Insurance
C. Retention and Custodial Requirements for Records
D. Program Income
E. Cost Sharing and Matching
F. Standards for Financial Management Systems
G. Financial Reporting Requirements
H. Monitoring and Reporting Program Performance
I. Payment Requirements
J. Revision of Financia.l Plans
K. Closeout Procedures
L. Suspensiom and Termination Procedures
M. Standard Form for Applying for Federal Assistance
N. Property Management Standards
0. Procurement Standards 5
Certain aspects of Attachments I and N were discussed earlier
in this section.
Limitation. The Circular applies to "grants to, and other
agreements with" the nonprofit sector. It excludes
from the tern "other agreements," however, "contracts which are
required to be entered into and administered under procurement
laws and regulations." Most agencies are permitted by statute
to issue either a grant or a contract for the bulk of the programs
conducted for them by the non-profit sector. Their contracts,
when they decide to use that instrument, are subject to the
applicable procurement regulations, with very few exceptions.
Thus, the great majority of contracts performed in the nonprofit
sector remain unaffected by Circular A-llO.
Both grants and contracts have been successfully used for
research, training, and other types of programs performed by
colleges, universities, and other nonprofit organization~~ The
failure of Circular A-llO to cover contracts means that a large
11-31
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65
body of agreements will continue to be subject to a multitude
of differing policies, procedures, and administrative require-
ments that are inconsistent, confusing and burdensOme.
Financial Reporting. The Commission examined in detail Attach-
ment G, Financial Reporting Requirements, as an example of the
items covered by Circular A-llO. This.topic was chosen because
fiscal reporting directly involves paperwork and because both
university and Government representatives have recognized it
as a problem. Although the problem affects both grants and
contracts, the uniform standards prescribed by Attachment G
are expected to resolve most of the difficulties under grants.
The problems under contracts fall into four categories:
1. The fact that forms differ from one another requires
respondents to master separate sets of instructions
and apply them as reports fall due. It also inhibits
the use of data processing techniques in providing
financial information.
2. Duplication of data arises largely from the dual
purpose of financial reporting. Reports are used
in conjunction with the payment procedure as a means
of fiscal control. They are also used as a management
tool in monitoring contract performance. Such moni-
toring can indicate potential overruns, underexpenditures,
delays, or other significant variations from prior
estimates. Manpower data are frequently included as
part of financial reports, although this information
is not of a fiscal nature.
Despite the differences. in purpose, the report forms
used for financial control and for performance moni-
toring share, to a striking extent, many of the same
details.
3. The troublesome requirements for detailed itemization
arise less frequently frOm the offices responsible
for payment and financial management than from program
managers charged with monitoring contract performance.
11-32
PAGENO="0070"
66
These details often involve individual analysis
since they go beyond what the contractor's ac-
counting system normally records, although the
full detail is always available for audit pur-
poses. It is difficult for contractors to
understand the need or the use for the amount
of itemization demanded.
In many cases, program managers also require a
complete breakdown of the hours or man months
devoted to the contract by each employee. De-
tails of time spent by hourly-paid employees
are usually available in the accounting system.
The man-month data for salaried employees, how-
ever, are not normally recorded in the financial
ledgers but are more often available in the
division or department where the contract is
performed and where the periodic technical
progress reports are prepared. (Attachment H
of Circular A-llO sets forth procedures for
these reports.)
Manpower data might therefore more properly
be included as a part of these progress re-
ports, which are the major source of infor-
mation used for monitoring the contractor's
performance. This would avoid the necessity
of shuttling partially completed report forms
back and forth between two divisions of the
institution that may be some distance apart.
4. The frequency with which financial reports
must be submitted varies widely. Some pro-
grams specify only a final report while others
may require them as often as monthly. Exces-
sive frequency is particularly burdensome
when considerable detail is demanded, less so
when only basic figures are required.
In a 1976 survey conducted by NACUBO, nearly 75 percent
of the respondents (39 out of 53) considered financial re-
porting problems to be among the most burdensome in the
grant and contract field. A~ large western institution esti-
mated that 9,200 staff hours were spent on the preparation
of 909 fiscal reports during fiscal year 1976. A smaller
southern university provided a figure of 4,836 hours, and a
11-33
PAGENO="0071"
67
midwestern institution, whose program is relatively small,
reported 5,474 hours Another western university estimated
a saving of at least 1,500 hours if the forms w~~re designed
to permit use of a computer in their preparation A large/
private eastern university stated that "at least 20 man
/ I
years is expended each year at _______ in preparing fis~al
reports This institution agreed that computer use would
result in large economies but stated that the actua' savin~
would depend upon the degree of difficulty and detail in-
volved in any standard form
The differences in individual forms aggravate the pro-
blem One large northeastern university stateNd that the
types of expenditures incurred under agency awards really
do not vary much at all, yet we must adapt theNdata from
our accounting records to these various formats
Fiscal reporting burdens have also been recognized by
Government personnel.. The Department of Health, Education,
and Welfare, for example, established in the early autumn
of 1976, a task force to study the problem and devise stand-
ard forms and instructions for fiscal reports on contracts.
The task force proposals are designed to eliminate unneces-
sàry forms and to permit the use of the same forms for both
fiscal management and program monitoring. The latter pro-
posal arises from the task force's finding that the data
required for these two purposes was largely repetitive,
consisting primarily of a summary of expenditures, *current
11-34
PAGENO="0072"
68
and cumulative, made by the contractor
Financial reporting requirements are in many cases
excessive in detail and in frequency A considerable paper-
work saving could be realized if
o the same form were used for program monitoring
and for fiscal control since essentially the
same data is used for both purposes
o the amount of detail and the frequency of re-
* ports were limited to what is needed and used;
o fiscal reporting forms were standardized so
that requirements were compatible and suscep-
tible to computer technology; and *
o manpower data were excluded from financial re-
ports and incorporated, where needed, as part
of the technical program progress reports de-
scribed in Attachment H to Circular A-hO
In considering the application of Circular A-llO to
contracts, one fact must be observed Contracts are gen-
erally subject either to the Federal Procurement Regula-
tions or the Armed Services Procurement Regulation. Several
of the Attachments to Circular A-llO deal with topics not
treated in these procurement regulations. Where the same
topics are addressed by both, there may be some conflicts
which would require modifications in Circular A-lb so that
compliance with the procurement regulations can be assured.
Basically, however, the Circular can be applied readily,
in large measure, to the majority of contracts for research,
training, demonstration, and public service that are gen-
erally performed in colleges, universities, hospitals, and
other non-profit institutions Such application would not
11-35
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69
in any way blur the distinction between contracts and grants.
The identity of each of these instruments can and should be
preserved.
Recommendation No. 7
The Commission on Federal Paperwork
endorses the action of 0MB in establishing,
by means of Circular No. A-hO, a set of
standard administrative requirements that
will substantially reduce the burdens on
the nonprofit organizations to which the
Circular applies.
Recommendation No. 8
The Director of the Office of Management
and Budget is urged to extend application
of Circular A-llO, as earlier contemplated,
to contracts performed by the nonprofit
sector, wherever such action is appropriate.
Revisions to the Circular, or alternative
standards, should be provided where neces-
sary to conform to the major procurement
regulations.
11-36
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70
Protection of Human Subjects
The use of human subjects in biomedical and behavioral
research has been the focus of considerable concern in re-
cent years. The great bulk of this research is performed
under the aegis of HEW, and that Department has developed a
set of comprehensive regulations designed to provide pro-
tection of human subjects. Other agencies that sponsor such
research have also proposed regulations, constraints, and
injunctions on those who perform the research. Some of
these are inconsistent with and simetimes in direct conflict
with the HEW regulations. As a result, organizations per-
forming research involving humansubjects face reporting
and recordkeeping requirements that are confusing, duplica-
tive, incompatible, and thus unnecessarily burdensome.
Testimony at a Commission hearing in Nashville, Tennessee,
on January 8, 1976, by Lewis Lavine, Assistant to the Vice
Chancellor of Medical Affairs at Vanderbilt University, de-
scribed the magnitude of the problem. A clinical investi-
gatians committee there which oversees such research has 20
highly trained members, meets for two hours twice a month,
and requires 6,000 pieces of paper to complete its assigned
agenda.
HEW. The Public Health Service (PHS), a component of HEW,
has for some time been concerned with the protection of
human subjects in clinical investigation and other projects
carried on under its grants and contracts. The first formal
Government regulation covering extramural programs was is-
11-37
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71
sued in 1966. It was preceded by a long history of study,
debate, and consideration, which is documented in a mono-
graph by Dr. Mark S. Frankel.6 The formal regulation,
Policy and Procedure Order 129, was issued by the PHS on
February 8, 1966, and copies were sent to all grantees and
contractors by the National Institutes of Health, (NIH) and
other PHS units.
This Order required grantees to review all applications
for clincial research and investigation, to take steps for
consent by and protection of human subjects, and to provide
assurance in the grant application of compliance with PHS
policy. It was modified on July 1, 1966, when the require-
ment for separate assurances for each grant application was
replaced by one for an institution-wide general assurance
that would cover all subsequent applications from that in-
stitution.
In 1971, HEW adopted a similar policy as a Departmeflt
wide statement, incorporated as Chapter 1-40 of the HEW
Grants Administration Manual. The policy, no longer limited
to the health field, applied to all HEW-sponsored programs.
7
It also firmly established NIH as the cognizant agency with-
in HEW to which the assurances and reports required by the
policy were to be directed. Both of these policies have
remained in effect.
The HEW rules were subsequently strengthened and codified
as Part 46 of Title 45of the Code of Federal Regulations
11-38
PAGENO="0076"
72
~(45 CFR 46). Notice of proposed rulemaking appeared in the
Federal Register October 9, 1973. Final rules were published
May 30, 1974, (reprinted with some technical amendments
March 13, 1975,) comments in the interim having been received
from more than 200 sources
ERDA Proposed rules for the protection of human subjects
were published by the Energy Research and Development Admin-
istration (ERDA) in the Federal Register on August 17, 1976..
The preamble to the proposed rules stated that they were
"substantially the same as those adopted by the Department
of Health, Education, and Welfare There were sufficient
differences, however, to stimulate considerable comment,
and the agency, in announcing its final rules (10 CFR 745)
in. the Federal Register for November 30, 1976, included the
following statement
Although ERDA intended to substantially dupli-
cate the policies and procedures adopted by .
HEW (40 FR 11854, March 13, 1975,) comments
received in response to the proposed regula- .
tions identified differences that needed to
be resolved between the two sets of regulations.
Some of these differences are described below
o Institutional Review Boards. . The proposed
ERDA regulations stated that no Board shall
consist of a majority of persons who are
officers, employees, or agents of, or are
otherwise associated with the instItution,
apart from their membership on the Board
(emphasis added) This language differed
from HEW's, which stated that such officers,
employees, or agents may not constitute an
entire Board. ERDA's final rule (745.6(b)
* * T4)) was identical to that of HEW, acceding .
to comments. These comments pointed out,
among other compelling arguments, the dif- .
ficulty of finding, persons outside the in-
stitution, particularly those not located
in metropolitan areas, with sufficient ..
11-39
PAGENO="0077"
73
experience and expertise to fulfill the quali-
fications established for Board members.
o Action on Proposals. The original ERDA proposal
required that each application involving human
subjects at risk must be reviewed and approved
prior to its submission to ERDA. While the
Administrator of ERDA was authorizedto pro-
vide otherwise, no indication was given of
any plan to establish, as hEW did, a grace
period as agency practice.
The final ERDA rule specified (745.11(a)) the
acceptability of a written assurance that a
review is planned or in progress and that its
results will be forwarded within 60 days.
This change was in response to comments
pointing out the many cases of short lead
time arising, as one commentator stated, be-
cause of agency delay in announcing the dead-
line, because of the limited period often*
permitted for response to Requests for Pro-
posal, because of overload or unfortunate
timing of the investigator's responsibilities,
because of the development of new data, and
similar valid conditions.
o Records. HEW regulations provide that copies
of all documents used in Institutional Review
Board reviews are to be retained by the insti-
tution subject to the terms and conditions of
the awards. Under HEW practice, the period
of retention is normally three years and
virtually never more than five years. The
original ERDA regulation departed from that
of HEW by requiring that copies of all doc-
uments used in reviews
are to be retained by the
institution permanently un-
less permission is obtained
from the Administrator to
destroy specific records.
Upon termination of the life
of the institution, the fore-
going documents will be trans-
ferred to ERDA for further
retention.
The final ERDA language (745.19(a)) omitted
the last sentence in the cited passage, in
response to comments related to the institu-
tions' obligation to protect the privacy of
11-40
PAGENO="0078"
74
subjects. This obligation could well be violated
by an agreement to transfer such records to a
Government agency subject to the Freedom on In-
formation Act.
ERDA did not, however, revise its requirement for
permanent retention, and this remains as a dis-
tinct departure from the HEW rules. The ERDA
rulemakers appeared unmoved by comments that
Review Board approval is, in some cases (for
example, in sensitive matters such as drug
abuse), specifically conditioned on the investi-
gator's agreement to destroy materials which re-
veal the subject's identity as soon as the data
are aggregated and the study completed; by com-
ments that the requirement would involve storage
of thousands of consent forms and other documen-
tation into perpetuity, unless permission is
obtained to destroy specific records, which
would appear to require lists of prodigious
length; or by the wry comment from the Chairman
of Harvard University's Institutional Review
Board: "Think of the accumulation of records.
we would have here at Harvard had this regul-
lation been in effect in 1636."
CPSC. The Consumer Product Safety Commission (CPSC) pub-
lished in the Federal Register of September 2, 1976, its
proposed rules on the portection of human subjects. Its
language closely followed that of the HEW rules but dif-
fered from it in some significant respects.
One major difference concerned the written assurances
required of recipients or prospective recipients of grants
or contracts, stating that they will comply with the agency's
regulations on human subjects and describing the manner of
their compliance. A general assurance describes the pro-
cedures applicable to all activities supported by the agency.
A special assurance applies to a single activity or project.
Under HEW rules (64.5), a special assurance "will not be
11-41
PAGENO="0079"
75
solicited or accepted from an institution which has on file
with DHEW an approved general assurance.' For this reason,
HEW's requirements (46.4) for general and special assurances
include several elements in common.
The CPSC rules permit an organization to submit a copy
of its HEW general assurance, with no need for a separate
one for CPSC. The CPSC also states, however: "A special
assurance will be required from an organization although it
has an approved general assurance on file." This departure
from HEW procedure, while retaining HEW's descriptions of
the two types of assurance, means that each proposal to CPSC
must be accompanied by a considerable body of detail that
is already in that Commission's hands.
The CPSC rules have other variations from HEW language,
some substantive and others merely matters of paraphrase.
Even the latter are sufficient to have elicited questions,
and they require that each institution concerned must care-
fully study several pages of regulatory phraseology and
compare them with its procedures. Final CPSC rules had not
been published at press time.
ONR. A clause entitled "Use of Human Volunteers as Sub-
jects" was developed by the Office of Naval Research (ONR)
in 1974. This clause, among other things, directed contrac-
tors to adhere to the HEW regulations as set forth in 45 CFR
46. It further stated that, in the event of ambiguity or
inconsistency, the ONR provisions would govern. The major
11-42
PAGENO="0080"
76
conflicts between the ONR and HEW rules concern the legal
capacity of the subject to give consent and the acceptability
of consent given by another person on behalf of a subject.
There is some reason to believe that the ONR lanaguage was
derived, at least in part, from a previous regulation applying
to uniformed personnel who were patients in naval or mili-
tary hospitals. The problems have not yet been resolved.
The clause, however, is not incorporated into all contracts
as originally intended, but is confined to those that involve
hazardous situations for human subjects.
National Commission. The National Commission for the Pro-
tection of Human Subjects of Biomedical and Behavioral Re-
search was established by Section 201 of the National Re-
search Act, Public Law 93-348, July 12, 1974. The National
Commission's functions are associated primarily with HEW,
but Section 202(a) (3) of the Act instructs it to conduct an
investigation and study to determine the need for a mechan-
ism to assure protection of human subjects in programs not
subject to HEW regulations -- that is, sponsored by other
agencies. The statute says further: "If the Commission
determines that such a mechanism is needed, it shall develop
and recommend to the Congress such a mechanism." The Na-
tional Commission is scheduled to go out of existence De-
cember 31, 1977, but there is some indication that it may
be made a permanent body.
Findings. The protection of human subjects is a topic in
11-43
PAGENO="0081"
77
which there has been a clear and proper preemption of the
field by a lead agency: NIH acting on behalf of HEW. If
other agencies are permitted to deviate from or even to para-
phrase the NIH/HEW regulations, the result will be unneces-
sary duplication of reporting, recordkeeping, and other
activities on the part of the Government as well as the
organization involved. Some agencies, including the National
Science Foundation and the Department of Agriculture, have
accepted the NIH/HEW regulations by reference, without
finding it necessary to paraphrase, interpret, or expatiate.
Others, even while recognizing HEW's precedence, phrase
their regulations so as to require conformity, to their own
policies. This creates conflict if future changes in their
policies and in HEW's are not identical and simultaneous.
In addition, it requires miltiple submission of general as-
surances, which are frequently intricate and lengthy doc-
uments and which must be updated periodically.
The Interagency Task Force on Higher Education Reporting
Burden, whose report was issued December 14, 1976, included
representation from the Commission on Federal Paperwork and
14 other executive branch agencies. Its report specifically
cited human subject protection as an area in which a single
agency should be identified for managing the Federal interest
in order to minimize the reporting and recordkeeping burden.
(see Appendix B)
11-44
91~86OO.77..6
PAGENO="0082"
78
Recommendation No. 9
Cognizance for regulations in the specific
area of the protection of human subjects
shouldbe assigned to the Department of
Health, Education, and Welfare, acting
with the advice and consent of an appro-
priate interagency committee.
No agency other than NEW should be per-
mitted to paraphrase, interpret or par-
ticularize these regulations. Enforce-
ment responsibilities may, if desired,
be assigned to other agencies, partic-
ularly if the organization involved has
no grant or contract with HEW in which
human subjects are used. However, in
the regulations for a controversial
subject of this nature there should be
a mechanism for the Federal Government
to speak with one voice.
Single Agency Cognizance
There has been a steady increase in the number of areas
in which, as in the case of human subject protection, the
Federal Government interacts with individuals and organiza-
tions of all types. Each individual and organization is
likely to deal with a growing number of Federal agencies,
each with its own regulations, constraints, and injunctions..
In the absence of interagency coordination, these regulations
may very well be inconsistent with one another and in some
cases even indirect conflict.
The cognizant agency concept has been used for many
years as a means of coordination Federal requirements in a
given area. Such coordination is particularly needed when
the area and the requirements are technical, complicated,
11-45
PAGENO="0083"
79
or not readily comprehensible. Ex~raples include the Internal
Revenue Service, the Patent Office, the Copyright Office,
and the Cost Accounting Standards Board. Another instance
is the cognizance over Federal statistical activities which
has been assigned to the Statistical Policy Division of 0MB.
These agencies have been assigned complete responsibility,
within the limits imposed by statute, for the development of
all regulations in their fields. In other words, they are
the cognizant agencies in their areas.
A less effective arrangement is one in which a single
agency acts as the lead agency, providing the major initia-
tive. Under the lead agency concept, in contrast to that
of the cognizant agency, separate regulations may be issued
by agencies other than the lead agency, with a strong pos-
sibility of inconsistency, incompatibility, or conflict.
In some cases, cognizance may be assigned to two or
more agencies, each being given a mutually exclusive area.
In one instance, the equal employment opportunity require-
ments for Government contractors have been divided by sec-
tors: cognizance for contract compliahce in the education
and other nonprofit sectors has been assigned to HEW, as
pointed out in a later section. In another instance, the
financial audit and negotiation cognizance for each college
and university was assigned to a single agency. This was
accomplished through the Office of Management and Budget
Circular A-88, first issued May 15, 1968. This Circular,
subsequently but temporarily renamed FMC 73-6, assigned most
11-46
PAGENO="0084"
80
of these institutions to HEW, although others are under the
cognizance of the Departments of Defense or Interior or of
the Energy Research and Development Administration. These
assignments have meant that each institution needs tO deal
with only one agency, a development that has proven more
efficient for the agencies as well as for the institutions.
Use of the cognizant agency principle was suggested in
this section for the protection of human subjects, and it
is recommended in a later section for equal opportunity re-
porting. A further example, the disposition of patent rights
under Federally-sponsored programs, is given below. In ad-
dition, one section of the Commission's health report deals
with the cognizant agency concept as a long term approach
for the elimination of unnecessary paperwork. The principle,
as a long range approach, has potential value in the reso-
lution of future problems and, indeed, in the prevention of
problems.
Patent Rights. The disposition of rights to patents made
under Government-sponsored contracts and grants was the sub-
ject of a Memorandum and Statement of Government Patent Policy
issued by the President October 10, 1963. Some revisions,
based on the results of studies and of experience gained
under the 1963 Statement, were incorporated into a revised
Presidential Statement issued August 23, 1971.
The Federal Council for Science and Technology, recog-
nizing that a substantial amount of research is funded by
11-47
PAGENO="0085"
81
the Government at universities and nonprofit organization,
established a University Patent Policy Subcommittee to de-
termine whether special patent procedures for that sector
may be required in order to facilitate utilization of in-
ventions. The Subcommittee, headed by Normal J. Latker,
Chief of the Patent Branch in the office of the HEW General
Counsel, concluded that there are valid reasons for special
procedures and suggested specific measures.
The Subcommittee report7 described four different. ap-
proaches now being used by different agencies for the allo-
cation of patent rights under research grants and contracts
with universities and nonprofit institutions. One of these
involves the use of an Institutional Patent Agreement (IPA).
for those institutions that are found to have an established
technology transfer program that is consistent with the
stated objectives of the Presidential policy. This proce-
dure, already successfully used by HEW and the National
Science Foundation, is recommended by the Subcommittee for
use by all agencies, within the constraints, of course, of
their statutory authority.
A second procedure, now used by the Department of De-
fense, is based upon a "special situation" interpretation
under the Presidential Statement, which also permits deter-
mination of patent rights when the contract or grant is awarded.
The other two procedures, used by all other major agencies,
involve a case by case decision on each invention, which re-
quires the preparation, review, and response of detailed
11-43
PAGENO="0086"
82
data on each separate invention and entails a substantial
amount of administrative work on the part of both the in-
stitutions and the Government..
A proposed revision to the Federal Procurement Regula-
tions (FPR), implementing the Subcommittee's proposals, has
been circulated for comment both within and outside the
Government. If the revision is adopted, the Department of
Defense has indicated a disposition to amend similarly the
Armed Services Procurement Regulation (ASPR). Although
both FPR and ASPR apply only to contracts, the proposed
regulations have been written for application to grants as~
well, and the major agencies are understood tobe prepared
to include grants under the IPA procedure.
Adoption of this procedure on a Government-wide basis
would, as the Subcommittee report states, eliminate to the
~extent possible the wide difference in treatment of a. parti-
cular institution doing similar work for different agencies
(page 18), and reduce the administrative burden an all the
parties concerned (page 19). In this instance, the Subcom-
mittee has acted as a cognizant agency in designing a con-
sistent procedure for all agencies. The success of this
procedure will require the maintenance of a list of thefl
institutions and organizations that ~avë demonstrated their
technology transfer capability and thus their eligibility
for an Institutional PatentAgreement. A single cognizant.
agency could readily maintain this list
11-49.
PAGENO="0087"
83
Findings The cognizant agency principle has proven effective
in coordinating Federal requirements in a given area, parti-
cularly when the requirements are intricate and difficult to
understand Cognizance may be assigned to a single agency
or be divided into mutually exclusive spheres with different
agencies having cognizance for each When several agencies
issue separate regulations with respect to the same subject,
incons~L5tencies, conflicts, and burdensome duplications can
arise Even when a lead agency has published a carefully
devised code, these incompatibilities may occur, some mad-
vertently and others by design
Sole authority to promulgate regulations in the parti-
cular field must be assigned to the agency to which cogni-
zance is given, although enforcement of these regulations
may in some cases be assigned elsewhere. Even if an agency
encounters an unfOreseen. problem that requires revision of
the regulations, such revision must be made by the cognizant
agency
Attention has been given recently to the cognizant
agency principle. For example, the Interagency Task Force
on Higher Education Burden Reduction, to which the Commis-
sion staff contributed, proposed that the principle be ap-
plied where appropriate. This appears as Recommendation No.
`16 of the Task Force report. (see Appendix B)
Although the cognizant agency principle should be con-
sidered for subject areas that are recognized today, its
potential use for those that will arise in the future should
11-50
PAGENO="0088"
84
Recommendation No 10
The Commission on Federal Paperwork endorses
the cognizant agency concept as a useful tool,
particularly in cases that involve regulations
that are technically intricate and require
specialized experience for full comprehension
and conformance and urges 0MB to consider
* assigning a cognizant agency in all cases
where two or more agencies have overlapping
jurisdictions that might result in duplica-
tive or inconsistent regulations
not be overlooked.
11-51
PAGENO="0089"
SECTION 2
85
FOOTNOTES
1 Also known as Federal Management Circular 73-8
*2. University of California, Research Management Im-
* provement Project, Property Management (San Diego,
California 1974), p 13
3. For instance, officials at the. General Services
Administration and the Office of Management and
Budget.
4. It should be noted that the cost principles for
educational institutions, 0MB Circular No. A-21
* (also known as FMC 73-8) state,. in section C.4.
a: "Where the purchase of equipment or other.
capital items is specifically authorized under
a research agreement, the amounts thus authorized
for such purchases are allocable to the research
agreement regardless of the use that may subse-
quently be made of .the equipment or other cap-
ital items involved
5. Circular A-llO's Procurement Standands cover the
acquisition of supplies, equipment, construction~,
and other services with Federal funds under the
agreements subject to the Circular.
6. Mark Frankel, Public Health Service Guidelines
Governing Research Involving Human Subjects:
An Analysis of the Policy-Making Process, Pro-
gram of Policy Studies in Science and Technology,
Monograph No. 10, George Washington University
Washington, D C 1972)
7. Federal Council for Science and Technology, Re-
port of the University Ad Hoc Subcommittee of the
Executive Subcommittee of the Committee on Govern
ment Patent Policy, Washington, D.C., 1975.. (Un-
published)
11-52
PAGENO="0090"
86
III. STUDENT AID
During the l960's, the number of public and
private institutions of higher education increased
by more than 500 and enrollment more than doubled,
rising from 3.6 million ir~ 1960 to 8 million in
1970. The same period saw a tremendous growth in both
the number of student aid programs and the total amount
of financial assistance available to students from local,
State, and Federal government, institutional and private
sources. In the mid-l950's the total amount of financial
assistance available to postsecondary students was
estimated at $96 million. By the mid-l970's this amount
had grown to nearly $6.1 billion. The National Defense Education
Act of 1958 introduced Federal financial aid through the National
Defense Student Loans. The Higher Education Act of 1965 established
equality of access to postsecondary education as a
national priority and initiated a program of Federal
grants to low-income students, a guaranteed student
loan program, and Federal subsidies for part-time work.
In the enactments that followed, Federal support for
student aid steadily increased, reaching a peak with the
Education Amendments of 1972.
This statute established a program of "Basic Educational
* Opportunity Grants," that was based on the assumption that all
students are entitled to assistance to attend institutions of
postsecondary education.
hI-i
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The program was designed as the foundation or "floor"
upon which, ultimately, all student aid would be
based. Since its inception, the Basic Grants Program
has grown rapidly in terms of dollars expended and the
number of recipients. Appropriations were increased
from $122.1 million in the first year (1973-1974) to
$1.69 billion in the fourth year (1976-1977), while the
number of recipients increased from 185,249 to 1,268,300.
The Federal Government is now the major contributor of
student finanäial aid, providing over 80 percent of the
funds available for this purpose in the 1974-1975 academic
year.
Equally significant is the increased Federal
influence on policies and procedures affecting the
entire financial aid system. For example,OE regulations
issued in 1975 required, among other things, annual OE
approval of every formula used by institutions for determining
`reasonable" parental contributions to postsecondary
education. Increased Federal involvement has also meant
increased paperwork. The Government has not only made
available funds for needy students but has also issued rules
and regulations specifying to whom and how these fundr
can be awarded and requiring follow-up reports on how
funds were expended.
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The enormous growth in financial aid -- in particular
the increased Federal involvement has brought with it a
number of problems for students, their parents, and
educational institutions. The rapid implementation of relatively
massive Federal programs, together with the in-
creasing tendency of the Federal Government to direct
the provision of student aid, has often resulted in
duplicative and unrealistic data requests. The first
two parts of this section analyze specific paperwork
problems inherent in particular student aid programs
and recommend solutions which could be implemented relatively
quickly. These problems also provide insight into other
more fundamental issues: the need for greater coordination
of aid programs at the Federal level, and, equally
important, the need for greater coordination among all
student aid programs -- local, State and Federal, in-
stitutional and private. The final part of this section
presents Commission findings and recommendations related
to these more basic problems.
Guaranteed Student Loan Program
The single largest student aid program is the
Guaranteed Student Loan Program (GSLP) created by
Title IV, Part B of the Higher Education Act of 1965.
During its first eight years of operation, it served
8.8 million students and lent $9.5 billion. The GSLP
insures loans to students in two ways: through the
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26 States that operate their own State Guarantee Agencies;
and through a variety of private lenders in the remaining
States and territories under the Federal Insured
Student Loan (FISL) program.
In the first year of the FISL program, students
completed only one application but, as information
elements were added over the years, by the 1976 fiscal year
applicants were required to complete three separate
forms to secure one loan.
STUDENT APPLICATION FOR FEDERALLY INSURED LOAN
(OE Form 1154, 3/71) was the first form an applicant,
school and lender completed. It was 21 inches long,
in triplicate, with instructions for completing the
form printed on the reverse side. Such a location
for instructions was awkward, particularly if the applicant
were using a typewriter and had to reinsert the form
each time it was necessary to resort to the instructions.
Approximately two-thirds of the information requests on
Form 1154 were directed to the student; the others were
directed about equally to the school attended and to the
lender. Instructions for the school and lender were
on the reverse side also.
STUDENT LOAN APPLICATION SUPPLEMENT (OE Form 1260
1/73) was the second form required of students, schools
and lenders. Form 1260 required seven information items
each from students and schools to be repeated from
Form 1154. Instructions wereagain on the reverse side
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90
of this triplicate form, but their location was so in-
dicated on the face sheet
ADDEL DUN TO LENDER'S REPORT OF GUARANTEED STUDENT
LOAN (OE Form 1070), STUDENT LOAN APPLICATION
SUPPLEMENT (OE Form 1260) was the third form, required
of students only. It explained man Il-inch page
the information required by the Equal Credit Opportunity
Act and the Privacy Act. At the bottom of the page the
student could waive the requirement that OE keep an
accounting of disclosures of information necessary
to process and service the loan, including possible
transfer and ultimate collection
The National Association of Student Financial
Aid Administrators (NASFAA) reported that these forms
contained duplicative student identification data and,
further, the existence of three separate applications
increased the possibilities of having one or more
parts of the total application~ become separated from
the other parts or lost.
Compounding the problem was the fact that State
Guarantee Agency loans reinsured by GSLP also usually
required three separate student application forms.
Except for additional information required in some
instances by State law, the information requested was
the same as in the FISL program and frequently in the
same format. States must meet the basic requirements
of the Higher Education Act of 1965, but may: enact
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additional requirements that are not contrary to Federal
law.
As a result of suggestions from postsecondary
education associations,~the Office of Guaranteed
Student Loans (OGSL) initiated steps to solve the multiple
application problem in the FISL program. A mock-up
was developed of a booklet containing a single
applic~tion form and readily apparent instructions
and information. The single application form combined
the previous three, reducing data items by 21 for
students and 14 for schools by omitting duplicative
and unessential items.
The proposed new FISL form utilizes standard-sized
paper to simplify handling by the student and file storage
by the agencies. It contains some new information items
from students to assist in curbing `the growing default
rates as well as information on changes in loan limits
and eligibility enacted October 12, 1976, in the Ed-
ucation Amendments of 1976 (P.L. 94-482).
OGSL staff also consulted State Guarantee
Agency staffs which comprise the National Council of
Higher Education Loan Programs in an effort to achieve
consolidation of their multiple student application forms.
Recommendation No. 11
The U.S. Commissioner of Education should give
high priority to consolidating the three student
application forms in the Federal Insured Student
Loan application cycle for the 1977-78 school year.
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Recommendation No. 12
Each of the 26 State Guarantee Agencies should
consolidate their student application forms
as soo'i as possible
Recorrrnendations Nos 11 and 12 were adopted by the
Commission Decemoer 3, 1976 The Commissioner of Education
replied on January 14, 1977, that "conpletion
of the application redesign project is expected to
coincide with the beginning of the 1977-78
academic year, as per the Commission's recommendation.
Replies from several State agencies indicate that some
have completed consolidation of their application forms
Campus-Based Programs
Unlike the Guaranteed Student Loan program and
the Basic Educational Opportunity Grant (BEOG) program,
which provide funds directly to students, the three
campus-based Federal programs provide funds indirectly
to students through their institutions Under these
programs, funds are allocated to colleges and univer-
sities which then are free, within general constraints,
to select the students to whom these Federal funds should
be awarded
Although the campus-based programs have not experienced
as rapid a rate of growth as the GSLP or the BEOG, either
in terms of the appropriations or recipients, they have
been a source of serious paperwork problems for the more
than 4,000 institutions which annually apply for support
Indeed the campus-based programs constitute a case
history of `bad" paperwork, illustrating some of the
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unfortunate consequences, for the Federal Government
as well as the higher education community, of excessive
and unrealistic data requests
The three campus-based programs are admini-
stered by OE's Division of Student FinancialAsSiStanCe.
One of these programs, the Supplemental Educational
Opportunity Grants (SEOG), provides grants of from
$200 to $1,500 a year to students of "exceptional'
financial need who would be unable to continue their
education without such a grant. The second program,
College Work-Study (CWS), subsidizes the part-time
employment of needy students, while the National Direct
Student Loan (NDSL) program supports long-term, low
interest loans. These three programs are generally
regarded as supplementary to other forms of student
assistance (e.g. Basic Educational Opportunity Grants),
and financial aid officers "package" the various aid
components in different ways, depending on available
funds and student circumstances
Federal funding is initially allotted to the
States according to statutory formulas based essentially
on enrollment Funding levels for institutions within
each State are recommended by regional review panels
which base their decisions primarily on the institution's
previous utilization of funds and the aggregate financial
need of its students An institution applies each fall
for support of all three programs on a single con-
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solidated form commonly referred to as the"Tripartite
Application
In the early years of the campus-based programs,
this form was relatively simple, requiring only minimal
data on enrollment and institutional needs. Starting
in 1971, OE sought to collect additional information
to build a national matrix showing the aggregate
financial need of all students on each campus. The
aim was to demonstrate total need to the Congress and
to target funds to those institutions whose students had
the greatest need In the course of this project, the
application was expanded drastically. However, despite
the increased data requests, there were no major shifts
in funding because the State allotment formulas were
preserved Although the targeting concept was dropped,
the massive application has remained
Institutional Burdens Applicants report that the Tripartite
Application is difficult and time-consuming to complete
According to a survey conducted by NASFAA, the average
institution spends four to six weeks gathering the
data and preparing the application. Completion of the
form frequently interferes with other professional
responsibilities, for instance, reducing time available
for student counseling
1.
The current application is 15 pages and so
complex that OH has found it necessary to issue a
17-page set of instructions to accompany the form Applicants
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are required to supply three sets of figures -~ for the
preceding, current and following academic years -- for eaôh
of the following items:
o Enrollment: number of undergraduate and graduate
students eligible to participate in any of the
programs;
o Colle~~Work-Study Request: number of actual and
estimated recipients acco~ing to location of
employment (on campus/off campus), average award,
gross compensation to students;
o NDSL Request: number of actual and estimated
recipients, average loan, total loans advanced
to students, litigation and collection costs
on defaults, cash on hand, reimbursements for
loans cancelled for creditable teaching and
military service;
o SEOG Request; number of actual and estimated
redipients,~äverage grant, total funds expended
and requested;
o Institutional Need Analysis: total number of students
needing financial assistan~i and the figures
used to support the analysis (e.g. estimates of
family contribution, average cost, etc.);
o Costs for Needy Students: detailed breakdown
~Ucosts (tuition, 5oard~and room, etc.) for
single and married students, for those living
with parents and those living alone;
o Family Resources: breakdown of average and
~otaI family coflEributions for single and
married students;
o Other Resources: detailed breakdown of other
sources of aidTBasic Grants, `Veterans' `Benefits,
institutional aid, etc.) according to number of
students, dollar amount's, and size of average
award. `
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In addition, the applicant institution must furnish
a description of all key personnel (specifying their years
of experience, functions, and percentage of time devoted to
administration of student financial aid programs), a
narrative describing the method of projection, and a
summary of institutional aid expenditures over a three-year
period.
Probably the most burdensome aspect of the application
(aside from the sheer mass of data requested) is the
frequent requirement that institutions make estimates from
samples and weigh certain factors in order to arrive
at reasonable projections of the detailed costs of ed-
ucation, student resources and financial need for both the
current and following academic years. Officials of many
institutions claim that some of the data are impossible
to obtain.
For example, while fairly reasonable estimates for
the following year can be provided on the amount of aid
available from the institutionTs own resources, it is.
impossible to know the number of students who will be
eligible for Basic Grants or the amount of such awards.
The Basic Grants are subject to annual appropriations
which in the past have been either underutilized or have
required supplemental enactments. The rate. of participation
by students varies annually. Further, the awards are not
determined by the institution. Similarly, estimates on
the availability of loans and off-campus employment can only
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be made by guessing at future conditions in the local loan and
labor markets.
Agency Burdens. OE regional offices report that the
application requires an inordinate expenditure of their
own staff time and costly, complex panel review procedures.
In 1975, for exan'ple, Region V (the largest region)
received 740 applications each containing 15 pages and
1,362 data cells. Following established procedures, the
staff must check and edit each application for complete-
ness, conformity with guidelines, and the accuracy of
mathematical calculations. (One error can throw off
the entire request.) Thus, 1,007, 880 data items had
to be edited in Region V alone.
Estimates of regional staff time expended in the
entire application process (which includes workshops
for applicants, editing of applications, panels and post-
panel appeals boards) range from approximately 20 percent
in smaller regions such as Region I (Boston) to 40 or
even 50 percent in Region V (Chicago). The inordinate
expenditure of staff time has become a source of in-
creasing concern because staff are diverted from other
critical tasks such as monitoring programs to handle
the paperwork.
The mass of data and the number of items also make
the panel members' task of reviewing applications extremely
difficult. In 1975, OE found it necessary to issue a 50-
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98
page set of guidelines to assist panelists -- another in-
dication of the unrianageable nature of the form. The process
is further complicated by the fact that panelists must often
recalculate data items if they exceed the "yardsticks"
set by the panel. (The widelY-differing estimates sub-
rnitted by applicants often force panels to impose yard-
sticks for costs such as board and room as a basis for
judging the reasonableness of applications. The yard-
sticks are based on comparisons of entries from sImilar
institutions within the region.) Given the mass of data
and the need for recalculations, some panels indicate
that they seldom have more than 30-45 minutes to review
and evaluate each application. Panel sessions could
perhaps be extended but, in the Opinion of many re-
viewers, the problem lies more with the volume and
complexity of the data to be considered than the
duration of panel reviews which are already considerable
and, in most regions, last a week or two.
Questionable_Benefits. The burdens on applicants and regional
staff might be justified if the application achieved
reasonable results. However, there is considerable evidence
that it does not. It is widely acknowledged by GOvernment
officials and members of the financial aid community that the
current form encourages the inflation of applications;
that is, it encourages institutions to submit requests which
do not reflect the actual financial need of their students.
This problem was highlighted in a General Accounting Office
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99
(GAO) report issued in 1974:
The process through which educational institutions
are allocated funds under C~S, NDSL and SEOGs
does not ensure an equitable distribution of
appropriated funds. Some educational institutions
submit apolications which do not reflect accurate
estimates of student need of anticipated applicants.
Regional panels convened by OE to review applications
and recommend amounts to be allotted to the schools
do not always identify and make appropriate
adjustments to these applications.
A 1976 NASFAA study disclosed that 68 percent
of the panelists who participated in a survey believed
that "many to most applications were inflated."
Knowledgeable Government officials trace the
problem of inflated requests to the changes that were
made in the Tripartite Application in 1971. Initially,
institutions had been asked how much they had spent
on programs and how much would be needed the following
year, based on anticipated changes in enrollment. The
results, according to OE officials, were fairly realistic
estimates of institutional need. The new application,
however, required institutions to supply estimates on
all students by income category. The problem was that
most colleges and universities had not systematically
been collecting this information and were not prepared
to respond.
As a result, even well-meaning institutions built
in projections that showed more financial need than they
actually had. This initial unrealistic data request
triggered an unfortunate cycle which continues to plague
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100
OE: panels how almost routinely reduce applications, on
the assumption that most are inflated, while many colleges
and universities continue to inflate their requests,
knowing from previous experience that their ultimate
allocation will be only a small percentage of what had
been requested. This is not an attempt by the institutions
to defraud the Government; rather, as the GAO report
stated, colleges and universities are forced to "play
the game to meet the real needs of their students.
The current form contributes to the inflation
of applications by forcing institutions to speculate
on the future and by accepting unauditable data. This
point was the principal finding in a 1976 study of the
Tripartite Application undertaken by Region V officials:
The application assumes that the answers are
statistically sound, but in fact there is no
way that much of the data can be audited.. .Decisions
on funding are made on projected figures and these
projections cannot be validated until the follow-
ing year...
Compounding the problem is the fact that figures
in the application are not even compared with available
historical data to determine if the estimates are reason-
able. Each institution, for instance, must submit annually
a Fiscal Operations Report which requires, among other things,
data on actual funds expended and the number of student
applicants who were not aided because of insufficient
funds. Although these reports could be a valuable
resource for the panels, the GAO study found that only
t.hree of the seven panels surveyed used the reports in
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their reviews.
Further, staff review indicates that much of the
application data. is not used in arriving at final award
decisions -- in spite of the inordinate time and expense spent
gathering, editing and massaging the data. After the
panels hays met, their recommendations and the full
applications are sent to Washington where data is entered
into a computer for statistical analysis and generation
of award letters. The Director of the Student Financial
Aid Division informed the Commission that, in 1975, less
than a dozen data items were pulled from the applications
for storage in the computer bank.
Findin~s. Without exception, OE officials, panelists and
financial aid officers who were contacted by the Commission
agreed that the current application is highly undesirable
for one or more of the reasons discussed above. In response
to complaints from the financial aid. comm'unity and regional
offices, OE has organized several task forces to review the
application and devise ways .of simplifying procedures.
Possibilities under consideration include changing the
current panel allocation system to a formula approach
based either on enrollment or previous utilization of funds.
It appears that OE has been moving in a direction
that would place greater reliance on data that is readily
available and verifiable, while minimizing the number of
detailed and often unreasonable estimates currently required.
This is a direction that the Commission believes should
he pursued vigorously in the interest of both the efficiency
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102
and effectiveness of data collection The approach seeks
to aadress the major problem with the current system the
inability of institutions to estimate accurately and of
the agency to validate promptly such a mass of data
Another possibility that should be fully explored
is consolidation of the application and the F~scal
Operations Report into a shortened and redesigned form
This would eliminate duplicative data items while
making critical historical data available to the panels
Recommendation No 13
The Office ofEducation shouldgive a high priority
to shortening and simplifying of the Tripartite
Application
Recommendation No 14
Consider approaches that place greater reliance.on
data that is readily available and verifiable, while
minimizing the number of detailed estimates
Recommendation No 15
Consider, as a first step, the elimination of those
data items that may be impossible for institutions
to obtain projections on Basic Grants, State
Scholarships and Grants, VeteransBenefjts, other
loans, other employment and other sources of aid
Recommendation No 16
* Explore the possibility of merging the application
* and Fiscal Operations Report into a redesigned form;
and
Recommendation No 17
Continue to work closely with representatives of
the National Association of Student Financial Aid *
Administrators in all phases of the planning and
development of a new and improved application
These recommendations were adopted by the Commission
on February 25,1977.. In response, the Office of Education
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replied to the Commission on March 25, 1977 that its Division
of Student Financial Aid had:
* o Initiated proposed rule changes within the
* regulatory structure of each program, which
* will be subject to broad public comment. These
modified regulations will, when published this
year, govern a vastly foreshortened and simplified
form to be used in the fall.
o Proposed that except for instjtutions which are
first time applicants, this application will
secure verifiable data--a most important change.
o Recommended that, in light of organizational
changes in the student aid programs, and the
potential for continued consolidation and
streamlining of reporting requirements during
FY 1978, they will not attempt modification of
the fiscal report for these programs, to be used
in recording current year expenditures. However,
thereare plans to simplify, and streamline this
document for the 1978 reporting year.
o Engaged in widespread consultation with student
aid administrators, national leadership in the
higher education community and others concerning
this important easing of the paperwork burden.
More detailed information was promised "on the end product
when it is available this summer."
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104
Toward a Single Application
The specific paperwork problems inherent in the
Guaranteed Student Loan and campus-based programs
illustrate another more fundamental problem: the lack
of close coordination among Federal student aid programs,
in particular between the BEOG and the other aid programs
administered by the Office of Education. The BEOG program
has brought massive amounts of financial aid to students,
but to cite one example, the current application and allocation
system for the campus-based programs does not yet reflect
the full effects of the BEOG program, which is now the
foundation of all student financial aid.
The Tripartite system was not designed to accommodate
a new and massive source of funds. The "short form" of
the Tripartite Application, discussed above, was based on the
assumption that institutional need had already been established
through previously submitted "long forms" and that an
institution submitting the "short" form was seeking only
to continue its aid programs at the current rate with a
certain increase attributable to inflation. This assumption
does not take into account the fact that the "long forms,"
in many instances, were submitted prior to the emergence of
the BEOG program, and their information on other resources
is obsolete.
In recognition of this and other problems resulting
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105
from overlapping programs, stLident aid programs of the OE
were recently reorganized into a single Bureau of Student
Financial Assistance. previously, administration of
OE's seven student grant and loan programs was divided
between two offices: the Office of Guaranteed Student
Loans which over saw that masssiVe program, and the Bureau
of postsecondary Education which administered the other
six student assistance programs (BEOG, CWS, NDSL, SEOG,
State Student Incentive grants, and cooperative education
awards). The two offices had different policies and
procedures and little continuing contact or cooperation.
Although the paperwork implications of this re-
organization are not yet clear, the action appears to
be a necessary preliminary step for improved coordination
and management of these programs. It offers, for instance,
the opportunity for greater sharing of information among
the programs and possibly the development of a coordinated
and computerized data management information system of all
OE student aid programs in place of the separate systems
for each program currently in operation.
Consolidation of OE student aid programs in a
* single office then has potential for reducing paperwork
and streamlining the student aid system at the Federal
level. This, however, is only one, albeit a very important,
aspect of the paperwork problem as it relates to the delivery
of student financial aid.
Any serious study of paperwork problems inherent
111-20
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106
in student aid programs must recognize the interconnected
nature of the Federal student aid programs with those
from local., State, institutional and private sources.'
Federal student assistance represents only a part of the
entire constellation of aid programs which have different
purposes, policies, schedules and procedures. The impact
of so many diverse programs and procedures on the student
is the subject of these pages.
One of the fundamental problems is simply the
number of applications and needs analysis forms that
students and parents must complete to demonstrate their
eligibility for assistance. A student may file a separate
financial aid application with each college or university
to which admission is sought, another to a State agency for
State scholarship, and possibly a third for a Federal
Basic Educational Opportunity Grant. In addition, the
student may submit an application for a Federally Insured
Student Loan as well as separate applications for scholar-
ships or grants from private sources. To complete these
forms, students and their parents must assemble information
from income tax forms and other records and manipulate the
data in different ways to respond to slightly' different
questions on the various forms.
Multiple methods or systems for determining financial
need compound the problem. There are three major national
systems for needs analysis--those of the American College
Testing Program (ACT) and the College Scholarship Service
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107
(CSS), which provide determinations of parental ability
to pay postsecondary education costs to colleges and universities,
and the BEOG Analysis, which has its own eligibility
determination procedures.
In addition, an institution may use the income tax
method while some State agencies utilize other needs
analysis systems. Prior to the work of the Keppel Task
Force, which is discussed below, a family could provide
identical financial information to the two major services
(ACT and CSS), yet the estimates of the family's ability
to pay for educational costs provided by the two services
might vary by as much as $1,000 due to differences in their
respective procedures and formulas.
The application process is further complicated by the
lack of standard definitions for some of the data requested
and by different deadlines for the distribution and process-
ing of applications among private, State and Federal systems.
As the testimony of educational associations and student
groups has amply demonstrated, these factors have made
the application process highly burdensome and confusing
to students and their parents. Of even greater concern
to some is the distinct possibility that students might
be missing opportunities to secure necessary financial
assistance because of the multiplicity of forms.
Keppel Task In 1974, 26 education organizations
and institutions formed, the National Task Force on Student
Aid Problems to seek ways of simplifying and improving the
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108
system. The group is commonly known as the Keppel, Task
Force in honor of its director, Francis Keppel a
former U.S. Commissioner of Education. Its final report,
issued in 1975, contained major recommendations pertinent
to the analysis of student financial need, the collection
of data from students, and the coordination and management
of aid programs.
To eliminate confusion resulting from the different
needs analysis systems, the Task Force develOped, in
cooperation with several recognized economists, a "uniform
methodology" for determining parental ability to contribute
to educational costs. This methodology represented a
compromise between the existing systems. It was subsequently
adopted by ACT and CSS and is now used for the analysis of
all financial statements submitted to them.
The second major contribution of the Task Forcewas
development of a common form to collect data necessary
for needs analysis including all information necessary to
"drive" the "uniform methodology." Recognizing that immediate
adoption of the common form by all parties would be extremely
difficult, the Task Force recommended a developmental process
for its implementation. This called for initial adoption
of common data items and definitions by Federal, State, and
private student aidprograms as well as the major services,
followed by field testing of the common form and, finally,
adoption of this form by all parties for use in the academic
year 1976-77.
In view of the special needs of the SEOG program, the
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109
Task Force further recommended that this program continue to
have a separate processing function, but `students who so
requested could have a copy of the data (on the common form)
submitted to ACT and CSS or another agency transmitted to the
BEOG (contractor) for processing in lieu of a separate
application."
Until quite recently, these recommendations had met
with only partial success. Statewide field tests of the
common form were conducted in Kentucky and wisconsin in
1975-76. Based on these experiences, modifications were
made, and CSS and ACT agreed to adopt the common form for
their state aid programs.
Later Developments. Central to the success of the Keppel
Task Force was adoption of the "uniform methodology" and
common form by the Basic Educational Opportunity Grants
program, which was established by Congress as the foundation
upon which all other forms of financial aid would be based.
Because nearly all students file a separate BEOG application
in addition to other financial aid forms, significant improve-
ment in the student aid delivery system could be achieved
only with the participation of the Basic Grants program.
For a variety of reasons, however, OE had been unwilling
to adopt the Task Force recommendations. Following discussions
over the past two years between BEOG program staff and the
2
Coalition for Coordination of Student Financial Aid, a
compromise settlement was reached in January 1977 which goes
far toward simplification of the student financial aid delivery
111-24
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110
system.
The agreement between BEOG and the Coalition calls for a
new alternative delivery system for the BEOG which will
enable students to file one financial aid form and receive
consideration for all financial aid programs. This will be
accomplished through a tape exchange of selected data elements
between BEOG and State and private agencies collecting data
for needs analysis (see Figure 3).
As the first step, the Coaiition and OE will agree
on common data element definitions and instructions which
will be used to `drive" the BEOG'S and the "uniform
3
methodology." Beginning in January 1978, students who
file forms with approved national processor (e.g. ACT, CSS,
or a State agency) will have their BEOG'S processed at the
same time without having to file a separate application.
Eligible processors will provide carefully edited computer
tapes to the central BEOG contractor which will, in turn,
check its files against duplication and send "Student
Eligibility Reports" to students. Other than the tape exchange,
all other aspects of the BEOG application process will remain
the same.
Although the proposed system will represent a significant
improvement over existing procedures, a number of complex
administrative and technical problems must still be resolved.
For instance, the agreement is premised on the adoption of
a common calendar (January ]) for distribution of all finan-
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111
cial aid applications. This would allow the use of actual,
not estimated, income tax information on applications, as
reouired by the Basic Grants Program. Knowledgeable officials
agree that this and other administrative problems resulting
from the agreement can indeed be solved. In the process,
they anticipate further improvement and refinements in
the system.
Once implemented, the new system will allow a student
to complete one application form and receive consideration
for all Federal aid programs except the Guaranteed Student
Loan, most State programs, and all institutional aid programs.
A conservative estimate from the National Association of
Student Financial Aid Administrators is that the new system
could initially reduce the number of applications by 3-4
million a year. Potentially, it could save as many as 10
million applications once the system is fully implemented by
all parties.
Recommendation No. 18
The Commission on Federal Paperwork endorses the con-
cept of a single financial aid application for all
Federal, State, institutional, and private forms of
student financial aid.
Recommendation No. 19
The Commission on Federal Paperwork commend the U.S.
Office of Education and the Coalition for Coordination
of Student Financial Aid for their efforts to simplify
and improve the financial aid delivery system.
Recommendation No. 20
The Commission on Federal Paperwork urges the Office of
Education and the Coalition to give a high priority
to development of the Tape Exchange Program to ensure
its implementation for the 1978-79 academic year.
111-26
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FOOTNOTES
Section Three
1. Institutions which received funds for the past
two years and whose current requests do not exceed
110 percent of previous allocation may submit a
shortened version of the application. The use of the two
forns (the so-called short and long forms) which are
based on different criteria for review -- the long
form primarily on the aggregate financial need of
students; the short on the institution's previous
utilization of funds -- has created problems for
reviewers and contributed to inequities in the dis-
tribution of funds (see p. below). The short form
and other aspects of the Tripartite Application are
currently under review by OE.
2. A voluntary group from the higher education community
organized to follow-up on the Keppel Task Force
recommendations.
3. The Basic Grants Analysis and the Uniform Methodology
will still produce different estimates of a family's
ability to pay for educational costs. Both OE and
the Coalition agreed that this was appropriate given
the different purposes of the two systems: to determine
program eligibility in the case of the BEOGs, and to
estimate total financial need in the case of programs
using the Uniform Methodology.
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IV. NONDISCRIMINATION REQUI REMENTS
The Civil Rights Act of 1964 required desegregation of
public education (Title IV) and forbade discrimination on
the basis of race, color or national origin in programs re-
ceiving Federal financial assistance (Title VI). Thus, ten
years after the Brown v. Board of Education of Topeka decision,1"
nondiscrimination in education was mandated by statute.
Since then, comparable statutes have extended this protec-
tion from discrimination to other groups: women, the aged,
the handicapped, and veterans.
As seen by educational institutions today, nondiscrimi-
nation programs are based both on the principles of equal
educational opportunity for all and on affirmative action
to overcome past discriminatory practices. These concepts,
however, are not always compatible and have recently been
much debated. The educational community refers to this
dilemma as the "DeFunis Syndrome" and, in simplest
terms, the issue is how affirmative action programs
can be implemented for minorities and women without
discriminating against non-minority men. specifically,
the question is whether special admissions or financial
aid programs for minority students offend the rights
of other equally or better qualified students who
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are denied these benefits because they are not identified
with a minority. Judicial decisions are inconsistent,~1'
and until the issue is resolved, the meaning and administra-
tion of antidiscrimination programs will remain subject to
question.
Cognizant Agency
Responsibility for enforcement of equal opportunity and
affirmative action programs rests with many Government agen-
cies. As a result, reporting and recordkeeping requirements
are different; compliance reviews are duplicative; and the
necessity to reply to multiple forums places a tremendous
burden on respondents in terms of money, time, and paper-
work. These burdens weigh heavily on the educational com-
munit~', particularly the nation's colleges and universities.
Their admissions policies and employment practices are sub-
ject to review, and they are also recipients of Federal
grants and contracts.
The legislation, executive orders, regulations, and
judicial decisions of the past 15 years have combined to
create a veritable maze of equal opportunity requirements
administered by different Federal agencies with differing
criteria. The following are the significant laws, regula-
tions, and executive orders affecting the education com-
munity:
IV-2
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115
*o Title IV of the Civil Rights Act of 1964 provides
for the-desegregation of public education, but not
the assignment of students to public schools to
overcome racial imbalance. No regulations have been
issued; instead, Title IV has been the subject of
considerable judicial review.
o Title VI of the Civil Rights Act of 1964 prohibits
discrimination on the basis of race, color, or nation-
al origin in programs receiving Federal financial
assistance. Because Federal financial assistance
has been interpreted to include grants, loans and
even student aid, virtually every college -- public
or independent -- is subject toTitle VI. Enforce-
ment is the responsibility of those agencies pro-
viding financial assistance; however, most report-
ing by educational institutions is to HEW's Office
for Civil Rights (OCR).
o Title VII of the Civil Rights Act of 1964,
as amended by the ~q~l Opportunifl~ Act of
1972, prohibits discrimination in employ-
ment, hiring and firing, and compensation
on the basis of race, color, religion or
national origin. Enforcement is the re~pon-
sibility of the Equal Employment Opportunity
Commission (EEOC) to whose regulations edu-
cational institutions must adhere as employers.
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116
o The Equal Pay Act of 1963 also prohibits
discrimination in compensation, but on the
basis of sex It is enforced by the Wage
and Hour Division of the Department of Labor.
o Title IX of the Education Amendments of 1972
prohibits discrimination on the basis of sex
in education programs and activities receiving
Federal financial assistance. Like Title VI,
enforcement is the responsibility of those
agencies providing financial assistance, but
most reporting by educational institutions is
to OCR
o The Rehabilitation Act of 1973 provides that
otherwise qualified handicapped individuals
shall not be discriminated against under pro-
grams or activities receiving Federal financial assist-
ance, The Department of Labor's Office of Federal
Contract ComplianCe Programs (OFCCP) has po-
licy responsibility and oversees enforcement
of Section 503, dealing with employment. Re-
gulations and enforcement of Section 504,
prohibiting discrimination in programs or
activities receiving Federal financial assis-
tance, are the responsibility of. OCR.
PAGENO="0121"
117
o ~ F ployrnent Act of
1967, as amended, prohibits employment dis-
crimination against persons aged 40 to 65.
Enforcement is the responsibility of the
Wage and Hour Division of the Department of
Labor.
o The Age Discrimination Act of 1975 provides
that no person shall, on the basis of age,
be excluded from participation in, be denied.
the benefits of, or be subjected to discrimi-
nation under, programs or activities receiving
Federal financial assistance. Enforcement is an
OCR responsibility.
o The Vietnam-Era Veterans Readjustment Assistance
Act requires affirmative action in the employment
and advancement of disabled and Vietnam-Era veterans.
Written affirmative action plans are required of
Government contractors holding contracts in excess
of $50,000 or having 50 or more employees. Responsibility.
for enforcement is shared between two Divisions of
the Department of Labor, OFCCP and the Veterans
Employment Service. In addition, job openings are
listed with the various State employment services
for referral.
o Titles VII and VIII of the Public Health Service
Act, as amended by the Comprehensive Health Manpower
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118
Act of 1971, prohibit discrimination on the basis
of sex in the admissions and employment practices of
health training programs receiving Federal financial
assistance. Enforcement is an OCR responsibility.
o Revenue procedures issued under Section 501 of the
Internal Revenue Code provide that schools which do
not have a racially nondiscriminatory policy do not
qualify for exemption from Federal income tax. This
applies primarily to independent institutions at all
levels, and enforcement is the responsibility of
the Internal Revenue Service (IRS).
o Executive Order 11246, as amended, forbids Govern-
ment contractors from discriminating in employment
on the basis of race, color, religion, sex or
national origin. In addition, dontractors are re-
quired to take affirmative action to assure that
employees and job applicants are treated without re-
gard to these factors. Written affirmative action
plans, including utilization analyses of the work-
force and goals and timetables for remedying de-
ficiencies, are required of contractors with con-
tracts of $50,000 or more and 50 or more employees.
Policy and oversight are the responsibility of OFCCP
which has designated OCR as the compliance agency
responsible for enforcement with respect to contracts
* with educational institutions.
IV-6
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119
o Executive Order 11764 delegated to the Attorney
General the authority to coordinate and assist
agency efforts to enforce Title VI. By regulation,
the Department of Justice has set minimum standards
for agencies to use to ensure compliance. These
minimum standrads allow enough latitude so that Title
VI enforcement efforts can vary among agencies pro-
viding Federal financial assistance.
In addition to these laws and executive orders, many
State and local governments have similar antidiscrimination
laws or ordinances. Thus, enforcement is conducted, not
only by the Federal Government at both central and regional
offices, but at State and local levels as well.
Reporting and Recordkeeping
As employers and Government contractors, educational
institutions are subject to the sane laws and regulations
as other segments of the economy. These laws and regula-
tions have been analyzed by the Commission in a separate
report on Equal Employment Opportunity. In addition, edu-
cational institutions are subject to other reporting require-
ments as participants in specific Federal programs. One
such program, authorized by the Emergency School Aid Act,
provides grants to local education agencies for the purpose
of overcoming minority group segregation within the schools.
Some of the provisions cited above have been selected for
IV-7
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120
further discussion in this report because of the paperwork
burdens they impose. One must remember, however, that those
selected are not the total of antidiscrimination reporting
by the institutions. Rather, they are in addition to the
others outlined above, are generally applicable, and do not
relate only to specific educational programs or to employ-
ment practices.
Titles VI and IX
Title VI of the Civil Rights Act prohibits discrimina-
tion on the basis of race, color or national origin in any
program receiving Federal financial assistance. Title IX
of the Education Amendments of 1972 prohibits discrimination
on the basis of sex in educational programs receiving Federal
funds. Educational institutions must report to OCR as well
as file assurances of compliance with other agenci~s pro-
viding financial assistance (for example, grant-making agen-
cies such as the National Science Foundation, the National
Endowment for the Humanities, etc.).
Surveys. At the elementary and secondary levels, OCR re-
quires the nation's 16,000 public school districts to complete
the Elementary and Secondary School Civil Rights Survey (OS/CR
101 and 102) biennially. This survey collects data to
measure compliance with the Rehabilitation Act of
1973 as well as Titles VI and IX. Data requested
includes information on the number of pupils trans-
IV-8
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121
ported at public expense; vocational education pro-
grams; home economics and industrial arts enrollrnent~;
drop-outs; previous year's graduates; student discipline;
special education provided h3ndlcapped studei~ts; and bilin-
gual and Eng1ish~as-a-second-~language programs. Much of
this information must be 1)r0~cfl dO~n ~i)d repor ted by sex
and radial/ethnic designation. Nationwide coapldtion of
the 1975 survey is estimated to require 180,000 to 330,000
person hours..
At the college level, institutions are annually re-
quired to complete some forms in the HEGIS series, now
under joint sponsorship of OCR and NCES. Student infor-
mation pertaining to Titles VI and IX is collected via
the FALL ENROLLMENT AND COMPLIANCE REPORT OF INSTITUTIONS
OF HIGHER EDUCATION (CE Form 2300-2.9) and DEGREES AND
OTHER FORMAL ANARDS CONFERRED (OR Form 2300-2.3).
These forms ask for a breakdown of students enrol)ed
or degrees granted in 301 fields of study by racial!
ethnic category and sex. In addition, other HEGIS
surveys dccl with staff composition and salary distribution.
Assurances. Agencies providing Federal financial assistance
in the form of grants require assurances that recipients
are in compliance with Titles VI and IX. These are brief
forms which institutions must sign and return. Inmost
IV-9
PAGENO="0126"
122
cases, an institution conpletes each assurance one time for
every agency from which it receives Federal financial assist-
ance. Unless compliance status changes, future grant ap-
plications usually incorporate previously filed assurances
by reference. This procedure is used at NSF and HEW. A few
agencies, however, require Title VI and Title IX assurances
for each grant, and the same assurances nay be submitted
many times.
Self-evaluation. In addition to surveys and assurances,
Title IX required every institution receiving Federal finan-
cial assistance to conduct a self-evaluation by July 21,
1976, make modifications necessary for compliance, and take
appropriate remedial steps to eliminate the effects of any
discrimination on the basis of sex. A description of modi-
fications and remedial actions is to remain on file at the
institution for at least three years after completion of the
evaluation.
HEW did not prescribe the exact mode of conducting a
self-evaluation. However, a recommended format, prepared
under an Office of Education contract and used by many in-
stitutions, was promulgated in a 148-page book, Complying
with Title IX/Implementing Institutional Self-Evaluation.
Conducted nationally, the suggested format would have re-
quired some 13,546,292 pages of paper (148 pages per school,
multiplied by 91,529,~ the approximate number of public
elementary and secondary schools, and colleges and universi-
ties in the country)~
IV-lO
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123
L~gislative Intent. Title IX also presents a good example
of the problems executive agencies encounter when inter-
preting the statutory intent of Congress. The law provides:
`No person . . . shall, on the basis of sex . . . be sub-
jected to discrimination under any education program or
activity receiving Federal financial assistance.' Title IX
was first introduced as an amendment to Title VI and was
passed with little legislative history. It contains, how-
ever, certain exemptions which had not appeared in Title
VI. For instance, certain religious institutions are not
covered, and separate but equal housing is permitted.
After enactment of Title IX, OCR wrote regulations
which eventually became a source of much controversy and.
many questions. One concerned athletic programs: Does
Title IX require colleges to spend as much money on women's
athletics as revenue-producing men's athletics? An amend-
rnent proposed in.l974 to exempt revenue-producing sports
was deleted in conference and replaced by the Javits
amendment requiring HEW to "prepare an~ publish.. .proposed -
regulations implementing (Title IX) which shall include with
respect to intercollegiate athletic activities reasonable
provisions considering the nnture of particular sports.
In addition, the Bayh amendment, enacted December 31, 1974,
exempted tax-exempt sororities and fraternities, the YMCA,
YMCA, Girl Scouts, Boy Scout.s and other sioliar organizations
from coverage of Title IX.
IV-l 1
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124
Yet the controversy was not over. In reply to an
inquiry in July, 1976, OCR issued an opinion letter stating
that father/son and mother/daughter banquets were in vio-
lation of Title IX. The opinion was later reversed after
direct intervention by President Ford. Subsequently included
in the Education Amendments of 1976 was another set of exemp~
tions: Boys' and Girls' State; father/son and rnother/daugh-
ter events; and certain beauty pageants.
Althou~ the Title IX regulations have been a con-
tinuing sour~e of controversy for lack of what some consider
a "common sen~e approach," former OCR Director Nartin Gerry
cited the problems inherent in administering what he re-
ferred to as "sense of the Congress" civil rights legisla-
tion. As Gerry explained, the executive branch was given a
statute, with little legislative history to reflect Congres-
sional intent, and the task of drafting regulations carry-
ing out the will of the Congress. In essence, the approach
left much of the law to evolve from the regulations.
Tax Exempt Status
Revenue procedures issued under section 501(c) (3) of
the Internal Revenue Code provide that independent schools
without a racially nondiscriminatory policy do not qualify
as exempt from Federal income tax. In its application for
tax-exempt status an institution must provide data on:
IV-l2
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125
o Racial composition, current and projected,
of the student body and staff
o Amount of scholarship and loan funds awarded
to students and racial composition of reci-
pient group
o List of incorporators, founders, board
members, and major donors
o Statement whether any incorporators,
founders, or major donors have an ob-
je~tive of maintaining segregated edu-
cation and, if so, whether they are
officers or active members of the or-
ganization
o Year of organization.
Additional paperwork requirements imposed on tax-exempt
institutions include the printing of a statement of non-
discriminatory policy in all brochures and catalogs deal-
ing with admissions, programs, or scholarships and in other
written advertising. Further, IRS requires .that the follow-
ing records be maintained for three years: racial cornposi-
tion of student body, faculty, and administration; recipients
of scholarships and financial assistance; brochures, cata-
logs, advertising; and copies of all materials used by or
on behalf of the school to solicit contributions.
IV- 13
91.860 0-77 --9
PAGENO="0130"
126
Thus, the IRS requirements, while not. totally dupli-
cative, require maintaining data routinely submitted to other
Government agencies. For instance, racial composition of
the student body is regularly reported to OCR and staff
information to OCR, NCES, and EEOC. In this case, the ques-
tion is not the difficulty of providing information, but the
lack of cooperation among agencies in sharing the same basic
information.
Compliance Reviews
Compliance reviews are conducted by those agencies re-
sponsible for enforcement of the various statutes. They
may take several forms and be conducted by central or
regional office personnel. For instance, OCR reviews the
Elementary and Secondary School Civil Rights Survey and
HEGIS reports of enrollment, degrees granted, and staff
salaries to monitor compliance with Titles VI and IX. It
also reviews, under authority delegated by OFCCP, affirma-
tive action plans required of educational institutions
under Executive Order 11246. In addition, grant-making
agencies have similar authorities under Executive Order
11764.
As discussed in another Commission report, the Equal
Employment Opportunity Commission monitors responses to its
surveys of ELEMENTARY AND SECONDARY STAFF INFORMATION (EEO-
5) and HIGHER EDUCATION STAFF INFORMATION (EEO-6). In ad-
dition to reporting requirements, all enforcement agencies
IV- 14
PAGENO="0131"
127
have criteria for the preservation of specified records
needed to determine violations. Recordkeeping requirements
are part of enforcement procedures under Executive Order
11246 (monitored by OCR and OFCCP), the Equal Pay Act (mon-
itored by OCR), and IRS regulations. All these agencies
are empowered to review relevant records to determine whether
discrimination has occurred.
Colleges and universities have repeatedly pointed out
the duplicative nature of on-site investigations. For
example, representatives of Labor, HEW and IRS may all visit
the sane institution to audit equal opportunity programs.
During the course of their investigations, many materials
are requested. At one institution, IRS requested copies
of all fund-raising materials; in another investigation,
OCR asked for the floor plans of all dormitories and the
sex of the occupants.
This is not the full extent of Federal monitoring
of equal employrnemt policy. Other agencies may also be-
come involved. For instance, if a university operates a
radio or television station, it is required to file a state-
ment of its equal employment policy with the Federal Comnuni-
cations Co;n~13SiOfl (tCC). The fCC requests infor~tion on
general policy; responsibility for implementation; dissemi-
nation; recruitment procedures; on-the-job-training opportu-
nities; surveys of minorities and ~:omem in the workforce
Iv- 15
PAGENO="0132"
128
and the station's actual wor}zforce; the number of now hires
within the past year, showing how many were minorities or
women; promotion policy; and a brief narrative of the
effectiveness of the station's equal employment policy. If
complaints of discrimination are filed with the FCC, the
station's records are subject to review, and the matter
may become the subject of a hearing before an Administrative
Law Judge.
Some equal opportunity reporting may be initiated by
the courts, as in the OCR-bOO Series. In an article which
appeared in the July 5, 1976, issue of U.S. News and World
Report, Dr. Donald Reichard, Director of Institutional Re-
search at the University of North Carolina, cited "10 HEW
reports that swamped the computer for six months." These
were the OCR-l000 series, the "Report on Progress in Imple-
menting Statewide Desegregation Plans," required in eight
southern and border States by order of U.S. District Court
for the District of Columbia settling Adams v. Weinberger.4
The OCR-l000 series consisted of ten forms request-
ing information regarding employees, new employees,
departing employees, and promotions of employees in
institutions of higher education; student applicants,
acceptances, and actual enrollment in institutions of
higher education; financial assistance to students in
institutions of higher education; progression of students
in higher education programs; and reasons for students
not returning to higher education, as well as information
IV- 16
PAGENO="0133"
129
on employees of State boards and governing boards of educa-
tion and the composition of governing boards for higher
education.
Complaints
An individual who believes that he or she has been
discriminated against may file a complaint with the Federal
compliance agency having jurisdiction. Because there are
substantial areas of overlapping jurisdiction, a single
complaint may be taken from tribunal to tribunal in an
attempt to secure a favorable verdict. Although the paperwork
implications cannot be precisely measured, they are
clear: a complaint is filed in one forum; the
institution responds in accord with that agency's
rules, regulations and procedures; if the issue is
resolved in the institution's favor, the complainant
may proceed to another forum and the university must
again prepare its reply, this time in response to a
different complaint filed in accord with another
agency's regulations and procedures. This can be
repeated many times, since there are frequently State
as well as Federal bodies having jurisdiction.
Alternative Solutions
The duplicative nature of equal opportunity reporting
and recordkeeping and the corresponding overlap of juris-
IV- 17
PAGENO="0134"
130
dictional boundaries have been subjects of discussion for
several years. In 1974, the U.S.Commission on Civil Rights
recommended the formation of a National Employment Rights
Board5 with broad administrative and litigative
authority to eliminate discriminatory employment practices.
All similar authorities of other agencies would be
revoked and all Federal compliance authority would
rest with the Board. As proposed, the Board's primary
emphasis was to eliminate th~ patterns and practices
of discrimination rather than resolving individual
complaints. However, the proposal did include a mech-
anism for resolving complaints which entailed referring
individual charges to approved State and local agencies.
Complainants would then have a right of appeal to the
Board, but the local agencies' findings would be given
substantial weight on appeal.
Although this suggestion related only to complaints
involving employment, it appears a similar approach could be
taken to all such equal oppor~:unity CO:PplalnVs. In a speech
before the American Bar Association's National Institute on
the Law of Equal Employment Opportunity and Discrimination
in Institutions of Higher Education, Dr. Robben W. Fleming,
President of the University of I4ichigan, made the following
IV-l 8
PAGENO="0135"
131
points: the multiplicity of forums has resulted from a
hodgepodge of legislation; the various Government agencies
involved have separate and distinct regulations; and be-
cause of the overlap in jurisdiction and resulting high
case loads, the probability of enforcement is slight.
Dr.~ Fleming proposed a response to the problem: the law
should be corrected to remove multiple forums and, in addi-
tion, incentives created to resolve complaints at the
institutional level. To be more specific, local, neutral
bodies should be created to hea~ complaints, and complainants
should be required to exhaust these remedies before appeal-
ing to an agency or the courts. Likewise, as in the judicial
appeals system, the agency would have authority to decline
jurisdiction in cases it found to be properly resolved.
Dr. Fleming noted such a plan might be opposed from all
sides, each fearful of intrusions on its own turf. Signi-
ficantly, the idea was favorably accepted by the Insti-
tute's participants with the apparent consensus that the
present statutes have led to an overlap of authority and
caseload so great as to be virtually unenforceable.
The problem of duplicative reporting and record-
keeping has also been examined by the Interagency Task
Force on Higher Education Burden Reduction, convened
under White House initiative in November, 1976. It agreed
on the need to eliminate redundancy in enforcement of equal
opportunity, civil rights, and affirmative action programs.
IV-l 9
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132
Specifically, the task force recommended that the President
convene an appropriate group of knowledgeable persons from
relevant agencies and representatives from selected colleges
and universities to explore the problem and that they should
be given adequate staff and other support to prepare, within
90 days, both a plan for the consolidation of equal oppor-
tunity reporting and the legislative changes necessary for
its implementation. (See Appendix B.) At the same time the
Task Force recommended that the Department of Labor, Office
for Civil Rights (HEW), the Internal Revenue Service, the
U.S. Commission on Civil Rights, the Justice Department,
and the Equal Employment Opportunity Commission coordinate
their enforcement activities through a Memorandum of Under-
standing.
The Commission finds the theory commendable, but doubts
its effectiveness because previous memoranda of understanding
between EEOC and the Department of Labor have been virtually
ignored. Five of these agencies are members of the Equal
Employment Opportunity Coordinating Council which has been
r
working on revised employee selection guidelines since 1972.
On Novembet 23, 1976, proposed guidelines were published by
three of the five participating agencies. The Equal Employ-
ment Opportunity Commission responded by republishing its
previous regulations which had gone into effect in 1970.
Due to the advisory nature of its responsibility, the Civil
Rights Commission published nothing.
IV-2 0
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133
The Commission believes consistency could be achieved
through a single agency under whichcon~plaiflts are resolved
at the lowest possible level and coordination is provided
between State and Federal enforcement. For ir.stance,
regulations should allow for disposition of complaints at
the institutional level by a neutral third party and
ps:ovide for appcal, but give appellate levels the right to
decline jurisdiction if they find no basis for it on either
procedural or factual grounds. The rules should be the same
in initial hearings and appellate procedures, to eliminate
re-hearing the same complaint in similar, but different,
contexts under different sets of regulations.
Recommendation No. 21
The President should issue an executive order and propose legis-
lative changes, if required, to designate a single cognizant
agency for equal opportunity and civil rights recordkeeping,
reporting, and compliance in the field of education.
Recommendation No. 22
The President should form an appropriate group of knowledgeable persons,
including advocacy groups, to contribute in the development of the cog-
nizant agency, along the lines of the recommendation of the Interagency
Task Force on Higher Education Burden Reduction.
Recommendation No. 23
The administrative procedures of any single cognizant agency for equal
opportunity and civil rights in education should allow for resolution
of complaints at the lowest possible level and provide for coordination
of Federal and State enforcement efforts./
IV- 21
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134
In addition to pervasive problems of overlapping juris-
dictions and duplicative requirements examined in the pre-
ceding pages, the Commission reviewed also three specific
problems that reached it through its hearings and correspond-
ence from Congress and respondents. These problems dealt
primarily with insufficient lead time in the announcement
of compliance surveys and in changing and inconsistent défi-
nitions of racial/ethnic categories.
The Emergency School Aid Act
The Application for Local Education Agency
Grants Under the Emergency School Aid Act (OE Form
116-1) re~uired minority enrollment data which was
not reported according to stanóarci Government racial/
ethnic categories. Thus, the approximately 2,000
local education agencies which request these grants
annually cannot use the same data collected and
furnished to other Government programs. Instead, they must
collect it again in a slightly different form.
The Emergency School Aid Act (ESAA) was enacted in.
1972 to provide local education agencies financial assist-
ance to meet the special needs incident to the elimination
of minority group segregation and discrimination among~
students and faculty in elementary and secondary schools;
encourage the voluntary elimination, reduction or prevention
of minority group isolation in schools with substantial
IV-23
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proportions of minority group students and aid school
children in overcoming the educational disadvantages of
minority group isolation The grant application required
analysis of student enrollment using the following classi-
fications Negro, American Indian, Spanish-surnamed, Orient-
al, Portuguese, Alaskan Native, Hawaiian Native, Other
Minority, and Non-Minority
Local education agencies were already required by OCR
to maintain enrollment data according to the format employed
in the Elementary and Secondary School Civil Rights Survey,
which was mandated by Title VI of the Civil Rights Act of
1964, Title IX of the Education Amendments of 1972, and
Section 504 of the Rehabilitation Act of 1973. That survey
relies on a set of five standard racial ethnic categories
developed for Government-wide use in compliance, administra-
tive and statistical reporting 6 Specifically, those cate-
gories are American Indian or Alaskan Native, Asian or
Pacific Islander Black, not of Hsipanic Origin Hispanic
and ~ not of Hispanic Origin Likewise, the faculty
information required by the ESAA grant application did not
correspond to these standard racial and ethnic categories
by which elementary and secondary schools were also required
to report faculty and staff information to EEOC
Because the ESMi application did not use stand-
ard racial/ethnic categories, applicants had to gather
other information before applying for emergen~cy assistance.
For examole, although a school district regularly gathers
IV-24
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136
enrollirtent data according to OCR's requ1rer~ents,
the saic enroll icnt GaLa must be conplled again
according to similar, yet different, categories and
submitted with the ES~_ application. Thus, the local
education agency was required to provide similar
information in slightly different forms to two
offices within HEW. The effort requited and cost.
of collection were roughly twice what they would be
if both offices collected the data using the standard
classifications
Preliminary discussions with ESAA staff
indicated that the ESAA application for school
year 1978-79 could be changed so the applicaton's
minority group classifications corresponded to the standard
racial/ethnic classifications used by OCR and EEOC In
addition, ESAA officials, advised that such a' change in
classifications would.not affect the distribution of funds.
IV-25
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Recommendation No. 24
The Commission on Federal Paperwork, noting the establishment
of standard racial/ethnic designations to be used by all agencies
for~compliance, administrative, and statistical reporting, rec-
ommends to the Secretary of Health, Education and Welfare that
these standard categories be used in applications submitted to
the u. s. Office of Education for Local Education Grants under
the Emergency School Aid Act.
IV-26
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The Elementary and Secondary School
Civil Ri;hts Survey (OS/CR 101-102)
Local Education Agencies (LEAs) and State Educa-
tion Agencies (SEAs), through CCSSO, have requested since
1973 that formats for data collection from schools
and States be announced at least nine months prior
to the start of a school year. OCR conducts two sur-
veys of LEAs and SEAs: the School System Summary Report
(OS/CR 101), and the Individual School Campus Report
(OS/CR 102). Neither survey was provided to all respondents
until the start of the school year or later in 1974, 1975,
and 1976.
LEAs and SEAs normally plan their annual data
collection activities by the January preceding the
start of a school year. When data collection formats
containing new or expanded data elements are
announced after a school year begins, schools and
States are forced to search their records manually
for the data, an expensive and duplicative process.
OCR acknowledged in its memoranda announcing the
1976 surveys to SEAs and to LEAs that `much new
information," some of it retrospective to 1975,
was being requested. Commission consultation with OCR, CEIS,
and 0MB during a semi-annual meeting of CEIS in October, 1976,
indicated an interest by all parties that the nine-month
lead time problem be resolved for 1977 and future years.
IV-27
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Forms OS/CR 101 and 102 are compliance reports required
originally under Title VI of the Civil Rights Act of 1974 and
subsequently also by Title IX of the Education Amendments of
1972 and by Section 504 of the Rehabilitation Act of 1973.
They provide important information for the implementation
of recognized national policy. OCR began these surveys in
1968 to collect racial and ethnic information in order to
combat discrimination. Statutory changes in 1972 and 1973
required the addition of questions on sex and on handi-
capping conditions.
The School System Summary Report (OS/CR 101),
which was distributed in December, 1976, to 16,000
school.districtS receiving Federal assistance, required
new data on enrollment in vocational education,
discipline actions, students whose home language
is other than English, and enrollment in bilingual
or English-as--a-Second Language programs.
The Individual School Campus Report (OS/CR 102)
was distributed in December, 1976, to 3,500 school
districts containing approximately 40,000 schools.
It required data on pupils transported at public
expense, numbers of vopational education programs,
high school diplomas in previous years, and informa-
tion on student discipline, special education and
pupil cl~is~room assignments for a sample of classes.
IV-23
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These were expanded requirements from previous years.
Especially burdensome in 1976 because of lack of
sufficient lead-time in announcing the format for
data collection were reports for the prior school
year on pupils suspended, receiving corporal punishment
and/or referred for disciplinary action to courts or
juvenile authorities.
OCR had worked for almost one year in preparin9
the 1976 school survey forms and, that spring for
the first time, conducted a pretest under contract.
A dra ft copy of ~port on the Pretest of the Office
for Civil Rights Fall 1976 Survey Ii tiu~ents showed
average completion time to be 5.75 hours for
Form 101 and six hours for Form 102. For the
16,000 school districts and 40,000 schools directly
involved, the burden was estimated by the Commission
to be 150,000 person-hours based on median completion
time.
Because none of the 194 school districts with
enrollments of 25,000 students or more were field
tested, the total burden would undoubtedly have been
higher if they were included. The Commission consulted
two large districts which indicated their response
burden would range from 24 to 32 hours. The report on the
pretest reflected the need for lead-time and suggested a
nine-month period.
IV-29
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On October 5, 1976, 0MB withheld approval of these two
forms, citing as reasons the timing of the proposed request,
thd request for retrospective data, and target-sampling prior
to collection of screening information. On October 20, 0MB
cleared the forms but stated again its concern about requests
for retrospective data, particularly when schools had
been required to )~eep records to respond to different
formats. A special condiLion of final clearance ~as
the requirement that OCR include language in its
notices to schools and States indicating that, if
some schools demonstrated they did not have resr~on~ive
information available, OCR would discuss alternate data
responses.
In a three-page memorandum to LEAs and SEAs
late in the fall of 1976 announcing its 1976-77
Survey, OCR concluded with four lines saying it would
conduct surveys biennially in the future. OCR said
schools would be required to maintain similar (emphasis
added) records for non-survey years.
In response to annual widespread complaints concern-
ing the collection of all education data, including civil
right.s information, the Congress, aided by Congressional
members of the Commission, provided statutory language for
the Education Amendments of 1976, enacted on October 12,
1976. This language, discussed in the following chapter,
requires coordination of the collection of information and
data acquisition activities for the Education Division of
HEW and OCR. IV-33
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Recommendation No. 25
The Office for Civil Rights of the Department of Health, Educa-
tion, and Welfare should announce clearly by January, 1977,
whether the Civil Rights Survey (OS/CR 101 and 102) data require-
ments for recordkeeping in 1977 are to be identical to and no
more than those required in the survey year of 1976, subject
to legislative or judicial changes.
Recommendation No. 26
The Secretary of Health, Education and Welfare should direct
the Education Data Acquisition Council to require clearance
of Forms OS/CR 101 and 102 for the 1978-79 biennium in sufficient
time to enable announcement of 1978 survey data items by January
1, 1978.
IV- 31
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143
These recommendations were adopted by the Commission
* December 3, 1976. The Secretary's response, on January 19,
1977, indicated agreement on the need to provide sufficient
lead time and stated that the Director of OCR intends to
ensure that school officials "be informed of the specific
data requirements well in advance of the due~ dates" in
future years. The response added that a January, 1977,
announcement of the recordkeeping requirements would not
be possible, but that a decision would be reached no later
than March 31.
With respect to Recommendation No. 26, the Secretary's
letter stated that the OCR "will start to plan for the 1978-
79 biennial survey in the near future, and it should be
possible to make an announcement as to its contents by the
date you suggest, subject to legislative or judicial develop-
ments."
HEGIS
Two revised report forms instituted in 1976 by NCES
would have brought about an acute increase in paperwork for
3,000 institutions of higher education. These forms, for
the Higher Education General Information Survey (HEGIS),
were announced too late for the institutions to produce
the newly required information in a timely manner, and com-
pletion would have required a hand-search of records. The
problems arising from the new HEGIS report forms had been
IV- 32
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delineated in a letter to the Secretary of HEW by the New
York State Commissioner of Education; hearing testimony;
letters to the Commission on Federal Paperwork; and media
exposure of the financial pressures on higher education caused
by increasing paperwork burdens.
NCES, the data collection agency of the Education
Division, planned to send two substantially revised REGIS
forms to colleges and universities. The first form, DEGREES
AND OTHER FORMAL AWARDS CONFERRED BETWEEN JULY 1, 1975 and
JUNE 30, 1976 (OE Form 2300-2.1, 3/76), was due to be re-
turned by August 15, 1976. This report called for a new
format for reporting the distribution of degrees earned
in the various fields of study.
The second form, FALL ENROLLMENT AND COMPLIANCE
REPORT OF INSTITUTIONS OF HIGHER EDUCATION, 1976
(OE Form 2300-2.3, 3/76), was a combination of
the REGIS Fall Enrollment Survey, the annual report
of all enrollment figures, and an Office for Civil
Rights Compliance Report. The combined Fall
Enrollment Report was due to be returned by December,
1976. The substantial revisions from previous surveys
required a new data acquisition format for five racial/ethnic
and one nonresident alien category by ten individual major
fields of study and by classifications expanded to include
part-time students.
IV- 33
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145
Colleges and universities gather student informa-
tion by schooL years, with the gathering usually done
at registration. and commencement. Once decisions
have been made and forms prepared for the collection
of information, it is time-consuming and expensive to
accuire additional information before the next
annual cycle. The acquisition of this information
creates a paperwork burden for the institution.
The 1976 summer graduation had already taken place
when the change in information requirements in the Degrees
Conferred Report was announced. A hand-search of graduation
records was required to provide information which formerly
ha~ been collected without records search, if the institu-
tions were to comply with the new HEGIS request.
On June 24, 1976, the Commission made three recornrnenda-
tions to the Secretary of HEW with respect to HEGIS, under
which colleges and universities provide annual statistical
data. These were:
IV-34
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146
Recommendation No 27
A one-year moratorium on changes in the form on which racial/
ethnic categories are reported by major fields of study. The
Cornmjssjon suggested that the earlier form- used by the Office
for Civil Rights remain in effect until such time as the in-.
stitutions could prepare in advance to gather the data.
Recommendation No. 28 . . . . .
Full consultation with the higher education community before
revised forms are used in future surveys
Recommendation No 29
The distribution of REGIS forms to the responding institutions
by December of the year prior to their intended completion
IV-35
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147
The Secretary's response cited difficulties in accept-
ing the first recommendation The earlier form used by
the Office for Civil Rights could not be retained because
the racial/ethnic categories prescribed for standard Fed-
eral use had been changed Furthermore, the urgent demand
for the data made a moratorium unfeasible The letter
stated that the second and third recommendations could be
implemented and that efforts to implement them had already
begun
Suggestions for HEGIS. The HEGIS series conducted by NCES
involves up to eight additional surveys in addition to the
two discussed above. These call for data on institutional
characteristics, staff, finances, physical facilities,
libraries and students. A task force of the.NACUBO paper-
work committee, with Commission consultation, examined these
surveys and identified many instances of insufficient lead
time, changing formats, too frequent collection, absence of
sampling techniques, and late feedback of results
This task force suggested that two surveys be con-
ducted annually, Institutional Characteristics and Opening
Fall Enrollment, with racial/ethnic data in the latter form
collected every two o~ three years Two other surveys were
recommended for less frequent collection: Degrees and Other
Formal Awards Conferred, biennially, and Upper Division
Post Baccalaureate Enrollment by Degree Field, every three
or four years, using a sample of institutions In all
IV-36
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148
instances collection forms sould be provided atleast nine
months in advance.
To help meet the problem of late feedback, where pub-
lications arrive three or four years after collection of
data, the task force urged NCES to provide data tapes for
early use by researchers and to utilize a check-off system
at the time of collection so institutions can indicate
whether publications are desired. The Commission acknowl-
edges that NCES has begun to consider some of these sug-
gested changes and supports these efforts.
IV-37
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FOOTNOTES
Section IV
1. 347 U.S. 483, 74 S. Ct. 686, 98 L Ed. 873 (1954).
2. In DeFunis v. ~ 82 Wn 2d 11, 507 P. 2d 1169
(1973), the Washington Supreme Court upheld the concept,.
while in Bakke v. Board of Regents, University of Cali
fornia, 19 Cal a 3d 34 (1976), the California Supreme
~ã~urt found that such special programs offend the Equal
Protection Clause of the Fourteenth Amendment. This
Case is to be considered by the Supreme Court in its
1977 term.
3. U.S. Department of Commerce, Bureau of the Census,
Statistical Abstract of the United States, 1975 (Wash-
Ii~ton, D.C.: Government Printing Office, 1975), p. 110.
4. 391 F. Supp. 269 (1975).
5. U.S. Commission on Civil Rights, The Fed?ral Civil
Rights Envorcement Effort -- 1974, Vol. V: To Eliminate
Employment Discriminati2fl (Washington, D.C.: 1975), p.
649.
6. Staff of the Office of Management and Budget's Statisti-
cal Policy Division have worked with representatives of
-the General Accounting Office and various Federal execu-
tive agencies (HEW, Labor, HUD, Justice, Census, and
EEOC) to establish, test and promulgate a set of stand-
ard categories for the reporting of racial and ethnic
data. In August, 1976, they obtained agreement from the.
affected agencies on a standard set of racial and
ethnic categories to be used for compliance, administra-
tive and statistical reporting.
IV- 38
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V. MANAGEMENT CONTROLS
In the three preceding sections, specific problems
were described and immediate steps recommended for their
solution. This section discusses management techniques
to resolve entire groups of paperwork problems, including
the need to coordinate education data collection, utilize
standard terminology, and provide an automated index of
data elements. The section also discusses agency respon-
sibility for data collection and use, Congress as an influ-
ence in the creation and control of paperwork, and the
role of respondent education groups.
Coordinating Data Collection
Essential to the management and control of paperwork
is closer coordination of the collection of education data
by Federal, State, and local governments. Responsibility
for education data collection is highly decentralized. The
National Center for Education Statistics (NCES) has
the primary responsibility in the Education Division of HEW
for the collection of general purpose statistics and the
adjunct responsibility for reporting on the condition of
education in the United States.
Substantial portions of education data collection
through the Federal system are gathered also by OE, which
has primary responsibility in the Ethication Division for
accumulating information on the administration and impact
of Federally supported programs. Responsibility for the
collection of specific program data is spread throughout
V-i
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the various components of OE, including the Bureau of School
Systems, the Bureau of Education for the Handicapped, the
Bureau of Postsecondary Education and the Bureau of Occupa-
tional and Adult Education. The Office of Planning,
Budgeting and Evaluation within OE collects and analyzes
information required to evaluate the effectiveness of specific
Federal education initiatives and, in addition, performs an
annual analysis to produce a comprehensive evaluation of
Federally supported education programs.
The National Institute of Education (NIE), another
major component of the Education Division, collects and
analyzes data concerning the development, testing and imple-
mentation of new educational techniques, services and deli-
very mechanisms. In addition, NIE shares the responsibility
for meeting the requirements of certain Congressionally
mandated studies.
Other HEW agencies affecting the education system
gather and use data to measure the impact and effectiveness
of activities under their purview. These programs include
regulatory activities such as those of OCR, which are
designed to insure equal access to educational services, and
grant programs which provide funds for the delivery of
specific services to students such as H~W's Headstart program
directed by the Office for Child Development.
V-2
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152
RecQgnizing the need for coordinating the collection
of education data, the Assistant Secretary for Education
chartered the Education Data Acquisition Council (EDAC) in
1975 to prepare the Education Divisions's Annual Data
Acquisition Plan. EDAC has established criteria for evalua-
ting data requests and has implemented clearance procedures
for the Education Division. This preliminary clearance
effort has been beneficial both to 0MB in its final clearance
review and to respondent groups, since it allows checking
for duplication and use of common definitions. But it serves
primarily as an overall planning mechanism only for the
Education Division data collection.
The only attempt to coordinate education data collection
prior to 1975 was made by NCES through the establishment of
a close working relationship with the Council of Chief State
School Officers and its working arm, the Committee on.
Evaluation and Information Systems (CEIS). CEIS has been
working for several years with NCES and other Federal agencies
to formalize a process for review of Federal data request
from the respondent's point of view. The emphasis by EDAC
and NCES has been directed until recently to the elementary!
secondary school level, but NCES, recognizing the importance
of this review effort, has now extended this process to the
Postsecondary education level through liaison with the
State Higher Education Executive Officers.
\73
PAGENO="0157"
153
Congress also recognized the need for coordination in
order to eliminate the excessive detailand unnecessary or
redundant information requests by enacting the Control of
Paperwork Amendment (Sec. 406 (g)) as a part of the Educa-
tion Amendments of 1976 (P.L. 94-482). This statute pro-
vides that the Secretary of HEW and the Assistant Secretary
for Education shall coordinate the collection of information
and data acquisition activities of the Education Division and
OCR. The review and coordination procedures are to be
directed by the Administrator of NCES. The statute covers
only the Education Division and OCR.
Certain general education data are gathered by agencies
outside the Education Division of HEW. These include the
collections of elementary/secondary school systems' financial
statistics by the Bureau of Census; information concerning
school breakfast and lunch programs by the Department of
Agriculture; student data by the Bureau of Indian Affairs,
Department of the Interior; information for certification of
programs by the Veterans' Administration; education data
regarding programs sponsored by the Department of Defense;
data on students and teachers, particularly in the scienti-
fic and engineering fields, by the National Science Founda-
tion; information on education manpower by the Bureau of
Labor Statistics; and data on intelligence and achievement
V- 4
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154
of children in the Health and Nutrition Examination Survey
conducted by the National Center for Statistics.
There may be other Federal agencies which collect or
plan to request information from the education community.
All agencies, with the exception of the independent Federal
regulatory agencies, would be included in the recommendatiOns
contained in this section. Forms clearance for the inde-
pendent Federal regulatory agencies is a responsibility of
the General Accounting Office, rather than 0MB, under the
Federal Reports Act as amended. These agencies, however,
rarely have a direct effect on education.
Established EDAC procedures will provide a significant
step toward central coordination of data collection in the
Education Division and OCR. The other agencies requesting
data from education respondents, however, are not required
to use EDAC as a clearinghouse for education data collec-
tion. Despite the attention given to unnecessary, redundant
collection, the Control of Paperwork .~mendment is not
broad enough to encompass the coordination of education data
collection outside the Education Division and OCR.
Data collection activities that cut across Federal
agencies often lack the necessary coordination to alleviate
redundancy which generates unnecessary paperwork. The
redundancy presently stems from the lack of comparability
V- 5
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155
in data elements and definitions. It is important to be
able to review or monitor all educational data collection
in light of each agency's needs and to systematize the
process to insure comparability by using standard methods
and definitions. The utilization of information would be
enhanced through coordination by making it useful to more
than one agency. Comparability and compatibility would also
allow the development of more comprehensive statistical pro-
files. *The fragmentation of present data collection prac-
tices contributes to the lack of accurate, readily accessible,
educational information needed by policy makers.
The importance of establishing a central clearinghouse
in Federal education data collection has not only been sup-
ported by Congress in the Education Amendments of 1976, but
also by respondent groups. In November, 1974, the Council
of Chief State School Officers urged HEW to centralize the
collection of all education data by Federal Government.
A similar recommendation was approved during the 12th Annual
Postsecondary Seminar in 1976. The importance of esta-
blishing a clearinghouse for data gathering was also sup-
ported in one of the four major recommendations in a 1976
report to HEW prepared by a panel of the National Research
Council of the National Academy of Sciences. There is
considerable support from all facets of the education
community for the concept of a single unit for coordina-
tion of education data production activities.
V- 6
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156
The dollar savings achieved by eliminating redundancy
or by utilizing generally acceptable methods and defini-
tions, which in turn will improve both comparability and
usefulness, should be a significant step in minimizing data
collection costs. The measure of the cost saving that nay
occur as a result of time)~and accurate information being
available for the determination of national education
policies would depend upon future information needs and policy
decisions, both of which are difficult to predict. The
importance of having accurate information available during
the development of legislation and national policy cannot
be underestimated.
Implementation of this recommendation will require a
minimum outlay of resources and only a minor change in
present procedures. It is an additional but necessary step
that will result in sound organizational management of data
production.
The Statistical Policy Division of 0MB has the authority
under the Federal Reports Act to establish guidelines for
forms clearance procedures and, under the Budget and Account-
ing Procedures Act, to develop programs and issue regulations
and orders for the improved gathering, compiling, analyzing,
publishing, and dissemination of statistical information.
V- 7
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157
Recommendation No. 30
The Office of Management and Budget should
provide for Federal coordination of educa-
tion data production by requiring, in its
forms clearance procedure, that all request
from any Federal agency for data from educa-
tion respondents be coordinated through the
HEW Assistant Secretary for Education prior
to 0MB clearance.
This recommendation wak adopted by the Commission on
February 25, 1977. In res~onse, the Director of 0MB replied
to the Commission on March1 28, 1977 that the general strategy
holds great promise. He skid EDAC is presently implementing
the Control of Paperwork A~nendment to include coordination
and review of OCR education data collections. If EDAC is
judged subsequently to be a viable mechanism, he stated 0MB
would advise the Secretary of HEW to coordinate education
data activities for the entire Department, and depending on
the outcome of that effort, 0MB would consider extending
coordination to all Federal departments.
Standardizing Terminolqgy
Equally important to coordination of collection mentioned
above is the standardization of terminology, which will increase
efficiency, comparability and multiple uses of data. Generally
accepted definitions of education1 terms must be established
* and monitored to assure understanking and a language for
communication.
V-8
91-860 0 - 77 -- 11
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158
This the second step in developing procedures and processes
that will assist in reducing burden and improving education
data production. A third step, suggested later, would provide
for indexing as a procedure that will enhance the overall
efficiency of data collection.
There are currently more than 16,000 elementary and
secondary school districts and over 2,700 institutions of
higher education in the United States. There are also many
organizations and institutions with specialized training and
instructional programs. All these institutions and organizations
have many data elements in common. There is a common core of
elements for institutions that have instruction as their cen-
tral purpose, and much decision-making involves similar infor-
mation. For data from different sources to be organized and
compared, there must be some standardization of data collection.
The standardization should include terms used, the definitions
of those terms, classification systems, and units of measure.
This is particularly critical if data and information from
different sources are to be shared or compared.
The need for standardization can be illustrated by the
example of establishing a cost per elementary or secondary
student which requires a unit of measure for cost and a unit
of measure for a student. For purposes of this illustration,
only variations of the student unit measure will be examined.
The alternatives would include:
V-9
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159
o Membership (number of students on the
current roll of a class or school for a
given date or period of time, reflecting
entries and withdrawals).
o Average daily membership (the average number
in membership during a given period of time).
o Average daily attendance (the average number~
of days of actual attendance by members).
o Enrollment (the number enrolled during a
certain period of time, disregarding
withdrawals).
Even in the third example, the definition of day of atten-
dance may vary not only from State to State, but also could
vary from local district to local district. For instance, when
an excused absence is counted as a day of attendance in some
schools or States and not in others, an inflated figure is
derived. These inflated figures then influence funding
allotments which are based in part on average daily attendance,
as under Title I of the Elementary and Secondary Education
Act.
NCES has made available a set of handbooks of standardized
terminology. These handbooks, which are revised periodically,
deal primarily with general information related to education
and stress standardized terms and definitions. Another NCES
project, the Common-Core-of-Data (CCD) program, has been
designed to facilitate the providing of information needed
on a recurring basis. NCES indicates in its publication
Projects, Products and Services of NCES, 1976 that "National
data-collection efforts in education continue to be seriously
V- 10
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160
restricted by delays in reporting, missing data, nonresponse,
and ambiguous information which results inevitably and directly
from lack of standardization in educational data elements,
recordkeeping, definitions, reporting procedures, and educa-
tional practices.'
The two najor functions of CCD are to develop a basic set
of data based on common .definitions and standards describing
elementary-secondary and postsecondary education and to give
technical assistance to State and local education agencies
to improve data gathering activities. There has been support
for the handbook series and the CCD concept from the 1976
Postsecondary Education Seminar in one of its summary
recommendations and by CCSSO in a resolution passed in June,
1973.
Although NCES is making a concerted effort to promote the
utilization of a set of handbooks as reference manuals for
establishing terms and definitions to be used in education
data collection activities, including the CCD project, all
Federal agencies are not utilizing these common references
or concepts.
Recommendation No. 31
The Assistant Secretary for Education should
use, as a common reference for all terms and
definitions used in education data collection,
the set of handbooks prepared by the National
Center for Education Statistics (NCES) for
that purpose, and all forms submitted for
clearance should be made to conform to those
* terms and definitions.
V-li
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161
Recommendation No. 32
The Assistant Secretary for Education should
give high priority to the Common-Core-of-Data
program developed by the NCES to facilitate
meaningful, comprehensive, and integrated
data collection systems.
These recommendations were adopted by the Commission
on February 25, 1977. In response, the Assistant Secretary
for Education replied to the Commission on April 1, 1977 that
education data acquisition activities must conform to the*
NCES handbook terms amd that Common-Core-of-Data has a high
priority in the Education Division.
Indexing ~
One of the primary tools important in utilizing large amounts
of loosely related data is an automated system for indexing or
cataloguing available data. An index system will provide a
guide to point out or facilitate reference. At present, no
index system is available at the Federal level to serve the
education data community. Plans shoul~f be developed to imple-
ment an indexing system that will not only increase the
utilization of available data, but also provide a necessary
management tool to assist in reducing duplication.
Users of education data generally include Congress, the
general public, Government agencies, education organizations,
news media and business. Although possibly the greatest use
of data is made by the collecting agency itself for program
administration, there are approximately 1,000 other requests
for education data each month to NCES alone. Additional
V- 12
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162
requests may be directed to other collecting agencies.
Utilization of data can be enhanced if the user can
establish relationships between variable data elements by
means of an indexing system. For example, the cost of educa-
tion and the performance of students of differing socio-econonic
backgrounds are variables whose relationship must be examined.
When the variables come from separate sources, indexing should
allow the user to determine if these relationships are currently
available. Indexing may also indicate additional variables
that are needed or relationships that are missing. Determina-
tion of need for additional data elements is most difficult
in the absence of an automated index system.
Duplication is described consistently as a major factor
in paperwork burden. Indexing should increase efficiencies
in proposed data collection by locating duplicative efforts
in advance. For example, where enrollment data are being
collected through general statistics, the data should be shared
with progran monitors. This does not always happen and, as a
result, the enrollment data is collected again and again in
the program area. Although this example may be an over-
simplification of the problem, it can become very complex
given the number of agencies, organizations and program areas
involved in collecting education data.
0MB presently has an inventory which lists forms by form
number, number of responses, and number of person-hours necessary
for completing the form. The 0MB forms inventory is arranged
V-l3
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by agency and type of information the forms will collect, such
as application, program management, etc., but it does not list
the individual data elements included on each form.
EDAC has developed an inventory system that lists forms
by broad content area and respondent groups. The EDAC System
was designed to analyze report forms in many different ways,
but it does not presently include the listing of each individual
data element contained on the data collection forms. There
are plans to develop an automated indexing function in the
EDAC system. An automated system would facilitate the detec-
tion of duplication and the identification of the agency that
had already collected the same, data.
The use of such a system must be extended to include those
agencies that do not presently fall under the EDAC purview.
The coordination of education data, recommended above, would
serve to make the indexing procedure much more comprehensive
than would otherwide be possible. Indexing would then be one
of the coordinating functions performed by EDAC in its role
as coordinator of education data collection.
Recommendation No. 33
The Assistant Secretary for Education should
further the implementation of the Education
Division's data acquisition system by including
in it an automated indexing system for cataloguing
available data. This indexing function
should extend to all agencies that collect educa-
tion data, and adequate funding for this purpose
should be requested.
V- 14
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This recommendation was adopted by the Commission on
February 25, 1977. In response, the Assistant Secretary for
Education replied to the Commission on April 1, 1977 that the
Education Division included in its Fiscal Year 1977 Supplemental
budget request the funds to develop an automated indexing system.
Reducing Burden
The first partial coordination of education data collection
and use is located in HEW's Education Division under the Assis-
tant Secretary for Education and is directed by the Administra-
tor of NCES. Representatives of each of the four agencies
comprising the Division serve on committees which review data
acquisition requests directed to elementary and secondary
education, postsecondary education, adult and vocational and
career education, and the education of handicapped children.
Those that are approved then become part of an annual data
acquisition plan comprising approximately 400 data-gathering
forms.
As this coordinating function developed in its first three
years, it has been limited to data gathered by the Education
Division. If Recommendation No. 30, above, is adopted, the
overview function will expand to cut across all Federal agencies
requiring 0MB forms clearance for data collection from education
respondents. Then, for the first tine, a central source in
the Education Division can maintain records on who is collecting
what, from whom, and for what purpose.
V-15
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The Education Division's annual data acquisition plan,
when considered in conjunction with information fron other
Federal agencies, will contain the data submitted in applica-
tions for grants, progran and managenent reports, surveys, ques-
tionnaires, recordkeeping requirements, and compliance reports.
These data will provide information on subjects s~ch as facili-
ties, finance, enrollment, staff, and program, among others.
The objective of the Education Division shot~ld be to
complete review of its forms in time to permit Federal Register
publication, by the January preceding the start of the school
year, of all plans to collect education data for that school
year. This will provide the nine-months of lead time States
and institutions require to build their data acquisition plans
and collecting activities, as recommended in Section IV. The
Education Division has not yet achieved this objective, one
which would relieve considerably the reporting burden on educa-
tion respondents.
Another potential contribution to the easing of paperwork
burden would be in the reduction or elimination of duplication
and redundancy. Respondents have complained about requirements
to submit identical or similar data on may forms. Frequently
NCES has already collected some of the data but has not been
able to process it quickly enough to provide it to another
agency in time to prevent a second collection of repetitive data.
V- 16
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Available data should be provided to permit--indeed, to require--
program managers to collect only that information that has not
already been gathered. Multiple uses of data in this way would
benefit both agencies and respondents. it can be made possible
by means of the automated index discussed in the Recommendation
No. 33 and prompt processing of data as they are received.
Recommendation No. 34
The Assistant Secretary for Education should review
all education data gathering instruments in the
calendar year preceding collection and announce
by the January preceding the start of the
school year the data elements to be collected
in September.
Recommendation No. 35
The Assistant Secretary for Education should
develop the capacity of the Education Division
to provide promptly, for multiple use by
agencies, data already collected such as in
surveys, applications, compliance reporting,
management reporting, financial reporting
and evaluation, and limit any further
collections to those items not already
in hand.
The Assistant Secretary for Education is not empowered
to require the adoption of a data announcement and collection
cycle or the multiple uses of data by agencies outside the
Education Division. The Commission believes the voluntary
observance of these recommendations by other agencies would be
equally efficient for them as well. Better data would be collected
with a nine-month lead time, and the respondent burden would be
lessened through elimination of much duplication.
V-l7
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Recommendation No. 36
The Office of Management and Budget should urge
all agencies, when they collect data only from
education respondents, to provide nine-months
advance notice of collection and to share their
data collections with the Education Division
for multiple uses wherever possible.
The Role of Congress
A volume of over 700 pages was required, at the close
of the 93rd Congress in 1974, to set forth the Federal education
laws that had originated with the Senate Committee on Labor
and Public Welfare and the House Committee on Education and
Labor. A similar publication containing education legislation
authorized by other committees would likely require an equal
number of pages. A study by the Library of Congress identified
439 statutory authorities affecting postsecondary education
alone. These authorities arose from the work of 18 of the 22
standing committees of the House and 16 of the 18 standing
committees of the Senate.
Most laws affecting education require paperwork, both by
those persons or institutions benefited or affected and by
the agencies which issue the regulations and administer the
programs. OE, a major administrator of education programs,
has had more than a tenfold increase in the last five years
in the number of documents it publishes annually in the Federal
Register, from 32~in Fiscal Year 1972 to an estimated 368 in
Fiscal Year 1977.
In addition to passing laws which result in programs
requiring paperwork, Congress also mandates special studies
V- 18
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and reports from HEW which in turn may require paperwork from
education respondents. Thirty-four of these reports were required
in the Education Amendments of 1972, 48 in the Education Amend-
ments of 1974 and 34 in the Education Amendments of 1976.
In that short span of tine, required reports have become so
numerous and have had such short completion time that the
agencies could not meet the response deadline. The Education
Amendments of 1976, for example, contained changes in completion
dates that would not be met for at least 19 reports in the
Education Amendments of 1974.
There are at least two causes of the short reporting dead-
lines in the case of the Education Amendments of 1974. First,
the introduction of bills and their amendments in committees
began early in the two-year tenure of that Congress. By the
time the bill had cleared each House and the two bills had gone
to conference for final agreement on a single bill, the Congress
approached the end of its two-year period, and the reporting
dates carried over from the original bills were no longer
achievable. Second, in the instance of the preparation of the
Education Amendments of 1974, Congress had changed the fiscal
year starting date from July 1 to October 1, thus shortening
the reporting time that had been based on the earlier date.
The Senate Committee on Human Resources and the House
Committee on Education and Labor, originators of most purely
educational legislation, have begun, however, in the last half
dozen years to try to control and manage paperwork burdens
V- 19
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169
created by education laws. Simultaneously, they have sought to
improve the quality and manage the quantity of information and
data necessary to assess programs and shape public policy. This
is being done in sympathetic response to complaints from
education respondents.
In the Education Amendments of 1972, for example, Congress
mandated an analysis by the Commissioner of Education of all CE
rules, regulations, guidelines, or other published interpreta-
tions or orders. The Commissioner was required to report to the
education committees within one year on the specific legal
authority of each section of each rule or regulation and to
publish these rules or regulations in the Federal Register for
comment no later than 60 days after the report. After a 60-
day comment period by interested parties, the Commissioner was
to report to the education committees any actions taken and
then to republish all regulations or rules in final form.
The magnitude of the study of all rules and regulations
ordered in the education Amendments of 1972, however, did not
permit their completion in one year. CE thus began the task
of studying the laws on a section-by-section basis. By early
1977, almost five years later, it had completed work on 49
sections and had published their regulations in the Federal
gister. 1 Eight sections remained to be completed at that
time but were in process and nearing completion.
In the Education Amendments of 1974, Congress took two
further actions to control burdens on the public. First, it
provided by law a 30-day comment period before the effective
V- 20
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170
date of any standard, rule, regulation, or general requirement.
Concurrent with publication in the Federal Register of rules or
regulations, Congress required also their transmission to the
two Houses to provide for disapproval by concurrent resolution
within a 45-day period if Congress found them inconsistent with
the laws. Thus far, the Congress has not taken such action of
disapproval but it has held occasional hearings on some subjects
of immediate concern.
Second, Congress established the National Center for
Education Statistics in the office of the Assistant Secretary
for Education to collect and disseminate statistics and other
data related to education. It also made the NCES administra-
tor's post an appointed position in the competitive service,
not subject to political influence. These actions gave NCES
independence from any other HEW agency, placed it in a leader-
ship role, gave it more responsibility, and made it subject to
direct consideration by the appropriations committees. These
actions later became the basis for Congress' first education
paperwork legislation.
In the Education Amendments of 1976, Congress for the
first time specifically addressed the burdens of paperwork in
passing the Control of Paperwork amendment, Sec. 406(g). It
said that "in order to eliminate excessive detail and unnecessary
or redundant information requests,' the Secretary and Assistant
Secretary for Education shall coordinate the collection of
information and data acquisition activities of the Education
V-2l
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171
Division and the Office for Civil Rights. It required the
Assistant Secretary for Education to provide staff to establish
a procedure for the review of infornation collection and data
acquisition under the direction of the Administrator of NCES.
Further, the Administrator was required to assist in this
coordination by requiring each of the two agencies to provide
a detailed justification of how information once collected will
be used and an estimate of the man-hours required by each
respondent to complete the requests. A public comment period
prior to final 0MB clearance was established also. And finally,
Congress directed that the Assistant Secretary for Education
make legislative recommendations necessary for meeting the
objectives of the paperwork amendment.
In several other sections of the Education IunendmentS of
1976, such as Section 802(b) (4) on cooperative education,
language on information gathering was changed from what the
Commissioner "may reasonably require' to such data "as are
essential." This represents another Congressional directive
to hold reporting to minimal limits.
Despite these efforts, the net effect of enacting new
education legislation every two years is an increase in number
of forms to be completed and regulations to be observed.
Congressional and agency policy makers are currently discussing
additional data needs to be obtained from individuals as well
as from institutions. They are interested in developing
information about the general population, the nomcollegiate
sector, and about teacher supply and demand by specific
V- 22
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areas and subjects, for example. All these demands for informa-
tion will require carefully planned annual data acquisitions and
multiple uses of information if respondents and agencies are to
keep current in supplying them.
Congress could assist greatly in easing paperwork burdens
on respondents by observing the need for adequate lead time
between an agency's announcement of its intent to collect data
and the actual time of collection. This could be achieved if
the Congress would allow, in mandating specific completion
dates for studies and reports, sufficient time for the agency
announcement in January prior to collection in September and
if, in the meantime, Congress would use available data until a
new collection is made. Such a course would facilitate imple-
mentation of Recommendation No. 34.
There is precedent for suggesting Congressionally approved
lead time for education. In the Study of the United States
Office of Education by the House Special Subcommittee on Educa-
tion in the Second Session of the 89th Congress, recommendations
were made for a full year of adequate planning before newly
authorized programs become fully operative and that appropriations
be made no later than May 1. All education programs are now
forward-funded by one year and the implementation of vocational
education programs in the Education Amendments of 1976 are
delayed for one year to permit agency planning.
V- 23
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173
Congress could also ease the burden of responding to
certain proposed regulations, by providing timely hearings
for the regulation-writers when the particular statute has
little or no hearing record or other legislative history.
Some recent examples would include Title IX on sex discrimina-
tion in the Education Amendments of 1972, the Family Educational
Rights and Privacy Act of the Education Amendments of 1974,
and Section 504 of the Rehabilitation Act of 1973. Such
hearings could encompass either oversight or a concurrent
resolution of disapproval under Section 431(d) (1) of the General
Education Provisions Act. However a record of Congressional
intent is established, agencies and respondents would benefit
by the necessary clarification.
Recommendation No. 37
The education committees of Congress (i.e., the
Senate Committee on Human Resources and the
House Committee on Education and Labor) should
review in every third Congress, beginning with
the 95th Congress, the reports and studies they
require of the Department of Health, Education,
and Welfare in order to eliminate those no longer
needed, consolidate those that can be combined,
and make the remainder compatible with an overall
plan for reporting.
Recommendation No. 38
The education committees of Congress should
recognize January 1 as the latest date by which
Federal agencies should announce the specific
education data to be collected at the start
of the following school year, to provide
sufficient lead time for States and institutions
to include such data in their annual acquisition
plans.
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91-860 0 - 77 -- 12
PAGENO="0178"
174
Recorr~nendatidn No. 39
The education committees of Congress should hold
hearings on proposed regulations or data-
gathering forms that are developed from
laws whenever agencies and respondents indicate
a need for guidance in preparing or responding
to the ensuing regulations or forms.
Respondent Participation
The Commission has observed the role and effectiveness of
respondent groups both in ensuring the collection of sufficient
and reliable data and in controlling the frequent desire for
excessive amounts of data. We believe the need for adequate and
accurate data is best met when originators of and respondents to
data requests first consult on what is to be collected, from whom,
and for what purpose.
The Control of Paperwork amendment cited earlier mandates a
public comment period for all data-gathering forms of the Education
Division when they are ready for final 0MB clearance. Although
the mandate establishes a check point near the end of the forms
clearance procedures, earlier consultation with respondents in the
preparation of forms would undoubtedly improve and expedite the
final product. Such consultation could include field tests of
forms and site visits by agency staffs, where possible, to evaluate
respondent burden.
Among the better organized groups are the Council of Chief
State School Officers (CCSSO), an independent organization of
State superintendents and commissioners of education, and its
v- 25
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175
Committee on Evaluation and Information Systems (CEIS), formed~
in 1972 and comprised primarily of one coordinator from each
State and from six other territorial jurisdictions. Another
100 or more State and local education agency staff persons assist
in monitoring and reviewing Federal data reports.
CEIS is divided into committees on data acquisition, evalua-
tion, and information systems development. These committees are
divided further into task forces which concentrate on specific
areas such as compliance reporting, food and nutrition services,
vocational education, education of the handicapped, common core
of data, standard terminology, and technical assistance. Results
from these task force efforts can be shown in the example of
school lunch paperwork cited in the first section. Through
consultation with the Department of Agriculture, CEIS was able
to achieve consolidation of three monthly report forms in one
instance and two monthly reports in another, plus the provision
for adequate lead time for both reports as well as others.
Representatives of the full committee and task forces meet
at least twelve times per year to consult on data collection
activities with agency staffs from the Education Division, 0MB,
Department of Agriculture, Census Bureau, Bureau of Labor
Statistics, Equal Employment Opportunity Commission, Office for
Civil Rights, National Science Foundation and many others.
Extensive records are maintained on each Federal form reviewed,
including the mamas of Federal Staff persons with whom CEIS meets
by schedule and consults by telephone or letter between meetings.
`These records show actions in 1976 to provide lead time for
V-26
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176
school civil rights surveys, justification of data items in a
bilingual survey of teacher's language skills, and the com-
bining of a study of English language proficiency with a pupil
survey of family income and education, among at least three
dozen other forms where agreements for collection were achieved
or continue under discussion until agreements can be reached.
These efforts to improve data collection and utilization
at the elementary and secondary levels are in part supported
financially by NCES. Late in 1976, this program of financial
assistance was expanded to include a representative organ~za-
tion in postsecondary education when NCES contracted with the
State Higher Education Executive Officers (SHEEO) to establish
a similar program of cooperation and planning in data collec-
tion and use. One purpose of support for SHEEO was the
creation of a communication network among all States which
would become the basis for exchanging postsecondary education
data between and among States and *the Federal Government.
Traditional higher education has functioned very well
over the decades as a respondent group under the auspices
of the American Council on Education (ACE), an umbrella
organization. Staffs of major college and university member-
ship groups which comprise ACE have met regularly for almost
20 years to review pending legislation, proposed regulations,
and data requests. These institutional membership groups
include:
V-27
PAGENO="0181"
177
o National Association of College and University
Business Officers (NACUBO),
o Association of American Universities,
o National Association of State Universities and
Land-Grant Colleges,
o American Association of State Colleges and
Universities,.
o American Association of Community and Junior Colleges,
o National Association of Independent Colleges and
Universities, and the
o Association of Jesuit Colleges and Universities.
These meetings, held at least weekly in recent years, have
been expanded to include a variety of specialized associations
in order to provide specific expertise on particular subjects.
All these membership organizations, sometimes through a lead
association, comment on most data-gathering requests and
proposed regulations and provide daily consultation to appro-
priate Federal agencies and the Congress.
ACE provides additional overall leadership for higher
education in a variety of ways. It recently arranged a series
of meetings, including one with the President, to meet the
new Administration and to discuss general problems facing educa-
tion. It also assigned responsibility to NACUBO to monitor
paperwork concerns in behalf of higher education. The NACUBO
paperwork committee, mentioned earlier in this report, will
continue to support implementation of Commission recommenda-
tions after this repOrt is issued.
V- 28
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178
A list of the various forms, proposed regulations, and
other instances where these higher education associations
have acted in cooperation with Federal agencies to reduce
paperwork burdens would be lengthy. Three notable examples
include regulations covering the Family Educational Rights
and Privacy Act of 1974; regulations implementing Title IX
of the Education Amendments of 1972; and the shaping of Form
EEO-6, which is used by colleges and universities to report
statistics of their employees by minority group, sex, job
category, and salary range. These organizations also regularly
consult with NCES on the annual Higher Education General
Information Survey, with the National Science Foundation on its
various surveys, and with other agencies.
Respondent groups cited in this report, and all such advisory
groups, can play a unique role. Because committees of Congress,
agencies of the Federal Government, and the States and their
education institutions work independently of one another for
the most part, these advisory groups can help improve decisions,
the Commission believes, by providing the necessary communica-
tion links between and among these committees, agencies,
and States.
The Commission believes further that while the Congress
and the Executive Branch on their parts are committed to
eliminating unnecessary paperwork burdens, respondent groups
must share equally in the responsibility to reduce excessive
paoerwork while simultaneously providing better information.
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179
Recommendation No. 40
Federal agencies planning to gather data from
educational institutions or State or local
education agencies should consult these groups
and/or their associations before making
decisions on either the scope or the form
of the requirement.
Recommendation No. 41
Education respondent groups should provide
consultation and comment to Congress and to
the agencies when consulted in advance and
when notices are published in the Federal
Register concerning data collection or
rulemaking.
FOOTNOTES
1/ Conversation with staff of the House
Committee on Education and Labor, March, 1977
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180
APP
REPORT OP ThE
INTERAGENCY TASK FORCE ON
HIGHER EDUCATION BURDEN REDUCTION
D~c~rrb~r 1%~ 1976
PAGENO="0185"
181
X~TROD~5CTION
The Fedaral Govatnment and colleges and universitieS have in
recent decades entered into a remarkable partnership, building
tha world's greatest capability for scholarship, advanced
education and the application of fundamental knowledge to the
pressing problems of our society. The Government played a
leading role in recognizing the unique resources represented in
our hi~her education institutiOnS, but has turned in the last
20 years toward offering support for those programs and incen-
tives which further national objectives directly. This growth
of categorical aid to universities and colleges has brought with
it the expected controls born of the need for stewardship in the
use of these Federal monies. Many institutions are critically
dependent on this Federal support. As wave after wave of regu-
lations, surveys, and compliance activities have hit, they have
until recently endured with suffering and silence, while resources
made scarce by shrinking dollars have been diverted to adminis-
trative and accountability functions.
In the last few years, however, there has been a rising level
of consciousness, an awareness by the institutions that unless
a widar perspective can replace the individualistic motivations
of those in Federal agencies who, by themselves, define the
need for data and detailed accountability, this special
p~at'ec~i.p ou~uaer~ GOVO~fii~flt .E:Yi the institutions will be
1st. IL c~en no;; 5CvCt'.ty straiflu -
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182
In his opaniilg remarks to this Thteragoncy Task Force on
}Iighor Edueation Burden Reduction, Dr. Mathews, Sec:cetary of
Heolth, Educntion, and Welfare, said:
"The strength behind that protest is considerable,
determined and permanent. It is an idea whose time
has come.
At this point, you have control of how the needed
changes will come about. They can come about with
some deliberation on the part of people who are
invested with the responsibility or they can come
about more precipitously with l~s thought. I am
fully convinced that it is in your interest and the
interest of your agencies to make some accommodation
to the petition of the institutions of higher learn-
ing and post-secondary education in this country
I think it serves your purpose and their purposes
as wall."
The Interagency Task Force brought together, under White house
initiative, 28 people from 15 agencies to: assess the problem;
evaluate a set of recommendations1 made by a group of college
and university experts on Federal pao~rwork and reporting
burdens; and propose specific stops which would have the
greatest effect on the reporting and recordkeeping burdens
of the institutions.
1/ ~POrt c~.the Secret~y's Work Grouo for Consolidation and
Si~ipli±ication_of Federal Reporting Recruiraoents_for
Ir~stitutid~~s of Higher Education, 11th, October .L5, 1976.
B- 2
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183
The charge was to hays an impact, and promptly. This
established the scope for the work of the Task Force. The re-
sultant recommendations below concentrate on relatively
immediate steps which wOuld considerably lessen the tensions
between academia and the Government and relieve much of the
workload that falls on the institutions and Government alike.
B- 3
PAGENO="0188"
184
RECO: :- --;N~)ATIONS
*1. At present there is no single directory or index to
Federal data gathering programs affecting higher
education insti tutions which can be used by the
agencies or the various forms clearance offices to
identify sources of data, technical survey design
expertise, or duplication. The Task Force recommends
~ that the Statistical Policy Division, Office of
I-ianagenent and Budget, should develop such an index,
with entries made at the earliest notice from the
agencies of plans -to collect data and updated as each
form is revised or new forms added. This fully-developed
capability might involve a computerized information
system which could be tapped by remote terminal permitting
a search by topic, by data element, and by agency.
Periodically it would be possible to produce from this data
base a directory of forms being used with higher education
institutiorts, making available a data source reference
for use by those seeking data about higher education
institutions.
2. The Task Force believes that the data accr,'icition plan
of the Education Division of }TE~7 is an impartant tool
for planning and evaluating information needs and
resources. This plan identifies the data gathering -
activities to be undertaken in the following fiscal year.
Those whith are approved are the only data acquisition
activities which can be mounted that year. The Task Force -
recommends that all Federal agencies develop data acqui-
sition plans. -
3. The Task Force does not find that control of the paperwork
* dilemma can be gained simply by demanding that agencies
meet even more stringent and detailed documentation
rcquirernents for the approval of forms than now exist.
Bany forms designed to collect survey data and to satisfy
administrative recordkeeping requirenents are well
desigeed, and reflect excellent conceptual, technical,
and consultative efforts. Requiring in all cases that
forms clearance be subject to extensive cleerance
docunentation discourages the responsible approaches to
infornacion collection which should be encouraged.
Increased internal paperwork within government can be as
needlessly burdcnson~ as it -is at colleges and universities.
B- 4
PAGENO="0189"
185
The Task Force thercfora recosc~ends that 0MB revise its
forms CIearCmCC procedures by requiring a notice to 0MB
of the intention to originate or renew a form. 0MB
would then assign the form to one of two clearance
tracks, using stratified random sampling method. However,
controversial or particularly burdensome forms could
be assigr.ecl to the second track with certainty. The
emeller set of forms in the `audit" track would require
the full and extensive package of documentation coiled for
in the current OHS instructions for Form 83 and else-
where in the Task Force report. Intensive 0MB review of
forms clearance packages in the second track on the
described sample basis should provide sufficient basis
for an assessment of the agency's capacity to produce
optimal information gathering instruments and complete
justifications.
In subsequent cycles, agencies with demonstrated success
in previous audits should continue to have their work
examined on the modified random basis described above.
Failure to satisfy the justification and documentation
requirements of the Federal Reports Act and related
regulations and 0MB circulars shall be taken as prima
facie evidence of an agency or division's inability to
control unnecessary, uneconomical, ineffective, or burden-
some reporting requirements. 0MB would then audit in
succeeding years a much larger portion of clearance
packages only from these offices which fail the initial
audit.
4. The Task Force recommends that higher education institutions
and their representative organizations should serve as
experts on the design, feasibility, necessity, and
appropriateness of statistical surveys of such institutioi.~.
This consultation should be sought by survey sponsors early
in the planning process, before data formats and definitions
are nearly finalized. Although such consultation would
be also available to the Clearance Offices of OHM and GAO,
its greater value will be in the development and evaluation
phases of survey picnnin~j by the agencies.
5. Although there are three basic measures used by 0MB to
measure Federal reporting requirenents (number of reporting
forms, number of respondents, and amount of time required to
B-S
PAGENO="0190"
186
complete the reports), identifying the level of burden
requires the accucate estinetion of all three measures.
The Task Force review of selected clearance packages
and CflQiyS±s of reporting procedures showed that
aaount of time required is Unlikely to be known
accurately by the agencies or O~.
Most forms require for their completion the cooperation
of many offices at colleges and universities, and the
number of respondents is a variable multl~le of the
number of institutions filing the report The under-
statement of number of respondents would not itself be a
serious problem if the number of person-hours required
to ôornplete the forms were actually known. The usual
agency practice of estimating average parson-hours in
almost every case ignores the range of effort across
institutions and the fact that the burden is knowable and
need not be guessed at by agencies in Washington.
The Task Force recommends that for all forms a sample
of respondent institutions be asked to report estimates
of marginal person-hours that are necessary to complete
the form. This estimate should be given in two categories:
(1) the time required for reporting the information after
it has been assembled; and (2) the time expanded in
collecting and assembling the information if it is not
already available.
Agencies should design the samples so that good empirical
estimates of he distribution of burden can be derived
for institutions of different size and type of control.
These estimates should be used in weighing the need for
the information against its burden to the respondents.
6. Complaints of response burden are frequehtly to be found
at the institution level but less recoqnize~ at the agency
level. In order to better evaluate the burden of Federal
forms, the Task Force recommends that agencies maintain
comment and complaint files on a fern-by-form basis cmi
use them in forms redesiqu and in interpretating the data
oh tamed.
7. The Teak Force finds ample evidence that the current
eractices of p]anuisq s~vays and protests, and the
current at tutor-i rec;u.~recsnt of fcmcs:l ciear~~-~ca of all
B-6
PAGENO="0191"
187
surveys addressed to more than nine respondents, are
insufficient to minimize the reporting burdens. The
Task Force recosmands commrehensive pretesting by
the form and survey sponsors at a representative group
of institutons prior to submission to 0MB or GAO for
final clearance to permit sponsors to identify poten-
tially onerous aspects of their proposed instruments
and generally improve the quality of data collected.
The Task Force also recommends that pretesting should
be done on si~e at institutions so form and survey
sponsors can see firsthand any special difficulties and
be more able ~o provide instructions and instruments
which will meet the criteria of efficiency, adequacy
and minimum burden on respondents.
8. The collection of highly detailed information by which
Federal agencies may discover the failure of institution..
to comply with regulations or statutes may be inappro-
priate when respondent burden and practical utility to
the agency are considered. The Task Force recommends
that screening surveys be utilized to detect the need
for the subsequent collection of more detailed data.
Although this two-stage approach may appear to take more
time, there will be far less respondent burden, the
compliance agency will not have to handle such a large
volume of unused data, and the staff can be made avail-
able for the analytic work which so often is pressed into
the background.
9. The Task Force recommends that special attention should
be paid by survey sponsors to the workload required for
statistical and administrative reporting as it impacts
on certain groups of institutions. For example, small
institutions have less capability to take on what might
be a modest request of a campus with more resources. The.
data which might be obtained from the smaller institutions
or other categories of institutions may weigh very lightly
in the corpus of data for decison-making, but nevertheless
pose a workload, perhaps a clear example of unnecessary
burden.
10. Sampling of the data items should also be used to reduce
respondent burden. For example, certain data might be
collected by a census of all institutions, while more de-
tailed data could be obtained from just a sample of those
instituL~ons. This approoch will still be considered a
single au~:vey by the Clearance Office, 0MB, he-cause its
ob-ject~.' in to reduce rcrortincf hurd.n.
B- 7
PAGENO="0192"
188
11. The Work Group rh~port1 raco;umsndnd that all Federal data
actiV) tins be conoolidd ted in a single agency in order
to reduce the number of Government/inStitutiOn contacts,
standardize definitions, remove cm, minimize
changes in definitions and date formats, and disseminate
the results in a timely fashion. Careful examination of
the inpl ications of this proposal has led the Task Force
to recommend against a single data collection agency.
In the view of the Task Force, these objectives would
not be guaranteed by such an ag -~cy.
On the other hand, there are counter-indications that a
single data collection agency could add problems. Uha~
is often thought by critics of Federal reporting require-
ments to be duplication of tan turns out to be not much
redundancy, but a very heavy lead of reporting which does
not appear necessary. In many cases data serve specific
progran or policy purposes, and increasing the distance
between user and data collector is inadvisable. No
currently es~.ahlished agency is staffed or otherwise
prepared to handle the heavy workload of such a consolida-
tion, and increased funding of that magnitude is unlikely.
Aqencien which become dependent on another agency for
their data will become vulnerable when exposed to data
policies or changing priorities which they cannot control.
The com3lexity of such a new organizatiofl~ would not lead
to sinflificatiOfl of the contacts between Government and
the institutions. The single agency could not be expected
to be able to provide the substantive expertise in the
depth no~i available in specialized agencies.
Pony of the recommendations of the Task Force, if inplemented,
can ba e~pected to cut back on unnecessary or poorly
dnsignsd data collection efforts. Instead of supporting
the single agency concept, the Task Force recommends
enhanced support for the continued im~ovement of statistical
agencies and units, such as the survey, data library and
d~ssamieation services at the National C:enter for Education
Statistics (NCTS).
The Task Force also recommends that survey dzita from non-
fecThral organisationa should ha added to the EDST2\T system
at ~~ES to broaden the base of statisticaL information.
3-8
PAGENO="0193"
189
12. The Tack Force rac~merLds that data clerants which
have ~~uiti-agcacy uses ho identified early in the
planning procece and that priority be given to the
early editing and release Of responses to these items.
The Task Force also urges agencies to utilize partially
pre-filled forms, drawing from data already in Federal
agency files.
13. The Federal Administrative Procedure Act establishes a
process for ensuring that public reaction to Federal
policies is considered during the development of regula-
tions. The several steps in this process include publi-
cation of a Notice of Proposed Rule Making (NPRN) with a
45-day comment period prior to publication of final regu-
lation; encouraging comments through public hearings;
requiring that Federal agencies maintain a record of
written comments received during the NPRM comment perio:1
for review by interested persons; and, publication of
final regulations reflecting public opinions and
suggestions for change.
A quick survey of thirteen of the agencies represented
on the Task Force indicates that public involvement is an
increasingly important factor in the regulations prosese,
and that the agencies should reflect this in a more
systematic way. The Task Force recommends that Federal
agencies should, where appropriate, introduca into the
current regulations development process a "notice of
intent to develop regulations" to be published in the
Federal Register with an allowed comment period of 45 dayc
prior to the NPRM stage. The current Notice of Proposed
Rule-Making process should, where appropriate, detail
the type of reporting forms that will be required by the
new sot of regulation and estimate thu burden institutions
will have to assume in collecting or maintaining data.
The agency should indicate its willingness to evalucte
within two years the impact of the regulation in ;Pojor
policy areas.
B- 9
91-860 0- 77 --13
PAGENO="0194"
190
14. Accoun~il~c~' for F:etoral Funds is necessary; herever,
ORO shenid rec.~uc: the [.0:1 tucional recor6kex~inq
renui:m~nts enc~clec in Federal tire and offurL ronort--
ing and cocu ntat~oo cc coec sharing by ensuring that
collected Loformetron is rcnninçjful end ucotul. Oi~B
should implement the Commission on Government Procure-
mont recocenandation (B-B) which wou:Ld effectiveLy eliminate
the nocensity for cost sharing on R&D projects ~ con-
currence with a similar recommendation endorsed by the
Federal Paperwork Commission at its meeting on December 3,
?97&. ORB should also seek omission of cost sharing
requirements in the Independent Offices-BUD and HELl-Labor
Appropriations Acts.
15. The Task Force recognizes the accomplishments inherent
in ORB Circular A-11O, which establishes uniform adminis-
trative renuirercents for grants arid other awards received
from Federal agencies. This Circular is expected to con-
tribute appreciably to the reduction of the recordhsep!ng
and reporting burden on colleges and universities on all
grants end on those contracts, though few in number, to
which it applies.
The Task Force believes that this contribution could be
coos idnrably enhanced if the standards set forth in ORB
Circular A-llO could apply, in some measure at leant, to
the majority of contracts for research,. training, demon-
stration, and piflic service that are generally perFormed
in colleges and universities. There would undoubtedly
have to he sonic flexibility in order to conform to the
major procurement regulations, but Circular A-liD ropre-
seats a significant achievement that should be extended
where possible to contracts.
ORB is urged to consider such extension.
16. A single agency should hs identified for managing tha
Federal interest in selec ted areas, such as human subjects
protectaon, care and use of laboratory anirels, clean
risc, pure water, and patents. Such on ap~roach c:ould be
modeled after tho exinting cognizant audit agency concept
ch has rof riced duolicotive activities ossocifrrtcd with
f:Lnnrcinl and its of federally-sponsored programs h
ass :gniorj mOult cslicgo nod .tr:tverslty to a siri.dle aunining
rv;ency, cj-cnct..o ii~ ti-~ egritcy wfth rho cirre ccitt support
iut.tution.
B-lO
PAGENO="0195"
191
The current macJo of operation in such areas could ha
characterized as an informal version of lend acjnacy
responsibility, i.e., one agency having the broa~l
legislative mandate in a given area, hut other interested
agencies are still able to regulate with no assurance
that individual provisions are conpatible to other
existing agency guidelines. A case in point is the area
of human subjects research. An institution of higher
education may have to negotiate separate general assurance
for the use of human subjects in research and related
activities reflecting the different requirements of, for
example, HEW, ERDA, and the Consumer Product Safety Corn-
mission:. Under the .cognizadt agency conceot, on the :other
hand, a single agency wo~ld assume complete responsi-
bility for the developnent of all regulations in that
area, reviewing existing regulations across Government
and prepare a codification with recommendations for legis-
lative changes as necessary to remove inconsistencies.
It would minimize the reporting and recordkeeping burden
by being the only agency having interface with higher
education institutions in a given area.
In support of the cognizant agency concept, the President
should direct all appropriate agencies to respond within
90 days to his request for agency positions in regard
to the assumption of the cognizant role in the areas of:
(1) human subjects protection, (2) care and use of labora-
tory animals, (3) clean air, (4) pure water, and (5)
patents. After submission of agency positons, OEB should
advise the President on the final selection of cognizant
agency to each area.
17. The suggestion to consolidate the Federal Government's
programs of enforcement of equal employment opoortunity,
civil rights and affirmative action is attractive although
the problems which need to be addressed are too hrosd and
complex to be included as a mission of this Tasb Force
with the current time frame. For example, there is
overlapping among various anticliscrimination legislative
provisions, Executive Orders, and their implementing
regulations designed to prevent discrimination by
Government contractors, grantees and employers, public
and private. These legislative provisions and Executive
Oyd.ars are ndvinistered by severel Fodutal ec~cnc.ies. This
situation, in so.ee lnsLa!cns, lends to undue burden in
tb~ form of dup3. i nitios cf onfocccmant act.:~ cities which
PAGENO="0196"
192
the r~oc~rces of all nnr tics; and I iinedes ~ [fective
en;:)s~:;?nL~ Civil rights c;;foscsm:;t end the aticinis-
tr~-s of :jilOtlCUS have been p rceivc;ci in sore in-
or 2:-.csslnq ur;measnnohie burdens * We have
era maci tb-s venous civil. rig}scs regulations e~d instruc-
tianc ee;d have cietnrminod that there is no significant
redurutency I n recordteeping and reporting recjuiremeiits.
The Tsr;k Force recommends that the President form an
aperorriate group of knowledgeable persons from nil re-
levant agencies and representatives from selected
universities and colleges who have expertise in these areas
to be convened by February 1977 to explore this complex
problem under the chairnanship of a distinguished leader
from the higher education community who is knowledgeable,
sensitive, and experienced in the field of civil rights.
Ad sate staff and other support must be provided in this
of srt. The Presidential group should prepare within a
90--iay period an action plan for this consolidation,
including the legislative changes necessary to assign
"cognizant agency" status (see flecoramanda Lion 16).
The Task Force also recommends that the Department of
Labor, the Office of Civil Rights (HEW), the Internal
Revenue Service, the TLS. Commission on Civil Rights,
the Justice Department and the Equal Employment Opportunity
Commission coordinate thei.r enforcement activities through
a memorandum of understanding.
18. The Federal Government permits recipients of granteand
other agreements to purchase nonexpendable personal
property. This property must, under 0110 Circular A-hO,
be accounted for if the purchase price of an i-ten is
$300 or more. The property management function of
the recipient institution involves considerable
effort in maintenance of unit records on: the item's
description; serial nunther; source of purchase;
acquisition date; cost; location;- condition; use; date
this information ~-ias reported; and ultimate disposition
data including sales price, method used to determine
fair market value, and other characteristics. In
addition -to crehtipg a record -on each ~uch item -~f
property purchased for $300 or more, a cornnleta physical
PAGENO="0197"
193
i~sntorv ~uusL ho taken et least biennially; a control
SyStool rnun-t ho estahlish:d to prevent loss, damocja or
theft with fuLl loves tication and documentation in the
e~'Eo~t of lone, Manage 00 ttief~; and adequate maintenance
procedures must be established to keep the equipment
in good condition. In short, higher education institu-
tions pay a very great addiEional price (i;e., burden)
~Thcn they agree to purchase even rather modestly priced
equipment with Federal money.
These provisions of 0MB Circular A-lb are, of course,
designed to assure proper stewardship of property
acquired at Government expense. The question has been
raised, however, as to why the $300 level has been set.
An estimate by the National Association of College
and University Business Officers indicates, that if the
accountability level were raised from $300 to $1,000,
there would still be accountability under Circular A-lb
for about 84 percent of the dollars represented by this
nonexpandable equipment category, but the number of items
to be handled as described above would drop 66 percent.
It should he noted that an item of equipment which costs
less than $1,000 becomes the institutior~s property without
reimbursement to the Government when there is no further
use for it on Government projects. Circular A-lb
appears to be interested in controlling the item under
$1,000 by extensive recordkeeping, handling, reporting
requirements only for tho duration of particular projects.
The Task Force recommends that the Financial Management
Branch, 0MB, change its Circular A-hO, Attachment N,
Section 2.c. to define "nonexpendable personal property"
to include that which is purchased for $1,000 or more,
rather than the current $300 level~ In this way, a
subs tan'tia 1 amount of property management and recordkeeping
rezeonsihility will be lifted from universities and
colleges.
19. Significant emendmonts to the filing requirements for
exempt organizations were enacted as part of the Fox
keform Act of 1969. At that tine, tho Internal flevenue
Snsvice agreed to accept from a variety of exempt orgari-
za tloas , includi n~ univorrities oral colleges, their own
nuhntitutw; for the dctaflncl financial information recoired
in torn 990, Par 11 in lieu of a completed Form 990. In
1970, [09 `.orninrd that it could no longer accept
PAGENO="0198"
194
sub:;tiLuten for two racans: (1) a s:i gnifLcent lack
of u~ 1 formity in the way financial records were
reported, and (2) the developrant within
Ik~ of criteria utilizing items from the Fore 990 to
be ag~Lied by coenuters in the selection of returns for
audit. For the past eighteen months, the National
Ass~cia Lion of College and University Business Officers
(~f~C1idO) a:;d its counsel have met with the IRS in an
attempt to find an acceptable compromise. The institu-
tibne believe that completion of Part II of Form 990
would require them to keep their financial records in
a way that often conflicts with recognized accounting
standards developed and approved for use by univarsities
macI colleges. As a direct result of these negotiations,
the Internal Revenue Service has agreed to certain changes
on the Form 990 for 1976 and will revicai instructions
for completing the 1975 and 1976 forms prepared by
NACUBO for dissemination to its menbership.
B-l4
~1
PAGENO="0199"
Department of Health,
Education, & Welfare
Department of Health,
Education, S Welfare
Deputy AcL-airistrmtor,
Extension Service
Director, Education
Study Group
Consul Lent
Director, Defense
Education
Director of Research
Special Assistant to
the Director of
Research
Senior Program
Associate for
University Programs
Director, Program
Reporting Division
Deputy Assistant
Secretary for Educa-
tion (Policy
Development)
Program Analyst
National Institutes
of Health
Acting Director,
Division of Survey
Planning & Analysis,.
1!ational Center for
Education Statistics
Acting Deputy Assistant
Dirnctor for P~eictir~
eTd Pr:,ijt'am Coocdin-~tio~
O~fice of Chi~. Rights
i)ep~'rteeit of Agriculture
Corve:ie a ion on Federal
Panerrock
Coircis s ion on Federal
Popermoek
Department of Defense
Equal Employment
Opportunity Coeaniss5 on
Equal Employment
Opportunity Commission
Energy Research and
Dcvclopment Adminis~ tion
Environmental Protection
Agcncy
Department of }Ieolth,
Education, & Welfare
195
`IAS;( ~`o~~c:r 1BFf~
(Cba.irir~a, Robert Wright)
Charles U. McDougall
flo;-nird E. 1(olcoeb
1!oeard Wile
Thomas W. Carr
Melvin Humphrey
Odessa H. Shannon
Sidney G. Roth
Frederick Lilly
Philip Austin
R. Wilf lam Dommel, Jr.
Theodore Drems
John }iodgdon
I)epirtinent of health,
Eduret ion, & Welfare
B-l 5
PAGENO="0200"
196
0 f I~~1 ~h, EiChaL~1 H. Sonnaa~ ran Spacial. .nais ta:iL ~o
tj'r~0~, & Wet thu DZg)u~ Con--
Iias~onar for Poet
Sacondat'! Education
Office of Education
:.~:r~L of Health, Burton Taylor Ac~.ing Director,
E~ilu:etofl, & Welrare Higher Education
Divison, Office of
Civil Bights
cnpartsent of Health, Gooloo Wunderlich Associate Director,
Educatioa, & Welfare Data Policy,
Assistant Secretary!
Health
.,tart5trlt of Justice Maurice Fiosenbsrg Spacial Assistant to
the Attorney Getaral
.~Pact~ent of Justice Nary Wagner Assistant to the
Deputy A a tornoy
General
~~tytnent of Labor Anne Blackuell Equal Eepleyraent
Specialist
~-~sent of Labor David Ganz Employee Bansfit~;
Specialist, Peoria
& Wcl(:rn Banrfit;
Proqr.ttt
tuarLratnt of labor RonaLd P Gilbort Weqo Hour Analyst
eational Aeronautics U. A. Greene Chief, Policy Cenrdi~
& Scare AdministratiOn . nation, Office of
University Affairs
-iatioual Foundation for David J. Wallace Special Assistant to
Arts & liurnnitieS the Chairman,
taa~otal Enfourunt o
V thu liomanitics
~;atfce;~1 Science Richard N. Berry St~udy, Director,
Foe:eiation University & Hoegro-
fit Institutions
Stuaii.ee
B- 16
PAGENO="0201"
~c~tic~el Science
Fouu~e clan
Of~Lca of flanagncent &
Offica of Management & Katherine Wallman
Budge
Department of Treasury Charles W. Rurnph
Suzacns Neclgyesi-tiitschang
Harry Travis
Shiroy A. Jases
Sarah Tho;ras
Staff Sueport
1Vacl, Science
Inclicatora Unit
Chief, Clearance
Office, Scatistical
Policy Division
Statistical Policy
Division
Special Assistant
for Exempt
Organization Matte~
Internal Revenue
Service
Director, Exempt
Organizations
Division, Internal
Revenue Service
Asoist.ant D5recto~,
Research S
Office of CualptrCl.
Educational Consult
Department of Health, Education & Welfare
Office of Regulatory Review
Department of Health, Education & Welfare
Office of Planning & Evaluation
Department of Health, Education, & Welfare
Office of flugulatory Review
Dapurtuont of Health, Education, & Welfare
Bureau of School Sysbens, Office of
Educe tion
197
Rcbrr Mr ight
Ro~e Joury
Department of Treasury
Joseph A. Tedesco
~feterans Administration Fred Dranon
Veterans Administration
Dennis Paradoweki
B- 17
PAGENO="0202"
198
Mr. HORTON. That was the result of six persons working approxi-
mately 13 months. At our last meeting of the commission, which
was held just last month, we adopted this report. So it has now been
adopted by the 14 commissioners of the Federal Paperwork
Commission.
Mr. Chairman, I do have a prepared statement but first I do want
to thank you for this opportunity to appear before the committee
and to give us the opportunity of talking about and presenting our
findings and recommendations of the Paperwork Commission in
this particular field of education
I think you may know that the commission is a two-year commis-
sion. It is composed of 14 members, 14 commissioners, and we have
divided the work so that basically what we are doing is looking at
the functions of what causes paperwork; in other words, what are
the things that cause paperwork problems?
We are also looking in certain programs, areas, such as in the
field of education.
The commission did decide it would have hearings around the
country. We have pretty well completed that process and, as a
result of that, we have gotten a lot of background information,
particularly in the field of education
I would say parenthetically that at every hearing we attended
someone, somewhere, testified on the problems and the magnitude
of paperwork as it is related to education. It is a very serious
problem, as I am sure you and the other members of the committee
are perfectly aware.
HEW Region X released a draft report on March 7 of this year
which says paperwork is a major issue that is adversely affecting
the delivery of services to people; that HEW reports from state and
Federal governments are found to be useless by one-third of the
Federal, state, and local officials.
Excessive paperwork is diverting faculty and administrative
staffs from the central business of teaching.
Mrs. Carolyn Warner, Superintendent of Education for Arizona,
who I believe will also testify here today, told us that "we are
stealing money from our children in education in order to provide
administrative framework, staff and clerical help to fill out the
forms...Teachers in the classroom have a job to do and that job is
not a clerical job, and yet for the first two years the benefits from
special education for the handicapped will be spent filling out forms
and complying."
At our hearings in Phoenix, Dr. William Ganer, Superintendent
of Ogden City Schools in Ogden, Utah, testified that the paperwork
costs under the Indian Elementary and Secondary Education Assis-
tance Act would cost $6,000 to complete, while the allocation of
funds was only $4,500. In other words, it would cost the school
district $1,500 over and above the total grant just to do the
paperwork.
The director of a school Food Service Department said that
"teachers are asking whether they are to teach or handle welfare
programs." He went on to tell us that 20,000 staff hours are
required to administer the school lunch program, using 200 reams
of paper each year, not including food tickets.
PAGENO="0203"
199
The total dollar costs to elementary and secondary education to
comply with excessive paperwork is growing out of all proportion to
the Federal contribution. While such costs are substantial to be
sure, the greatest cost may be intangible and occur in the losses of
good will and spirit of cooperation. On the actual dollar side, it can
cost up to $3.50 per data item, per school, for data that is not
readily available.
When you consider that states receive 135 to 140 forms annually
with hundreds of items to be collected from each school, you get
some idea of the magnitude of the burden.
Dr. Robert Benton, Superintendent of Public Instruction for the
State of Iowa, and a very valuable member of the commission who
worked as an economics adviser to this particular study group,
pointed out at the last meeting: "The Federal commitment to
education is around 11 percent, but they may impose 50 to 60
percent of the compliance requests on the local school system to be
eligible. People are posing the question `Is it really worth it'?"
Mr. Chairman, six major themes of symptoms of the ills of
excessive paperwork were identified by the commission in its report
on education. They are almost epidemic in their effect on all
education respondents. They are:
duplication in the collection of data;
unrealistic requests for information not readily available;
insufficient lead time to respond to Federal forms;
inconsistent terminology used in requesting data;
high costs of production data, and
late feedback of results on information supplied Federal agencies.
These problems can be surmounted. They can be surmounted by
improved management, better planning and greater oversight. We
have made several specific recommendations which will both re-
lieve immediate problems and provide the basis for long-term relief.
The commission believes that improvements can be aimed at
managing and controlling data-gathering, particularly in the ele-
mentary and secondary education programs. We have
suggested,first, that all Federal data collection from education re-
spondents be centrally coordinated.
We recommend that the Office of Management and Budget pro-
vide for Federal coordination of education data production by re-
quiring, in its forms clearance procedure, that all requests from any
Federal agency for data from education respondents be coordinated
through the HEW Assistant Secretary for Education prior to 0MB
clearance.
The Director of 0MB, Bert Lance, who also serves on the commis-
sion, responded on March 28, 1977 that this strategy held great
promise. He said that the Education Data Acquisition Council is
presently including Office for Civil Rights education data collection
in its review activities. This is in response to the mandates of the
Control of Paperwork Amendment initiated by this committee last
year, and which you referred to in your opening statement.
When the Education Data Acquisition Council proves to be a
viable mechanism for this coordination, Mr Lance said 0MB would
advise the secretary to coordinate education data activities for the
entire department and, depending on the outcome of that effort,
would consider extending coorination to all Federal departments.
PAGENO="0204"
200
Two additional steps have been recommended by the commission
to strengthen the central coordination process. One would require
the use of standard definitions and terms, a requirement also
contained in the Control of Paperwork Amendment, and the auto-
mation of an index for keeping track of data submitted.
Through the implementation of these three recommendations, we
would know readily who is collecting what, from whom, and for
what purpose. Incredible as it may seem, the Federal government
does not have this capacity at the present time.
A chronic problem for education respondents is the lack of
sufficient lead time to complete data requests, and we heard this
every place we went. States and schools begin to build their annual
data acquisition plans early in the calendar year for actual collec-
tion at the start of the next school year in September. Any forms
arriving after the start of a calendar year, containing requests for
new or differently classified data, require a manual compilation, an
expensive and time-consuming process.
Perhaps the major contributor to the problem of lack of lead time
in the last dozen years has been the extensive and increasing
amounts of Federal education legislation. Departments and agencies
and schools have not been able to keep pace.
The commission has recommended that all forms in the Educa-
tion Data Acquisition Council annual data acquisition plan be
cleared by the calendar year prior to fall collection. The Congress
and the executive branch will need to provide adquate staff and
support to achieve this objective. Once it is achieved, the Education
Division will be better able to make multiple uses of data, another
commission recommendation, and to review together all forms in a
program from application to final reporting rather than review
singly one form in one part of a program.
Mr. Chairman, many people feel that we in Congress are to blame
for the paperwork burdens on education. It is a charge that we
cannot treat lightly; there is much Congress can and must do. Yet
in our report on education, the commission has also recognized the
leadership and initiative which this committee has taken to begin
to solve these paperwork problems.
These oversight hearings today are a major step in the right
direction. I hope that the committee staff wil review in detail the
full report of the commission. We will be happy to work with you
and the executive agencies to see the recommendations implement-
ed; that is up until October when we go out of business. In the
meantime, these members of our staff at the Paperwork Commis-
sion would be very willing to participate and cooperate with your
staff in any way possible to implement the recommendations and
give you the benefit of whatever background data we have collected
in the Paperwork Commission.
Your action last year in passage of the first Control of Paperwork
Amendment, and other amendments which tightened up permissive
language for information-gathering from the broad "may reasonably
require" to "as are essential" should provide significant benefits in
future data-gathering.
Mr. Chairman, much has been done but much remains to be done
by the Congress.
PAGENO="0205"
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In our report on education, approved April 28, the commission
made three recommendations directed specificaLly to this commit-
tee. They are:
The education committees of Congress should recognize January 1
as the latest date by which Federal agencies should announce the
specific education data to be collected at the start of the following
school year, to provide sufficient lead time for states and institu-
tions to include such data in their annual acquisition plans.
That is a very important recommendation. I hope that the com-
mittee can follow up on that. I realize it creates a lot of problems.
We know this. We want to do everything we can to try to make that
date because that is a very important date as far as the education
people are concerned.
The second recommendation was that the education committee of
Congress should hold hearings on proposed regulations or data-
gathering forms that are developed from laws whenever agencies
and respondents indicated a need for guidance in preparing or
responding to the ensuing regulations or forms.
One of the things we have found out as we have gone through is
the inadequate attention to regulations and forms. Here is a very
tremendous oversight responsibility as far as the committees in
Congress are concerned, particularly in this instance the Education
Committee.
I sometimes feel, Mr. Chairman, that we have a corresponding
responsibility; we enact legislation and that is a very important
responsibility that we have as members of Congress. But quite
frequently we do not exercise that other responsiblity which we
have and that is oversight. That is equally important, in my
judgment, the oversight, and we are finding that to be true more
and more.
As I found out in my district last February, I saw over 500 people,
I summed it all up with three words, strangulation by regulation.
That is what is happening in the country. Regulations are
strangling business people, individuals, and everyone else. The need
for oversight was probably never as prevalent as it is today.
The third recommendation is the education committees of Con-
gress should review every third Congress, beginning with the 95th
Congress, the reports and studies they require of the Department of
Health, Education, and Welfare to eliminate those no longer need-
ed, consolidate those that can be combined, and make the remain-
der compatible with an overall plan for reporting.
Three of every ten citizens are directly related to education,
involving teaching and learning from preschool to postgraduate
levels, under either public or private auspices. Federal paperwork
touches on education at every level, from every direction. We
regulate, monitor, and require reports on everything from financial
aid policies to faculty documentation of personal services on Feder-
al research grants and contracts. Nearly every department and
agency of government has some reason to require paperwork of
individuals or institutions in education. Given those dimensions and
the limited staff and time available to the commission, it has not
been possible to examine in detail all the aspects of paperwork in
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202
education. We do feel, however, that we have isolated many of the
major problems and have made recommendations to solve them.
I might say parenthetically that what I have presented to you is a
summary of the report. The report that you have in front of you
says that the report of education made some 41 recommendations,
in grants and contracts there are 10, student aid 10,
nondiscrimination 9, management controls 12, a total of 41; 34 of
those recommendations have been accepted and are now being
implemented. The number relating to elementary and secondary
education is 16, nondiscrimination 6, management controls 10.
I have set out a summary of the 6 in nondiscrimination and the
10 in management controls to make it easier for the members of the
subcommittee to see the recommendations we have made.
[The document referred to follows:]
PAGENO="0207"
203
The report on Education makes 41 recommendatioflS
In grants and contracts 10
In student aid 10
In nondiscriltLthatiom 9
In management controls 12
41
The number relating to elementary and secondary education is 16:
In nondiscrimination 6
In management controls 10
16
The six recommendations in the section on nondiscrimination say:
o The president should issue an executive order and
propose legislative changes, if required, to desig-
nate a single cognizant agency for equal opportunity
and civil rights recordkeeping, reporting, and
compliance in the field of education.
o The President should form an appropriate group of
knowledgeable persons, including advocacy groups,
to contribute in the development of the cognizant
agency, along the lines of the recommendation of
interagency Task Force on Higher Education Burden
Reduction.
o The administrative procedures of any single cogni-
zant agency for equal opportunity and civil rights
PAGENO="0208"
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-2-
in education should allow for resolution of
complaints at the lowest possible level and
provide for coordination of Federal and State
enforcement efforts.
o Standard racial and ethnic categories should be
used in applications under the Emergency School
Aid Act.
o The Office for Civil Rights should announce
clearly by January 1, 1977, whether data require-
ments in the school civil rights .surveys, forms
101-102, are to be identical to those required
in 1976.
o The Secretary of HEW shouldrequire clearance
of forms 101-102 for the 1978-79 biennium in
sufficient time to enable announcement of the
1978 survey data items by January 1, 1978.
The ten recommendations in the section on management controls
say:
o The Office of Management and Budget should provide
for Federal coordination of education data production
by requiring, in its forms clearance procedure,
that all requests from any Federal agency for data
from education respondents be coordinated through
the HEW Assistant Secretary for Education prior to
0MB clearance.
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205
-3-
o The Assistant Secretary for Education should use
the standard terms in the National Center for
Education Statistics' handbook series in forms
clearance.
o The Assistant Secretary for Education should give
high priority to the common-core-of-data program.
o The Assistant Secretary for Education should
develop an automated indexing system for data,
one that would include data from all Federal
agencies.
o The Assistant Secretary for Education should
review all education data gathering instruments
in the calendar year preceding collection and
announce by the January preceding the start of the
school year the data elements to be collected in
September.
o The Assistant Secretary for Education should
develop the capacity for multiple uses of data
collected by all forms.
o The Office of Management and Budget should urge
all agencies, when they collect data only from
education respondents, to provide nine-months
advance, notice of collection and to share their
data collections with the Education Division for
multiple uses wherever possible.
PLUS THE THREE RECOMMENDATIONS DIRECTED TO THE EDUC~ TION
COMMITTEES OF CONGRESS that would provide for:
o the review of required reports,
o the recognition of the January announcement-SePtember
collection cycle, and
o hearings on regulations or data_gathering forms.
91-860 0- 77 --14
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206
Mr. HORTON. I might say that I have been informed by the
Administration that to replace the Director of IRS, who is a public
member of the Commission, appointed by the President, Mr. Don
Alexander, who resigned from the government, the new Adminis-
tration is going to appoint in his place, the head of HEW, Joseph
Califano.
I think that is an important addition to the commission because
this Administration, Mr. Carter, (I have talked with the President,)
Mr. Lance, the 0MB Director who is a member of the commission,
and now Mr. Califano, are very dedicated to trying to resolve this
paperwork problem and to eliminate a lot of it.
I might add that there was an article in the paper this morning
where Mr. Califano has accepted one of our recommendations
which was to eliminate a Federal form widely used by college
students applying for governmental financial assistance. The recom-
mendation was that they use the forms that the colleges use.
Mr. Califano has now accepted that and said, in accepting that,
that the decision to accept nongovernment forms will eliminate
duplicate paperwork for millions of students and their parents, who
generally apply both to the government and their colleges for
financial assistance.
On page 16 we have a number of points that we have raised in
this report with regard to student education where students have to
file a number of forms, this sort of thing. This is one of the
recommendations that we made to Mr. Califano, and he has fol-
lowed up on it.
Mr. Chairman, I and the members of the staff are available here
to answer whatever questions you might like to ask.
Chairman PERKINS. All right.
First let me compliment you, Mr. Horton, for such an outstanding
job. In my own district, all businesses, especially small businessmen
and school superintendents and principals, are telling me that they
are bogged down with paperwork and asking why do we not do
something about it in Washington? I think largely it is because we
have tried to legislate at too great a length.
This was not always the case. For example the Civilian Conserva-
tion Corps Acts established during Franklin Roosevelt's Presidency,
was only about three paragraphs in length. We can write a bill-
maybe the bill will be 15 pages-and the regulations will consist of
50 or 60 pages.
Somewhere along the line the cost to the government has just
about reached the cost of the program.
We have to do something about the situation; we have to hold
people accountable for the money they receive and see that it is
expended in the right way. But everybody that has a hand in
writing regulations wants to say that they need some kind of report.
The top people in the departments have just got to make sure that
this thing is eliminated. The people in the country really are going
to rebel against this paperwork and get to the point where they say,
well, if we have to spend all of our time, the laws that we enact are
not going to serve their purpose if this paperwork is not cut back.
I am hopeful that we will take steps, and that the departments
will take steps to reduce this paperwork and we certainly want to
PAGENO="0211"
207
hold oversight hearings to make sure that this paperwork is, to a
great degree curtailed.
I notice that you make a number of recommendations for admin-
istrative changes. You also urge our committee to recognize Janu-
ary 1 as the latest date for announcing data collection, to hold
hearings on data requests, and to review periodically the studies we
require on legislation.
In addition to these recommendations, do you believe we should
pass any legislation trying to better control data than it is presently
being controlled?
Mr. HORTON. I have a bill that I have sponsored along with Tom
Steed, who, as you know, is a member of this commission and is
very much interested in it. He and I have a bill that would require
that we change the rules of the House so there would be a require-
ment that we would get something comparable to what you might
call a paperwork impact statement that would require the Congress
before it enacts legislation to require that there be a statement
made with regard to the cost benefit ratio insofar as paperwork is
concerned. I think something like that is very important.
I do think we are going to need legislation to bring it to the
attention of the members of the House. Senator McIntyre, a mem-
ber of the commission on the Senate side, and Senator Hatfield, did
sponsor the same type of legislation. Senator McIntyre did get the
Democratic Caucus to adopt that. That is now part of their rules in
the Senate.
It is going to be necessary, as we walk through these recommen-
dations of the Paperwork Commission, that there be legislation
enacted to try to assist with regard to data collection.
I think it is going to be very important for us in the Congress to
recognize that.
The first thing that we have recommended here, that I think can
be very helpful, is the placement of this data collection through
0MB so when they do the forms clearance, they can get the
information there and have some handle on it.
Chairman PERKINS. From your review, can you tell us whether
the paperwork problems are greater for certain types of school
districts, especially small districts? Could you also tell us whether
the really onerous data requests or program requests are requests
for general information to fulfill general Federal requirements such
as the antidiscrimination laws?
Mr. HORTON. I am going to ask Mr. Holcomb to answer the
question specifically and then I will add a comment to it.
Mr. HOLCOMB. The cost to education seems to fall quite evenly
whether schools are small or large; they just have different kinds of
problems. The larger schools are better equipped, have more staff,
but they have more data and students to deal with and frequently
have to fill out additional forms.
The cost is borne in dollars. It is psychological, emotional as well,
as you cited in some of your comments, Mr. Chairman.
As for data that comes in relating to nondiscrimination or general
information, it would seem that if data could be announced in
sufficient time so schools could adequately collect it and therefore
have better data to submit to the Federal government and getting it
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208
a little earlier, there would be opportunities for multiple uses of
that data. We have not gone into each and every one of the 400
forms in the education division, alone, which are a burden that you
cited. There are forms beyond that and burdens beyond that, in the
Agriculture Department and in other places in HEW.
Chairman PERKINS. Mr. Simon.
Mr. SIMoN. Thank you, Mr. Chairman.
First of all, a general comment. I went over to your office. I
frankly went over there, just going through a list of agencies and
commissions that we had, and I thought if there is one more way of
creating papework it is to have a Commission on Paperwork. I went
over there fully expecting to come away loaded with material to say
"Here is one we ought to do away with. That is one way of saving
paperwork." But I came away most impressed by what you and the
commission members and the staff are doing there. I think it is a
real contribution. I have just one question.
Mr. HORTON. Thank you for that, Paul. I appreciate your
kindness.
Mr. SIMON. I wish you well in any way I can help.
Mr. HORTON. As you know, we self-destruct, we go out of business
October 2. We have a 2-year life. Our recommendations will be right
on target. We will be finished and will close up shop within a few
months after that. We will still have a few people on board to finish
up the reports and do what is necessary to make the recommenda-
tions effective. So far as the work of the commission, it will be
finished October 2, 1977.
Mr. SIMoN. My question really relates to that fact. How do we
follow through in the education field? I know you have done some
work in the agricultural field, for example. How do we make sure
that these excellent ideas aren't just going out into the air and that
is it?
Mr. HORTON. Much of the remainder of the time that is left will
be devoted to that very question. At our last meeting the Comptrol-
ler General, Elmer Staats indicated that the General Accounting
Office would work very closely with the commission and-he is a
commissioner also-and that they would follow up. So they have
taken onto themselves a responsibility to follow up as they were
required to and did in the Procurement Commission. So that will be
an important step to follow up.
Next the bill, itself, requires 0MB to have a rsponsibility for
follow on up. I am certain there will be recommendations by the
commission that there be established some type of agency to carry
on generally the type of work that needs to be done.
Some of the work that we are doing, for example, if you have an
opportunity, there is a telephone number that your constituents can
call-I sent a notice around to all my colleagues and you should
have gotten one-that they could call this ombudsman line. We
have someone answering that telephone. That ombudsman function
as established at the very beginning of this commission and has
been a very important adjunct of the commission. A little guy will
call from Oregon, Washington, Rochester, New York, wherever it
happens to be, and say "This is a problem of paperwork" and our
people will go to work on that and resolve it in most instances. That
PAGENO="0213"
209
is the type of thing we have done as a result of the hearings. I
expect there will be follow-on recommendations to that.
Mr. SIMON. I have seen so much paperwork, I missed that
particular message you sent out.
Mr. HORTON. The number is 800-424-9882 toll-free. Here is the
pamphlet we will leave with you.
Mr. SIMON. I have no further questions.
Mr. HORTON. Mr. Holcomb wanted to comment.
Mr. HOLCOMB. The final two recommendations in the report give
responsibility to the educational respondent groups, themselves,
and make reference to the Committee on Evaluation and Informa-
tion Systems, Council of Chief State School Officers, which has set
up a fine organization to monitor the development of forms and
regulations, and so on, and get into the comments process early on,
and post-secondary education is moving in the same direction. It
has to be a partnership of the Executive Branch, the Congress and
respondent groups.
Mr. HORTON. I would add one other thing. I think the Paperwork
Commission has spotlighted what the problem is, and I can't under-
score enough the commitment of the President and this Administra-
tion to try to do something about it. If we can get that same
commitment from the Congress, people such as yourself, the Chair-
man, and other members, to realize what we have wrought, if we
can get that kind of commitment, I think we can cut back on
paperwork. That will be a followup~that is interesting.
Mr. HOLCOMB. Let me say once again, I think what you have done
is a substantial contribution, and anyway I can help, I want to help.
I have no further comments, Mr. Chairman.
Chairman PERKINS. Mr. Le Fante, do you have further questions?
Mr. LE FANTE. Yes, I would like to ask one question, if I may.
I agree with Chairman Perkins and Congressman Simon about
the excellent job Frank Horton is doing with the Commission. I
would be curious, Congressman, to know if the Commission been
able to determine the differential between, say, the actual legisla-
tion that the Congress passes versus the amount of paperwork
suggested by regulations of the various departments or agencies. Is
there a way you can put it on a scale to balance it?
Mr. BUHLER. Congressman, that is difficult to answer because it
varies from program to program. In almost every case you will find
regulations well tied to legislative authority. That is because there
is a great deal of very broad legislative authority which, for in-
stance, this committee recognized and changed in the education
amendments of last year.
We have found a number of instances in HEW and Department of
Labor where the regulations have greatly exceeded legislative au-
thority and pointed that out to the committee involved.
In general, I think the regulations we find substantially increase
the amount of paperwork over what Congress expected and planned
when they legislated programs. That is again why oversight is so
important.
Mr. HORTON. We haven't run totals, taken a bill and run out
regulations, and that sort of thing. We didn't have the time and
staff to do that type of job.
PAGENO="0214"
210
Mr. LE FAJ,~m~. I think that is a major area of concern. Sometimes
when a short piece of legislation is enacted and it is measured
against some of the regulations and forms that the agency or the
department issues as a result of that legislation, you wouldn't even
recognize the intent of the legislation.
Mr. HORTON. I think that is a very good point, and I would hope
the committee could do something in connection with that, because
that is where it is all at, right there. No question about it. That is
what creates the paperwork, it is the Congress enacting legislation
and then the overexuberance of the administrators with regard to
the regulations. That is what creates the paperwork. There is no
question.
Mr. LE FANTE. I think what we are saying is that the difference
between the initial legislation as enacted and the enforcement by
regulations is the foundation of bureaucracy, and they build upon it
from there. I think that is where we have to attack the problem.
Mr. HORTON. That is right. That is why I said before, the deeper I
have gotten into it, the more I realize that the Congress has
responsibility not only to legislate but to oversee, and we have that
responsibility of looking at the legislation that we enact; oversight
function can do away with a lot of this paperwork. But it is just
because we get so busy with legislation, we don't have the time, and
it is not that sexy a subject, you know, to go back and see what have
we done and call people in to find out.
As you know, I serve on the Government Operations Committee
where we have the oversight function; that is our job to check on
that, and in the Reform Act we allocated to each committee that
oversight function, but it is because we are so busy with other
things we don't get the time. We have arrived at the point where
there is a crisis today, and that is why I say the Congress has that
responsibility to oversee, and if we did a better job of that, I think
we would be more inclined to cut back on a lot of paperwork.
As I mentioned to you before, the acceptance of the Administra-
tion of these recommendations that we are making, the commit-
ment of the Administration is significant. For example, Mr.
Califano, making that change, which is smaller, but it will end a lot
of paperwork with regard to the student applications. I am sure you
know the amount of duplication in that program and inefficiency
and the amount of forms that have to be filled out in connection
with that student aid program. A 1~t of people just get to the point
they say it is not worth it.
Mr. LE FANTE. It turns them off, really.
Mr. HORTON. That is right.
Mr. LE FANTE. Thank you, Congressman.
Mr. PERKINS. Mr. Kildee.
Mr. KILDEE. Thank you Mr. Chairman, I too wish to commend the
Congressman, as chairman of the Commission, and the Commission
for the job they have done so far. I think I initially had some of the
same fears that Mr. Simon expressed, but I think you have done a
tremendous job and are to be commended.
Mr. HORTON. Thank you very much.
Chairman PERKINS. Let me thank you very much, Mr. Horton,
and all your assistants. You have been invaluable, and we are going
PAGENO="0215"
211
to follow this thing through. It may take us some years, but we are
going to do something about the situation. It has to be done. It is
just destroying the effectiveness of too many good programs in the
nation, keeping people working on paperwork all the time instead
of carrying out the intent of the Congress and enforcing the
programs.
Mr. HORTON. Thank you, Mr. Chairman.
Chairman PERKINS. Our next witness is Mrs. Carolyn Warner,
Superintendent of Arizona State Department of Education.
Without objection, Mrs. Warner, your prepared statement will be
inserted in the record, and you may proceed in any manner you
prefer.
[The prepared statement of Mrs. Warner follows:]
PAGENO="0216"
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CAROLYN WARNER
~\ rizoirn
May 24, 1977
~ePurtmettt of ~thucattnu
Congress of the United States 271-4361
House of Representatives
Committee on Education and Labor
Subcommittee on Elementary, Secondary,
and Vocational Education
Carl D. Perkins, Chairman
Mr. Chairman - Members of the Committee:
I thank you for the opportunity of sharing Arizona' s Achievements in Redo ing~
Federal Paperwork in Elementary and Secondary Education.
Can Federal data requests be reduced? Is it possible?
The answer is Yes! Federal data requests have been reduced in Arizona.
Nay 1975 May 1977 Reduction
268 Reports 110 58.9%
980 Pages 328 66.5%
33,978 Items 16,175 52.3%
Let me share with you, if I may, how this occurred. The office I hold, Superin-
tendent of Public Instruction, is an elective position, a partisan position. As
a candidate for this office I made a campaign promise. The promise was prompted
by the condition of education in Arizona that administrators were burdened beyond
the point of survival with paperwork. The staff of the Arizona Department of
Education and I established a plan of action and they began to address the charge.
The charge was "reduce Federal data requests by 50%." They have done a fantastic
job. They reduced Federal data reports by 58.9%.
Why was Federal paperwork a concern, a concern of mine, then and now?
It was and is a concern because, to my way of thinking, education in the United
States of America, is in a very serious condition. If I were to entitle my general
remarks concerning the condition of education, I think I would talk about the en-
dangered species. That species being the institution - education. Let me share
with you why I believe education, the "can do" institution is ill today -- why
education is the endangered species.
Data shows us that in 1900 we graduated 5% of our students. In 1976 we graduated
76% of our students.
In Arizona the percent of graduates is even higher. In Arizona the dropout rate
is currently 12% rather than 24% elsewhere. We're not proud of the 12% rate and
we're working to further reduce it.
PAGENO="0217"
213
Nonetheless, education has done a fantastic job in America! You here today are
products of that system.
Remember when you attended elementary and secondary education. You can remember
certain teachers, perhaps some administrators. You can remember the facilities,
the cfesks, the girl who sat in front of you, the color of her pigtails.
Let me suggest there's a different perspective today. Different from the per-
spective when you and I attended school.
How is it different?
Education - the "can do" institution was discovered!
Education was discovered, and isolated as the institution that "can do" anything
and everything. Virtually every major change in society has been assigned to
education in the last thirty to forty years.
I believe education, the "can do" institution, has been burdened to the point that
it may not be able to survive. -
You may say, what burdens?
Let me share some of the activities of education, the "can do" institution.
At the moment we provide our children with some consumer production education.
We are the integration institution in America. We provide programs in adult and
continuing education. We provide disadvantaged, gifted, and handicapped education.
We provide some bilingual education. We provide some hot lunches and hot break-
fasts. Education is the largest single transportation agency on earth. How about
environmental and energy conservation education? We provide some art and human-
ities education. We are expected to provide education in Law, Agriculture, Busi-
ness, Driver and Safety, Consumer Homemaking, Distributive, Cooperative, and
Physical Education. We provide some Health education, in child abuse, corrections
as well as international, Indian, and vocational and career education.
These are some of the activities -- oh yes, we are responsible to enable our
students to learn to read, to write, and to cojp~g. And, we should somehow
inculcate g~!, ~~pect, and responsibilities as we continue.
I don't know whether or not education can continue to survive, carrying the
responsibilities we are expected today.
Perhaps Title IX is worthy of mention in the above listing.
I have no quarrel with any one of the programs. We're finally arriving at the
goal of providing equal educational opportunity for all.
My concern is -- can education survive with all of these responsibilities?
In Arizona, for the learning process of our 540,808 students, the taxpayer provides
92Z of the necessary funding from state and local resources. For proper account-
ability, to assure appropriate expenditure of funds, we require some data collection,
16% of the total pages required.
2
PAGENO="0218"
214
Arizona utilizes in the learning process som~ 7-8% of taxpayer money from the
Federal government. The Federal data requirement is massive, 84% of the total
pages required. -
We find ourselves in a situation whereby the Federal government is providing
for education in Arizona 7-8% of taxpayer funding and imposing 84% in data re-
quests (paperwork). Can you understand my concern?
Where are all the Federal data requests coming from? Some are from the Office -
of Civil Rights, the Department of Interior, the Office of Safety and Health
Administration, the Office of Education and others.
Let me suggest, my friends, that it appears those people must not be talking
with one another. They were all collecting essentially the sane data-, with an
occasional caveat that related to the particular whim of their bureau chief, or
agency, or program. This kind of lack of coordination simply cannot continue to
exist.
We in Arizona were able to redice paperwork, Federal data paperwork, by 57.8%.
Possible, because we wanted to, because we tried. How - we went to the victim,
the person in the field who is charged with the responsibility of providing the
information, and said -~ come, let us help you to do your job better.
The Arizona Department of Education became a service agency. We tried to help the
education institution do its job, rather than being that person out there beating
then over the head for compliance. We took a different tact - how may we help
you accomplish the job that all of us want to do - for children. Using that
approach, we asked people to come in -- the victim - and help us reduce paper-
work. Not a single person. said no. Everyone (not only did not say no) contri-
buted, freely, their time, energy, and skill, once a month and helped us. They
worked with our program people to reduce paperwork, to reduce the redundancy, to
eliminate the duplication, to build a calendar for data collection that makes
sense, that any normal business person or administrative officer would implement
in their agency or business.
We feel that education in the State of Arizona is more healthy than elsewhere, but
we feel that education is constantly threatened by the overprotective help of the
Federal government.
We need the Federal funds (taxpayers dollars).
We have a great need for disadvantaged in the State of Arizona. Arizona has many
American Indian students and many Hexican American students who have language
difficulties. Arizona has its share of handicapped students. We want to serve
each and every student and provide all an equal educational opportunity. But, we
want to do that very thing.
We do not want to destroy American education, by taking teacher time and adminis-
trator time to fill out endless forms for whatever eventual purpose, some of us
have yet to fathom.
We want to spend the time with the child, in the classroom, and help that child
succeed. We want to help each child to become the extraordinary person they have
the capability of becoming, given the opportunity.
3
PAGENO="0219"
215
I feel that Federal paperwork is taking the opportunity of America, the great ex-
pectations we have for education, away from the child. Our energies are being
diverted into filling cabinets and massive piles of paper that are to be punched
into computer cards and to be stored somewhere. Maybe, to be reviewed, maybe to
be evaluated, maybe to be used, and maybe not. At the same time, that child that
we're there to serve, and for whom we collect that data, is not ~ served.
I believe that this continual proliferation of paperwork is counter-productive
to the overall goal of equal educational opportunity for every American child.
I would suggest several things; one, we have developed a device, a process, a way,
a plan, to reduce paperwork. You are welcome and I encourage you to utilize the
plan. We have been requested to submit our plan to over 300 individual agencies,
divisions, and bureaus. Every state in the nation has requested a copy of our
data reduction plan. To date, over 60 businesses have requested a copy of our data
reduction plan.
May I suggest another way, in addition to the plan, for your serious consideration.
Should you, the Congress of the United States, require that every Federal agency
who sends a series of forms, or requeb~.s data, provide a check to pay for the
doing of the work, along with the request. This would enable the local district
to continue to work in oducation, to work with the child, rather than collect
sometimes redundant, sometimes unnecessary and oftimes unused data.
Should Congress so do, I would suggest and if possible, guarantee, you would see
a autden, a drastic reduction in the amount- of data requested. I would further
suggest you would get more nearly to the truth of what was really needed, of what
was really going to be used.
If a Federal agencyhad to divide its own operating budget. .into...apor.tion of data
collection and send a portion of its budget to the victim, it would begin to make
a great deal of sense to them, immediately, to examine and prioritize their re-
quests.
I submit that what we're talking about today is much more important than just the
reduction of paperwork, though heaven knows, I can think of nothing that is more
urgently needed.
I suggest that what you're discussing here today, in committee, is very simply
whether or not you're going to be able to allow education to survive, whether
you're considering the endangered species. Is the institution of education, going
to be considered of sufficient importance to this country? Is the education of a
child, a small child in a classroom, going to be given sufficient importance as
compared to collecting more and more Federal paperwork?
We must enable educators to educate children in the basic skills of ~
and arithmetic, in the areas of career and vocational education for that
world of work, and reinstitute into education the 3'Rs of ~4g~s, ~ and
~~ponsibility~. If you, the Congress of the United States, want these things,
truly want these things to happen, then you must, you must to keep education alive,
reduce the strangling, terminal effect of continually increasing Federal paperwork.
Carolyn Warner
Superintendent of Public Instruction
State of Arizona
4
PAGENO="0220"
216
Cutting
DATA
REDUCTION
ACHIEVEMENTS
the
Paperwork
CAROLYN WARNER, SUPERINTENDENT
ARIZON~ DEPARTMENT OF EDUCATION
PAGENO="0221"
217
UNNECESSARY PAPERWORK IS REDUCED
3rd Data Acquisition Plan---the vehicle
Relief is in sight for school personnel who have been buried by unnecessary paperwork.
To reduce unnecessary paperwork, the Arizona Department of Education (ADE) has
implemented its third Arizona Data Acquisition Plan (ADAP).
Through the process of standardizing forms so school districts might use a single form in
multiple areas, the Plan has reduced the number of required forms by 57.8 percent.
Total number of pages of forms also has been reduced 62.6 percent and more than
26,598 data items have been eliminated.
Mrs. Carolyn Warner, State Superintendent of Public Instruction, earlier pledged that
ADE would reduce data acquisition paperwork by more than 50 percent.
Copies of the Plan fulfilling that pledge are mailed annually on May 1 to the school
administrators throughout the State to afford them the maximum lead time in the
decision-making process.
The Annual Data Acquisition Plan is one of seven (7) documents that comprise the
Arizona Data Management Model. The Arizona Model has been requested by every state
and by over 50 private firms. The total of copies requested from out of state, to date,
is 247 copies.
"We've proven that we can meet the need and improve the efficiency and mobility of our
data acquisition system," Mrs. Warner said.
"We've removed the burden of unnecessary paperwork from the backs of school
administrators.
"And, the Plan will be further improved and updated on a monthly basis."
The Plan not only represents the combined efforts of field and department personnel, but
is an orderly, systemized vehicle for administrators.
PAGENO="0222"
218
DATA STANDARDIZATION'S
IMPACT ON SCHOOLS
The standardized concept in a systems approach adds many time-saving benefits to the
districts. The following, when implemented, will result in decreased workloads for district
personnel:
1. Common items assist in defining what is required in program reporting.
2. Staff training time is reduced when relating to common items.
3. Common items assist in establishing data needs.
4. Recognition of prioritized information is improved, more handily stored, and more
easily retrieved.
5. Comprehension of common items shortens program writing time.
6. Reporting errors decrease when dealing with fewer unique items.
7. Office management skills are likely to improve.
8. Save on paper and postage.
9. Once collected, the data can be incorporated in more than one report.
10. Program monitoring becomes more manageable.
11. The evaluation and statistical analysis becomes less burdensome.
12. The entire spectrum of program preparation, implementation, evaluation, and
reporting improves the skills and accuracy of the doers.
PAGENO="0223"
219
REDUCING PAPERWORK...THE PROCESS
The Third Annual Data Acquisition Plan is a continuing step forward in the control of
the burdensome paper flow that has inundated all segments of the State educational
community. The ever increasing demands for public informétion, ancillary services,
program reporting, student accounting, individual rights, ethnic dialogue, and every
dimension of accountability have been so extensive and ever changing that the need to
control the reporting burden of the local school administrator became a highly prioritized
item.
The Third Annual Data Acquisition Plan is a first in that any data collection instrument
required, by either federal law, state law, or state school board policy, has been reviewed
and approved by a department committee and a committee of local school
administrators. These two committees have reduced the number of required forms
by 57.8 percent; the number of separate pages by 62.6 percent; and more than 26,598
separate data items.
This accomplishment fulfills a pledge made earlier by Mrs. Carolyn Warner, State
Superintendent of Public Instruction, that ADE would reduce data acquisition paperwork
more, than 50 percent.
The Plan will be further refined and updated on a monthly basis.
IRAC MEMBERS & DUTIES
The Information Review Administrative Committee (IRAC) of ADE, coordinates
departmental efforts (with DAAC) in the review and revision of data collection items.
IRAC members are appointed by the Superintendent's cabinet while DAAC members are
appointed (from school district personnel) . by Mike McCormick, Executive Director of
Arizona School Administrators. Representatives from county offices are appointed by the
president of the Arizona Association of County School Superintendents.
Members of I RAC responsible, with DAAC, in compiling the Third Annual Data
Acquisition Plan, include:
Peg Denham General Operations
Charles Hathaway Business and Finance
Tom Russell General Education
Hoyt Kenmore Vocational Education
PAGENO="0224"
220
DAAC MEMBERS & DUTIES
Forms sent to school districts from the Arizona Department of Education (ADE), first
are reviewed and approved by the ADE Data Acquisition Advisory Committee (DAAC).
DAAC simplifies and limits the requesting of information from local school districts by
determining which forms are necessary, combining forms where possible or feasible and
eliminating unnecessary ones.
To simplify the reporting of districts, DAAC compiles an annual data acquisition plan
which includes forms needed by the districts.
Persons of the present DAAC responsible for compiling the Third Annual Data
Acquisition Plan (with the assistance of the ADE Information Review Administrative
Committee), include:
Larry Anderson Frank Glotfelty Tom McCraley
Office of Evaluation Services Business Manager Superintendent
Phoenix Dist. No. 1 Casa Grande School Dist. No. 4 Bullhead City School Dist. No. 15
Tom Arviso Gene Hunt Jerry Parks
Business Manager Superintendent Acting Director of Federal Programs
Window Rock Dist. No. 8 Yavapai County School Office Tucson Dist. No. 1
Tom Boone Jim Irwin William Raymon
Maricopa Administrative Business Manager Technical Services Center
Services Cooperative Sunnyside School Dist. No. 12 Mesa Public Schools
Laverne Brown Fred Lewis Alan Robinson
Business Manager Superintendent Assistant Superintendent
Holbrook School Dist. No. 3 Whiteriver Dist. No. 20 Safford School Dist. No. 1
Chon Canchola Anita Lohr Department of Education
Superintendent Superintendent Tony Cavallo, Chairman
Santa Cruz County School Office Pima County School Office
Jim Cornwall Charles Maxwell
Head Teacher Business Manager
Owens Whitney Dist. No. 6 Prescott School Dist. No. 1
PAGENO="0225"
221
ADE REDUCTIONS
REPORTS REDUCED~
Before
512
____Now
p 216
57.8% Reduction
DEFINITION OF TERMS
Common Itnms-R econeing infonmation DAAC-Dato Acqoodion Adonony
eqoested by the Aniaosa Depantment sf Commttee, is a csn,mttee conssting of
Edocatisn. boniness managees and sopeeieteedeets of
Dta-Ayq 5 d td pblsc w t t w g
disteict to which it most nesposd.
Complionse-Folfilling by local school
Data Needs-That infonneatien needed fee distnicts of stats and fedenal laws
sequined ropoet. specified, and state board policies.
DotaCollectien System-An information- Aseoesese-Legal cenfification that local
gothening system. school distnicts ane complying with laws,
ADAP-Aenual Data Acqoisitios Plan, is a noles, and nrgclations of an edocatisnal
systems appnsach to soetnolling data. pnognam.
IOAC-fefonmation Reciecs Administnatice Dato'AcqosstiOn ttems-lnfonmahon stems
Committee, is a committee ot Depaetment ecolced n the collector pnscess.
at Edcsatinn pensoenel with the specific
doty to eeoiew and approce all data items.
PAGES REDUCED~
Before______
14O8~DJJ
____Now
526
~Lll
62.6 °Io Reduction
~ITEMS REDUCED
Before
50,848
Now
24,250
52.3% Reduction
91-860 0 - 77 --15
PAGENO="0226"
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PAGENO="0227"
223
A SYSTEMS P4'PROACH TO FORMS MANAGEMENT
FOR
ARIZONA DEPARTMENT OF EDUCATION
Carolyn Warner
Superintendent of Public Instructio~i
July, 1975
Prepared by
School Finance and Statistical Ir~formation Unit
Arizona Department o~ Education
PAGENO="0228"
224
A SYSTEMS APPROACH TO FORMS MANAGEMENT
1.0 DEFINITION
A systems approach is a theory in continuous process but embodying a
core of procedures which can be identified and used to good effect.
Forms management is one phase of the systems approach, a model, a
function within the Department of Education.
A viable data collection process is an organized arrangement for making
the right information available to those who need it, when they need it,
in the desired format and at the least possible cost.
2.0 NEED
It is recognized that decision makers at all levels need information
from which wise decisions designed to improve educational opportunities for
children and youth be made. Merely collecting information and statistics
on the state of affairs is not sufficient. Data should be explored on a
wide assortment of choices and alternatives to suggest better courses of
action than current practices.
The ever increasing demand for better quality, greater quantity, and
faster retrieval of data has caused the Arizona Department of Education
to focus upon a more efficient approach to the data collection system.
Thus, establishing a data base and retrieving data from that base to
better serve the needs of the public schools are fundamental to this
administration.
In a larger sense, the systems approach depends upon new knowledge as
well as new legislative procedures for more research on group behavior,
on basic mechanisms that effect our decisions, our reactions to one
another, and to new ideas.
The systems approach elements are:
2.1 Design for action - Find the right questions to ask. Defining
objectives in behavioral terms in ways that demand concrete action.
Criteria is then selected as to how well the objectives are being met.
2.2 Seeking alternatives - There must be an organized way to search out
alternatives, perhaps the most important and creative phase of the
systems analyses.
2.3 Evaluation - It is a repetitive process--a realistic plan depends
on trade-of fs and compromise. Qualitative factors are always con-
sidered along with quantitative factors, there are always political
implications, questions of morale, etc., which may not be measurable
in satisfactory terms.
PAGENO="0229"
225
3.0 PROGRAM DESCRIPTION
3.1 A Data Collection - Forms Clearance unit will be formed within the
Department of Education and given the responsibili~y and the
authority for coordinating all data handling. This will be a
separate administrative unit supported by a commitment of other
parallel units within the Department. Adequate staffing will be
provided to assure competent leadership, continuity in development,
and efficiency of operation. Requests for data from both within
and outside the Department will be channeled through this
administrative unit. In turn, requests will be evaluated in
terms of:
3.1.1 Whether the data requested are already available within the
system;
3.1.2 The Department's responsibility for providing the requested
data in consideration of the overall objectives and commitments
of the Department;
3.1.3 The feasibility of collecting new and different data; i.e.,
the relative value of having the data, compared with the time
and effort required of the school and agency personnel to
obtain it;
3.1.4 The value and benefits of processed data and reports to
school and agency personnel.
3.2 An Information Review Administrative Committee, primarily of the Deputy
Associate Superintendent level, will be an integral part of the review
process. Since the Department of Education is the primary vehicle
charged with the preparation and implementation of the majority of
forms that are currently used, department coordination and practical
procedures for evaluation of all requests will assist in eliminating
data collection that is unnecessary, undesirable, unfeasible, or
redundant.
3.3 A Data Acquisition Advisory Committee with representation being
primarily from superintendents of schools, and with area representation
a prime consideration, will be included in the forms management system.
Their input will rank high in the form-clearance and authorization process.
3.4 In summary - the three groups must be cognizant of state and federal
requirements and sensitive to the needs of the Department and the
local educational agencies. These groups will progress to a point where
they are working at least one year in the future in identifying data
needs and procedures. The commitment of the above three groups and
Superintendent of Public Instruction are all critical to the entire
process for the success of the forms management effort.
-2-
PAGENO="0230"
226
4.0 Statement
There are many aspects of waste and useless labor in most data collection
systems and it stems largely from the inadequacies of definitions which
have been developed in a haphazard manner. The system can only be as
good as the data from which it is built. To insure that definitions are
provided and understood, a systematic approach (forms management) will
be established. Policies will be established and carried into practice
which support all aspects of forms management. Purposes of forms manage-
ment include:
4.1 Avoiding duplication of data items collected by the Department of
Education Staff;
4.2 Assisting staff members in the development and design of data collection
documents;
4.3 Ascertaining the reasons which necessitate the collection of data;
4.4 Reviewing all instructions and terminology used in data collection;
4.5 Assisting staff members in determining cost effectiveness of data
collection efforts;
4.6 Structuring and categorizing data and information elements;
4.7 Developing a plan with the user which would include data items,
definitions, instructions, time schedules for printing, dissemination
and return, processing and- analyses schedules, and also a description
of the final reports with target populations.
4.8 Perhaps one more salient point should be added concerning accuracy.
ACCURACY should be the first criteria and must precede all others--
if data cannot be collected accurately, it should not be collected at
all.
5.0 Strengths and Constraints
In order to provide people with insight into the consequences of the
Superintendent of Public Instruction's statement on -a forms management
unit, the following strengths and constraints of that statement are
offered:
5.1 Strengths
A thorough exploration of the systems approach to the forms manage-
ment concept will reveal the following strengths:
5.1.1 It is extremely important for the successful operation of the
forms management function to be established with the philo-
sophical position that the function is one to provide service.
5.1.2 The control of forms should be viewed as a "positive assistance"
rather than a "negative constraint."
3.
PAGENO="0231"
227
5.1.3 We know more accurately what we are getting for our dollars
as we seek that high level of quality which we desire so much
for our children.
5.1.4 A forms management system does not of itself produce better
education. It should, if used seriously, present educators with
the opportunity to recognize more exactly what they want to
achieve, plan a program of how they want to go about it and
assess honestly the outcome of their actions.
5.1.5 The essential power of the forms managment system is that it
offers the chief school officers a solid objective foundation
in the decision making process.
5.1.6 A systems approach will enhance the validity of a service
oriented Department of Education in the eyes of all school
agencies in the State of Arizona.
5.2 Constraints
No system, of and by itself, will produce better education. Those
educators who feel that the systems approach will be the answer to
all their problems should be aware of certain conditions and/or
attitudes which could hinder or deter the implementation of a forms
management unit.
5.2.1 System investigators have much to learn from educators and
educators have much to learn from them. Wisdom is more
than ever a collective thing, more in the possession of groups
and less in the possession of individuals, however talented.
5.2.2 Can analytical techniques be applied specifically to the
intensely political problem of getting things done?
5.2.3 Can the opposition to change be overcome or effectively reduced
by the use of the systems approach?
5.2.4 The systems approach is not a set established procedure with
clearcut rules to follow in dealing with all problems. Machines
cannot think, they return absurd answers only to absurd questions.
5.2.5 The nature of the relationship between the systems specialist
and those responsible for major decisions is critical. If
the relationship is not close, the specialist's work tends to
be academic.
5.2.6 The delivery system will be hopelessly taxed if processing
time is not zealously scheduled with patience and pre-planning.
5.2.7 Human editing is not eliminated, but dollars are saved and
accuracy increased.
-4-
PAGENO="0232"
228
6.0 Bibliography
Downie, N.M., Heath, R. W.; Basic Statistical Methods, Harper & Rowe
Publishers, Inc., New York, NY, 1959, pp. 16-28.
Mitchell, J. E., Iowa; Ellis, W.E., South Carolina; Position Paper on
Form Management for Management Information Systems for State
Educational Agencies, presented from Committee on Coordinating
Educational Information, Washington, DC, June, 1974.
Pfeiffer, John; New Look at Education, Odyssey.Press, New York City, 1968.
Russell, Don; Forms Management in DPI, Department of Public Instruction,
Wisconsin, 1975.
-5-
Ml/sm/02-06/7 .14
PAGENO="0233"
229
DATA COLLECTION AND FORM CLEARANCE
REVIEW AND AUTHORIZATION
PROCEDURE
CAROLYN WARNER
SUPERINTENDENT OF PUBLIC INSTRUCTION
JULY 1975
PREPARED BY*
SCHOOL FINANCE AND STATISTICAL INFORMATION UNIT
ARIZONA DEPARTMENT OF EDUCATION
PAGENO="0234"
230
1.0 INTRODUCTION
Functional responsibility for developing and implementing a Data
Collection System within the Department of Education has been assigned
to the Data Collection and Forms Clearance unit of the Section of
School Finance and Statistical Information. The objectives of the
DC-FC unit are:
1.1 (1) to promote maximum coordination and efficiency of data
collection activities within the Department of Education.
1.2 (2) to make recommendations for the consolidation of data
collection instruments in order to minimize duplication;
1.3 (3) to simplify reporting requirements and reporting formats
of the Department of Education data collection instruments;
1.4 (4) to provide technical assistance to the Department's staff
in the development and design of data collection instruments
and activities;
1.5 (5) to provide Arizona School Districts with advance knowledge
of the State Department's data collection needs in a given
fiscal year through the preparation and dissemination of
the Annual Data Collection Plan with one year lead-up time.
2.0 REVIEW AND AUTHORIZATION POLICY
All data collection instruments, state or federal, which are distri-
buted to public or private shcool personnel by or under the sponsorship
of the Arizona Department of Education staff members must be submitted
for review and authorization prior to distribution.
3.0 DATA COLLECTION INSTRUMENT DEFINED
A data collection instrument is defined as any form, application,
memoranda, or other device which requests public or private school
personnel to collect and report data to the Arizona Department of
Education.
The, following types of instruments are subject to the policy and
procedure covered by this document:
3.1 Recurring reports - reports due more frequently than once yearly.
3.2 One time survey report - an instrument which has been prepared
to collect data one time only and which is not intended to be
used on a recurring basis.
3.3 Emergency report - an instrument that has been authorized on the
cabinet level, which due to time constraints, cannot be processed
through the normal review and authorization process.
PAGENO="0235"
231
3.4 Occasional repprts - reports for which no due date has been
established. These reports are either filed as needed by the
district or are filed at a date determined by the appropriation
and release of Federal funds.
3.5 All Federal reports will be so titled and listed by month due.
4.0 REVIEW AND AUTHORIZATION DEFINED
4.1 Reviç~ entails the approval of data collection activities and
the technical analysis of format, content, and other special
techniques or methods used in conjunction with instruments in
order to gather, process or analyze data.
4.2 Authoriza~pp~ is the determination that sufficient justification
exists in law, regulation, or program needs to permit the distri-
bution of a data collection instrument to public or private school
personnel.
4.3 Authorization of approval of all or any data collection instrument
must be passed by the Data Acquisition Advisory Committee (DAAC)
with appellate authorization vested in the Superintendent's Cabinet.
(See Appendix 1).
4.3.1 EXCEP~I Emergency Instruments will be approved on
the cabinet level only. (See Appendix 1).
5.0 REVIEW AND AUTHORIZATION SCHEDULING
Data collection instruments must be scheduled for review and authorization
as follows:
5.1 Annual review and authoriza~4pP - instruments currently in use must
be submitted through channels (DC-FC) prior to distribution in each
fiscal year. Instruments will be authorized only for a twelve month
period.
5.2 ~ in data collection activities - review and authorization will
be required when the following occur:
5.2.1 Revision of existing instruments, subsequent to annual
review and authorization, in order to add or delete
data or to make changes in the format.
5.2.2 Elimination or consolidation of one or more instruments
subsequent to annual review and authorization.
5.2.3 Development of new data collection instruments including
one time surveys and emergency instruments, each of which
will contain an expiration date of six months.
PAGENO="0236"
232
6.0 GENERAL REQUEST FOR DATA COLLECTION
The ADE will prepare a form ,a~C-Fc 2, included) to be filled out by
the originator of each data collection instrument request. The form
is self-explanatory in that it will supply the DC-FC unit with all
the necessary information for the Annual Data Acquisition Plan and
include the first two sign of fs in the Review and Authorization
process. It will also act as the cover sheet and agenda position
for IRAC, the deputy associate review, team.
7.0 THE SUMMARY SHEET
Prepared by the ADE, the summary sheet (DC-FC 3) will be the cover
page of each instrument contained in the Annual Data Acquisition
Plan. It is the official authorization page that not only will
contain information but will have form identification, authorization
date, expiration date, mailing date, and return due date.
Recipients of ADE collection instruments which are not accompanied
with an official Summary Sheet need not respond to the request.
8.0 THE ANNUAL DATA ACQUISITION PLAN - is a notebook intended to make
reporting information required by the ADE a more manageable task
for local school districts. Toward that end, the Annual Data
Acquisition Plan includes a list of the reports which all or most
school districts must complete during FY 76, as well as actual
or facsimile copies of all reports.
It is hoped that reporting requirements and planning can be published
one year in advance of the due date.
9.0 PROCEDURAL STEPS IN THE FORMS AUTHORIZATION PROCESS
See ADE form DC-FC 1. Any and all criteria included herein is subject
to the additions and/or deletions of the Data Acquisition Advisory
Committee.
9.1 The sponsor is one who either originates or is assigned to prepare
or perpetuate a data collection form. He initiates action with
DC-FC. When form is prepared it goes to:
9.2 Deputy Associate for signature - the Deputy Associate can
the process or send it to~
9.3 (IRAC) A committee on the deputy associate level to represent
the ADE. IRAC is charged with the total review of the instrument
and if approved it is placed:
9.4 on the agenda of DAAC, an advisory committee composed on the
Superintendent of School level, who have the approval authority
to send it to:
9.5 DC-FC for summary sheet and implementation.
9.6 Disapproval by either IRAC or DAAC does not preclude an appeal
to the Superintendent's Cabinet by the sponsor.
9.7 The Cabinet also will rule on all emergency requests with
check of fs with IRAC and DAAC.
PAGENO="0237"
233
FORM REVIEW ~NI) AUTHORIZATION PRO('EHtRI
SPONSOR
FORMS
ADE(DC-FC I)
PAGENO="0238"
234
SUMMARY SHEET PAGE
FORM NO. ______
ADE ADAP _____
Form Approved Date _________
Mailing Date __________ Title
Form Return Date
Form Expiration Date _________
AGENCY REQUIRING
INFORMATION [ I ADE [ I FEDERAL [ I OTHER ______________
MAJOR
PUBLICATION (Name and Date of Publication/Report)
ETC.
(Name and Date of Publication/Report)
SPONSOR
(Name) (Unit)
JUSTIFICATION [ I Law
I Rules and Regulations _______________________
I Guidelines
Legislative Request _______________________
State Board Requirements _______________________
I Management Information _______________________
[I Other
STATUS [ I New data for one-time survey
I New data for recurring form
I No change from previous form
I Revision of previous forms
POPULATION [ I Sample [ I All Districts [ I All Schools
I Other ________________________
RECOMMENDED FOR COLLECTION BY
I DAAC - Data Acquisition Advisory Committee
I ADE - Cabinet
Please notify the School Finance and Statistical Information Unit
(271-5695) of any data request that does not include a copy of this
summary sheet. There is a posibility that such forms have not
received proper clearance. Your notifying us of problems of this
kind will assist us in controlling duplication of information and
in seeing that forms are properly reviewed prior to distribution.
ADE-(DC-FC 3)
PAGENO="0239"
235
DEFINITIONS AND CRITERIA FOR FORMS
APPROVAL BY DATA ACQUISITION ADVISORY CONMITTEE
1. REDUNDANCY: a. Any form item that can be eliminated without loss
of essential information is redundant.
b. Any item within a form will be declared non-essen-
tial if the information is readily available at
the Arizona Department of Education and is
retrievable. (Example: School District Street
Addresses, etc.)
2. DUPLICATION: Information items previously gathered for one program
should not be duplicated in subsequent forms for the
same program.
LEGAL
3. REQUIREMENTS: Legal requirements are those requirements specified in
the Rules and Regulations and are usually distinct and
separate from procedural recommendations. Any item is
declared to be non-essential if it goes beyond the
scope of the law in reference to ADAP approval.
Exceptions will be those demographic items required by
forms management.
The committee or its sub-groups will rely on the
program director or his representative to be present
during the scheduled review periods to provide back-
ground knowledge and insight to the legal ramifica-
tions pertaining to the form.
4. FEASIBILITY: It is a judgmental criteria whether the information
gathered is worthy of the time and cost spent in
collecting the data.
5. FORM FEBMAT: a. Paper size: 8 1/2 X 11 preferable; data items on
one side; instructions for completion of items
and/or a recap of the legal requirements are
recommended to appear on the backside.
b. Margins and Space: Leave one substantial margin
for book-filing purposes. Even if printed, care
should be taken that line spacing is adaptable to
typewriter spacing.
c. Numbering Pages and Coding: If more than one page
is used, then number as follows, `page 1 of 6,"
etc.
d. The following items are to be placed in the lower
left corner of first page: The Arizona Department
of Education form numbers which will be consistent,
and revisions which will be specified with month
and year. (Example: ADE 21-101; rev. 10/75.)
PAGENO="0240"
236
Definitions and Criteria for Forms
December 15, 1975
Page 2
e. Data Items: List all data items from top to bottom
1, 2, 3, etc., in sequential order without duplica-
ting any number throughout the form.
f. Columns: List columns (1), (2), (3), etc., from
left to right without duplicating numbers.
(Purpose: Simplification of indexing and cross-
indexing)
g. Form Identification and Title: The top of each
front page should list the mailing address on the
left, the center portion should contain the
division name and the title; and the due date
should be placed on the right. Division or pro-
gram identification should appear top center of
subsequent pages. Example:
APPLICATION
FOR FUNDING
ESEA Title I
Arizona Dept. of Ed~
*
1535 West Jeffersot~
Phoenix, AZ 85007
Due 6/30/75
PAGENO="0241"
237
CAROLYN WARNER
~rnrfmfnt uf ~Ebur~xtion
1535 WEST JEFFERSON
PHOENIX, ARIZONA 85007
271.4361
April 26, 1977
MEMORANDUM
TO: School Adminis rators
FROM: Carolyn Warn
SUBJECT: Third Annual Data Acquisition Plan
The "Third Annual Data Acquisition Plan" is prepared for ~ use and con-
venience. It is your "telephone book" in management and planning of your
reporting requirements for FY `78. The Plan reflects changes so please
throw the old Plan away and substitute the new one in its place.
In this light, the Departnent of Education is committed to reduce any need-
less collection of data and we continue to encourage your input for sug-
gested improvement. Diligent effort is being made to shift the reporting
burden to the Department of Education where practical; increase the validity
of the reported data by standardization and improved definition; and afford
maximum lead tine for your planning and performance.
It was indeed gratifying to me to observe the oneness of purpose exhibited
by all of you in meeting the challenge and the frustrations of complying
with the Office for Civil Rights' forms 101 and 102. However, the major
issue, as to how the data collected is to be used, is far from settled.
The collection and reporting of data, accountability, and the measurement
of success and failure will continue to be a fundamental part of our daily
existence.
Only in togetherness can we control the flow of redundant and ineffective
data. The first step in the control of data is to not respond to any
request of data that is not listed in the Annual Data Acquisition Plan or
its subsequent updates.
If you have any questions concerning the status of any reporting instrument,
please call Tony Cavallo, 271-5695. Your consideration and utilization of
the Plan will result in better reporting, better data, and improved perform-
ance.
gec
91-860 0 - 77 --16
PAGENO="0242"
238
~rI ANNUM
A ft
I by the Data Acquisition Unit, General Operations I
~f the Arizona Department of Education Carolyn ~v
PAGENO="0243"
239
PREFACE
The Third Annual Data Acquisition Plan is a continuing step forward in
the control of the burdensome paper flow that has inundated all segments
of the state educational community. The ever increasing demands for
public information, ancillary services, program reporting, student
accounting, individual rights, ethnic dialogue, and every dimension
of accountability have been so extensive and ever changing that the
need to control the reporting burden of the local school administrator
became a highly prioritized item.
The Third Annual Data Acquisition Plan is a first in that every data
collection instrument required, by either Federal law, State law, or
State School Board Policy has been reviewed and approved by a department
committee and a committee of local school administrators. These two
committees had reduced the number of required forms of the first Data
Acquisition Plan by 54.6%; the number of separate pages by 86%; and
more than 20,000 separate data items. Many thanks go to these committees
for their good work.
ADE 41-300, REV 5/77 I
PAGENO="0244"
240
FOREWORD
The Annual Data Acquisition Plan concept is the tying together in a sequential.
and explicit order the majority of reporting tasks during a given fiscal year
to assist the decision makers in the administration of their school districts.
It is unique in that the review and approval procedures conducted to determine
the criteria, format, and content of the forms included herein were accomplished
by a volunteer cormaittee of local school and county administrators, namely;
Mr. Larry Anderson
Mr. Tom Arviso
Mr. Tom Boone
Ms. Laverne Brown
Mr. Chon Chanchola
Mr. Jim Cornwall
Mr. Frank Glotfelty
Dr. Gene Hunt
Mr. Jim Irwin
Mr. Fred Lewis
Ms. Anita Lohr
Mr. Charles Maxwell
Dr. Tom McCraley
Mr. Jerry Parks
Dr. Bill Raymond
Mr. Alan Robinson
Phoenix
Window Rock
Maricopa Administrative
Services Cooperative
Holbrook
Santa Cruz County
Wikieup
Casa Grande
Yavapai County
Sunnyside
Whiteriver
Pima County
Prescott
Bullhead City
Tucson
Mesa
Safford
the review and approval procedure is ongoing and the Data Acquisition Advisory
(:osvntttee, named above, is supplemental to the Department's information Review
Administrative Committee composed of staff representing each Associate Super-
intendent, namely;
Ms. Peg Denham
Mr. Charles Hathaway
Mr. Tom Russell
Mr. Hoyt Kenmore
General Operations
Business and Finance
General Education
Vocational Education
ADE 41-300, REV 5/77
II
PAGENO="0245"
241
ACKNOWLEDGEMENTS
The efforts of many divisions and individuals whose effective
participation has helped assure the usefulness and accuracy
of the contents of this notebook are, greatly appreciated. The
implementation of the Annual Data Acquisition Plan will enhance
the quality of the data, while encouraging the development of
adequate safeguards for protecting the confidentiality of
students and preventing unauthorized or inappropriate use of
information.
The function of this notebook is to identify terms, definitions,
and procedures which represent the combined best judgment of the
Information Review Administrative Committee and the Data
Acquisition Advisory Committee participating in the cooperative
development of the notebook materials.
ADE 41-300, REV 5/77 .` III
PAGENO="0246"
242
INTRODUCTION
The format of the Third Annual Data Acquisition Plan is not
intended to give you a copy of all approved forms, but rather a
series of short indices that will easily identifythe approved
forms by Title and ADE nunber.
The number of reporting requirements has not decreased, but
the standardization of asking for those data items has been
accomplished. For example, one budget page form can be used
for every program application, every program amendment, every
program periodic report, and every program completion report.
Eight out of ten pages in the average federal program applica-
tion will be common to all federal program applications.
The time saved by each school district would be difficult to
n~asure. Much has been accomplished and many forms have been
eliminated, reduced, or combined with other forms. Itis
~pperative that you throw away the content of the Second
Annual Data Acquisition Plan, and check the new Plan for
numbers and identification. Your diligence in making the
Plan work will save you many, many dollars.
ADAP is divided into six parts, as follows:
PART I
Preface, Foreward, Acknowledgement, and Introduction.
PART 1
A Calendar Index--based on due date the report is
expected to be returned.
PART II
An Index by Receiving Office--lists all the pages (forms)
and reports due a particular office. The combination of
sheets listed will also satisfy the requirements of an
amendment, periodic report, completion report, and final
evaluation.
PART III
DISTRICT USE ONLY-- Title 15 stipulates that the Superintendent
of Public Instruction prepare certain forms for district use.
These forms are listed for your benefit and are NOT RETURNED
to the ADE.
ADE 41-300, REV 5/77 IV
PAGENO="0247"
243
INTRODUCTION
PART IV
List of Voluntary Forms. The forms listed in Parts I
and II are mandated by law or Board Policy if the district
elects to participate in the program. All other forms that
are reviewed and approved, but not mandated, will be placed
in this group.
PART V
Part V lists forms used in student organizations or clubs
that have ADE sanction, and have been reviewed and approved
by the standing committees.
Updating and changes: It is assumed that as of Nay 1, 1977, not
all forms have been listed in ADAP, and that changes are necessary
and unpredictable. The Plan will be updated on a monthly basis.
ADE 41-300, REV 5/77 V
PAGENO="0248"
CALENDAR - MAY
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
PART I
Composite: Each page in an application, amendment, periodic ~ and completion report has a separate form
number for standardization purposes. The program director will inform the district of the combina-
tion of pages (form numbers) to be included in any specific reporting packet. See Part II for
application composite.
DUE DATE FORM #
TITLE - DESCRIPTION
UNIT
Statement of Intent to Participate
A.B.E. Application
Citizenship Application
G.E.D. Application
Application for Grant for Federal Funds
Class Reporting System
Estimates - Free and Reduced-Priced Lunches
Free Loan Driver Car Survey
Claim for Reimbursement - Child Care
Reimbursement Claim, Food-Nutrition
Non-Public School Claim for Payment - Special Ed. Voucher
Summary of School Construction Projects
Estimated Membership Info. - State Aid
Financial Status Report
Intent to Carryover or Release Funds
State Aid for Pupils of Parents Employed by State
Special Ed.
Adult Ed.
Adult Ed.
Adult Ed.
Adult Ed.
Adult Ed.
Bus. & Finance
Driver Ed.
Food & Nutrition
Food & Nutrition
Special Ed.
Admin. Services
Data Processing
Migrant Ed.
Title I
Bus. & Finance
PART I
05-01
05-01
05-01
05-01
05-01
05-05
05-05
05-09
05-10
05-10
05-15
05-15
05-15
05-15
05-16
05-30
ADE 30-005
ADE 32-008
ABE 32-009
ADE 32-010
ADE 32-120
ABE 32-209
ABE 45-108
ABE 33-402
ADE 45-118
ABE 45-107
ABE 35-105
OE 4017-2
ABE 41-107
ADE 41-114
ADE 31-111
ABE 46-002
CALENDAR - JUNE
06-01
Composite
Title I Application
Title I
06-01
ABE
41-110
Proposed/Adopted School
District Annual
Budget
County
Sch. Office
06-05
ADE
32-209
Class Reporting System
Adult Ed.
06-06
ABE
41-801
CUES Periodic Report
Special
Programs
06-10
ABE
45-107
Reimbursement Claim, Food-Nutrition
Bus. &
Finance
06-10
ABE
45-002
Reimbursement Computation,
Food-Nutrition
Bus. &
Finance
ADE 41-300, REV 5/77
PAGE 1
PAGENO="0249"
CALENDAR - JUNE (Cont'd.)
PART I
Bilingual Application
Claim for Reimbursement - Child Care
Work Study Report
Summer Plan of Teachers on Extended Contracts
Non-Public Claim - Special Education Voucher
Application Program Prior Approval - Gifted
Annual Evaluation Report (Regular)
Claim for Exemption from Establishment of Kindergarten
Budget Summary Worksheets Expenditures
Election for Special Budget Increase
State Financial Aid - Certificate of Ed. Convenience Claim
State Financial Aid - Students from Unorganized Territories
CUES Progress Report
Completion Report Title IVB
Advice of Encumbrance
Evaluation Summary, Regular
Migrant Application, Regular
Enrollment/Nembership Report
Title IVB Application
Class Reporting System
Completion Rept. - Entitlement
Completion Rept. - Teacher Ed.
Completion Rept. - Curriculum Development
Completion Rept. - Disadvantaged - Handicapped
Completion Rept. - Contracted Instruction Plan
Completion Rept. - New Program Plan
Completion Rept. - Work Study Plan
Completion Rept. - Consumer-Homemaking
Completion Rept. - Education Professions Development Act
Reimbursement Claim, Food-Nutrition
Reimbursement Computation, Food-Nutrition
Claim for Reimbursement - Child Care
Bilingual Annual Evaluation
Bilingual Ed.
Food & Nutrition
Voc. Ed.
Voc. Ed.
Special Ed.
Special Ed.
Migrant Ed.
Admin. Services
County Sch. Office
Admin. Services
Bus. & Finance
Bus. & Finance
Special Programs
Title IVB
County Sch. Office
Title I
PART I
Migrant Ed.
Admin. Services
Title IVB
Adult Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Bus. & Fin.
Bus. & Fin.
Food & Nutrition
Bilingual Ed.
DUE DATE FORM #
TITLE - DESCRIPTION
06-10
06-10
06-15
06-15
06-15
06-15
06-15
06-18
06-18
06-18
06-20
06-20
06-20
06-30
06-30
06-30
Composite
ABE 45-118
ABE 22-129
ADE 23-103
ABE 35-105
ADE 35-500
ADE 31-201
ABE 41-105
ABE 41-113
ABE 41-108
ADE 46-001
ABE 46-003
ABE 41-800
ABE 41-114
ABE 40-001
ABE 31-101
UNIT
CALENDAR - JULY
07-01
07-01
07-01
0 7-05
07-09
07-09
07-09
07-09
07-09
07-09
07-09
07-09
07-09
07-10
07-10
07-10
07-15
Composite
ABE 41-301
Composite
ABE 32-209
ABE 41-114
ABE 41-114
ADE 41-114
ABE 41-114
ABE 41-114
ADE 41-114
ABE 41-114
ABE 41-114
ABE 41-114
ABE 45-107
ABE 45-002
ADE 45-118
ABE 31-402
ABE 41-300, REV 5/77
PAGE 2
PAGENO="0250"
CALENDAR - JULY (Cont'd.)
PART I
Special Ed.
Career Ed.
Pupil Transportation
PART I
08-01 ABE 41-006C Admin. Services
08-05 ADE 32-209 Adult Ed.
08-10 ADE 45-107 Bus. & Fin.
08-10 ADE 45-002 Bus, S Fin.
08-10 ABE 45-118 Food S Nutrition
08-15 ADE 35-105 Special Ed.
08-15 ABE 41-202 Admin. Services
08-20 ADE 41-001 Admin. Services
08-20 ABE 41-002 Admin. Services
CALENDAR - SEPTEMBER PART I
09-01 ADE 41-114 Migrant Ed.
09-01 ABE 41-114 Bilingual Ed.
09-01 ABE 41-114 Title IV C
09-01 ADE 41-114 Title I
09-05 ABE 32-209 Adult Ed.
09-05 ABE 41-112 Admin. Services
09-10 ABE 45-107 Bus. & Fin.
09-10 ABE 45-002 Bus. & Fin.
09-10 ABE 45-118 Food & Nutrition
09-15 ABE 31-101 Title I
09-15 ABE 35-105 Spec. Ed.
09-15 ABE 33-604 Special. Projects
09-15 ABE 33-605 Special Projects
09-21 ABE 35-304 Special Ed.
09-26 ABE 33-401 Briver Ed.
09-30 OE 4037 Admin. Services
DUE DATE FORM ft TITLE - DESCRIPTION
07-15 ABE 35-105 Non-Public Claim - Special Ed. Voucher
07-15 ABE 41-114 Special Project Budget and Fiscal Report
07-31 ABE 41-502 Pupil Transportation - Bus Inventory
CALENDAR - AUGUST
UNIT
Annual Bays in Session
Class Reporting System
Reimbursement Claim, Food-Nutrition
Reimbursement Computation, Food-Nutrition
Claim for Reimbursement - Child Care
Non-Public Claim - Special Ed. Voucher
Annual Report Summary Worksheets
3rd Grade Reading Achievement Test Order Form
5th Grade Math Achievement Test Order Form
Completion Rept.
Completion Rept.
Completion Rept.
Completion Rept.
Class Reporting System
Budget Summary Worksheet - Revenue
Reimbursement Claim, Food-Nutrition
Reimbursement Computation, Food-Nutrition
Claim for Reimbursement - Child Care
Evaluation Summary - (summer or other)
Non-Public School Claim - Special Ed. Voucher
Commercial Exhibitor's Contract Agreement
Booth Reservation Form (School/Program)
Name and Address of Provisionally Certified Teachers
Application for Driver Ed. Approval
Determine Final Payment-8l-874
ABE 41-300, REV 5/77
PAGE 3
PAGENO="0251"
CALENDAR - OCTOBER
PART I
DUE DATE FORM II TITLE - DESCRIPTION UNIT
10-01 ABE 41-201 Admin. Services
10-01 ABE 33-600 Special Projects
10-01 ABE 35-102 Special Ed.
10-05 ABE 32-209 Adult Ed.
10-10 ABE 33-602 Free Enterprise
10-10 ABE 33-703 Metric Program
10-10 ABE 45-001 Bus. & Fin.
10-10 ABE 45-002 Bus. & Fin.
10-10 ABE 45-118 Food & Nutrition
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 APE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-114 Voc. Ed.
10-15 ABE 41-204 Admin. Services
10-15 APE 35-105 Special Ed.
10-30 ABE 31-308 Indian Ed.
CALENBAR - NOVEMBER PART I
11-01 ABE 41-200 Admin. Services
11-01 ABE 30-005 Title IVC
1105 ABE 32-209 Adult Ed.
11-05 ABE 45-108 Food & Nutrition
11-10 ABE 45-107 Bus. & Fin.
11-10 ABE 45-002 Bus. & Fin.
11-10 ABE 45-118 Food & Nutrition
11-15 ABE 35-105 Special Ed.
Enrollment/Membership Report
Nomination for Ariz. Teacher of the Year
Special Education Census
Class Reporting System
Free Enterprise Mailing List and Classroom Materials
Application for Inservice Training
Reimbursement Claim, Food-Nutrition
Reimbursement Computation, Food-Nutrition
Claim for Reimbursement, Child Care
Periodic Rept. - Entitlement
Periodic Rept. - Work Education
Periodic Rept. - Teacher Ed.
Periodic Rept. - Curriculum Bevelopment
Periodic Rept. - Disadvantaged and Handicapped
Periodic Rapt. - Contracted Instruction Plan
Periodic Rept. - New Prog. Plan
Periodic Rapt. - Work Study Program
Periodic Rapt. - Consumer-Homemaking
Periodic Rept. - Education Professions Development Act
School District Employee Report
Non-Public School Claim - Special Ed. Voucher
American Indians Enrolled in Public Sch. PL 92-318
Statistical Summary of Private and Parochial Schools
Statement of Intent to Participate
Class Reporting System
Estimates - Free and Reduced-Priced Lunches
Reimbursement Claim, Food-Nutrition
Reimbursement Computation, Food-Nutrition
Glaim for Reimbursement - Child Care
Non-Public School Claim - Special Ed. Voucher
ABE 41-300, REV 5/77
PAGE 4
PAGENO="0252"
CALENDAR - DECEMBER
PART I
Comparability Report
Comparability Report
Class Reporting System
Non-Public School Claim - Special Ed. Voucher
Reimbursement Clai~n, Food-Nutrition
Reimbursement Computation, Food-Nutrition
Claim for Reimbursement - Child Care
Preliminary Proposal for New Program Application (Part I of II)
Title I
Title I
Adult Ed.
Special Ed.
Bus. & Fin.
Bus. & Fin.
Food & Nutrition
Voc. Ed.
CALENDAR - JANUARY
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-02
01-05
01-10
01-10
01-10
01-15
01-15
01-15
01-15
01-31
ADE 21-201
ADE 22-001
ADE 22-106
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
ARE 22-610
ARE 40-003
Composite
Composite
ARE 32-209
ARE 45-107
ARE 45-002
ADE 45-118
ARE 41-114
ADE 35-105
ADE 31-205
ADE 41-114
OE 4019
PART I
Voc. Ed.
All Voc. Ed. Programs
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Adult Ed.
Bus. & Fin.
Bus. & Fin.
Food & Nutrition
Career Ed.
Special Ed.
Migrant Ed.
Migrant Ed.
Admin. Services
12-01
12-01
12-05
12-05
12-10
12-10
12-10
12-31
DUE DATE FORM II TITLE - DESCRIPTION UNIT
OE 4560
OE 4560-1
ADE 32-209
AI3E 35-105
ADE 45-107
ADE 45-002
ARE 45-118
ADE-22- 208
Work Education R.F.P./or Application
Statement of Assurances
Exemplary Projects - Letter of Intent
Entitlement Application
Area Voc. Ed. - Secondary-Appl.
Area Voc. Ed. - Postsecondary-Appl.
Consumer-Homemaking Appl.
Work Study Application
New Programs Plan Appl.
Contracted Instruction Plan Appi.
Disadvantaged and Handicapped Appl.
Education Professions Development Act
Voc. Ed. Field Coordinators Application
intergovernmental Agreement
Curriculum Development Appl.
Teacher Education Appl.
Class Reporting System
Reimbursement Claim, Food & Nutrition
Reimbursement Computation, Food & Nutrition
Claim for Reimbursement - Child Care
Special Project Budget and Fiscal Report
Non-Public School Claim - Special Ed. Voucher
Interim Performance Report
Financial Status Report
Appl. for Assistance in Federally Affected Areas, 815-874
ABE 41-300, REV 5/77
PAGE 5
PAGENO="0253"
CALENDAR - FEBRUARY
PART I
02-01
02-01
02-01
02-01
02-05
02-10
02-10
02-10
02-15
02-15
02-15
02-28
03-05
03-05
03-08
03-10
03-10
03-10
03-15
03-15
03-15
03-15
03-15
03-15
03-15
03-15
03-15
03-15
03-15
03-15
ABE 33-601
ABE 35-102
Composite
ABE 35-001
ABE 32-209
ABE 45-107
ABE 45-002
ABE 45-118
ADE 23-102
ABE 35-105
ABE 35-305
OE 4376
ADE 32-209
ADE 35-105
Composite
ABE 45-107
ABE 45-002
ABE 45-118
ABE 41-114
ABE 41-114
ABE 41-114
ABE 41-114
ADE 41-114
ABE 41-114
ABE 41-114
ABE 41-114
ABE 41-114
ABE 41-114
ABE 41-501
ABE 21-001
UNIT
Special Projects
Special Ed.
Title IVC
Special Ed.
Adult Ed.
Bus. & Fin.
Bus. & Fin.
Food & Nutrition
Voc. Ed.
Special Ed.
Special Ed.
Title I
Title I
Adult Ed.
Special Ed.
Nigrant Ed.
Bus. & Fin.
Bus. & Fin.
Food & Nutrition
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Voc. Ed.
Pupil Transportation
Career Ed.
DUE DATE FORM II TITLE - DESCRIPTION
Statewide Reading Achievement Program
Special Education Census
Title IVC Application
Annual Appl. for Approval of Spec. Ed. Programs
Class Reporting System
Reimbursement Claim, Food & Nutrition
Reimbursement Computation, Food & Nutrition
Claim for Reimbursement - Child Care
Final Report of Supervised Occupation Experience
Non-Public School Claim - Special Ed. Voucher
Handicapped (P.L. 89-313)
Annu. Survey of Children in Neglected and Delinquent
Institutions, or Children in Adult Correctional Institutions
02-28 OE 4376-1 Annu. Survey of Children in Local Insts. for Neglected or
Delinquent Children in Correctional Insts.
CALENDAR - MARCH
PART I
Class Reporting System
Non-Public School Claim - Special Ed. Voucher
Migrant Summer Application
Reimbursement Claim, Food & Nutrition
Reimbursement Computation, Food & Nutrition
Claim for Reimbursement Child Care
Periodic Rept. - Entitlement
Periodic Rept. - Work Ed.
Periodic Rept. - Teacher Ed.
Periodic Rept. - Consumer-Homemaking
Periodic Rept. - Work Study Plan
Periodic Rept. - New Program Plan
Periodic Rept. - Contracted Instruction Plan
Periodic Rept. - Disadvantaged and Handicapped
Periodic Rept. - Curriculum Development
Periodic Rept. - Education Professions Development Act
Pupil Transportation - Route Report
Career Education Request for Proposal
ABE 41-300, REV 5/77
PAGE 6
PAGENO="0254"
CALENDAR - MARCH (Cont'd.)
PART I
1)UE DATE FOld) 9
`liTLE - 1)ESCRtPTION
UNIT
CALENDAR - APRIL
PART I
03-24
A1)E
21-002
Student S LEA Staff Impact
Career Ed.
03-24
ADE
21-003
Student & LEA Staff Trspact (Continued)
Career Ed.
03-24
ADE
21-004
Qualifications of Proposed Staff
Career Ed.
03-24
ADE
21-005
Participating School Districts
Career Ed.
03-24
ADE
21-006
Coal Priority and Clustering
Career Ed.
03-24
A1)E
21-01)7
Budget Analysis
Career Ed.
1)3-24
ADE
21-008
Resolution
Career Ed.
03-31
ADE
25-305
Handicapped (P.L. 89-313)
Career Ed.
04-01
ADE
35-302
Provisional Certification Supervision
Special Ed.
04-01
ADE
35-303
Supervisors Assessment of Special Ed. Teacher
Special Ed.
04-05
ADE
32-209
Class Reporting System
Adult Ed.
04-05
ADE
45-108
Oct. & Mar. Estimates - Free or Reduced Price Lunch
Food S Nutrition
1)4-10
ADE
45-107
Reimhuraement Claim, Food-Nutrition
Bus. & Fin.
04-10
ADE
45-002
Reimbursement Computation, Food-Nutrition
Bus. S Fin.
04-10
ADE
45-118
Claim for Reimbursement - Child Care
Food S Nutrition
04-15
AI)E
35-102
Special Education Census
Special Ed.
04-15
04-15
OE
ADE
4017-i
35-105
Application for Financial Assistance for Public
School Construction
Non-Public School Claim - Special Ed. Voucher
Admin. Services
Special Ed.
04-15
ADS
30-001
Statement of Assurance
All lien. Ed. Programs
04-30
ADS
35-306
Annual Applic. for Appr. of Private Spec. Ed. Schools
Special Ed.
~J1
ADE 41-300, REV 5/77
PACE 7
PAGENO="0255"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/ 77
Form No. of
Number Pages Form Title
As Needed +* ADE 30-001
As Needed * ADE 40-100
05 01 ADE 32-002
05 01 ADE 32-003
05 01 ADE 32-004
05 01 ADE 32-005
05 01 ADE 32-008
05 01 ADE 32-009
05 01 ADE 32-010
05 01 * ADE 41-114
05 01 ADE 32-111
05 01 ADE 32-112
05 01 * ADE 40-002
05 01 * ADE 40-004
As Needed ADE 32-120
Statement of Assur. - Gem. Ed.
Project Appl./Amend. Approval
Application for Funding
Needs, Goals, Objectives
Activities, Evaluation
Calendar of Events
Adult Basic Ed. Application
Citizenship Application
G.E.D. Project Application
Special Projects Fiscal Report (Budget)
Salaries Budget Breakdown
Supplies and Materials Budget Breakdown
Capital Outlay
Estimated Needs - Payment Sched.
Application for Grant for Federal Funds
Dir. of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir. of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir. of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir. of Adult Ed.
Dir, of Adult Ed.
FED. PROGRAMS REPORTS
Appl. and Permanent Record Form (GED)
Class Reporting System
Registration & Reinstatement
Staff Registration
Student Separation
Glass Start Notice
Dir. of Adult Ed.
Dir. of Adult Ed.
Dir. of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
Dir, of Adult Ed.
* Multi-use common forms + One submission covers all Gen. Ed. programs.
PART II
BY RECEIVING OFFICE
ADULT ED.
Mail Completed Form To:
FED. PROGRAM APPLICATION
3
1
1
1
1
1
1
1
1
2
1
1
1
1
1
As Needed
ADE
32-200
1
Monthly 05
ADE
32-209
10
As Needed
ADE
32-210
1
As Needed
ADE
32-211
1
As Needed
ABE
32-212
1
As Needed
ABE
32-225
1
ABE 41-300, REV 5/77
PAGE 8
PAGENO="0256"
PART II
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77.
+ One submission covers all Gen. Ed. programs.
BY RECEIVING OFFICE
BILINGUAL ED.
Form
Due Date
Mo Da
Statement of Assur. - Gen. Ed. Programs
Project Appl./Amend. Cover Sheet
Special Project Fiscal Report (Budget)
Estimated Needs - Payment Schedule
Capital Outlay
Participants and Activities
Personnel Requirements
Parent Involvement
Program Format - Needs Assessment
Program Format - Description
Program Format - Dissemination
Program Format - Calendar of Events
FED. PROGRAMS REPORTS
Bilingual Education Annual Evaluation
Updated Inventory Report
Request to Remove Equipt. from Inventory
Completion Report
Div. of Gen. Ed.
Dir, of Biling. Ed.
Dir. of Biling. Ed.
Dir, of Biling. Ed.
Dir, of Biling. Ed.
Dir, of Biling. Ed.
Dir. of Biling. Ed.
Dir. of Biling. Ed.
Dir, of Biling. Ed.
Dir, of Biling. Ed.
Dir. of Biling. Ed.
Dir, of Biling. Ed.
Dir, of Biling. Ed.
Dir, of Biling. Ed.
Dir. of Biling. Ed.
Dir. of Biling. Ed.
Form No. of
Number Pages Form Title
PROGRAM APPLICATION
Mail Completed Form To:
As
Needed
+~ ADE
30-001
3
06
10
* ADE
40-100
1
06
10
* ADE
41-114
2
06
10
* ADE
40-004
1
06
10
* ADE
40-002
1
06
10
* ADE
31-005
1
06
10
* ADE
30-111
1
06
10
* ADE
31-003
1
06
10
* ADE
30-006
1
06
10
* ADE
30-007
1
06
10
* ADE
30-008
1
06
10
* ADE
30-009
1
07
15
ABE
31-402
2
As
Needed
* ABE
30-004
1
As
09
Needed
01
* ABE
* ABE
30-107
41-114
1
2
ABE 41-300, REV 5/77
PAGE 9
PAGENO="0257"
* Multi-use common forms.
Form
Due Date Form
Mo Da Number
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/Ql/77
+ One submission covers all Gen. Ed. programs.
No. of
Pages Form Title
FED. PROGRAM APPLICATION
Statement of Assur. - Gen. Ed. Programs
Project Appl/Amend. Cover Sheet
Special Project Fiscal Report (Budget)
Estimated Needs - Fund Payment Sched.
Capital Outlay
Participants and Activities
Personnel Requirements
Parent Involvement
Program Format - Needs Assessment
Program Format - Description
Program Format - Dissemination
Program Format - Calendar of Events
Summer Application
FED. PROGRAMS REPORTS
Interim Performance Report
Annual Evaluation Report, Regular
Updated Inventory Report
Request to Remove Equipt. from Inventory
Certificate of Pupil Eligibility
Annual Performance and Evaluation Report,
Summer
Completion Report
Special Project Fiscal Report (Periodic)
Special Project Fiscal Report (Periodic)
Div. of Gen. Ed.
Dir, of Migrant Ed.
Dir. of Migrant Ed.
Dir, of Migrant Ed.
Dir, of Migrant Ed.
Dir, of Migrant Ed.
Dir, of MigrantEd.
Dir, of Migrant Ed.
Dir, of Migrant Ed.
Dir, of Migrant Ed.
Dir, of Migrant Ed.
Dir. of Migrant Ed.
Dir. of Migrant Ed.
Dir, of Migrant Ed.
Dir. of Migrant Ed.
Dir. of Migrant Ed.
Dir. of Migrant Ed.
Dir. of Migrant Ed.
Dir. of Migrant Ed.
Dir, of Migrant Ed.
Dir. of Migrant Ed.
Dir. of Migrant Ed.
0
PART II.
BY RECEIVING OFFICE
MIGRANT ED.
Mail Completed Form To:
As Needed
* ABE 40-100
1
As Needed
* ADE 41-114
2
As Needed
* ABE 40-004
1
As Needed
* ABE 40-002
1
As Needed
* ADE 31-005
1
As Needed
* ABE 30-111
1
As Needed
* ADE 31-003
1
As Needed
* ABE 30-006
1
As Needed
* ADE 30-007
1
As Needed
As Needed
* ABE 30-008
* ABE 30-009
1
1
As Needed
Composite
01 15
ABE 31-205
4
06 15
ABE 31-201
9
As Needed
* ABE 30-004
1
As Needed
* ADE 30-107
1
As Needed
ABE 31-203
2
08 31
ABE 31-206
4
09 01
* ABE 41-114
2
01 15*
05 15
* ABE 41-114
* ABE 41-114
2
2
ABE 41-300, REV 5/77
PAGE 10
PAGENO="0258"
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
* Multi-use common forms
+ One submission covers all Gen. Ed. programs.
Form
Due Date
Mo Da
FED. PROGRAM APPLICATION
Mail Completed Form To:
PART II
Form No. of
Number Pages Form Title
TITLE I
As
Needed
+* ADE
30-001
3
Statement of Assur. - Gen. Ed. Programs
06
01
* ADE
40-100
1
Project Appl./Amend. Cover Sheet
Dir, of Title
I
06
01
* ADE
41-114
2
Special Project Fiscal Report (Budget)
Dir, of Title
I
06
01
* ADE
40-004
1
Estimated Needs - Fund Payment Sched.
Dir, of Title
I
06
01
* ADE
40-002
1
Capital Outlay
Dir, of Title
I
06
01
ADE
31-104
1
Target School Selection
Dir, of Title
of Title
I
I
06
01
* ADE
31-004
1
Nonpublic School Certification
06
01
* ADE
31-012
1
Participants
Dir. of Title
06
01
* ADE
30-111
1
Personnel Requirements
Dir. of
06
01
* ADE
31-003
1
Parent Involvement
Dir, of Title
I
06
01
* ADE
30-006
1
Program Format - Needs Assessment
Dir, of Title
I
06
01
* ADE
30-007
1
Program Format - Description
Dir, of Title
I
06
01
* ADE
30-008
1
Program Format - Dissemination
Dir. of Title
I
06
01
* ADE
30-009
1
Program Format - Calendar of Events
Dir, of Title
I
FED. PROGRAMS REPORTS
06
30
ADE
31-101
14
Evaluation Summary
Dir, of Title
I
05
16
ADE
31-111
1
Intent to Carryover or Release Funds
Dir, of Title
I
As
Needed
* ADE
30-004
1
Updated Inventory Report
Dir, of Title
I
As
Needed
* ADE
30-107
1
Request to Remove Equipt. from Inventory
Dir, of Title
I
As
Needed
ADE
31-110
2
Certification for Partic. in Coop. Project
Dir, of Title
I
09
01
* ADE
41-114
2
Completion Report
Dir.
of Title
I
CJ~
ADE 41-300, REV 5/77
PAGE 11
PAGENO="0259"
ARIZONA DEPARTMENT OF EDUCATION PART II
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
*Nulti_use common forms + One submission covers all Gen. Ed. programs. TITLE I (Cont'd.)
Form
Due Date Form No. of
Mo Da Number Pages Form Title Nail Completed Form To:
02 28 OE 4376 1 Annual Survey of Children in Institu- Dir. of Title I
tions, Operated or Supported by State
Agency, for Neglected or Delinquent
Children or Children in Adult
Correctional Insts., ESEA Title I
02 28 OE 4376-1 2 Annual Survey of Children in Local Dir. of Title I
Insts. for Neglected or Delinquent
Children in Correctional Insts.,
ESEA, Title I
12 01 OE 4560 1 ESEA Title I Comparability Report Dir, of Title I
12 01 OE 4560-1 1 ESEA Title I Comparability Report Dir. of Title I
C~i
ADE 41-300, REV 5/77 PAGE 12
PAGENO="0260"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Gen. Ed. programs.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
Statement of Assur. - Gen. Ed. Programs
Project Appl./Amend. Cover Sheet
Special Project Fiscal Report (Budget)
Estimated Needs - Fund Payment Sched.
Capital Outlay
Participants
Personnel Requirements
Program Format - Needs Assessment
Program Format - Description
Program Format - Dissemination
Program Format - Calendar of Events
Mail Completed Form To:
Div. of Gen. Ed.
Dir, of Title IV B
Dir, of Title IV B
Dir, of Title IV B
Dir, of Title IV B
Dir, of Title IV B
Dir. of Title IV B
Dir. of Title IV B
Dir, of Title IV B
Dir. of Title IV B
Dir, of Title IV B
* Multi-use common forms
PART II
BY RECEIVING OFFICE
TITLE IV B
As Needed
07 01
07 01
07 01
07 01
07 01
07 01
07 01
07 01
07 01
07 01
As Needed
As Needed
06 30
As Needed
As Needed
+* ADE 30-001
* ADE 40-100
* ADE 41-114
* ADE 40-004
* ADE 40-002
* ADE 31-012
* ADE 30-111
* ADE 30-006
* ADE 30-007
* ADE 30-008
* ADE 30-009
* ADE 30-004
* ADE 30-107
* ADE 41-114
ADE 33-003
ADE 33-002
3
1
2
1
1
1
1
1
1
1
1
1
1
2
1
1
C)1
FED. PROGRAMS REPORTS
Updated Inventory Report
Request to Remove Equipt. from Inventory
Completion Report
Maintenance of Effort
Evaluation Summary
Dir.
Dir.
Dir.
Dir.
Dir.
of Title
of Title
of Title
of Title
of Title
IV B
IV B
IV B
IV B
IV B
ADE 41-300, REV 5/77
PAGE 13
PAGENO="0261"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Gen. Ed. programs.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
Statement of Assur. - Gen. Ed. Programs
Project Appl./Amend. Cover Sheet
Special Project Fiscal Report (Budget)
Estimated Needs - Fund Payment Sched.
Capital Outlay
Participants
Personnel Requirements
Program Format - Needs Assessment
Program Format - Description
Program Format - Dissemination
Program Format - Calendar of Events
FED. PROGRAMS REPORTS
PART II
BY RECEIVING OFFICE
TITLE IV C
Mail Completed Form To:
Div. of Gen. Ed.
Dir. of Title IV C
Dir. of Title IV C
Dir. of Title IV C
Dir, of Title IV C
Dir. of Title IV C
Dir, of Title IV C
Dir, of Title IV C
Dir. of Title IV C
Dir, of Title IV C
Dir. of Title IV C
11 01 * ADE 30-005 1
As Needed ADE 33-002 1
09 01 * ALE 41-114 2
Statement of Intent to Partic,
Evaluation Summary
Completion Report
Dir. of Title IV C
Dir. of Title IV C
Dir. of Title IV C
* Multi-use common forms
02
01
* ADE
40-100
1
02
01
* ADE
41-114
2
02
01
* ABE
40-004
1
02
01
* ADE
40-002
1
02
01
* ABE
31-012
1
02
01
* ABE
30-111
1
02
Dl
* ABE
30-006
1
02
01
* ADE
30-007
1
02
01
* ABE
30-008
1
02
01
*
ABE 41-300, REV 5/77
PAGE 14
PAGENO="0262"
PART II
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Gen. Ed. programs.
BY RECEIVING OFFICE
SPECIAL EDUCATION
Form
Due Date
Mo Da
Form No. of
Number Pages Form Title
02 01 ADE 35-001 2
Annual Appl. for Appr. of Special Ed.
Programs
Dir, of Spec. Ed.
STATE PROGRAM REPORTS
As Needed ADE 35-101 4
04 01 ABE 35-302 1
04 01 ABE 35-303 1
10 01 ADE 35-102 1
02 01 ABE 35-102 1
04 15 ABE 35-102 1
Contract with Private Agency
Provisional Certification Supervision
Supervisor's Assessment of Spec. Ed.
Teachers
Special Education Census
Special Education Census
Special Education Census
Dir, of Spec. Ed.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
C~11
3
1
2
1
1
1
1
1
1
1
FED. PROGRAM APPLICATION
Gen. Ed. Div.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
STATE PROGRAM APPLICATION
Completed Form Mail To:
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
+* ADE 30-001
* ABE 40-100
* ADE 41-114
* ADE 40-004
* ABE 40-002
ABE 35-104
* ABE 30-006
* ABE 30-007
* ADE 30-008
* ABE 30-009
Statement of Assur. - Gen. Ed. Programs
Project Appl./Amend. Cover Sheet
Special Project Fiscal Report (Budget)
Estimated Needs - Fund Payment Sched.
Capital Outlay
Project Participants
Program Format - Needs Assessment
Program Format - Description
Program Format - Dissemination
Program Format - Calendar of Events
ADE 41-300, REV 5/77
PAGE 15
PAGENO="0263"
Form
Due Date
Mo Da
05 01
Monthly 15
06 15
09 21
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
04 30
02 15
03 31
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/ 77
Form No. of
Number Pages Form Title
ADE 30-005
ADE 35-105
ADE 35-500
ABE 35-304
ABE 35-103
ABE 35-200
ABE 35-201
ABE 35-301
ABE 35-700
ADE 35-701
ABE 35-702
ABE 35-306
ABE 35-305
ABE 35-305
FED. PROGRAM REPORTS
Dir. of Spec. Ed.
Dir. of Spec. Ed.
Dir. o~ Spec. Ed.
Dir. o~ Spec. Ed.
Dir. ~f Spec. Ed.
Dir. ~bf Spec. Ed.
Dir, of Spec. Ed.
Dir.' of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
Dir, of Spec. Ed.
Dir, of Spec. Ed.
Dir. of Spec. Ed.
Dir, of Spec. Ed.
* Multi-use common forms + One submission covers all Gen. Ed. programs
PART II
BY RECEIVING OFFICE
SPECIAL ED. (Cont'd.)
Mail Completed Form To:
1
1
1
1
2
1
1
1
2
1
1
4
1
1
Statement of Intent to Partic.
Non-Public Sch. Claim for Payment (Voucher)
Application Prior Gifted Program Approval
Name & Address of Provisional Certified
Teachers
Application for Permanent Voucher
Request for Child Find Advocate
Agency Service Census (Child Find)
Approval for Out of State Spec. Ed. School
Appl. for Participation-Evaluation-ABDP
Referral for Evaluation-ADDP
Evaluation Summary Sheet
Annual Application for Approval of
Private Spec. Ed. Sch.
Handicapped (P.L. 89-313)
Handicapped (P.L. 89-313)
ABE 41-300, REV 5/77
PAGE 16
PAGENO="0264"
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
* Multi-use common forms + One submission covers all Gen. Ed. programs. GEN. ED. TECHNICAL ASSISTANCE
SERVICES
Form
Due Date Form No. of
Mo Da Number Pages Form Title
3 Dir, of Driver Ed.
2 Dir, of Driver Ed.
2 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
1 Dir. Technical Serv.
15 Dir. Technical Serv.
PART II
05 09
09 26
09 15
09 15
As Needed
As Needed
As Needed
As Needed
As Needed
10 10
10 01
02 01
10 10
As Needed
ALE 33-401
ALE 33-402
ADE 33-604
ALE 33-605
ADE 33-200
ALE 33-300
ALE 33-700
ALE 33-701
ADE 33-702
ALE 33-703
ADE 33-600
ALE 33-601
ALE 33-602
OE 5354
Mail Completed Form To:
Appl. for Driver Ed. Approval
Free Loan Driver Ed. Car Survey
Commercial Exhibitors Contract Agreement
Booth Reservation Form (Schools)
ALE Film Booking Slip
Right to Read LEA Contract
Consultant Cadre Indentification Form
C.C. Expense Reimbursement Form
C.C. Individual Appraisal
Inservice Training-Metric Systems
Nomination for Teacher of the Year
State Reading Achievement Program
Free Enterprise - List of Materials
Appl. for Grant - Right to Read
ALE 41-300, REV 5/77
PAGE 17
PAGENO="0265"
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
PART II
BY RECEIVING OFFICE
ENTITLEMENT
Form
Due Date
Mo Da
Form No. of
Number Pages Form Title
01 02 ADE 22-100
01 02 +* ALE 22-001
01 02 * ADE 40-100
01 02 ADE 22-006
01 02 * ADE 22-002
01 02 * ADE 22-003
01 02 * ADE 22-004
Dl 02 * ALE 22-005
01 02 * ADE 41-114
01 02 * ALE 22-401
01 02 * ALE 40-002
01 02 * ADE 40-004
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
10 15 * ALE 41-114 2
03 15 * ALE 41-114 2
07 09 * ALE 41-114 2
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Mail Completed Form To:
1
3
1
1
1
1
1
1
2
1
1
1
FED. PROGRAM APPLICATION
ENTITLEMENT
Statement of Assurances
Project Approval Form for Appl./Amend.
District Voc. Ed. Program Summary
Needs Statement, Project Description
Goals and Objectives
Activities
Time Line and Specific Responsibility
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Equipn~nt Capital Outlay
Estimated Needs/Payment Schedule
FED. PROGRAM REPORTS
ALE 41-300, REV 5/77
PAGE 18
PAGENO="0266"
* Multi-use common forms
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
PART II
BY RECEIVING OFFICE
WORK EDUCATION RFP
Mail Completed Form To:
FED. PROGRAM APPLICATION
01 02 ADE 21-201
01 02 +* ADE 22-001
01 02 * ADE 40-100
01 02 * ADE 41-114
01 02 * ADE 22-401
01 02 * ADE 40-004
WORK EDUCATION R.F.P.
Statement of Assurances
Project Approval Form for Appl./Amend.
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Estimated Needs/Payment Schedule
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
FED. PROGRAM REPORTS
10 15 * ADE 41-114 2
03 15 * ADE 41-114 2
Periodic Report
Periodic Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Form No. of
Number Pages Form Title
81
3
1
2
1
1
ADE 41-300, REV 5/77
PAGE 19
PAGENO="0267"
PART II
* Multi-use common forms
* ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
BY RECEIVING OFFICE
AREA VOC. ED. - SECONDARY
Form
Due Date
Mo Da
01 02 ARE 22-107
01 02 +* ADE 22-001
01 02 * ARE 40-100
01 02 * ARE 41-114
01 02 * ARE 22-401
01 02 * ARE 40-004
AREA VOC. ED. CENTERS - INTERDISTRICT
ATTEND, SECONDARY
Statement of Assurance
Project Approval Form, Appl. and Amend.
Special Project Fiscal Report (Budget)
Det4iled Expenditure Report
Estimated Needs/Payment Schedule
FED. PROGRAM APPLICATION
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Area Voc. Ed. - Postsecondary
01 02 ARE 22-118
01 02 +* ARE 22-001
01 02 * ARE 40-100
01 02 * ADE 41-114
01 02 * ARE 22-401
01 02 * ARE 40-004
AREA VOC. ED. CENTERS, INTERDISTRICTS
ATTEND, POSTSECONDARY
Statement of Assurances
Project Approval Form, Appl. and Amend.
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Estimated Needs - Payment Schedule
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Form
Number
No. of
Pages
Form Title
FED. PROGRAM APPLICATION
3
1
2
1
1
Mail Completed Form To:
3
1
2
1
1
ARE 41-300, REV 5/77
PAGE 20
PAGENO="0268"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
PART II
BY RECEIVING OFFICE
CONSUMER AND HOMEMAKING
Mail Completed Form To:
1
3
1
1
1
1
1
1
1
1
10 15 * ADE 41-114 2
03 15 * ADE 41-114 2
07 09 * ADE 41-114 2
Periodic Report
Periodic Report
Completion Report
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
* Multi-use common forms
01 02 ADE 22-203
01 02 +* ADE 22-001
01 02 * APE 40-100
01 02 * APE 22-002
01 02 * APE 22-003
01 02 * APE 22-004
01 02 * APE 22-005
01 02 * APE 41-114
01 02 * APE 22-401
01 02 * APE 40-002
01 02 * AbE 40-004
CONSUMER AND HOMEMAKING PROJECT
Statement of Assurance
Project Approval Form, Appi. and Amend.
Needs Statement - Program Description
Goals and Objectives
Activities
Time Lines and Specific Responsibilities
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Equipment Capital Outlay
Estimated Needs - Payment Schedule
FED. PROGRAM REPORTS
APE 41-300, REV 5/77
PAGE 21
PAGENO="0269"
PART II
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
BY RECEIVING OFFICE
WORK STUDY PROGRAM
Form
Due Date
Mo Da
01 02 ADE 22-205
01 02 +* ADE 22-001
01 02 * ABE 40-100
01 02 * ABE 41-114
01 02 * ABE 22-401
01 02 * ABE 40-004
Div.
Div.
Div.
Div.
Div.
Div.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
1
3
1
2
1
1
Mail Completed Form To:
WORK STUDY PROGRAM VOC. ED.
Statement of Assurances
Project Approval Form, Appl. and Amend.
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Estimated Needs - Payment Schedule
FED. PROGRAM REPORT
As
Needed
ABE 22-128
Div.
of Voc.
Ed.
06
15
ABE 22-129
1
Work-Study Report
Periodic
Div.
of Voc.
Ed.
10
15
* ABE 41-114
2
Report
Periodic
Div.
of Voc.
Ed.
03
15
* ABE 41-114
2
Report
Div.
of Voc.
Ed.
07
09
* ABE 41-114
2
Completion
ADE 41-300, REV 5/77
PAGE 22
PAGENO="0270"
Form No. of
Number Pages
01 02 ADE 22-610
01 02 +* ADE 22-001
01 02 * ADE 22-002
01 02 * ADE 22-003
01 02 * ADE 22-004
01 02 * ADE 22-005
01 02 ADE 40-003
Form Title
PROGRAM APPLICATION
Vocational Education Field Coordinators
Application
Statement of Assurances
Needs Statement and Project Description
Goals and Objectives
Activities
Time Line and Responsibility
Intergovernmental Agreement
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
* Multi-use common forms
Form
Due Date
Mo Da
* ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
PART II
BY RECEIVING OFFICE
FIELD COORDINATORS
Mail Completed Form to:
1
3
1
1
1
1
2
ADE 41-300, REV 5/77
PAGE 23
PAGENO="0271"
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
PART II
BY RECEIVING OFFICE
EDUCATION PROFESSIONS
DEVELOPMENT ACT
Form
Due Date
Mo Da
01 02 ADE 25-312
01 02 +~ ADE 22-001
01 02 * ADE 40-100
01 02 * ADE 22-002
01 02 * ADE 22-003
01 02 * ADE 22-004
01 02 * ADE 22-005
01 02 * ADE 41-114
01 02 * ADE 22-401
01 02 * ADE 40-002
01 02 * ABE 40-004
Professional Development Application
Cover Sheet
Statement of Assurance
Project Approval Form - Appl. and Amend.
Needs Statement - Program Description
Goals and Objectives
Activities
Time Lines and Specific Responsibilities
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Equipment Capital Outlay
Estimated Needs - Payment Schedule
Other Federal Forms as Needed
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
FED. PROGRAM REPORTS
10 15 * ABE 41-114 2
03 15 * ADE 41-114 2
07 09 * ABE 41-114 2
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
Mail Completed Form To:
3
1
1
1
1
1
2
1
1
1
ABE 41-300, REV 5/77
PAGE 24
PAGENO="0272"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
FED. PROGRAM REPORTS
PART II
BY RECEIVING OFFICE
NEW PROGRAMS PLAN
Mail Completed Form To:
10 15 * ABE 41-114
03 15 * ABE 41-114
07 09 * ABE 41-114
2
2
2
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
* Multi-use common forms
Div.
of Voc.
Ed.
01
02
ABE
22-208
1
II)
NEW PROGRAM FOR VOC. ED.
01
02
+*
ABE
22-001
3
II of II)
Statement of
Div.
of Voc.
Ed.
01
02
*
ABE
40-100
1
Project Approval
Div.
of Voc.
Ed.
01
02
*
ABE
22-002
1
Form, Appl. Amend.
Needs Statement -
Div.
of Voc.
Ed.
01
02
*
ABE
22-003
1
Program Description
Goals and
Div.
of Voc.
Ed.
01
02
ABE
22-004
1
Objectives
Activities
Div.
of Voc.
Ed.
01
02
*
ABE
22-005
1
Time Lines and Specific
Div.
of Voc.
Ed.
01
02
*
ABE
41-114
2
Responsibility
Special Project Fiscal
Div.
of Voc.
Ed.
01
02
*
ABE
22-401
1
Report (Budget)
Detailed Expenditure
Div.
of Voc.
Ed.
01
02
*
ABE
40-002
1
Report
Equipment Capital Outlay
Div.
of Voc.
Ed.
01
02
*
ABE
40-004
1
Estimated
Div.
of Voc.
Ed.
ABE 41-300, REV 5/77
PAGE 25
PAGENO="0273"
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
Form
Due Date
Mo Da
01 02 ADE 22-209
01 02 ~* ADE 22-001
01 02 * ADE 40-100
01 02 * ADE 41-114
01 02 * ADE 22-401
01 02 * ADE 40-004
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
FED. PROGRAM REPORTS
10 15 * ADE 41-114 2
03 15 * ADE 41-114 2
07 09 * ADE 41-114 2
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
* Multi-use common forms
PART II
+ One submission covers all Voc. Ed. programs. CONTRACTED
INSTRUCTION PLAN
Form
No. of
Number
Pages
Form
Title
Mail Completed Form To:
1
3
1
2
1
1
FED. PROGRAM APPLICATION
CONTRACTED INSTRUCTION PLAN FOR VOC. ED.
Statement of Assurance
Project Approval Form - Appl. and Amend.
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Estimated Needs - Payment Schedule
ADE 41-300, REV 5/77
PAGE 26
PAGENO="0274"
Form
Due Date
No Da
01 02 ADE
01 02 +*ADE
01 02 *ADE
01 02 *ADE
01 02 *~]~E
01 02 *ADE
01 02 *ADE
01 02 *ADE
01 02 *ADE
01 02 *ADE
01 02 *ADE
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
PROGRAM FOR DISADVANTAGED AND HANDICAPPED
Statement of Assurances
Project Approval Form - Appl. and Amend.
Needs Statement - Program Description
Goals and Objectives
Activities
Time Lines and Specific Responsibility
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Equipment Capital Outlay
Estimated Needs - Payment Schedule
PART II
BY RECEIVING OFFICE
DISADVANTAGED AND HANDICAPPED
Nail Completed Form To:
10 15 * PDE 41-114 2
03 15 * ADE 41-114 2
07 09 * ADE 41-114 2
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
* Multi-use common forms
24-202
22-001
40-100
22-002
22-003
22-004
22-005
41-114
22-401
40-002
40-004
1
3
1
1
1
1
1
2
1
1
1
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
FED. PROGRAM REPORTS
ADE 41-300, REV 5/77
PAGE 27
PAGENO="0275"
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
* Multi-use common forms
÷ One submission covers all Voc. Ed. programs.
CURRICULUM DEVELOPMENT
Form
Due Date
Mo Da
Form No. of
Number Pages Form Title
01 02 ABE 25-312
01 02 +* ABE 22-001
01 02 * ABE 40-100
01 02 * ABE 22-002
01 02 * ABE 22-003
01 02 * ABE 22-004
01 02 * ABE 22-005
01 02 * ABE 41-114
01 02 * ABE 22-401
01 02 * ABE 40-002
01 02 * ABE 40-004
Professional Development Application
Cover Sheet
Statement of Assurance
Project Approval Form - Appl. and Amend.
Needs Statement - Program Description
Goals and Objectives
Activities
Time Lines and Specific Responsibilities
Special Project Fiscal Report (Budget)
Detailed Expenditure Report
Equipment Capital Outlay
Estimated Needs - Payment Schedule
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
FED. PROGRAM REPORTS
10 15 * ABE 41-114 2
03 15 * ABE 41-114 2
07 09 * ABE 41-114 2
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
PART II
FED. PROGRAM APPLICATION
Mail Completed Form To:
3
1
1
1
1
1
2
1
1
1
ABE 41-300, REV 5/77
PAGE 28
PAGENO="0276"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
Form No. of
Number Pages Form Title
FED. PROGRAM APPLICATION
PART II
BY RECEIVING OFFICE
TEACHER EDUCATION
Mail Completed Form To:
01 02 ABE 25-312
01 02 ~* ABE 22-001
01 02 * ABE 40-100
01 02 * ABE 22-002
01 02 * ABE 22-003
01 02 * ABE 22-004
01 02 * ABE 22-005
01 02 * ABE 41-114
01 02 `~ ABE 22-401
01 02 * ABE 40-002
01 02 * ABE 40-004
10 15 * ABE 41-114
03 15 * ABE 41-114
07 09 * ABE 41-114
Professional Development Application
Cover Sheet
Statement of Assurances
Project Approval, Appl./Amend.
Needs Statement - Project Description
Goals and Objectives
Activities
Time Lines and Specific Responsibility
Special Project Fiscal Report (Budget)
Betailed Expenditure Report
Equipment - Capital Outlay
Estimated Needs/Payment Schedule
FED. PROGRAM REPORTS
Periodic Report
Periodic Report
Completion Report
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
* Multi-use common forms
Div. of Voc. Ed.
3
1
1
1
1
1
2
1
1
1
2
2
2
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
of Voc. Ed.
of Voc. Ed.
ofVoc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
of Voc. Ed.
ABE 41-300, REV 5/77
PAGE 29
PAGENO="0277"
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Voc. Ed. programs.
PART II
BY RECEIVING OFFICE
MISC. VOC. ED. REPORTS
Form Title
FED. PROGRAM REPORTS (MISC.)
Vocational Student Enrollment Card
Vocational Class Enrollment
Secondary Former Student Questionnaire
Application for an Approved Arizona Voc. Ed.
Course for Adults
Final Report of Supervised Occupation
Experience
Summer Plan of Teachers on Extended Contracts
Exemplary Project Plan - Letter of Intent
Specialty Field Available
Specialty Field Goals
Personnel Available
Personnel Update
Post Secondary Student Questionnaire
Post Secondary Student Questionnaire
(Follow up)
Adult Former Student Questionnaire
Adult Former Student Questionnaire
(Follow up)
Dir. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Clearinghouse
Clearinghouse
Clearinghouse
Clearinghouse
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Div. of Voc. Ed.
Due
Mo
Form
Date
Da
Form
Number
No. of
Pages
As
As
As
As
Needed
Needed
Needed
Needed
ABE 22-300
ABE 22-301
ABE 22-302
ABE 24-100
1
1
1
1
02
15
ABE 23-102
4
06
01
As
As
As
As
As
As
15
02
Needed
Needed
Needed
Needed
Needed
Needed
ABE 23-103
ABE 22-106
ABE 21-600
ABE 21-601
ABE 21-602
ABE 21-603
ABE 22-303
ABE 22-304
1
1
1
1
1
1
1
1
As
As
Needed
Needed
ABE 22-305
ABE 22-306
1
1
Mail Completed Form To:
ABE 41-300, REV 5/77
PAGE 30
PAGENO="0278"
ARIZONA DEPARTNENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
* Multi-use common forms
+ One submission covers all Gen. Ed. programs.
CAREER ED. RFP
Form
Due Date
Mo Da
Form No. of
Number Pages Form Title
83
1
1
1
1
1
1
1
1
2
1
PROGRAM APPLICATION
Div.
Div.
* Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
Div.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
of Career Ed.
01 15 * ADE 41-114 2
07 15 * ADE 41-114 2
Periodic Report
Periodic Report
Div. of Career Ed.
Div. of Career Ed.
PART II
03 24 ADE 21-001
03 24 * ABE 40-100
03 24 ADE 21-002
03 24 ADE 21-003
03 24 ADE 21-004
03 24 ADE 21-005
03 24 ABE 21-006
03 24 * ADE 22-005
03 24 ABE 21-007
03 24 * ADE 41-114
03 24 ABE 21-008
Mail Completed Form To:
Career Education RFP
Project Appl./Amend. Cover Sheet
Student and LEA Staff Impact
Student and LEA Staff Impact (Cont'd.)
Qualifications of Proposed Staff
Participating School Districts
Goal Priority and Clustering
Time Line and Specific Responsibility
Budget Analysis
Special Projects Budget and Fiscal Report
Resolution
PROGRAM REPORTS
ABE 41-300, REV 5/77
PAGE 31
PAGENO="0279"
Form
Due Date
Mo Da
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
Form No. of
Number Pages Form Title
PART II
BY RECEIVING OFFICE
GENERAL OPERATIONS
ADMINISTRATIVE SERVICES
3
1
1
1
1
3
3
1
1
1
12
11 01 ADE 41-200 3
10 15 ADE 41-204 1
03 15 ADE 41-501 1
State Summary of Private and
Parochial Sch. Survey
Sch. Dist. Employee Report
Pupil Transportation - Route Report
All Cooperative Programs
Dir, of Admin. Services
Dir, of Admin. Services
Dir. of Admin. Services
Dir. of Admin. Services
County School Office
County School Office
County School Office
County School Office
Dir, of Admin. Services
Dir. of Admin. Services
Dir. of Admin. Services
Dir. of Admin. Services
Dir, of Admin. Services
As Needed ADE 4l-006A
As Needed ADE 41-OO6B
08 01 ADE 41-006C
10 01 ADE 41-201
End of Second Reporting
Period ADE 41-301
05 15 ADE 41-107
Register Activation Report
Membership Absence Report
Annual Days in Session
Enrollment/Membership Report
Enrollment/Membership Report
Estimated Membership Info, for State Aid
Data Processing Center
Data Processing Center
Data Processing Center
Data Processing Center
Data Processing Center
Data Processing Center
* Multi-use common forms
As Needed
06 18
As Needed
06 18
As Needed
06 01
06 18
09 05
06 18
07 31
08 15
ADE 40-003
ADE 41-105
ADE 41-106
ADE 41-108
ADE 41-109
* ADE 41-110
* ADE 41-110
* ADE 41-112
* ADE 41-113
ADE 41-502
ADE 41-202
Mail Completed Form To:
STATE FORMS - ALL DISTRICTS
Intergovernmental Agreement
Claim Exemp. from Establishing Kindergatn.
Absence Appr. Request to Adjust ADM
Election for Special Budget Increases
Report of Bond Election Results
Proposed Sch. Dist. Annual Budget
Adopted Sch. Dist. Annual Budget
Budget Summary Worksheet - Revenue
Budget Summary Worksheet - Expenditures
Pupil Transportation - Bus Inventory
Annual Report Summary Worksheets
1
1
1
1
1
1
ADE 41-300, REV 5/77
PAGE 32
PAGENO="0280"
*Multj_use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 5/01/77
+ One submission covers all Ceo. Ed. programs.
PART II
BY RECEIVING OFFICE
GENERAL OPERATIONS
PROGRAMS
Form Title
Johnson O'Malley Program Application
Indian Enrollment (JOM)
JON Eligible Indian Enrollment
and First Eight Months' Average
Membership
Instructional Cost for Out-of-State
Contract Pupils in Peripheral
Dormitory Program FY
Instructional Coats for Out-of-District
Pupils in Peripheral Program
American Indians Enrolled in Public
Schools, Title IV, Part A, P.L. 92-318
Mail Completed Form To:
Dir, of Indian Ed.
Dir, of Indian Ed.
Dir. of Indian Ed.
Dir. of Indian Ed.
Form
Due Date
Mo Da
As Needed
As Needed
As Needed
Form
Number
ADE 31-301
ADE 31-302
AIDE 31-303
No. of
Pages
1
1
1
As Needed ADE 31-305 1
As Needed ADE 31-307 1
10 30 ADE 31-308 1
Dir, of Indian Ed.
Dir, of Indian Ed.
AIDE 41-300, REV 5/77
PAGE 33
PAGENO="0281"
* Multi-use common forms
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
+ One submission covers all Food & Nutrition programs.
PART II
BY RECEIVING OFFICE
GENERAL OPERATIONS
PROGRAMS
Program Application Cover Sheet
New Participants - School lunch,
breakfast and Spec. Milk
School lunch, breakfast and Spec. Milk -
School Sites and Participants
Food Service and Assurances Agreemeilt
Free and Reduced Policy - NSL, B and SM
Simplified Free and Reduced Price
Policy for Non-pricing Programs
Report of USDA Food Loss
Non-Food Assistance Application
Claim for Non-Food Assistance
Reimbursement
Site Information Sheet - Child Care
Food Program
Management Plan for Sponsoring
Organization (Child Care)
Child Care Food Program Participant Info.
Sponsor Info. Summer Food Service
Financial and Admin. Plan - Summer Service
Summer Camp - Donated Foods/Spec. Milk
Reimbursement Claim - Summer Food Program
Advance Funding Claim - Summer Food
Program
Reimbursement Computation
Reimbursement Claim
Oct-March Estimates for Free Lunch
Reimbursement Claim - Child Care Program
Mail Completed Form To:
Dir. of Food & Nutrition
Dir, of Food & Nutrition
Dir. of Food & Nutrition
Dir, of Food & Nutrition
Dir. of Food & Nutrition
Dir, of Food & Nutrition
Dir. of Food & Nutrition
Dir, of Food & Nutrition
Dir, of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir. of Food & Nutrition
Dir, of Food & Nutrition
Dir, of Food & Nutrition
Dir. of Food & Nutrition
Dir, of Food & Nutrition
Form Title
Due Date
Mo Da
Form
Number
No. of
Pages
As Needed
As Needed
ADE 45-101
ADE 45-102
1
1
As Needed
ADE 45-103
1
As Needed
As Needed
As Needed
ADE 45-104
ADE 45-105
ADE 45-106
3
1
1
As Needed
As Needed
As Needed
ADE 45-109
ADE 45-113
ADE 45-114
1
5
1
As Needed
ADE 45-115
1
As Needed
ADE 45-116
3
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
ADE 45-117
ABE 45-119
ADE 45-120
ADE 45-121
ADE 45-122
ADE 45-123
1
2
1
1
1
1
Monthly 10
Monthly 10
Nov-Apr 5
Monthly 10
ADE 45-002
ABE 45-107
ABE 45-108
ADE 45-118
1
1
1
1
ABE 41-300, REV 5/77
PAGE 34
PAGENO="0282"
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
STATE FORMS
Guidelines for Developing Proposal
Abs tracts
Appi. f or Financial Assistance for
Public Sch. Const.
Summary of Sch. Const. Projects for
which Application for funds is made
Appl. for Sch. Assistance in Federally
Affected Areas
Report for Determining Final Payment
Pursuant to Title I of P.L. 81-874
08 20 ADE 41-001
08 20 ADE 41-002
06 20 ADE 41-800
06 06 ADE 41-801
1
1
1
1
Third Grade Reading Test Materials
Fifth Grade Math Test Materials
CUES Progress Report
CUES Periodic Report
PART II
GENERAL OPERATIONS
SPECIAL PROGRAMS
Gen. Op. Special Program
Gen. Op. Special Program
Gen. Op. Special Program
Gen. Op. Special Program
* Multi-use common forms
Form
Due Date
Mo Da
Form
Number
No. of
Pages
As Needed
HEW 6081
3
04 15
OE 4017-1
6
05 15
OE 4017-2
6
01 31
OE 4019
6
09
Form Title
PART II
BY RECEIVING OFFICE
GENERAL OPERATIONS
PROGRAMS
Mail Completed Form To:
State School Board
Gen. Operations Programs
Gen. Operations Programs
Federal Area Office
Gen. Operations Programs
ADE 41-300, REV 5/77
PAGE 35
PAGENO="0283"
ARIZONA DEPARTMENT OF EDUCATION PART II
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77 BY RECEIVING OFFICE
* Multi-use common forms BUSINESS & FINANCE
Form
Due Date Form No. of
Mo Da Number Pages Form Title Mail Completed Form To:
06 20 ADE 46-001 1 State Financial Aid Certificates of Dir, of Bus. & Finance
Educational Convenience Claim
05 30 ADE 46-002 2 State Financial Aid for Educating Pupils Dir, of Bus. & Finance
of Parents Employed by State Institu-
tions Claim
06 20 ABE 46-003 1 State Financial Aid for Students From Dir, of Bus. & Finance
Unorganized Territories Claim
As Needed ABE 41-104 1 Certificate of Educational Convenience Dir, of Bus. & Finance
ADE 41-300, REV 5/77 PAGE 36
PAGENO="0284"
Form No. of
Number Pages
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
STATE FORMS - ALL DISTRICTS
Advice of Encumbrance
Certificate of Excuse for Non-Attendance
Affidavit
Sch. Dist. Travel Expense Claim
Ariz. School District Voucher
Aris. Sch. Dist. Voucher Supplement Expense
Ariz. Sch. Dist. Voucher Suppl Capital
Projects Expense
Ariz. Sch. Dist. Voucher Suppl. (Cont'd)
Expense
Ariz. Sch. Dist. Voucher Suppl. - Payroll
Ariz. Sch. Dist. Voucher Suppi. (Cont'd.)
Payroll
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
County Sch. Supt.
* Multi-use common forms
Form Title
Forts
Due Date
Mo Da
06 30
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
PART II
BY RECEIVING OFFICE
COUNTY SCHOOL SUPT.
Mail Completed Form To:
ADE 40-001
ADE 41-130
ABE 41-207
ADE 41-510
ABE 40-101
ABE 40-102
ABE 40-103
ABE 40-104
ABE 40-105
ABE 40-106
1
1
1
1
1
1
1
1
1
1
ABE 41-300, REV 5/77
PAGE 37
PAGENO="0285"
PART III
Form Number Pages
ARIZONA DEPARTMENT OF EDUCATION
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
STATE FORMS - ALL DISTRICTS
ADE 23-100
ADE 30-001, PA 3
ADE 40-111
ABE 40-112
ABE 41-006
ADE 41-115
ABE 41-116
ABE 41-122
ABE 41-123
ABE 41-124
ABE 41-125
ABE 41-126
ABE 41-127
ABE 41-128
ABE 41-129
ABE 41-203
ABE 41-206
ADE 41-210
ABE 41-211
ABE 41-500
Final Report of Student Supervised Occupational
Experiences
Private Non-Profit Schools Statement of
Assurances to Public Sch.
High School Attendance Record Card
High School Attendance Record Card (Cont'd.)
Arizona Public School Register
Election Notice
Certificate of Election of School Trustee
Certificate of High School Record
Official Notice of Pupil Withdrawal
Tally Sheet-Poll List
Budget Ledger
Fund Ledger
Revenue Ledger
Cash Control Ledger
Warrant Ledger
Certificate of Appointment - School Trustee
Certificate of Election of President and Clerk
Probationary Teacher's Contract
Continuing Teacher Contract
Bus Driver's Contract
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
District Use Only
Title
DO NOT RETURN TO ADE
1
I
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
ADE 41-300, REV 5/77
PAGE 38
PAGENO="0286"
ARIZONA DEPARTMENT OF EDUCATION
Part IV
Voluntary Voluntary
NOTE: The review committees were not originally charged to review voluntary forms for format or content. The
review concept will be expanded to include this class of forms.
Voluntary Forms: Are those forms that are not mandated by law or board policy but are consistent to educational
inquiry and administrative practices initiated by educational institutions, the Department,
and professional educators, such as: research projects, questionnaires, cost analysis,
legislative inquiry, etc.
Example ADE 41-505: Some school districts desire to participate in a state contract price agreement with the
Division of Finance (State Statute 41-731) in the purchase of new buses. The ADE in this
case becomes a vehicle of service for the school district and the Department of Finance.
VOLUNTARY FORMS
Voluntary
ANNUAL DATA ACQUISITION PLAN
From
Due Date
Mo Da
As Needed
As Needed
As Needed
As Needed
10 01
02 01
10 10
09 15
Form No. of
Number Pages
ADE 21-600
ADE 21-601
ADE 21-602
ALE 21-603
ALE 33-600
ADE 33-601
ADE 33-602
ADE 33-604
Form Title
Mail Completed Form To:
1
Clearing House
1
Specialty
Fields Closed
Clearing House
1
Personnel
Available
Clearing House
1
Personnel
Update
Clearing House
1
Nomination
for Teacher of the
Year
Div. of Gen. Ed.
1
Reading Achievement
Program
Div. of Gen. Ed.
Compilation
of Free Enterprise
Data
Div. of Gen. Ed.
ADE 41-300, REV 5/77
PAGE 39
PAGENO="0287"
ARIZONA DEPARTMENT OF EDUCATION
Part IV
Voluntary VOLUNTARY FORMS (Cont'd.) Voluntary
ANNUAL DATA ACQUISITION PLAN
Form
Form Title
Nail Completed
Form To:
Due
Date
Number
Pages
As
Needed
ADE 33-700
1
Consultant Cadre Indentification Form
Consultant Cadre Reimbursement Form
Div. of Gen.
Div. of Gen.
Ed.
Ed.
As
Needed
ADE 33-701
1
Consultant Cadre Service Individual
Div. of Gen.
Ed.
As
Needed
ADE 33-702
1
1
Appraisal
Appl. Metric Inservice Training
Div. of Gen.
Ed.
10
10
ADE 33-703
1
Az R. to R. Support of National R. to
R.
Div. of Gen.
Ed.
As
Needed
ADE 33-300
2
Free Loan Driver Ed. Car Survey
Div. of Gen.
Ed.
94
09
ADE 33-402
for Child Find Advocate
Div. of Spec.
Ed.
As
Needed
ADE 35-200
1
Request
Service Census
Div. of Spec. Ed.
CA~
ADE 41-300, REV 5/77
PAGE 40
PAGENO="0288"
ARIZONA DEPARTMENT OF EDUCATiON
ANNUAL DATA ACQUISITION PLAN
AS OF 05/01/77
Form Title
Conference Registration
Housing Form
Registration for Individual Skill and
Leadership Events
Consent Form
Suggested Judges for Competitive Events
Speakers Bureau
Nomination for Adult Recognition
Scholarship Application
State Officer Candidate Nomination Form
Report on State Officer's Chapter Visit
Mail Completed Form To:
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Career and Voc. Ed.
Student Clubs VOLUNTARY Student Clubs
VOLUNTARY
Form
Due Date
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
As Needed
Form
Number
ADE 22-251
AJ)E 22-252
ADE 22-253
ADE 22-254
ADE 22-255
ADE 22-256
ADE 22-257
ADE 22-258
ADE 22-259
ADE 22-260
Part V
Student Clubs
No. of
Pages
2
2
2
1
1
1
1
3
2
1
ABE 41-300, REV 5/77
PAGE 41
PAGENO="0289"
285
ARIZONA DEPARTMENT OF EDUCATION
DATA ACQUISITION FORM REVIEW
COVER SHEET AND ADVANCE PRINTING NOTICE
SEND TO: DATE: _______________
ORIGINAL COPY Received
TO
DATA ACQUISITION UNIT ___________________
DAAC Review
1. Title
2. Form No. Assigned ____________________________ 3. Due Date From User ________________
4. Originator
Name of Unit
5. Signature of Approval ____________________________________________________________________
Deputy Associate or Authorized Agent
6. Purpose:
REQUIRED - by Statute, Public Law, or Rules and Regulations
REQUIRED - by Statute for Other Agencies
I NECESSARY - Deemed Logically Unavoidable by ADE to Function as an Agency
VOLUNTARY - Desirable but Response is at Option of User
7. Status:
* I I Correction of Current Form I I One-Time Survey
I New Form I I Annual Review
8. DUPLICATING REQUIREMENTS: Obtain printing priority from proper authority if delivery
expectation is less than 10 days after review approval.
Quantity ____________________ This it a Reorder [ ] Date Desired _________________________
Special Paper _______________________________________ Color _________________________
Composer Typing I I NCR Paper I I To Be Contracted Outside
REVIEW COMMITTEES ACTION
IRAC DAAC CABINET
Date _______________ ________________________ _________________________
Date _______________ _________________________
Date _________________
I Approved [ I Approved I I Approved
ADE 141-300, REV 9/76 PAGE 1 OF 1
91-860 0- 77 --19
PAGENO="0290"
286
DATA ACQUISITION FORM REVIEW
COVER SHEET AND PRINTING APPROVAL
SEND TO: DUE DATE: As Needed
Data Acquisition Unit
School Finance and Stat. Section
Administrative Services Division
1. Originator
Name of Unit
2. Signature of Approval _______________________________________________________
Unit Deputy Associate
3. Form No. Assigned ___________________ 4. Due Date of Form __________________
5. Title
6. Estimated No. of Forms Needed _______ 7. Date Required from Printing ______
8. Complete Form or Part of Packet (Check One)
9. Purpose of Data Collected Federal Program Application
Federal Program Report
D State Program Application
State Program Report
~ State Law Requirement of All Districts
Other ______________________________________
10. Status
No Change from Previous Form
Revision of Previous Form
New Form
Survey (One-Time)
CABINET
ABE 141-300, REV 4/76
PAGE 1 OF 1
PAGENO="0291"
287
Ma 1977 ARIZONA
DATE ISSUED ~` DEPARTMENT OF EDUCATION
SUPERSEDES May 1976 POLICI4 &~PROCEDtARE
NO. GE-i
{~EET 1 Oc 5
SUBJECT:
DATA ACQUISITION FORMS APPROVAL
FILING INSTRUCTIONS
& Pr~dsi~ Manual)
As item GE-i
I. POLICY
All data collection instruments, state or federal, distributed by or
under the sponsorship of Arizona Department of Education staff members
to personnel, parties, or organizations outside the Arizona Department
of Education must be submitted for review and authorization, prior to
distribution, in accordance with this Policy and Procedure. This in-
cludes all distributions requesting data from public schools, nonprofit
private schools, private agencies, community colleges, educational units
of colleges or universities, student organizations and other state
agencies.
II. DATA COLLECTION INSTRUMENT DEFINED
A data collection instrument is defined as any form, application, memo-
randa, or other device which requests the above parties to collect and
report data to the Arizona Department of Education. The following types
of instruments are subject to the policy and procedure covered in this
document:
A. Recurring reports - reports due more frequently than once yearly.
B. One-time survey report - an instrument which has been prepared to
collect data one time only and which is not intended to be used
on a recurring basis.
C. Emergency report - an instrument, which due to time constraints, can
not be processed through normal review and authorization processes
and is approved in a Quick Response Review Committee.
D. Occasional reports - reports for which no due date has been estab-
lished. These reports are either filed as needed by the districts
or are filed at a date determined by the appropriation and release
of Federal funds.
III. REVIEW AND AUTHORIZATION DEFINED
A. Review entails the consideration for approval/disapproval of data
collection activities and the technical analysis of format, content,
and other special techniques or methods used in conjunction with
instruments in order to gather, process, or analyze data.
B. Authorization Is the determination that sufficient justification
exists in law, regulation, or program needs to permit the distribu-
tion of a data collection instrument to the intended respondents.
PAGENO="0292"
288
DATE SSUED
SUPERSEDES
I ARIZONA
May 1977 DEPARTMENT OF EDUCATION
May 1976 1 POLIC4 &j PROCEDURE
NO GE-i
SHEET 2 OF 5
SUBJECT:
DATA ACQUISITION FORNS APPROVAL
(Po~es& PmcedssesMassual)
Sechos GENERAL
As tees GE1
IV. REVIEW AND AUTHORIZATION SCHEDULING
Review and authorization oust be obtained:
A. When new data collection instruments are developed. This would
include one-time surveys and emergency instruments, each with
an expiration date of six months.
B. When revising existing instruments to add or delete data or to
make changes in format.
C. When eliminating or consolidating one or more data collection
instruments.
U. Annually - Instruments previously approved and currently in use
must be re-authorized annually prior to distribution in each
fiscal year. Authorization will not exceed a twelve-month period.
V. PROCEDURE
Performed By Action
A. Originator 1. Prepares draft of new or revised
(Person initiating or data collection instrument.
responsible for the use
of the data collecting 2. Prepares, in triplicate, Porn No.
R instrument). ADE-l4l-300 Data Acquisition Porn
Review (copy attached).
R 3. Obtains signature of Associate
Superintendent or authorized agent.
R B. Associate Superintendent 1. Approves or rejects.
R C. Originator 1. Submits three copies of Form
ADE-141-300 and 10 copies of data
collection instrument to the Data
Collection Forms Clearance Unit.
R D. Data Collection Unit 1. Forwards No. 3 copy of Porn
ADE-14l-300 to Duplicating Services
as advance info copy. Retains
No. 1 and 2 copies.
R 2. May make recommendations for the
consolidation of data collection
instruments to minimize duplication.
R = Revised --
PAGENO="0293"
3. May make recommendations to simplify
reporting requirements and reporting
formats.
4. Provides technical assistance in the
development and design of data col-
lection instruments and activities.
5. Schedules reviews with internal and
external review committees. The
internal review committee entitled
the Information Review Administrative
Committee (IRAC) is a standing com-
mittee of four, one member selected
by each of the Associate Superin-
tendents. If the instrument is in-
tended for data collection from
public schools and/or nonprofit pri-
vate schools, an external review is
scheduled with the Data Acquisition
Advisory Committee (DAAC), a standing
committee of 15 selected from County
and School District Superintendents
and Business Managers. If the data
collection instrunent requests data
from community colleges, educational
units of universities, private agen-
cies, student organizations, other
state agencies, or any group other
than public and nonprofit private
schools, the external review is
scheduled with a Functional Review
Committee selected from the re-
spondent groups.
1. Reviews instrument.
2. Delegates Data Collection Forms
Clearance Unit to convey one of
the following actions:
a. Approve instrument as submitted
and pass on to the appropriate
external review committee.
b. Approve with additions, re-
visions, and/or deletions.
c. Reject.
289
ARIZONA
DATE ISSUED May l97~J DEPARTMENT OF EDUCATION
SOPEESEDE5 May 1976 ~POLIC1f &0t)1t1~
SUBJECT:
~O GE-l
5eEET3 OF
FILING INSTRUCTIONS
DATA ACQUISITION FORMS APPROVAL
.-..- ..~ -...~ .-..-.. ~
StO~GENERAL
As item GE-l
~
R
E. Information Review Ad-
ministration Committee
(IPAC)
R = Revised
PAGENO="0294"
ARIZONA
DATE ISSUED May 1977 I DEPARTMENT OF EDUCATION
S~9ERS~DES May 1976 POLICI4 &~ PROCEDURE
SUBJECT:
DATA ACQUISITION FORMS APPROVAL
FILING INSTRUCTIONS
Pstcot & Procedures Manual)
Section GENERAL
As tern GE1
1. Informs Originator if IRAC rejects
or approves.
2. Negotiates with Originator to de-
termine if IRAC recommendations
for additions, revisions, and/or
deletions are acceptable. If ac-
ceptable, the review process con-
tinues with the external review
committee.
3. If rejection or recommendations are
not acceptable to the Originator,
he/she may request review by the
Superintendent's Cabinet.
Reviews instrument and IRAC comments.
Delegates Data Collection Forms
Clearance Unit to convey one of the
following actions:
a. Approve instrument as submitted.
b. Approve with additions, re-
visions, and/or deletions.
c. Reject.
1. May resubmit to IRAC if external
review actions differ significantly.
2. Informs Originator if external re-
view committee rejects or approves
(also any further IRAC actions).
3. Negotiates with Originator to de-
termine if external review recom-
mendations for additions, revisions,
and/or deletions are acceptable.
4. If rejection or external review
recommendations are not acceptable
to the Originator, he/she may re-
quest review by the Superintendent's
Cabinet.
290
so. GE-i
SHEET 4 O~ 5
R
F. Data Collection Unit
G. External Review Committee 1.
(Data Acquisition Advisory
Committee DAAC, or Func- 2.
tional Advisory Committee).
H. Data Collection Unit
R = Revised
PAGENO="0295"
291
taTE issuts M~Y 1977 DEPARTMENT OF EDUCATION so. GE-i
~ ?OLICI4 &PROCEDURE SHEET 5 OF 5
~
DATA ACQUISITION FORMS APPROVAL GENERAL
5. Prepares and distributes minutes of
all review meetings (IRAC, DAAC,
etc.) to all Originators.
6. Arranges for preparation of approved
master copy.
7. Prepares Copy Request Form
ADE-l43-500 or Duplicating Services
Request Form ADE-DUP-4 and forwards
to Print Shop with master copy.
(no Advance Printing Approval is
required).
8. Stamps No. 2 copy of Form ADE-14l-301
R when forms are printed and in stock
and forwards No. 2 copy to Originato
Retains No. 1 original on file.
VI. NOTATIONS
A. IRAC and DAAC committees usually meet the last week of the month.
B. The review and approval procedure usually takes 40 days.
C. Quick Response Review Committees, IRAC and DAAC, (3 in each group)
are established for emergency approvals, where necessary.
0. Printed forms are stored by Duplicating Services and may be ordered
by form number.
E. If Print Shop service is required for collating forms drawn from
inventory, allow at least 5 days for delivery.
F. Adequate inventories can be maintained if Originator allows suf-
ficient lead time in the planning process.
C. No Advance Printing Approval is required for data acquisition forms
processed under this procedure. Originator need not be involved in
preparing master copy, Copy Request, or Duplicating Services
Request.
R = Revised
PAGENO="0296"
292
ARIZONA DEPARTMENT OF EDUCATION
DATA ACQUISITION FORM REVIEW
COVER SHEET AND ADVANCE PRINTING NOTICE
SEND TO: DATE: _______________
Received
DAAC Review
1. Title
2. Form No. Assigned _____________________________ 3. Due Date From User
4. Originator
Name of Unit
5. Signature of Approval ____________________________________________________________________
Associate or Authorized Agent
6. Purpose:
I REQUIRED - by Statute, Public Law, or Rules and Regulations
REQUIRED - by Statute for Other Agencies
I NECESSARY - Deemed Logically Unavoidable by ADE to Function as an Agency
I VOLUNTARY - Desirable but Response is at Option of User
7. Status:
I I Correction of Current Form I I One-Time Survey
I I New Form [ Annual Review
8. DUPLICATING REQUIREMENTS: Obtain printing priority from proper authority if delivery
expectation is less than 10 days after review approval.
Quantity ____________________ This is a Reorder [ ] Date Desired _________________________
Special Paper ________________________________________ Color _________________________
Composer Typing I I NCR Paper I I To Be Contracted Outside I I
PAGENO="0297"
293
STATEMENT OF MRS. CAROLYN WARNER, SUPERINTENDENT,
ARIZONA STATE DEPARTMENT OF EDUCATION
Mrs. WARNER. Mr. Chairman, thank you for the opportunity of
being here today. I think it is appropriate that this be the day that
we have an opportunity to share some of our concerns in this area.
Mr. Horton indicated that we are examining what we have
wrought, and I think that the first public telegraph message sent
was sent in about 1844, and the words were, "What hath God
wrought," so perhaps it is a day to question what Congress and the
Administration has indeed done to public education.
I thank you for the opportunity, and I would like to encourage
you by saying Federal paperwork can be cut and at the same time
without loss of information or knowledge that is needed upon which
decisions must be based. The reason I say this is it is not a matter of
fantasy, nor is it a fond hope. It is indeed a fact, and we have done
it in the State of Arizona.
In May of 1975, we were at that time working on attempting to
look at the problem with a very simple directive from the Superin-
tendent of Public Instruction that we were going to cut paperwork
by 50 percent. Now that is a ridiculous statement, and the figure
plucked directly from the air and yet amazingly enough when
administration is committed to a concept, it is astonishing what
staff can do. Commitment, I must say, is key, is absolutely essential,
and if it is, the job can be done expeditiously and in truth beyond
expectation.
Our staff were able to work in such an effective and cooperative
fashion that we were able to reduce Federal paperwork in the State
of Arizona by almost 60 percent. So it is neither a fantasy, nor is it
a fond hope. It can be done with the will and with the commitment.
As you know, the Superintendent of Public Instruction in our
state is a partisan office, elected by the people at large, and, at the
time I decided to run, I made a pledge, a campaign promise, if you
will, and that was that we would reduce paperwork, for the simple
reason that education in the State of Arizona, as Mr. Horton has
indicated is true nationwide, was being strangled by excessive
paperwork. The concept of public education in our state was being
thwarted by the amount of paperwork that teachers, administra-
tors, clerical help were required to do.
So it became a serious concern of mine to establish first the goal
of education, or reestablish in our state, that being to help children
achieve their optimum capabilities. They were being diverted from
this because they had to spend, the administration teaching staff,
an undue amount of time filling out forms.
I think perhaps today we are discussing a broader question, and
the broader question in truth is the serious question. The broader
question is education has been the can-do institution in our country.
It has been the one institution to which we turn at any given point
in time to accomplish major national objectives. It has been so
successful, so unbelievably successful, in America, that it has been
automatically assumed that it is then the institution that can
accomplish all things and virtually every burden is placed upon
education.
PAGENO="0298"
294
As a result of this, I think education is terminally ill. I do not
believe it can long exist and provide for this nation what it expects
until and unless the effects of data reduction are seriously
considered.
Once we discovered that education was the can-do institution,
virtually every major change in society has been assigned to educa-
tion for eventual accomplishment.
I would like to share with you today what we are attempting to
do in the field of education, and I have only a very partial itemiza-
tion. We are attempting to provide some of our students with
consumer protection education. The integration institution of Amer-
ica is the public schools. We provide programs in adult and continu-
ing education, community education, provide disadvantaged, gifted,
handicapped education. We provide some of our young people with
bilingual education, hot lunch, hot breakfast. Education is the
largest single transportation agency on earth.
How about environmental and energy conservation education?
That is the big new thing. We are expected to provide education in
law, agriculture, business, driver and safety education, consumer,
homemaking, distributive, cooperative, physical education. We pro-
vide some with health education, child abuse, correction education,
international education, Indian education, vocational and career
education, and, incidentally, we are expected to teach our young
people to read, to write, and compute. I say incidentally because it
is almost incidental that we get to the point that we can address the
primary responsibility.
I have a second agenda that I believe we have largely ignored in
the educational system in this country because we have supplanted
so many overlay programs, and that is that there certainly is some
responsibility, at least in my view, for public schools in the U.S. to
address another 3-R's. That is rights, responsibilities, and respect.
We have emphasized certain areas, but we have de-emphasized
other areas, and until and unless we begin to provide our young
people with the opportunity to understand that they must respect
the rights of others as well as insist upon their own, that it is a 2-
way street, until and unless we aid our children in understanding
that we do indeed have a responsibility to them, that again is a 2-
flow system, in and out, they have a responsibility to themselves
and to others. And until and unless we help them to understand
that they are deserving of respect as living, functioning human
beings, but, in addition to that, that, too, flows both ways, and they
must indeed respect others and their rights and their
responsibilities.
So I will attempt to suggest to you that in our small state, and it
is a small state, 2 million people, a microcosm, if you will, repre-
senting about one percent of the population of our nation, we have
about 540,000 students. The taxpayer in Arizona provides approxi-
mately 92 percent of the necessary funding from state and local
resources.
For proper accountability in our state, and I come from the world
of business, I am interested in accountability, to assure appropriate
expenditure of funds, we are required also, as a state, to collect
data. Sixteen percent of the total pages required in Arizona collect
PAGENO="0299"
295
the information necessary to determine whether educational funds
in our state are being properly expended. Sixteen percent.
Arizona utilized in the learning process some 7-8 percent of
taxpayer money from the Federal government. Federal data re-
quirement represents 84 percent of the total pages required. We
have an inverse relationship of absolutely astronomical proportions.
In order to justify seven or eight percent of the money that is spent
in our state for education, it generates 84 percent of the total pages
of data required. I think this in and of itself is an absurdity of the
utmost proportion.
So we find ourselves in the situation that is difficult for educators
to understand. Where do all the data requests come from? Some
from the Office of Civil Rights, the famous 101 and 102 forms; the
Department of Interior; from the Office of Safety and Health
Administration; from the Office of Education; Department of Agri-
culture; Bureau of Indian Affairs, and a variety of others.
Let me suggest, my friends, that it is apparent to me, and I am
sure obvious to you, that these people are not talking to one
another. They simply are not communicating. Either they are not
interested or the channels of communication are closed.
Essentially the data that is being collected is identical, and yet it
is coming from such a variety of sources who apparently are not
sharing in any way that it continues to proliferate with each and
every new program, new national incentive, and continues to prolif-
erate at an absolutely astonishing rate.
We in Arizona were able to reduce Federal paperwork. We did it
because we tried and because we were committed to it, and the way
we did it very simply was to go to the victim, to go to the person
who had to fill out the forms.
We committed our Department of Education to the concept of
service which I believe is what government is all about. We said to
them, "How can we help you operate more effectively and get back
to your primary objective, which is educating young people?" We
asked them to come in to the Department of Education and to assist
us in order to help them make their job easier. No one said no.
Everyone said yes. They committed their time and their energies to
assisting in a fashion that is exemplary and at no cost to the
Arizona Department of Education.
They worked with our program people to reduce paperwork, to
reduce redundancy, to eliminate duplication and the most simple
and obvious thing of all, to build a calendar for data collection that
makes sense, that any normal business person or administrative
officer would implement in their agency or in their business.
We feel that education in the State of Arizona is perhaps more
healthy than it is in some other places, but we feel that education is
constantly threatened by the overprotective help of the Federal
government.
I have no quarrel with the programs. We indeed are making
progress. I have a great deal of difficulty understanding the process
or the lack of process.
In our state we need the Federal funds. We have a great need for
disadvantaged in the State of Arizona. Arizona has many American
Indian students, many Mexican-American students who have lan-
PAGENO="0300"
296
guage difficulties. Arizona has its share of handicapped students,
and we want to serve each and every student. We want to provide
them with that opportunity that Thomas Jefferson spoke of, to
enable ordinary citizens to become extraordinary people. We think
it can happen, but we want to do that very thing.
We do not want to destroy education in our state by taking
teacher time and administrative time to fill out endless forms for
whatever eventual purpose some of us have yet to fathom if there is
any purpose. We want to spend the time with the child in the
classroom and help that child succeed. We want to help each child
individually, and we are being precluded from that opportunity.
I feel that Federal paperwork is taking the opportunity of Amer-
ica, the great expectations we have for education, away from the
child. Our energies are being diverted into filling cabinets with
massive piles of paper that will be punched into computer cards to
be stored somewhere, maybe to be retrieved, maybe to be evaluated,
maybe to be used and maybe not. That child, at the same time that
we are there to serve and for whom we collect the data, is not being
served. It is a dichotomy of rather immense proportions.
I believe that the continued proliferation of paperwork is
counterproductive to the overall goal of equal educational opportu-
nity for every American child. I suggest several things.
We have developed a device, process, a way, a plan, to reduce
paperwork. We have encouraged all of the people in education in
the State of Arizona to share with us their concerns. I welcome and
encourage you, if you have an interest, to utilize the plan.
We have been requested to submit our plan to over 300 individual
agencies to share. Every state in the nation has requested a copy of
our data reduction plan, and today, interestingly enough, over 670
businesses have requested a copy of our data reduction plan.
May I suggest that, in addition to the plan, for your serious
consideration should you consider requiring that every Federal
agency who sends a series of forms or requests data, provide a check
to pay for the doing of the work along with the request, we would
find some interesting happenings instantly. This would enble the
local district to continue to do its work in education. That is, after
all, why it is there, to work with the child, for the child, rather than
collect sometimes redundant, sometimes unnecessary, and much of
the time unused, data.
Should Congress consider this, I would sugggest, if possible I
would guarantee, that you would see a sudden, a drastic reduction
in the amount of data requested. I would further suggest that you
would get more nearly to the truth of what is truly needed, of what
was going to be used. If the Federal agency had to divide its own
operating budget into a portion of data collection and send a portion
of its budget to the victim, it would begin to make a great deal of
sense to them immediately to examine and prioritize their requests.
I submit what we are talking about today is much more impor-
tant than just the simple reduètion of paperwork. I suggest what we
are discussing here today in committee is very simply whether or
not we are going to be able to allow education to survive, whether it
is indeed going to be, as the endangered species, allowed to continue
to function.
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297
The institution of education is either important to this country,
or it isn't. Is the education of the child, a small child, single child, in
a classroom going to be given sufficient importance as compared to
collecting more and more Federal paperwork?
We must enable educators to educate children in the basic skills
of reading, writing, arithmetic, in the areas of career and vocational
education for that world of work, and reinstitute into education the
3-R's of rights, respect and responsibility.
If the Congress of the U.S. wants. these things truly to happen,
then we must, you must, keep education alive, reduce the
strangling, possibly terminal effect of continually increasing Feder-
al paperwork.
I see here a commitment to that concept. We feel that we have
successfully implemented a component of that, and yet we are
working in opposition in many situations to Federal agencies,
though finally we have received their agreement that we may
reduce their forms and collect for them only the necessary data.
I want to commend you for being responsible and for being
responsive. Many people feel that government is not. I find indeed
your main thrust is that of responsive and responsible leadership.
Again, thank you for the opportunity, and I would be happy to
share with you any of the accumulated experience we as a single
state have experienced in our effort. Thank you very much.
Mr. LE FANTE (presiding). Thank you, Mrs. Warner. I think your
testimony has been most helpful. I am sure every member of the
committee will review the testimony with intense interest, and I
hope that perhaps we can come up with something a lot sooner than
most people expect us to.
I would like to ask you one question. On page 3 of your testimony,
at the very top of the page you* state, "Arizona is utilizing in the
learning process some 7-8 percent of the taxpayer money from the
Federal government. The Federal data requirement is massive, 84
percent of the total pages required."
Would you give me some breakdown of how you define 84 percent
of the total pages required? I don't think I have a complete under-
standing of that.
Mrs. WARNER. Let me share with you this: We first talked about
the dollars, approximately 40 million Federal dollars, approximate-
ly 400 million in state dollars, to assist the educational process in
our state, and of the numbers of pages, numbers of reports, num-
bers of data items requested in order to substantiate, receive or
provide information relative to Federal programs, that total consti-
tutes 84 percent of the total amount of data requests that are
generated for education in our state.
Mr. LE FANTE. That is fantastic.
Mrs. WARNER. Fantastic.
Mr. LE FANTE. It is almost unbelievable.
Mrs. WARNER. Virtually unbelievable, but carefully documented.
May I suggest that those small school districts in our state who
say to me, "I cannot afford the luxury of Federal help" are simply
stating a reality. They haven't the staff; they haven't the adminis-
trative time; they feel they can afford to take no more teacher time
away from educating the children to comply with the request. It is
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298
such an onerous burden on the small school district, difficult for the
larger ones, but I am finding more and more small school district
administrators saying, "I cannot afford the luxury of Federal
assistance."
Mr. LE FANTE. I think if we take a good look all around us, you
can apply that to almost anything the government is involved with,
not only education. We were holding hearings yesterday and again
this morning in the Small Business Committee on the effect of all
the regulations that we impose on small business, and they are
screaming that we are driving them out of business.
Here just 24 hours later, I am hearing educators and administra-
tors tell us we are driying the school system out of business, too.
Mrs. WARNER. May I suggest, sir, that for some 25 years my
husband and I have been involved in our own small business,
thanks to the Small Business Administration and a little helping
hand.
It has finally, though I am no longer involved in the business,
reached the point that small businesses, as you have mentioned
earlier in your hearings yesterday, are in serious jeopardy; whether
or not they can continue to exist is something that I indeed
question, as you do. We are a small concern; we do about $2 million
worth of retail business a year.
The staff that we have had to employ in order to comply with the
requirements is absolutely astronomical. It raises the overhead to
the point that profit was severely jeopardized. No profit, we don't
exist.
Mr. LE FANTE. I have no further questions.
Mr. Kildee?
Mr. KILDEE. Again, no questions, just to state that I was in charge
of the Department of Education budget while serving in the Michi-
gan Legislature, and I would hope you would share your ideas with
our Superintendent.
Mrs. WARNER. You have an excellent Superintendent.
Mr. KILDEE. Yes, John Porter is an excellent superintendent.
Mrs. WARNER. He is indeed.
Mr. KILDEE. Thank you very much.
Mrs. WARNER. Thank you.
Mr. LE FAism~. Counsel, do you have questions?
Mr. CROSS. Thank you. I wonder if you could take a program like
title I and just briefly tell us how you went about doing this? I have
a hard time reading your statement and looking at the materials
and really seeing or visualizing exactly the process involved; so if
you could take a moment.
Mrs. WARNER. Thank you, sir. Title I, or any other specific
program, the Department of Agriculture Food and Nutrition Pro-
gram, each and every program was examined individually with staff
that are responsible for the administrative functioning of that
entire program. We created two committees, one in-house and the
other we lovingly call our out-house committee. Those are people
from outside; those are the victims. They sit together. We have
given an enormous amount of responsibility to the out-committee
and have said to them that though your final result will not be
necessarily applied, it will in 99 percent of the cases be the way we
continue to operate.
PAGENO="0303"
299
Each and every data request is placed before the panel for each
program, title I, for example. Each and every one of their forms are
submitted to our advisory committee.
That committee then examines the forms and goes through item
by item, line by line, to look for redundancy, to look for information
that is repeatedly on one form and another, and another, and they
eliminate them by simply blue-lining, as an editor does, those that
are redundant.
We have been able to reduce the number of forms by over 50
percent, the number of data items that are repetitive by over 60
percent, and the number of pages by a bit over 50 percent.
The same is true in all other programs, be it title I or any other.
Mr. CROSS. In most cases you are using a Federal form?
Mrs. WARNER. In all cases.
Mr. CROSS. What has been your relationship to the program
offices in OE in terms of your attempts to cut down on what they
have requested? Also, some items you say you are cutting out
because they have been asked someplace else, so that the informa-
tion is there. How do you get that back into the system so it is
available then to those people who want it for another program?
Mrs. WARNER. We develop a retrievable system, fast retrievable
ADP, and the information is stored once, not a multiplicity of times.
You asked the initial question concerning our relationship with
the Office of Education, Department of Agriculture, BIA, and oth-
ers. Initially it was stormy, threatening clouds all above, but as we
worked with them and shared with them the work of the Depart-
ment of Education, and outside educational administrators, they
began to see that we were not refusing to supply information that
they requested in any area.
We do then conform to each and every data request, but by
eliminating redundancy, building in lead-time, eliminating duplica-
tion, and building a calendar for local school districts and their data
compliance requests, we finally are operating in a far more efficient
and effective fashion with the Federal offices.
As a result, I believe if you would query them, you would find
that we have an excellent working relationship, a very satisfactory
working relationship, supplying any information at any time on
request, immediately, if needed, and certainly conforming to all of
the necessary data.
Mr. CROSS. Does the State department then have all of the data
for all of the school districts on tape or available in computer, and
does each district then have that same information?
Mrs. WARNER. Each district has their information. If the district
does not retain their information, if it is a head teacher in a school
district of 100 students, obviously that person who teaches full-time
handles administration and has to fill out forms, cannot retain that
sophisticated a system, it is immediately available from the Depart-
ment of Education, on request.
Mr. CROSS. So that teacher in that district with 100 students or
smaller, I suppose in some cases, fills out the form, submits it to the
State department, who keypunches them or puts them in a comput-
er and has them available for retrieval.
PAGENO="0304"
300
Mrs. WARNER. And the program officer in title I, for example, has
available any and all information that may have been collected by
another division, but it is there readily available and accessible.
Mr. CROSS. I notice in the one sheet that came, the vocational
education, with the greatest reduction in reports and items, was
that all Federal?
Mrs. WARNER. All Federal.
Mr. CROSS. Fine; thank you very much.
Mrs. WARNER. Thank you, sir.
Mr. KILDEE (presiding). Does Majority Counsel have questions?
Mr. JENNINGS. Mrs. Warner, my question has to do with whether
it is possible to translate your experience from a state where you
have 2 million people to a state like California, where they have
maybe 22 million people.
Mrs. WARNER. Mr. Chairman, and Mr. Jennings, I would have
some staff with me today, except at this moment they are on their
way to California.
Mr. KILDEE. Are they missionaries?
Mrs. WARNER. Yes, sir; we are sending missionaries to see if we
can help our compatriots in the Far West to share with them our
data acquisition plan to see if it cannot be implemented in a large
state such as California. The way the State of California is looking
at the system is breaking it down into regional centers, if I under-
stand correctly, and there they will go through the identical or
similar process that we have. Their Department of Education will
again be the core, and the Department of Education will negotiate
with all the various program officials in order to cause this to come
about. We believe that it is a pattern that is applicable; simply
overlay with whatever caveats are required for a specific need in a
specialized situation.
Mr. JENNINGS. I remember when I was out in Arizona and talked
to you about a year and a half ago, you said one of the most
effective techniques you used in reducing paperwork was to bring
bureaucrats from your agencies into a room and have them sit at a
table with local school administrators and the general public and
ask them to justify each data request they were going to make.
Using that device, you found that the bureaucrats were willing to
do away with a lot of their requests. That seems to me to be a very
effective device, but it seems to be a device which can be used in a
small state, and I wonder whether you can use that same type of
device in a large state?
Mrs. WARNER. Mr. Chairman, Mr. Jennings, it depends entirely
on the leadership, I believe, and their commitment to the process.
Interestingly enough, in following through on bringing the individ-
ual program officers in, seating them at a table, alone, with the
committee around them, requiring them to justify every single data
request, they all of a sudden developed a desire of empathy for local
school administrators, county school superintendents, business offi-
cials, that has not only aided us in the data reduction process, but
has built our Department of Education into truly the service agency
with known quantities between our staff and local school districts;
it has helped us become far more responsive to the needs of local
school districts. There are a variety of additional benefits over and
above the initial process which was data reduction.
PAGENO="0305"
301
As far as transferring it to a large state, or to the Federal
government, if you are willing to give credence to the point of view
of the victim, the one who must comply, it will work anywhere. If
prior to the implementation or construction of the rules and regula-
tions and the data requests, the results of the bureau were brought
in, the people who have to comply, then I believe that immediately
were the motivation, were the philosophy present, serious, I believe
we would not have to talk about data reduction, but we would begin
with a requirement that was manageable and handleable. There
isn't a school administrator in the nation, to my knowledge, that
would say there is no need for data collection, nor that they would
not comply.
They simply cannot understand the duplication, the redundancy
and the ridiculousness in some cases of unused stored data they
must generate.
Mr. JENNINGS. Thank you. You have done a tremendous job out
there.
Mr. KILDEE. You used the term victim. Did you have difficulty in
getting that term across, or did you find receptivity to the term
victim?
Mrs. WARNER. Sir, the victims, to begin with, didn't believe it.
Mr. KILDEE. They didn't know they were victimized?
Mrs. WARNER. They said we will come and probably be victimized,
yes, but once they recognized that the Office of Superintendent was
serious and they had a tremendous amount of responsibility and
attendant authority, they took the job very seriously. And, as a
result, we have not had one single appeal by a single program
officer in the Department of Education. There is an administrative
appeal process. It has not been used once. The committee of victims
has been so fair and so concerned and objective that no program
officer has felt they have been dealt with unfairly. So it has been a
shared educational process that has been enlightening and
rewarding.
Mr. KILDEE. You seem to have a program that could well be
replicated in other states.
Mrs. WARNER. We believe it will be.
Mr. KILDEE~ Mr. Quie.
Mr. QUIE. I have no questions.
Mr. KILDEE. The committee will recess until 9:30 tomorrow
morning.
Thank you very much, Mrs. Warner.
Mrs. WARNER. Thank you, sir.
[Whereupon, at 10:37 a.m., the committee recessed, to reconvene
at 9:30 a.m., Wednesday, May 25, 1977.]
[Material submitted for inclusion in the record follows:]
91-860 0- 77 --20
PAGENO="0306"
302
TESTIMONY ON PAPER WORK PROBLEMS IN
ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
SUBMITTED BY
DR. BARBARA THOMPSON
SUPERINTENDENT OF PUBL IC INSTRUCTION
WISCONSIN DEPARTMENT OF EDUCATION
My name is Barbara Thompson and I am Superintendent of Public
Instruction for the State of Wisconsin. I am also the Chairperson
for the Council of Chief State School Officers' (CCSSO) Coordinating
Committee on Educational Information (CCEI). In both capacities I am
charged with the responsibility of addressing data collection concerns
with the goal of keeping paperwork to a minimum. I, along with other
Chief State School Officers, have the unique opportunity to view the
problem from both sides, i.e., as a collector and user of educational
data for state program operation and evaluation; and as a supplier of
federally required data as well as a representative for local education
agencies relative to federal reporting. From this vantage point it is
becoming increasingly apparent that significant action is required at
both the Federal and State level to create a systematic approach to
collection and utilization of meaningful information in a manner that does
not overwhelm local administrators and teachers with paperwork.
The Coordinating Committee on Educational Information (CCEI) has
been involved with this particularly difficult problem for the past
several years. The Committee has delegated the detail responsibility
for staff support to the Committee on Evaluation and Information
Systems (CEIS) consisting of a state coordinator from each state and
extra-state jurisdiction.
PAGENO="0307"
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Page two
This committee undertakes its activities through the use of
subcommittees and task forces assigned specific areas of responsibilities,
supplemented by the inclusion of Local Education Agency personnel (LEA)
and intcwacting with appropriate federal personnel. CEIS has involved over
100 state and local personnel this past year in representing state and local
agencies interests in federal data collection, evaluation, and information
system development. CCEI provides oversight for the activities of CEIS
and communicates recommendations and concerns of CEIS to the Chiefs
and appropriate Federal Officials. This technique has led to some
dramatic improvements in local/state/federal relations and has permitted
a broader appreciation of paperwork problems.
With this short introduction to our committee structure an'1
activities I would like to move on to some of the major problems
perceived by state and local education agency personnel and some recommen-
dations offered for your consideration:
1. Lack of adequate lead time. Over the years this has
been a consistent problem leading CEIS to adopt a standard
position requiring 9 months lead time prior to implementation
of data collection activities. More specifically, this
requires that data requirements be definad by January for
the ensuing school year. This lead time is required due
to the necessity of development and communication of needs
to local districts by state education agencies, and modifi-
cation or re-programming of data collection procedures at the
local level. This implies that Congressionally mandated data
collections should consider appropriate timing, not only in
terms of legislation but also the subsequent regulation develop-
cent.
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Page three
2. Cost of Data Collection. A major problem facing
education today is the increasing demand for mandated
program evaluation data, compliance information, etc.,
without commensurate increases in appropriations to cover
the costs associated with generating this data. The
Paperwork Commission Report on Education includes the
following quotes:
* `A western State says the Federal Government
imposes 40 percent of its data collection
requirements yet provides only 10 percent of
the funds".
* "A mountain State shows that 39 percent of
the data it collects is required by the
Federal Government which provides only 5
percent of its funds".
* "A midwestern farm State says that 30 to
50 percent of its reporting time is due
to Federal requirements, yet it receives
only 4 percent of its funds from Federal
sources".
* A midwestern State estimates it may cost
$3.50 per data item per school to provide
data not readily vailable".
PAGENO="0309"
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Page four
Mandated studies should not be considered prior to
assessing the financial impact imposed on the respondents.
This can best be accomplished by ensuring that respondents
have an opportunity to determine financial and response
* burden prior to finalizing any legislation requiring data
collection for reporting or evaluation.
I would be remiss if I did not mention some positive
activity in this area over the past several years.
Legislatively supported Title I Assistance Centers,
Technical Assistance for State and Local Education Agencies
and the information and personnel exchange programs sponsored
by NCES have all been successful in enhancing state agency
capabilities to comply with educational data demands but
represent only a minor investment in addressing a major problem.
I would definitely recormiend increased appropriations and
support for this type of activity.
3. Insufficient Governmental Management Controls. A
review of the total education data needs of the Federal
Government and the financial impact of data collection,
processing, and utilization at all levels of government
dictate that a highly sophisticated, integrated and responsive
data management system be defined and put in-place. Excessive
duplication and redundancy, inconsistent terminology, unrealistic
data requests, lack of ability to manipulate and feed-back
information, all reflect the inability to effectively coordinate
and control the data acquisition process.
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Page five
While I am quick to admit that State Education Agencies
do not have foolproof mechanisms and that a panacea is
not on the horizon, I am firmly convinced that a great
deal more attention needs to be directed toward this
problem than has been the case in the past. I recognize
that full control and coordination would require a drastic
increase in personnel and funding levels at the Federal
level but currently the burden for this inability to
properly manage the data acquisition process is shouldered
in the main by state and local staff and resources.
Recent years have shown that improvement is being made and
the potential exists for securing a grasp on the problem. In particular,
the Chiefs recognize and applaud the continued surveillance and objective
analytical reviews by the Office of Management and Budget, (0MB)
the creation and implementation of the Education Data Acquisition Council
(EDAC) and its resulting Annual Data Acquisition Plan, and the
establishment of a close working relationship with the Council of Chief
State School Officers (CCSSO) by the National Center for Education
Statistics. This process has led to improved justification for collecting
data, common terminology and reduced duplication.
However this mechanism covers only the HEW Division of Education
and the Office for Civil Rights. Numerous other federal agencies currentTy
collect data from state and local education agencies and are not under
the responsibility of the current EDAC review process. The exclusion
from the review process tends to increase paperwork not only in terms of
exact duplication but also due to inicomparability and incompatability by
non-standard definitions and procedures.
PAGENO="0311"
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Page six
It is felt that a great many of the current problems and
weaknesses could be corrected by considering implementation of the
following: (as included in the Commission on Federal Paperwork's
Report on Education)
* All requests for data from educational
respondents should flow through the HEW's
Education Data Acquisition Council prior to
0MB clearance.
* All forms submitted for clearance should use
terminology consistent with the NCES Handbooks.
* The Education Division should include an automated
indexing system for cataloguing available data
as an instrument to assist EDAC staff in detecting
duplication or identifying location of already
existing data.
* A meaningful, comprehensive and integrated data
management system should be designed and implemented
to maximize utilization of data with an emphasis on
a single collection of data items for multiple users.
It is anticipated that the Common Core of Data (CCD)
program developed by NCES may lead to this desired type
of data administration.
* Congress should institute a practice of periodic
reviews of mandated operations to monitor necessity to
continue these activities.
PAGENO="0312"
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Page seven
CCEI, CEIS and the Council of Chief State School Officers
all recognize that the recommendations presented may appear to be an
oversimplification of the approach necessary to solve the many faceted
data problem, but we are convinced that they represent a point of departure
that will lead to long needed improvements in this area.
PAGENO="0313"
309
~p'~mn~ fPuttia ~IzooL~
Frank Ladd, Ed. 0., Superintendent
601 252-2*83
~d/~LL~~ 1S~l!Ii,z9~, ~41~i~ii~tifz/zi 38635
May 2, 1977
The Honorable Carl Perkins
Chairman, Committee on Education
House of Representatives
Washington, D. C.
Dear Mr. Perkins:
I am writing this letter with hope that you will help educators
with the problem of over regulation, which has become strangulation,
by the Federal Government. We, in education, are faced with the
task of complying with Title IX, Public Law No. 94-142, for the
Handicapped and Title I, ESEA, plus many other guidelines, laws
and guarantees of everyone's civil rights. I do not believe
that most of us in education want to violate or abridge anyone's
rights; however, the guideline writers and enforcers of these
guidelines seem to be self serving in their efforts to dictate
educational policy and educational decisions.
During a time when many people are looking askance at the growing
bureaucracy, the guideline writers and enforcers are requring
a continued growth of this bureaucracy to handle the paper work,
reports and compliance assurances they thrive on. It appears to
this writer that the Congress needs to closely scrutinize the
guidelines and interpretations by professional bureaucrats of
Congressional intent.
One of the greatest strengths of this country has been an
educational system with local control, which met local and
national needs. The many guidelines coming out of Washington are
having an adverse effect on education by fragmenting educational
effort. The main goal of education is to provide an education
that is appropriate for students who range from extremely bright
and college bound to extremely slow, who need a different education
with different goals. It seems that instead of the Federal
Government providing needed assistance, they are listening to
people with little or no educational experience and people with
some special interest, or a crusade for a special cause.
I am enclosing copies of some of the things that are coming
from the bureaucracy that are restrictive, unproductive and
expensive to implement.
PAGENO="0314"
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The Honorable Carl Perkins
Page 2
May 2, 1977
We couldn't possibly list all the forms nor tell you the time
required to fill out all the forms that are required to show
whether we are violating some particular group~s rights.
I will be happy to testify before a committee regarding guidelines,
restrictions, etc.
Yours sincere'y,
Frank Lad~
FL :pd
Enclosures
PAGENO="0315"
311
DEPARTMENT OF HEALTH, EDUCATIO~1, AND WELFARE
OFFICE OF EDUCATION
WASHINGTON. DC ~
Dear Colleague,
For more than a year technical assistance materials on the implementation
of Title IX of the Education Amendments of 1972 have been under development
for the United States Office of Education. The initial results of th'is
development effort were disseminated during the suniiier of 1976 in a package
entitled Complying With Title IX: A Resource Kit. The kit consisted of the
following nine components: Equal Opportunity-A Fundamental American Right;
Why Title IX?; Title IX of tfié Education Amendments of 1972: A Summary of
the Implementing Regulations; Identifying Discrimination: A Review of
Federal Antidiscrimination Laws and Selected Case Examples; Complyipg
With Title IX: The First Twelve Months; Complying with Title IX: Implement~~
Institutional Self-Evaluation; Title IX: Selected Resources; Equal Educational
Opportunity; and Equal EmpTh~nent Opportunity.
The second part of this materials development effort is now being disseminated.
The individual components are: Competitive Athletics: In Search of Equal
Opportunity; Selecting Professionals in Higher Education: A Title ix Per
spective; A Student Guide to Title IX; Implementing Title IX: A Sample Work
~ Title IX and Physical Education: A Compliance Overview; and Title IX
Grievance Procedures: An Introductory Manual.
All of these materials are technical in nature and should not be viewed as
interpretive of the Title IX regulation, a responsibility of the Office
for Civil Rights. The Illustrations or examples in these materials are not
necessarily to be interpreted as Title IX requirements.
I want to thank the contractor and, in particular, the project director,
Dr. Shirley McCune, and her staff at the Resource Center on Sex Roles in
Education. The Center also receives support from the Ford Foundation, and
much of the research behind the Title IX endeavor comes from that source.
also want to thank the Maryland State Board for Higher Education for under-
taking the task of disseminating these materials.
The entire education community should be making every effort to provide educa-
tional equity for all individuals. We in the Office of Education hope these
materials contribute to your efforts in this regard. You are invited to
reproduce all or part of these materials according to your needs.
SI ~
an E. Duval
Director
Women's Program Staff
PAGENO="0316"
312
Your Fundamental Responsibility
As you read this booklet, you will learn about
the rights you have as a result of Title IX. You will
also learn that you have a very basic responsibility to
make these rights a living reality in your school.
You may find that your own school sometimes
discriminates on the basis of sex. It is your responsi-
bility to inform your school of any violations of your
rights In this way you can work to translate your
kgal rights into actual practice in the classrooms and
`(ices of your school.
Sometimes this will be very simple. There are s ~ ~ -r-
many principals, teachers, and parents who believe 1T~ ~"r' ~ v 0
strongly in the idea of equal opportunity for all stu- ~s.JIOLATiO~4$.
dents, regardless of race, ethnic group, or sex; they
will help you. At other times, you will face an uphill
battle. In either case, you will want to discuss any problems with the Title IX coordinator for your
school district. By Federal regulation, all school districts must have a Title IX coordinator. This is
the man or woman in charge of making certain that your rights under Title IX are really working in
your school system. Moreover, your school system also has a grievance procedure. This means, if
you have a complaint about sex discrimination in your school, you are entitled to present it and to
receive a response. In other words, there are people in your school system right now who are respon-
sible for helping you understand and exercise your rights under Title IX. -
It is also your responsibility to let your school know when it is doing a good job in providing
fair treatment for all students. Your praise will encourage those people in your school who are con-
~erned about insuring your rights to equal educational opportunity.
Your freedom is in your hands. Your responsibility is to make certain that your freedoms are
recognized by your school. If they are not recognized, then you should follow your school proce-
dure and policy in complaining about this violation. If your school system refuses to recognize your
rights or if you feel you will not get a fair hearing you should consider filing a complaint with the
Federal Government or bringing court action in order to gain your rights.
It is up to each of-you to make individual freedom a reality.
Taken from: A STUD~T GUIDE TO TITLE IX
Written by: Myra Sadker
Prepared under Contract 300-7S-02S6 for
the Women' a Program Staff, U. S. Office
of Education, Department of Health,
Education and Welfare.
PAGENO="0317"
171)1
Data Acquisition Council and the 018cc
of Management and Budget.
Description of the propoeed collcctioii
of Information and data acquisition ac-
tivity follow below.
Written comments on the prolooed ac-
tivities age Invited. Comments should re-
fer to the specific sponsoring agency and
form number and must be received on or
before May 2, 1977. and should be ad-
dre.cscd to Administrator, National
Center for Education St.atlstic.c, ATTN:
Manager, Information Acquisition, Plan-
ning, and Utilization. Room 3001, .400
Maryland Avenue SW., Washington,
D.C. 20202.
Ptjrther information may be obtained
from Elizabeth M. Proctor of the Na-
tional Center for Education Statistics.
202-245-1022.
Dated: March 28, 1977.
MArIE D. ELDRIDC.E,
Adnsinistrator, National Center
br Education Statistics.
Deacatraaope or a Psoposet, Cotrscrmrs or
INFORMATIOpi AND DATA ACQUISITION ACTIVITY
1. TITLE OF PROPoSED ACTIVITY
Elementary and Secondary School Civil
Rights 8urvey: School Year 1977-78.
2. £CENCT/SUREasJ/t~r~'p~
001cc for Civil Rights.
2. AGENCY FORM HoMers
08/CR 101 and 102.
4. LRG01LATIVg AUTHORITY 70* Tills AtTIVITY
* * Each recipient shall keep sti-It ccc-
oe~ and submit to the responsible Depart-
ment o01elal or his/her designee timely.
complete roil accurate compliance reports
at such time and in such form and ro~t~(~.
ing such information, as the responsible De-
partment o01cial or his/)ser designee may
determine to be necessary to enable him to
ascertain whether tile recipient has coot-
plied or is complying with this part" I
(45 CFR 80.8(b))
Title IX of the Education Amendments of
1972. rh. procedural regulation ~pt~ticab1e
to Title Vt of the Civil Rights Act of 19(14
are adopted and incorporated by reference.
These procedures may be found at 45 CPa
so-a-co--u and 45 CFR Part 81. (45 CFR 56.-
71).
Section 501 of the Rehabititititoti Act of
1073. Procedures found in Appendix B of the
proposed final regulation and at 45 CFR 806-
11 and 45 CFR Part 81 5 84.82.70. These pro-
cedural provisions itre those applIcable to
Title VI of the civil Rights Act of 1964 and
sea adni,$sd and Iheoroorated by reference.
I. l'OI,UICT~5y/Os ~.TORY NATURE (`P
RESPONSE
Oblittatory.
5. 110W INFORMATION TO RE CO1.5.ECTtD 550.1.
RI IJSF.D -
The major purpose of the OCR data cot-
lection activity is to review an individual
school district's potential compliance with
`lit to VI of the Civil Rights Act of 1064, Titie
lx of the Edtlcation Amendments of 1072
and section 504 of the Rehabilitation Act of
3973. Specifically. OCR is mandated to niotti-
tor and investigate possible cases of dis-
crimination on the basis of race, ethnicity.
national origin, sex, and/or handIcapping
condition,.
The primary plan for analysis centers
around comparisons between:
(1) The number of actions taken witlhin
a specific school regarding the assignment
of students, sdm!nistration of discipline.
313
Assistant Secretary for Education
EDUCATION STATISTICS
Comments on Collection of information
and Data Acquisition Activity
Pursuant to section 406(g)(2)B).
Oeneral Education Provisions Act, notice
~ hereby given as follows:.
The Olflce for Civil Rights has pro-
posed a collection of Information and
data acquisition activity which will re-
quest Information from educational
aevnclea or Institutions.
The purpose of publishing this notice
In the PriasAt Rrois~xs Is to comply with
paragraph (g) (2) (B) of the "Control
of Paperwork" amendment which pro-
vides that each educational agency or
InsUtutlon subject to a request under
* the collection of Information anti data
nequisition activity and their represent-
ative organizations shall have an oppor-
tunity. during a 30-day period before
the transmittal of the request to the Di-
rector of the 018cc of Management and
Budget, to comment to the Administra-
tor of the National Center for Educa-
tion Statistics on the collection of In-
formation and data acquisition activity.
This data acquisition activity Is sub-
ject-to review by the HEW' Education
FIDesAt -REGISTSR, VOL. 42, NO. 62-THURSDAY, MARCH 31, 1977
PAGENO="0318"
PAGENO="0319"
PART 2: PAPERWORK PROBLEMS IN ELEMEN-
TARY AND SECONDARY EDUCATION
WEDNESDAY, MAY 25, 1977
HOUSE OF REPRESENTATIVES,
SUBCOMMITTEE ON ELEMENTARY, SECONDARY,
AND VOCATIONAL EDUCATION
COMMITTEE ON EDUCATION AND LABOR,
Washington, D.C.
The subcommittee met, pursuant to notice, at 9:30 a.m. in Room
2261, Rayburn House Office Building, Hon. Carl D. Perkins (chair-
man of the subcommittee) presiding.
Members Present: Representatives Perkins and Weiss.
Chairman PERKINS. The committee will come to order.
A quorum is present.
Our first witness this morning is Mrs. Marie Eldridge, Adminis-
trator of the National Center for Education Statistics, accompanied
by Mr. Darwin Stolzenbach, Executive Director of the Education
Data Acquisition Council, National Center for Education Statistics;
Today we will also hear from Dr. Calvin Frazier, Commissioner of
Colorado State Department of Education, representing the Council
of Chief State School Officers, accompanied by Mr. George Rush,
Director of the Joint Data Project, Council of Chief State School
Officers; and Mr. William Peek, Assistant to the State Superinten-
dent, North Carolina Department of Public Instruction.
We will hear first from Mrs. Eldridge. I will let you all ome and
give your statements and we will hold our questions until last.
If there is any way we can eliminate paperwork in government,
which is taking the time of so many of government people and
especially those charged with administration of programs and the
teachers in the classroom and everybody, we will be so happy.
Without objection, your prepared statement will be inserted in
the record.
[Mrs. Eldridge's statement follows:]
(315)
PAGENO="0320"
316
TESTIMONY OF MARIE 0. ELDRIDGE, ADMINISTRATOR OF THE
NATIONAL CENTER FOR EDUCATION STATISTICS, BEFORE THE
SUBCOMMITTEE ON ELEMENTARY, SECONDARY, AND VOCATIONAL
EDUCATION OF THE COMMITTEE ON EDUCATION AND LABOR OF
THE HOUSE OF REPRESENTATIVES, MAY 25, 1977
I welcome this opportunity to testify on paperwork problems in the field
of education, on our current efforts to deal with these problems, and on
progress in itnplenenting Section 406 of Public Law 94-482.
We recognize two important and inter-related problems:
(1) an increasing resistance by school officials and teachers to the
total paperwork burden placed on them by all levels of govern-
ment;
(2) the need to establish effective and efficient control over
forms, surveys, and other types of data acquisition activities
to eliminate redundancy and unnecessary burden;
Let us consider the first problem, increasing resistance. As I see it,
the most important reason for the increasing resistance on the part of
State and local officials to the increasing load of Federal data requests
is their perception that such data requests divert scarce resources, both
in personnel and dollars, from their major mission of educating children.
This perception is underscored by the generally increasing concern about
the quality of our educational processes. Recording and reporting data to
State and Federal officials is not generally seen by local officials as
contributing to improving educational quality. Similarly, State officials
are increasingly reluctant to impose, or to acquiesce in Federal data col-
lections, even if Federal dollars are made available to cover some or all
of the cost. This is becoming a very serious problem.
PAGENO="0321"
317
Page.2
/A forceful illustration of this nay be found in the Center's current
feasibility study for our developing Common Core of Data (CCD) system.
The CCD system is being designed to eliminate some current data collections,
consolidate others, and provide a sounder data base for educational admin-
`istrators, planners, and researchers `at all levels. In our feasibility'
study, currently in progress, the Center has written small purchase-order
contracts to determine the feasibility of filling out the planned CCD
forms. This information is to include an assessment of the availability
of the data and the States' estimates of the incremental cost of filling
out the CCD forms--incremental in the sense of estimating the costs of
providing *data required by the Federal government beyond that which the
State currently collects or would use for its own purposes.
While this feasibility study is not yet complete, two preliminary findings
are noteworthy: First, the estimated costs reported to date are so widely
varied, and so high in some cases, that it is not yet clear what the total
cost for this system will ultimately be, nor how soon CCD can be made an
operational system. In view.of the volurkarynature of our data collections,
and the fact that the State and local systems clearly perceive themselves as
overburdened in this respect, it is evident that we must expect to provide
extensive support to these respondents to offset their incremental costs of
supplying needed data, if we are to have a functioning CCD system.
The second preliminary finding is that, even with the anticipation of support
for incremental costs, and despite the support of the Council of Chief State
School Officers (CCSSO), many States have expressed an extreme reluctance
to consider cooperation with the proposed CCD data collection when so little
appears to be happening to control the expanding overall burden of Federal,
education-related paperwork.
91-860 0 - 77 -- 21
PAGENO="0322"
318
Page 3
In this connection, I must point out that many State officials do not
differentiate among the various Federal agencies that sponsor these data
requests; the National Center for Education Statistics is looked upon as
the agency which should havn the responsibility of doing something about
the data requests of all Federal agencies - the Office of Education, the
Office for Civil Rights, the Equal Education Opportunity Commission, the
Food and Nutrition Service of the Department of Agriculture, The Bureau of
the Census, to mention some. Clearly, the Center' has neither the authority
nor the capability of reviewing and coordinating all Federal education data
* requests.
With regard to the second problem, each new Act of Congress establishing a
new grant program, modifying or expanding an existing program, requiring
new efforts to reduce discrimination, requesting more intensive evaluation
of existing programs and greater accountability for the funds expended
contains the seeds of added data collection burden. The effect of this
situation on those managing the school system is a constant clamor for
more coordination and more control over the paperwork burden, slowdowns
in complying with data requests, and either reluctance or refusal to
cooperate with future data collection efforts even if renumeration is
offered for the time and effort required to complete forms and question-
naires. Let me expand further on the Center's efforts to deal with this
problem.
PAGENO="0323"
319
Page 4
The Center's Role in Paperwork Problems
Following your hearing on May 7, 1974,' the Comptroller General's Report of
March 24, 1974, and the enactment of Public Law 93-380 in August 1974, the
Center created a new position in the office of the Administrator, a Manager
of Information Acquisition, Planning and Utilization. The appointment of
Darwin Stolzenbach, who is with me here today.,, marks the first time the
Education Division has had a full-time senior staff person with responsi-
bility for managing a paperwork control effort embracing all agencies
of the Division.
On September 3, 1975 the Assistant Secretary for Education signed a
charter establishing the Education Data Acquisition Council (EDAC),
replacing the then defunct Office of Education Task Force for' Planning
Acquisition of Information.
The basic functions of EDAC, as set forth in its charter, are to advise the
Assistant Secretary for Education on data acquisition policy, to develop,
approve, and disseminate standards, criteria, and guidelines for planning
and developing a sound body of national education data, and to assist the
National Center for Education Statistics in the preparation of the Annual
Data Acquisition Plan of the Education Division.
Upon its establishment, EDAC authorized review groups, developed and
promulgated criteria for the inclusion of data acquisition activities in
the Plan, approved the policy of not allowing any data acquisition activity
to be sent to the Office of Management and Budget for clearance unless it is
included in the Plan, and approved a policy for consultation with representa-
tive respondent groups such as the Council of Chief State School Officers.
PAGENO="0324"
320
Page 5
The Manager, Information Acquisition Planning and Utilization of the National
Center has been designated as the Executive Director of EDAC and has the
overall responsibility for managing the review operations in accordance with
the policies of EDAC and for the preparation and maintenance of the Annual
Data Acquisition Plan.
The main review function under EDAC is performed by three review groups,
consisting of senior professional staff persons d~esignated by the partici-
pating agencies and bureaus. Since April 1976 these groups have been meeting
regularly once a week. The reviews of proposed data acquisition activities
are scheduled at the tine when the 0MB clearance package is ready for trans-
mittal to 0MB. The groups have the option of approving an activity for
inclusion in the plan or not, or of negotiating changes in the activities
with the sponsor. Since the groups began operating in April 1976, 156 acti-
vities have been reviewed. Of these 127 were approved, 17 substantially
modified, and 7 were disapproved. The 7 that were disapproved represented
a total potential respondent burden of 11,400 man-hours.
A good example of an activity that was substantially modified during the
review process is the Needs Assessment Survey of the Bureau of Education for
the Handicapped (OE). As originally presented, the sponsor intended to survey
all (some 200,000) of the nation's special education teachers, and the
respondent burden would have been an estimated 134,000 man-hours. The survey
as finally approved will seek responses from a national sample of the universe
of special education teachers, representing an estimated respondent burden
of 11,000 man-hours. The resulting burden reduction is the equivalent of
approximately 114 teaching years.
PAGENO="0325"
321
Page 6
Our evaluation of the results of the first year of EDAC operations indi-
cates several ways in which the effectiveness and efficiency of the EDAC
review process can be improved.
First, we believe that the criteria for justification of a data acquisition
activity can be sharpened by more explicitly specifying the uses of data
that will justify them as necessary. Frequently, a sponsor will be unable to
demonstrate actual usage of data but will claim that the data are required
by existing regulations. We will in such instances initiate an examination of
such regulations and take the necessary steps either to revise such regulations
or to have them revoked.
Secondly, we have noted that practically all evaluation and research data
* acquisition activities are designed by contractors, and that by the time
the activity is ready for EDAC review a heavy investment of time and funds
has already been made; if changes in the survey design or the instruments
are to be made, the delays in beginning the field work may be costly and
might well interfere with a planned schedule of program operations. Under
these circumstances, review groups have been reluctant to recommend dis-
approval or substantial modifications. Our approach to solving this problem
is to have an up-front review of the work statements prior to the publication
of requests for proposals.
Thirdly, many of the data acquisition systems presented to review groups
involve extremely complex considerations, which strains a part-time staff.
Owing to budget and personnel ceiling limitations we have utilized the
Intergovernmental Personnel Act and obtained, on a temporary one-year basis
the services of a senior person from The California State Department of Education.
PAGENO="0326"
322
Page 7
Implementation of the `Control of Paperwork" subsection (406(g)) of the
General Education Provisions Act as amended
With the enactment of subsection 406(g) we proceeded ininiediately with steps
to implement it. The first step was to initiate a procedure for .affordi~ng
respondent educational agencies and' institutions an opportunity to comment
on each proposed data Acquisition activity (406(g)(2)(B)). Since November
1976 we have been publishing a notice in the Federal Register describing each
proposed data activity and inviting comments within 30 days. The `comments
we receive are sent immediately to the sponsor (for reply), and' to the chair-
man of the appropriate EDAC review group.
Early in December 1976 we drafted revised procedures for EDAC in order to
comply with 406(g)(l)(C). The principal feature of this revision is, of
course, to bring the Office for Civil Rights into the orbit of EDAC. We are
also proposing to add the Deputy Assistant Secretary for Planning and
Evaluation (Education) to the Council as a voting member and to' make the
Council advisory to the Administrator. As of this date these new procedures
are awaiting approval by the Secretary.
With respect to the role assigned to the Administrator of assisting each
bureau or agency in performing the coordination required (by the subsection)
we have already begun to explicitly offer the services of our professional
statistical staff to assist sponsoring project officers in the design of
appropriate survey methods and instruments. This activity is carried out
independently of the EDAC functions. A prime recent example of this is
the set of survey instruments proposed by the Office for Civil Rights for
PAGENO="0327"
*323
Page8
their biennial survey of elementary and secondary schools. The extent
to which NCES can provide such advice is, of course, a function of how much
of our personnel resources we can afford to divert to this purpose.
Subsection 406 (g) specifies three criteria for data activities: necessity,
redundancy, and excessive burden. With respect to redundancy we now haiie,
in our FY-77 Supplemental Appropriation, sufficient funds with which to
develop, under contract, a data item indexing system and a compatible com-
puterized facility for quickly identifying data-item redundancy.
With respect to 406(g)(3) requiring the Administrator to provide summaries
of informatiàn collected and data acquired, we contemplate issuing guide-
lines to the agencies as to how summaries of data collected shall be
disseminated. In some instances computerized summaries may be required
for inclusion in our EDSTAT facility.
With respect to 406(g)(4) requiring the Administrator to develop a common
set of definitions and terms, this provision involves an augmentation of
the NCES handbook program. Using funds made available in our FY-77 Supple-
mental Appropriation we shall contract to prepare a dictionary of all the
terms used in the data acquisition activities of the Education Division and
the Office for Civil Rights and a collation of those terms with the terms
in the NCES handbook series. The result of this effort will provide a basis
for a program of handbook revision and updating in order to comply with this
new provision of law.
Thank you for inviting me to present this testimony. Mr. Stolzenbach and I
will be pleased to answer any questions you might have on this subject.
PAGENO="0328"
324
STATEMENT OF MS. MARIE ELDRIDGE, ADMINISTRATOR, NATION-
AL CENTER FOR EDUCATION STATISTICS, ACCOMPANIED BY
DARWIN STOLZENBACH, EXECUTIVE DIRECTOR, EDUCATION
DATA ACQUISITION COUNCIL, NATIONAL CENTER FOR EDUCA-
TION STATISTICS
Ms. ELDRIDGE. I am very pleased to be here and I will spend just a
few moments highlighting the testimony, if that is permissible.
I would like to introduce Mr. Stoizenbach, sitting to my left, who,
as you indicated, is the Executive Director of the Education Data
Acquisition Council, National Center for Education Statistics. The
functions of the Council are addressed quite fully in my testimony.
When we talk about the paperwork burden you see two very
important and related problems. The first is very obviously the
increasing resistance by school personnel to this burden which is
placed on them by all levels of government, not just the field
component.
Secondly, the need to establish effective controls over the data
acquisition activities in order to eliminate redundancy and unneces-
sary burden. I believe the resistance on the part of state and local
officials stems mainly from their perception of the data require-
ments as a chore which diverts scarce resources, both personnel and
dollars, from their major mission of educating children.
Also there is increasing reluctance to cooperate in federal data
collection even if federal dollars are available.
The problem snowballs because many state officials do not differ-
entiate among the various federal agencies involved and they look
to the National Center more and more as the agency which should
have the responsibility of doing something about the burden which
may be generated by OE, OCR, EEOC, Food and Nutrition Services
of the Department of Agriculture, and the Census, to mention a few.
They do not differentiate between Office of Education data, data
for the Office of Civil Rights, data for Food and Nutrition Service in
the Department of Agriculture, or even Census Bureau data. It is
just in one big glob; it is perceived as more a Federal data burden
and they are looking to the National Center [data] for some relief. I
think it is very clear that I am sympathetic to the role which they
would like us to have, but it is also very clear we have neither the
authority nor the capability to carry out that overview function.
I have not had the time or the resources, to catalog all the data
requested at the Federal level.
However, in the Education Division alone we have approximately
175 data collection activities currently in the education data plan~
for public elementary and secondary schools. They generate an
estimated burden of 1.2 million man-hours.
I would like to submit for the record some tabulations which we
have prepared which were not part of the testimony submitted
yesterday which break out that burden in terms of the generating
agencies and the types of respondents.
I think you will find some very interesting figures in those tables,
and we will submit them for the record if that is permissible.
PAGENO="0329"
325
Chairman PERKINS. Without objection, when it is received.
[The information referred to follows:]
TABLE I
EDUCATION DIVISION ANNUAL DATA ACQUISITION PLAN
FISCAL YEAR 1978
NUMBER OF DATA ACQUISITION ACTIVITIES
BY SECTION OF PLAN AND EDAC STATUS
E lement aryl
Secondary
EDAC
Status
Postsecondary Adult/Vocational Total
Proposed
59
13
22
94
Approved
143
96
18
257
Total 202 109
40
351
PAGENO="0330"
TABLE 2
RESPONDENT BURDEN OF DATA ACQUISITION ACTIVITIES DURING FY 1973
ON PUBLIC ELEMENTARY AND SECONDARY SCHOOLS
(000's of Man-Hours.)
Number of Percent of
Agency/Purpose Systems Man-Hours Total Man-Hours
NCES
41
99
7.5
NIE
.`
31
27'
2.1
,.
*
OE (Total)
(101)
*
(1190)
(90.4)
Applications
Program Management
Evaluation
53
26
22
*
767
261
162
*58.3
19.8
12.3
TABLE 3
RESPONDENT BURDEN OF DATA ACQUISITION ACTIVITIES OF ThE OFFICE OF EDUCATION
ON PUBLIC ELEMENTARY AND SECONDARY SCHOOLS
(000's of Man-Hours)
State Local
Education Education
Agencies Agencies 1/ Other2/ Total
326
173
1316
TOTAL
Purpose
100.0
Application
31
533
198
767
Program Management
24
91
146
261
Evaluation
1
136
26
162
TOTAL 56 760 370
1/ All Administrators, teachers, and staff serving students enrolled in
education agencies.
2/ All institutions other than the local public education agencies.
1190
local public
PAGENO="0331"
327
TABLE 4
RESPONDENT BURDEN OF DATA ACQUISITION ACTIVITIES
ON PUBLIC ELEMENTARY AND SECONDARY SCHOOLS
BY NUMBER AND PERCENT OF MAN-HOURS REQUIRED
Number of . Percent Cumulative
Form Number Description Man-Hours of total Percent
OE #362 Migratory Program, ESEA,
Title I Instructions for
Application for Federal
Assistance 156,000 .13.1 13.1
OE #362-I Instructions for Financial
and Performance Reporting
Migratory Programs,
ESEA Title I 99,000 8.3 21.4
OE #506-1 Indian Student Enrollment
Certification: Individual 75,000 6.3 27.7
OE #4037 Report for Determining Final
Payment pursuant to Title I
* of Public Law 81-874 60,000 5.0 32.7
OE #4019 Application for School
Assistance in Federally
Affected Areas (Title I
* of Public Law 81-874) 60,000 5.0 37.7
OE #502-3 Practical Achievement
Scale 53,492 4.5 42.2
OE #502-8-1 Student Participation
Roster-Reading 50,575 4.2 46.4
OE #453 Community Education Programs-
Instructions for Applications
for Federal Assistance 40,000 3.4 49.8
OE #326 Application for Federal
Assistance (Non-Construction
Programs) Instructions for
Environmental Education
Programs 40,000 3.4 53.2
OE #4524A ESEA Title I Comparability
Report: General Information 36,000 3.0 59.2
OE #4524B ESEA, Title I Comparability
Report: Detailed School Data 36,000 3.0 56.2
PAGENO="0332"
328
TABLE 4 (Continued) Page 2
RESPONDENT BURDEN OF DATA ACQUISITION ACTIViTIES
ON PUBLIC ELEMENTARY AND SECONDARY SCHOOLS
BY NUMBER AND PERCENT OF MAN-HOURS REQUIRED
Number of Percent Cumulative
Form Number .. Man-Hours of Total Percent
OE #4561 Application for Federal
Assistance (Non-Construction
Programs) for Bilingual
Education-Instructions &
Supplementary Questionnaire 34,000 2.9 62.1
OE #9037 Instruction for Application
for Federal Assistance
(Non-Construction Programs)
Handicapped 28,170 2.4 64.5
OE #360 Financial Status and Per-
formance Report For Dis-
cretionary Grants, Bureau
of Occupational and Adult -
Education 27,960 2.3 66.8
OE #9047 Application for Federal
Assistance (Discretionary
Grant Application for
Private Nonprofit Organiza-
tions UnderP.L. 93-380) 27,000 2.3 71.1
OE #3176 Vocational Education Programs
Instructions for Application
for Federal Assistance 24,000 2.0 73.1
OE #355 Data to Determine Eligibility
and Compute Maximum Grants-
- Financial Assistance for
Public School Construction 24,000 2.0 75.1
OE #116 Application for Federal
Assistance, ESAA 24,000 2.0 77.1
OE #502-1 Summer Activity Slipsheet 21,396 1.8 78.9
OE #3600 Application for Grant Equip-
ment and Materials to Improve
Undergrad~iate Instruction 16,148 1.4 80.3
PAGENO="0333"
329
Ms. ELDRIDGE. I believe it must be recognized that much of the
data burden results from the directed agencies' interpretation of the
new acts of Congress which either establish new programs or revise
or enlarge existing programs. I think this is undoubtedly where the
burden is generated.
All this sounds very grim and is probably very redundant in
terms of what you have already heard and what you are going to
hear in subsequent testimony, but I personally believe there are
significant things that have been undertaken by HEW in the area
of data burden reduction and I would like to discuss some of those
in terms of their effectiveness.
Following your hearings in May of 1974, the Comptroller Gener-
al's report in March 1974 and the passage of Public Law 93-380, the
National Center recruited and dedicated a senior fulitime staff
person to the paperwork problem, and the Assistant Secretary for
Education created the Education Data Acquisition Council (EDAC),
replacing the then defunct OE Task Force on Planning Acquisition
and Information. I am not going to take the time to review the
functions of the Council because I think those are spelled out in my
testimony. However, I would like to highlight some of the results of
that EDAC process.
One hundred fifty-six activities have come before EDAC since
April of 1976, when the Council became operative. Seventeen of
those were substantially modified and 7 were disapproved. The
respondent burden associated with the 7 which were disapproved
and did not go to 0MB for forms clearance approval, amounted to
11,400 hours. This figure would indicate that no major program was
completely eliminated as a result of the EDAC review, which I
think is not surprising when you consider that this was the first
year of the EDAC process and we are just gearing up.
While I do not have the figures on the net effect of the 17
modifications, I do not think we should consider those as being a
minor contribution in terms of data reduction. In fact, we have an
example, and there are others, where the modifications affect
substantial reductions.
A good example of the significant refinements in survey design is
described in my testimony and relates to one particular survey
where the original proposal called for a census of all the teachers in
special education. As a result of the EDAC review, we shifted that
survey design to a national representative sample.
The original proposal had associated with it 134,000 man-hours in
terms of estimated burden. The revision, based on the sample, has
an estimated burden of 11,000 man-hours. The reduction of 123,000
man-hours equates to approximately 114 teacher-years. I do not
think that that is insignificant.
The EDAC function, as I have just mentioned, is just a year old.
We have identified improvements which we expect to phase in as
our budget and personnel constraints permit us. With the enact-
ment of Section 406 of Public Law 94-482, we have expanded the
jurisdiction of EDAC to include the Office of Civil Rights. Notices of
proposed data collection are now appearing in the Federal Register.
That started in November of 1976 and through that mechanism we
invite potential respondents to comment on any survey that is
under review by EDAC.
PAGENO="0334"
330
To the extent possible we are also explicitly offering our statisti-
cal expertise to survey sponsors in the area of survey design so that
we can do more of what I mentioned earlier in terms of evaluating
the need for a census versus a sample design, or even optimizing the
sample design, in order to reduce the data burden.
We also have developed a system which I did not include in my
prepared testimony, which is the Fast Response Survey System
which has been recognized very clearly by the Council of Chief
State School Officers as a very potent mechanism for potential
burden reduction. The Fast Response Survey System is a "quickie"
mechanism whereby we zero in on policy-related issues, restrict the
questionnaire to postcard-size, and get the results back in approxi-
mately three months.
The thought behind this system was not originally to reduce
burden but we recognized after the first few surveys which were
conducted through this system that if we can get the key data in,
that may in fact satisfy the policymakers and may eliminate the
need for more extensive surveys.
We have great hopes for this Fast Response System. It is relative-
ly inexpensive, and the states are extremely pleased with the
system because the burden is clearly minimized. I think that is a
very important component of what NCES is doing in data burden.
The supplemental appropriations for fiscal 1977 are, of course,
going to permit us to automate and formalize some of the EDAC
functions. That will take place in fiscal 1977 and 1978. Again, I
believe that is adequately covered in my prepared testimony and I
will not take time to discuss that any further.
Thank you very much.
Chairman PERKINS. Thank you very much for your statement,
Ms. Eldridge. It will be very helpful.
Let's hear from Dr. Frazier before we go to questioning.
STATEMENT OF DR. CALVIN FRAZIER, COMMISSIONER, COLORA-
DO STATE DEPARTMENT OF EDUCATION, REPRESENTING THE
COUNCIL OF CHIEF STATE SCHOOL OFFICERS, ACCOMPANIED
BY GEORGE RUSH, DIRECTOR OF THE JOINT DATA PROJECT,
COUNCIL OF CHIEF STATE SCHOOL OFFICERS
Dr. FRAZIER. My name is Calvin Frazier, from Colorado, and I
have been Commissioner of Education for four years and prior to
that worked in local school districts and at a couple of universities,
so my perspective stems from about 25 years in education in various
contexts with the Federal agencies and offices.
With me is George Rush, who was formerly a member of the
Kentucky state department and is now with the Chief State School
Officers and the U.S. Office of Education in this special project.
I think for my comments this morning I would like to highlight a
few of the problems but basically focus on recommendations.
[The statement of Dr. Frazier follows:]
PAGENO="0335"
331
TESTIMONY GIVEN TO THE HOUSE OF REPRESENTATIVES
SUBCOMMITTEE ON
ELEMENTARY, SECONDARY, AND VOCATIONAL EDUCATION -
PAPERWORK PROBLEMS IN ELEMENTARY AND SECONDARY
EDUCATION PROGRAMS *
WEDNESDAY, MAY 25, 1977
COLORADO COMMISSIONER OF EDUCATION, DR. CALVIN M.. FRAZIER
Mr. Chairman, members of the subcommittee, I am Calvin M.
Frazier, Commissioner of Education for the State of Colorado, a
position I have occupied since 1973. Thank you for the opportunity
to appear today and discuss the serious problems surrounding paper-
work burdens on educational agencies. The views I present here
today represent not only my personal opinions but also those of
the Council of Chief State School Officers (CCSSO).
A combination of factors and circumstances have produced the
paperwork burden placed upon government agencies and the private
sector. It is my position that many federal and state agencies,
as well as lawmakers themselves, must accept responsibility for the
uncontrolled growth of paperwork. Therefore, it is our collective
responsibility to take measures to effectively reduce the staggering
response burden. There is need for all parties to assess the
legislative wording that sometimes triggers data collection, rules
that compound the problem, and administrative practices that informally
add paperwork demands.
PAGENO="0336"
332
Page two
Those of us who are involved in the paperwork process acknow-
ledge that it is a complex problem. Today, however, I would like
to concentrate on seven elements which appear to me to be the
most serious for Colorado and the other 49 states ~ad six territories.
They are:
1. The dollars expended supplying data to the
federal government.
2. The number of data items sent to federal agencies.
3. The duplication of information.
4. The impact of mandated information systems.
5. The influence of private contractors in the
collection of data.
6. The limited lead-time provided for state education
agencies and local education agencies to respond
to information requested.
7. Data and paperwork as they relate to achieving
Congressional intent.
Our concept of data in relation to the cost of supplying that
data must change. Until recently we have considered data as an
1output' from a computer or information "they'supply. There was
a detachment and an impersonal relationship existing between the
requestor and the supplier. Data were like inanimate objects. We
must look upon data as a commodity - a commodity which must be pro-
duced by someone and paid for by some person or agency. Currently,
there are insufficient appropriations in federal programs to cover
the costs of supplying data to federal agencies, therefore, limited
state and local resources must be expended to meet federally imposed
PAGENO="0337"
333
Page three
reporting requirements.
Data costs are difficult to compute. Costs are dependent
upon variables such as the availability of the information requested,
time needed to aggregate the data, ease of understanding instructions,
data item definitions, need for start-up and organizational adjust-
ments, and countless other factors. However, the question of
`how much will it cost?' is becoming increasingly important.
Colorado is in the midst of a data cost study. It will not
be concluded until August or September 1978; however, our findings
to date indicate that the average cost to report a data item is
$1.31. Reporting costs range from 30 cents per item to ~2O per item.
A data item is defined as a single response to a question, such as,
"How many students do you have in the sixth grade?" Our cost figures
include only the obvious costs and few of the indirect clerical and
systems costs. Our most recent study of the Office for Civil Rights
101 and 102 forms indicate that the direct costs of this study to
181 school districts in Colorado was in excess of $200,000. In collecting
over 2 million items of educational information for federal agencies
in 1975-76, we estimate that Colorado spent approximately $3,000,000.
For our state, this figure does not include vocational education data.
If our state is an indication, this would mean $250 to $300 million
dollars were spent compiling K-12 educational data by all states
last year.
Unfortunately, a number of factors have propelled us toward
massive data collection efforts.
91-860 0 - 77 -- 22
PAGENO="0338"
334
Page four
One factor is that our educational systems have taught us to
"get the facts - all the facts." This has been reinforced by
Congressmen and legislators placing federal and state program managers
in a position where they are expected to be able to answer all
questions.
Another factor relates to the basic human characteristic of
not being able to moderate our appetites after a once scarce commodity
becomes abundant. Only 15 years ago, the capability of storing and
processing vast amounts of data was limited. The computer has since
eliminated many collection barriers, and we have over-reacted and
collected more data than we need or can use.
We anticipate the data response burden will increase~substan-
tially with changes. in the vocational and special education laws.
It should be noted that cost estimates provided by federal officials
in their data acquisition announcements have been grossly underestimated
in the judgement of many of us. This may be partly attributed to
an unawareness at the federal level of the total state effort. For
example, several million individual student data items were collected
by the Colorado vocational education system in order to report to
the federal government only 1,000 summarized data items. This example
dramatically emphasizes the reporting burden that states and local
districts have faced in fulfilling federal data requirements.
Duplication of data and the absence of key data definitions
pose additional problems. Some progress has been made in eliminating
duplication of data and efforts must be continued.
PAGENO="0339"
335
Page five
While the Educational Data Acquisition Council has had a positive
influence on the reduction of the data burden, there is little
evidence coming through to the states that federal agencies are
attempting to coordinate their data collection activities.
The information system is in fact an extension of the management
process and reflects the needs of a particular district and its style
of management. Because of the vast dissimilarities among districts
throughout the United States, data required and utilized by one
district may be unimportant in another district. These dissimilarities
often lead to misunderstandings, misinterpretations and lack of
agreement about definitions of data. The lack of common definitions
substantially reduces the accuracy and reliability of the information
derived from the data.
In terms of legislation we are somewhat concerned over the
specificity in mandating information systems. Recently information
system development has been included in legislation for vocational
education, education for the handicapped, Right to Read, use of
federal funds (Section 437 of GEPA), and. an NIE research and develop-
ment system. A fear exists that too much specificity will become
a liability and consequently add to, rather than reduce the paperwork
problem.
A growing complaint voiced by both local and state education
agencies relates to the involvement of private contractors. For
several reasons there has been an increased use of contractors to
conduct surveys and design data collection procedures.
PAGENO="0340"
336
Page six
We have observed instances where a contractor has nbt had a
sufficient understanding and appreciation of state and local
district policy and procedures to recognize the impact and response
burden imposed on the supplier of information. While federal personnel
must become sensitized to the data concerns of local and state agencies,
so, too, must the contractors who are under performance pressures
that, in some instances, have led them to collect excessive amounts
of. data.
State and local educational agencies need adequate lead time.
Since the advent of computers and elaborate accounting systems, it
is most important that advance notice be given to allow for system
design alteration and computer programming, informing participants
at all levels, and conducting any personnel training necessary.
In the past, an inordinate amount of time has been spent at
the federal level prior to announcing data requirements to state
and local jurisdictions. Development of regulations has consumed
much time and energy and reporting deadlines are almost reached
by the time regulations are adopted. This sets in motion a
crash program to install appropriate mechanisms at the state and
local level that undermines the entire program. A related problem
is that of regulations calling for retroactive data collection that
forces state and local school districts to recreate data as best
they can. This after-the-fact approach increases the time and costs
involved in responding and makes such data suspect in terms of its
validity.
PAGENO="0341"
337
Page seven
Lastly, the data collection process must be examined in
relationship to achieving the intent of the legislation. If the
process is effective, all levels of government involved in the imple-
mentation of a program gain insight into the strengths and weaknesses
of the program effort. Data and paperwork become important as one
basis for evaluating the legislation passed by Congress.
Breakdowns in the data collection process effectively eliminate
any systematic feedback to Congress on the attainment of changes
sought by passing the legislation. For this reason, the redu~tion
of the paperwork demand is only part of the picture. The other and
perhaps more difficult challenge is to design the process in such
a way that the data collected is useful in assessing the contribution
of the legislation. It does not appear that such a process exists
and, until this problem is addressed, any changes in the paperwork
demand become a somewhat superficial tampering with the system.
Recommendations
The magnitude of the problem precludes any quick and easy solutions.
I would like, however, to make several recommendations that, in the
minds of school officers, may lead to an improved local/state/federal
mechanism for delivering meaningful information to policy makers and
program managers~.
1. Centralize the review of data collection forms and procedures
in one agency. It would appear that the Office of Management
and Budget could be assigned this responsibility. 0MB could
also review the data processes of federal regulatory agencies
currently under the Government Accounting Office (GAO). If
0MB is not the appropriate point of review, the Secretary
of HEW and federal educational
PAGENO="0342"
338
Page eight
leaders should propose another suitable central
clearinghouse to perform this function.
2. Expand the scopeof responsibility of preliminary
review of forms by the Assistant Secretary of Education
through the Educational Data Acquisition Council (EDAC)
p!ocess. Not only those forms emanating from the
Division of Education and the Office for Civil Rights,
but all federal data collection activities impacting the
educational community should be cleared through the EDAC.
Additionally, we would reconnend that representatives of
respondent groups be involv~d in the preparation and
development of information collection activities. The
Council of Chief State School Officers has a Committee
on Evaluation and Information Systems (CEIS) performing
in this capacity now and this Comittee has been a
valuable vehicle for improving data collection processes
in recent years. The concept should be expanded.
3. Investigate a means whereby each major federal report
could contain funding provisions to reimburse the suppliers
of the data for incurred costs. The reimbursement process
should utilize a method that permits appropriate audit trails.
Limitation of funds for data collection will force program
managers to concentrate on the more critical informational
needs and forego information that is in the "nice-to-know'
category. At a minimum, a systematic sampling should be
made by federal agencies on the cost of data collection.
This would tend to keep this issue before the various federal
agencies and allow assessment of the cost/benefit factor on
PAGENO="0343"
339
Page nine
some forms.
4. Develop a centralized, integrated, information
management system. Hopefully, this type of approach
would enable the federal gciernment to utilize computer
technology to store and retrieve coniiionly used educational
information with emphasis on collecting data one time and
processing multiple sets of data for information users.
To maximize this approach, it would be necessary to place
control over the collection of a common data base in one
organization and require all other federal agencies dealing
with education to access this data base, using survey
forms only when it has been demonstrated that required
information is not available in the existing data base.
We feel that such a system may be in the early stages of
development in the proposed National Center for Educational
Statistics (NCES) Common Core of Data program. We would
support necessary funding to fully develop this technique.
5. Coordinate federal data collection activities impacting
local school districts through the State Education Agency.
Forms sent directly to local school districts increase the
possibility of duplication due to the potential of the State
having similar data requirements.
6. Avoid development of data requirements for special categorical
p~pgrams such as vocational education and special education
as separate information systems.
PAGENO="0344"
340
Page ten
The data requirements for all categorical programs
should be integrated to the extent possible in the
Common Core Data requirements.
7. Establish a data item directory within the National
Center for Educational Statistics. Such a directory
could serve as a means for identifying duplication of effort.
8. Require all new requests for data and changes to existing
surveys to be defined and approved for collection by the
December prior to the school year in which it is to be
collected. In an attempt to assist in better planning
and orderly change in Colorado we are providing our
districts with our data requirement five to six months
before the beginning of the school year. It has resulted
in better data being delivered on time.
9. Review the legislative intent and data requirements as a
critical step to remedying the paperwork problem. Congress
should adopt laws containing a clearly defined expectation
for what data will be needed to determine the value of the
legislation, who will be responsible for providing this
information, the costs to be incurred in collecting these
data, and when the information will be needed and used.
This means a data analysis of these points prior to the
passage of any legislation having significant data impli-
cations.
PAGENO="0345"
341
Page eleven
10. Congressional and administrative support for coordinating
existing data collection mandates. States are about to
embark on significant data collection efforts in support
of Public Law 94-142, Education for All Handicapped Children.
The data collection format should be established now
and immediate attention given to the question of how all
of us can judge the effectiveness of this major piece of
legislation. This requires a commitment to judge our
use of federal resources and the impact we have in improving
the educational opportunities of handicapped children.
Although many states have had similar legislation, little
has been done to evaluate our efforts in this area. The
federal law, P.L. 94-142, could be a means for upgrading
our state evaluation efforts while setting the federal
program in motion.
11. Develop federal data collection procedures in such a
way that state data collection capacity is enhanced.
It is important to see the state's data processing ability
as a key cornerstone of a good federal system. As state
leaders are included in data and paperwork studies, local
school districts will profit. A team approach is needed
because of the scope of this problem and we as Chief
State School Officers are prepared to do what we can in
a collective effort with congressional and federal officials.
PAGENO="0346"
342
Page twelve
In closing, the good news in this area should be noted.
Progress has been made with the establishment of the Federal Paperwork
Commission, the objective analytical review process performed by tne
Office of Management and Budget and the creation and operation of
the preliminary review process by the HEW Education Data Acquisition
Council (EDAC). In addition, the Chiefs have made a contribution
in the formation of its own committee, CEIS, the Committee on Evaluation
and Information Systems. This organization consists of over 100
representatives from state and local education agencies interacting
with federal personnel in identifying and resolving problems associated
with data collection, evaluation, and information systems.
Recently we learned that some federal agencies had brought back
regulations and mandated surveys to congressional staff members to
ensure that the developed materials were consistent with the intent
of the legislation. This is an encouraging sign and continued use
of this techniqe should prevent some of the problems of the past
leading to the collection of unnecessary data.
Last, but certainly not least, the Chief State School Officers
have also been complimentary of the cooperative spirit demonstrated
by Marie Eldridge and the staff of the National Center for Education
Statistics in establishing procedures to insure adequate input in their
activities by the representatives of respondent groups.
PAGENO="0347"
343
Page thirteen
During the last 10 to 15 years, perhaps the state agencies
as well as Congress and federal officials have unknowingly allowed
the infc~rmation process to become extremely complex. It seems
appropriate that we collectively take strong and positive action
to correct this serious situation. I offer the services of CCSSO
and CEIS in advisory capacities as you consider paperwork problems
in the reauthorization of elementary and secondary education legislation.
Once again I would like to express my appreciation for having
the opportunity of appearing before you this morning.
PAGENO="0348"
344
~`the Constituents of Coloradø arc lnterested and very c~ncorncd
a~ut the data burden required of state and ~.oca1 agoacien
and the private soctor. The attachcd edItorI~1 i~ a typical
reflection c~ co1orado'~ concern. The otber or publisher.
The Denver Post, has published a number of simIlar editorIals
a~d artIcle~ecccern1n~ t~tc subject. .
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PAGENO="0349"
345
Dr. FRAZIER. I think from the standpoint of many meetings that
we have had as chiefs, perhaps some of our comments as to where
do we go on this might be maybe somewhat unique in terms of how
we would see this, although I think we are in general agreement on
the problem. Rather than highlight many of the problems, I would
rather look more at the legislative aspects as we see them and the
relationship between the legislation that is passed and ultimately
the data process that is encumbered as a result of that.
In my prepared testimony I mentioned the 6 or 7 problems as we
see these from the Chief State School Officers standpoint, the
dollars expended, the number of items that are collected, the
duplication, the problem posed by mandated information systems,
the use of private contractors, the limited lead time, and finally I
think again my focus is going to come back to the relationship of
data and paperwork as it would relate to achieving congressional
intent.
I believe I should say at the outset here, while I am discouraged
with the paper work I think it is our collective responsibility do do
something about this; that we as Chief State School Officers may
have contributed to the problems here, and states contribute, con-
gressmen contribute; it is kind of a snowballing effect.
I think there have been some changes in attitudes toward data
collection. I think we are now realizing this is like a commodity,
something that has to be developed and produced by somebody and
paid for by someone or some agency. So I think we are rather
positive there have been some changing attitudes brought about by
the Paperwork Commission and various other groups that lay a
good groundwork here if we can get together on some of the
recommendations.
I would mention that from the standpoint of the cost aspect in
Colorado we have been working on this for about the last two years.
A specific example-one reason I am encouraged by the attention
the Federal Government has given to this-last summer the U.S.
Office of Education funded a program that the State of Colorado
conducted, in which we had representatives from all the states and
territories meet in Denver to go over how to reduce paperwork and
data acquisition at the state level, things that we could control.
The Office of Education was very helpful in that, and we tried to
do a good job on this. Our studies have yielded the finding of about
$1.31 for every item that we are collecting, that is, every time you
would ask a question, how many students in the sixth grade, that
would be an item, and our total cost of compiling all this would run
about $1.31.
Some items are expensive. They run as high as $20 on some of our
studies for districts and our processing. We calculated the expense
of the Office of Civil Rights Forms 101 and 102 at about $200,000 for
our state. That is the state level, and it would not include any
- processing at the Federal level.
We have also estimated that Colorado spent last year for educa-
tional data, kindergarten through 12th, exclusive of higher educa-
- tion, probably somewhere between three and four million dollars.
Translating that to other states, this would mean that the state
cost of data could well approach about $300 million, and I suspect
PAGENO="0350"
346
that is a very conservative figure for last year, putting together the
data that finally came to the Federal offices.
Then there would be your costs on top of that. The cost of data is
hard to calculate because there are many hidden costs and because
many times we give a summarized total to the Federal level that
may in fact represent many millions of items, almost as it did in
vocational education recently, where some 10 million items were
accumulated by our 181 school districts but translated to only 1,000
items that finally came in a summarized form to the Federal offices.
We are encouraged by something that was mentioned by the
previous speaker in terms of the contribution made by the Educa-
tional Data Acquisition Council and the review this group has
brought to the data problem. I would commend our previous speak-
er on her part in that.
Let me mention a couple of items that I did not find had been
covered in some of the previous testimony. One is the use of private
contractors and the control of private contractors by Federal agen-
cies who in themselves may be really protecting the state and
Federal interests on the data, but when you inject in the element of
the private contractor to some extent that contractor must be
sensitized to the problems of collecting data.
I felt in a recent involvement that our state had for instance with
a private contractor about to collect information on the bilingual-
bicultural programs under Title VII, that much work has to be dOne
with private contractors.
There was statutory provision for NIE to involve the private
contractor, but that contractor must also be sensitive to the kinds of
things that we talked about this morning or you have injected
another element here that is going to run roughshod over the states
too.
We are concerned about the occasional demand by statutes and
by agencies for retroactive data. We got into a little of this with the
Office of Civil Rights, Forms 101 and 102, where we had to go back
and kind of recreate as best we could data from the 1975-76 school
year and there was a retroactive there that probably made some of
that data invalid. That, I think, is to be avoided.
In summary of the problems, the reduction I think in paperwork
is only one aspect of this. The other aspect is to make sure that the
data collected is feeding back to Congress and helping bring about
an assessment of whether that particular bill or act did in fact
achieve the intent of that legislation. Therefore, I am arguing that
data is important, data must be given a high priority but it must be
done on a very selective basis and it must go back to the
policymakers.
I think that the previous speaker indicated the reaction of the
states and the local school districts.
I think it is safe to say if there was a feeling the data were being
used, and used to evaluate progress and change in education, you
would find the states very strong in presenting the data needs that
would flow back to you.
I think it is fair to say that in Colorado and elsewhere the one
common theme that I hear around the state has to do with report-
ing back to the constituent the quality of the educational program.
PAGENO="0351"
347
Likewise, I would like to think at the Federal level and for Con-
gress, that your ultimate aim has to be in terms of determining
whether or not something was achieved by passing that legislation.
I think the one breakdown in data has been that it has not come
back to the policymakers as a judgment on the appropriation and
the act passed that stimulated programs in handicapped vocational,
and so forth, with a hope and prayer but no concrete data
sometimes.
The recommendations I would focus on very quickly. There has
been a lot of progress in centralizing the review of data collection
forms. Much progress has been made there but still work needs to
be done so there is a consistency from one agency to another in the
review of these forms and the basis for collecting this data that
every agency has to respond to. I mention progress has been made
but we should continue in that area.
The work of the Educational Data Acquisition Council has been
very good, and I think that has led to a preliminary review of forms
that has been helpful to the states. It should be expanded. We set in
motion in the Council of Chief State School Officers a committee on
evaluation and information systems that we refer to as CEIS, very
closely with the number of agencies here with very good results by
our involvement on that. I think that has helped the feeling
between states and the Federal Government.
Thirdly, I think that the idea of funding some of the major data
collection efforts would be valuable. I notice you indicated schools
are still reluctant even when funds are made available. I think,
however, that if you can combine those funds with a purpose that is
understood by all and a feedback that ultimately will come back to
the states, that would still be important.
A centralized integrated management system I think would be
helpful because we are still getting many f the agencies asking for
the same kind of information and if there was some kind of central
depository at the Federal level, and that common core of data is an
essential aspect from our standpoint to see developed, this would
eliminate the redundancy.
We would like to see that the Federal data collection activities
are handled and processed through the state education agency. In
OCR forms that go directly to the local district, often they are
asking for information that the state has collected. We could just as
easily have transmitted 90 percent of some of the information
requested to OCR on behalf of the school districts, and there was
about 10 percent unique to the school district that could have been
sent in, but as it was, every district reproduced the same data.
Number 6 on my sheet, the tying together of the categorical
program requests such as vocational education and special educa-
tion, not as separate information systems but as a part of an
integrated system, so that as the vocational people working in the
Bureau of Handicapped have need for educational data, they then
extract from this common core of data generally collected items
things that meet their needs and then add only on those things that
are unique to vocational and special education.
The important thing in terms of timing as a general rule is to
know at least by December that data that needs to be collected by
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the following fall. In other words, at least a 9-month lead time is
necessary for states so that we can get it into our state data
processing system and also into the local reporting system. If we
know by December, we can prepare the local school districts for the
material to be collected in the following fall. Again, OCR 101, 102,
violated this to the degree that we were caught in a late fall
announcement for data due in 3 months, yet completely out of
sequence with our normal collection.
Finally I would like to deal a little bit with the importance of the
legislation. Right now, in terms of data-and I am going to deal only
with data as it relates to the evaluation of programs, which is
probably the most essential direction we need to pursue at the
Federal and state level.
In looking over the Elementary and Secondary Education Act
provisions, the requirements for data, for evaluation, vary all the
way from a general charge to the Commissioner of Education, to
develop a valuation program to be used by the states, a very general
statement, to specific request charging an agency like NIE to put
together information that will come back to Congress with some of
the specifics.
We have other legislation that allows the local school district to
develop and evaluation process and forward that data in, so then
you are faced with getting perhaps sixteen or seventeen thousand
districts submitting evaluation data with no common direction, no
way that you can possibly evaluate that at the Federal level.
Therefore we have a wide range of this. I think if a model has any
value at the state level, what we are trying to do in Colorado might
be looked at in this sense. When a piece of educational legislation is
drafted, we start at that point writing the rules for that piece of
legis1ation~ We do this while the session is pending or while it is in
session because then those rules are being thought through by staff
members and local and state people.
You begin to see there are certain provisions in that law that is
being proposed and debated that will lead to trouble in writing rules
and regulations. At that point you are able to adjust the legislation
to correct those kinds of problems that you are going to run into.
The second thing that is done is that a data impact report is
developed with that piece of legislation so that the amount of
information to be collected is known and the estimated cost is also
attached to the bill so that the legislators, in looking at the piece of
legislation, begin to get an idea of the total impact of that bill
should it pass the session.
How much of that is possible at the Federal level I would not be
able to judge. I think you have done some of that already, but we
would certainly want you to do more than that if at all possible.
Number 10 in the recommendations is a suggestion to the admin-
istrators of the various Federal agencies to realize when something
is put into effect like the Federal handicapped bill, 94-142, that
many states have already developed rather large data bases on this
very topic and that to the extent we could coordinate efforts with
state collection systems, many times we could be answering ques-
tions for both state laws on handicapped as well as Federal laws on
handicapped.
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I think many times that coordination has not taken place be-
tween the states, the Bureau of Handicapped and the NIE, and
other groups.
I think as a good example, we missed to some extent on the
bilingual-bicultural. We had 12 states working in this area collect-
ing information that could have been a data base that could have
fed into the NIE study, so that again federal data could have been
interchangeable with state data, and likewise our dollars could have
been used for something that would have been used ultimately by
NIE, an opportunity that was lost as that study progressed.
Finally, the idea that if at the Federal level there is a realization
that as states improve their data collection ability and capacity, this
ultimately helps the Federal Government. We have appreciated, as
I have indicated before, the idea that OE and others have helped us
develop our system. We are doing a better job than we were 5 years
ago, and to that extent I think your data collection at the Federal
level is better.
Let me close on a positive note. I do think contributions have
been made by the Federal Paperwork Commission, by the Educa-
tion Data Acquisition Council, by our own Chief State School
Officers Committee on Evaluation and Information Systems. It has
been encouraging to me to find so many of our congressmen, as we
met with them, aware of the problem and wanting to do something
about this. So I think the climate is there, the National Center for
Educational Statistics and our previous speaker have helped this.
There is a good cooperative feeling there. So I am not as
discouraged.
I might mention the Rocky Mountain News, one of our major
papers, had an editorial called "The Paperwork Disaster." I have
attached that to my testimony not because I agree with it or that it
represents the Chiefs' points of view, but only because this is typical
of editorials that are appearing almost every three or four weeks in
either the Denver Post or the Rocky Mountain News and reflects, I
think, a national interest in this particular topic.
So collectively I hope we can work on this, the states and the
Federal agencies and Congress. I appreciate the opportunity to be
here this morning.
Mr. WEISS. I wonder if you could start your testimony, Mr. Peek,
and by that time the chairman will be back.
STATEMENT OF WILLIAM PEEK, ASSISTANT TO THE STATE SU-
PERINTENDENT, NORTH CAROLINA DEPARTMENT OF PUBLIC
INSTRUCTION
Mr. PEEK. I bring to the committee, similar to Dr. Frazier, my
perspective and viewpoint. Although from North Carolina, it has a
similar kind of base to the one he gave to the committee.
[The statement of William Peek follows:]
91-860 0 - 77 -- 23
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PAPERWORK PROBLEMS
IN
ELEMENTARY / SECONDARY
EDUCATION PROGRAMS
A Statement to the Subcommittee on Elementary, Secondary, and
Vocational Education of the Committee on Education and Labor
Wednesday, May 25, 1977
by: William W. Peek -
Assistant to the State Superintendent of Public Instruction
North Carolina Department of Public Instruction
Raleigh, North Carolina
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Mr. Chairman and Distinguished Members of the Committee:
It seems to me to be appropriate that I begin by expressing our
appreciation for this opportunity to present to you the viewpoint and concerns
of the North Carolina Department of Public Instruction regarding paperwork
problems in elementary/secondary education programs. This viewpoint and
accompanying concerns will not, I am sure, be completely new to you since
they are shared in by most of the state and local education agencies in the
Nation. Despite this fact, however, it is heartening to be given the
opportunity to express our own version of these concerns to those who are
in position to make decisions that will lessen or eliminate the problems---
and for this opportunity, we are grateful.
The North Carolina Department of Public Instruction, an extension of
the Office of the State Superintendent of Public Instruction, recognizes
and understands the needs of Congress and of the United States Office of
Education for educational data and supporting information. We are also
keenly aware of the massive response burden placed on state and local
education agencies by ever-increasing data collection requirements. Our
purpose in making this statement is to suggest ways in which data can be
collected, analyzed, and disseminated, without at the same time overburdening
the state and local education agencies which must respond.
Lead Time
Congress, federal agencies, and state education agencies must give more
thanlip service to the concept that data are not created in a vacuum. Valid
data can be collected Q~jy if the data items to be collected are known at the
lowest reporting level pri~. to the beginning of a reporting period. In order
to maintain data that are valid, it must be known at the individual classroom
PAGENO="0356"
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-2-
level at the opening of the school year exactly what information will be
requested at the end of the year. Further, if the data are to be maintained
in a realistic and easily retrievable format, it is essential that the
reporting format itself be known at the individual school level from the
beginning of the reporting period.
Consistency
A closely related factor is that of consistency and uniformity. The
most frustrating thing possible to the respondent is to have anticipated
one reporting format only to be faced with a different format after the fact.
Even though the data items themselves may be very similar, the manner in
which they have been captured for one reporting format may be entirely
unsuitable if a different reporting format is used. Changes to reporting
instruments should not be made lightly, and changes should never be made
without sufficient lead time being given to the respondent.
State Plans
Congress has made possible greater flexibility on the part of state and
local education agencies by including the `state plan" approach in legislation
authorizing a number of elementary/secondary education programs. Under this
legislation, the states are theoretically able to write plans for administering
educational programs in a manner that is both educationally sound and
practical for that state. It is of great concern in North Carolina and in
most other states that the United States Office of Education has designed
state plan formats that decrease flexibility, minimize originality, and
generally thwart any possibility for preparing the kind of clear, concise, and
understandable document that Congress apparently intended. Indeed, USOE
designed state plan formats have resulted in the preparation of voluminous
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-3-
documents that often substitute verbosity for clarity. Title IV, ESEA, state
plans are a noteworthy example. North Carolina's Title IV plan for Fiscal
Year 1978 is sixty pages long.
We urge that new legislation require the submission of a state plan in
the initial ~Lof operation ~ with the initial plan providing for changes
in subsequent years through the process of amendments to the initial plan. It
is further recommended that new legislation provide that statements of
assurance shall be sufficient in most instances in lieu of the detailed
documentation which is required all too often in current plan formats.
Annual Performance or Progress Reports
It is reasonable for Congress to expect that annual performance or
progress reports should be useful to USOE and to Congress in assessing
program effectiveness. For this reasonable expectation to be factual, it is
essential that state education agencies be able to provide to local education
agencies at the beginning of the prdg~~ ~ an accurate analysis of the data
they must maintain for reporting purposes. Despite this rather obvious fact,
states often do not know what data should be maintained during the year since
reporting forms seem to evolve during the program year, and final drafts of
the report forms are sometimes not available until well after the program year
has ended. State education agencies then wind up playing a no win guessing
game--either they collect massive amounts of unnecessary data that nobody
needs or they run the risk of having insufficient data to complete reporting
forms that are not developed and distributed until the program year has ended.
We suggest that all reporting instruments be finalized, reviewed, and
approved by the National Center for Educational Statistics, and distributed
to the states no later than nine months prior to the due date for the report.
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-4-
It is further suggested that program administrators be required to justify
each data item contained in any reporting instrument by documenting the
authority under which it is collected and the use that is to be made of the
data after it is collected. It is our belief that the quality of data will
be markedly improved, paperwork will be diminished, and all educational needs,
including Congressional needs, will be better served if these steps are taken.
Improved Coordination at all Levels
We have talked for years about the fact that redundancy in reporting
continues to exist, that the same data items appear over and over again in
different reports--but talking about it has not changed the fact that it
continues to exist to a far greater extent than most of us are willing to
admit. It is our contention that a reasonable solution to this problem
exists through the establishment of a "common core" of educational data in
the National Center for Educational Statistics with an accompanying mandate
to program administrators that prohibits the collection of items of data
included in the "common core" from any source other than NCES. States have
had a reasonable degree of success in implementing this concept through
management information systems, and there is no reason to assume that it
cannot be implemented successfully at the federal level provided Congress
provides initial direction and support.
Civil Rights Data
North Carolina's Department of Public Instruction has a firm and continuing
commitment to provide equal educational opportunity to every child. We
believe our record of support for human rights is unsurpassed by any state.
Because we have consistently demonstrated this commitment and support, we have
not hesitated to speak out when we found ourselves to be in disagreement with
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-5-
processes that we believe to be counterproductive, even when these processes
have emanated from the Office for Civil Rights.
The amount of paperwork generated by the data collection mandates of
the Office for Civil Rights during the past 12 months is simply unbelievable.
Initial discussions between the Committee on Evaluation and Information
Systems, a permanent committee of the Council of Chief State School Officers,
and representatives of the Office for Civil Rights gave every indication
of achieving some common understandings. At a meeting held in June, 1976,
there was a general understanding by all participants that OCR accepted the
fact that several data items projected for inclusion in the 1976 survey
(forms OS/CR 101 and 102) had not been maintained in 1975 in the format
proposed for collection. It was generally understood that these items were
to be eliminated from the final version of the report form. Instead, the
form as finally distributed contained not only the items that had been
agreed on as items that were difficult or impossible for local education
agencies to provide but also included additional items of the same
that had never been included in discussing versions of the report. As has
been pointed out by the Commission on Federal Paperwork, a by-product of such
insensitivity and lack of understanding of the burden imposed on respondents
can only bring about an "atmosphere of hostility within educational institutions"
toward both federal and state governments.
In addition to the fact that the need for lead time for respondents
and the need for consistency in reporting instruments were both ignored by
OCR in preparing the 1977 survey, they also rejected input from the states
in other important aspects of the survey. Supposedly a national sample,
the survey in fact included response from all 16,000 plus school districts
in the Nation to form OS/CR 101, plus reponse from all of the individual
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-6-
schools in 3,500 school districts having relatively large minority populations
to form OS/CR 102. In North Carolina, this included responses from all 145
local education agencies to form 101 and response from each individual school
campus in 117 of the 145 local education agencies to form 102. Calculations
based on a 20 percent sample of the North Carolina local education agencies
involved indicated that this survey involved more than fourteen man years of
effort that cost the state in excess of a quarter of a million dollars---!!!
Because of the storm of protest from all states because lead time and respondent
input were totally ignored, OCR has already announced that an identical survey
will be carried out in October, 1977, despite the fact that no information is
available from earlier surveys and no schedule for processing this year's
data has been announced!
A very considerable amount of the information requested by the OCR survey
forms is already included in state plans, projects, and report forms of
other federal agencies, particularly those dealing with the Emergency School
Aid Act and the Equal Employment Opportunity Act. Increasingly, similar items
are being requested by such agencies as the Bureau of Adult, Vocational, and
Technical Education and the Bureau for Handicapped. There is no justifiable
reason for failing to capture these data items one time ~]y~ during each fiscal
year and requiring that each agency use data from this comoncore rather than
requiring it separately for each function.
We are convinced--and many other states share our conviction--that OCR,
EEO, and other agencies dealing with monitoring compliance must get out of
the business of routine, massive data collection. We believe that Congress
should direct that the data collection function in elementary/secondary
education become solely the responsibility of HEW's Assistant Secretary for
Education with the advice and consent of the Office of Management and Budget.
We further believe that all components of the United States Office of Education
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-7-
and of all other federal agencies which collect data from schools should be
required by Congress to collect data only as approved by the Assistant
Secretary for Education, with appropriate input from the Committee on Evaluation
and Information Systems of the Council of Chief State School Officers.
Zero-Based Reporting
A conceptual approach that should be most helpful in reducing the
paperwork problem has already begun in a very limited way. It involves
self-monitoring by the staff of each proposed data collection instrument to
determine:
(a) Can this report be eliminated?
(b) Can it be amended and reduced in scope because some of the
information is already available in other agencies?
Cc) Can the response burden be justified in terms of the value of the
information sought?
It is our opinion that this self-monitoring concept should be expanded
by setting up within the National Center for Educational Statistics in the
Office of the Assistant Secretary a unit that provides continuing monitoring
of all educational data collection instruments submitted for approval, using
the criteria set forth above. It seems realistic to require that such an
evaluation be made prior to submission of the form for final approval by the
Office of Management and Budget.
Surveys and Sampling
Many of us continue to be concerned regarding the impact of multitudinous
surveys on the paperwork burden of local education agencies. Because sample
selection is carried out at the federal level in the interest of insuring a
representative "national sample and because potentital respondent groups are
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358
-8-
generally stratified by size (population), there is a strong tendency for the
same local education agencies to appear in survey samples on a recurring basis,
thereby compounding the paperwork problem for those particular agencies. It
would seem to us that some limitations should be established covering the
number of surveys in which a state would be asked to participate in a given
year, with some limitations imposed on the sample size or number of participating
local education agencies selected in each state. In any event, a realistic
approach to the reduction of paperwork burden must include an analysis of
the impact of sample surveys on state and local education agencies.
Dissemination
It seems obvious to us that all data collection should be based on a
definitive plan for the specific use of the data collected, including a
schedule for analysis of the data and a schedule for dissemination of summary
findings as other reports. A requirement for submission of such plans to the
Assistant Secretary of Education p~j~ to the collection of the data, coupled
with requirements that schedules contained in the plan be strictly adhered to,
will almost certainly have a very salutory effect on reduction of future
paperwork burden.
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Mr. PEEK. Added to that is perhaps the fact that in my daily work
I am in constant contact with local superintendents who add a great
deal to my own knowledge of the problem as it exists in each of the
local school districts.
I want to express my appreciation for the opportunity to bring to
this group our viewpoints and our concerns-and we do have them.
I will be able to be quite brief in that many of the points that were
made by Dr. Frazier are points that are contained in my own
testimony, and that is not surprising in view of the fact that I have
been a long-time member of the CEIS committee, the Committee on
Education and Evaluation of Information Systems, that is, a perma-
nent member of the Chiefs. We have been on that since its incep-
tion. We probably have very common outlooks on the problem and
the scope of the problem.
I would add one thing that is perhaps to tie together some of the
points that have been made. I see at both the state and Federal
level a kind of educational syndrome that deals with program
administrators feeling that the success of a program is to some
degree measurable in the amount of data collected about that
program.
We talk a great deal about coordination of data collection efforts,
which is the root cause of the paperwork problem that we deal with.
The coordination is not going to just happen. It has to be imple-
mented through a group of people who are authorized by statute or
otherwise to implement a coordinative program and they are going
to have to have the necessary support to get the job done.
I would like to underline two or three things that were included
in my own testimony and that of Dr. Frazier. The lead time element
is of total importance in terms of getting not only valid data but in
terms of making the collection of data, even limited amounts, a less
than traumatic experience. It is essential that that lead time not
involve simply a few people who are knowledgeable about what is
going to be collected for the next ensuing reporting period but that
that knowledge be available to the persons who actually collect the
data in the individual classroom back in the hills of North Carolina
or Colorado or elsewhere. They need to know what questions are
going to be asked of them at the end of the reporting period, and
they need to know that before the reporting period ever begins
because otherwise they cannot collect the data.
A similar sort of need exists in terms of the consistency and
uniformity of the format on which the data is collected. Even a
minor change in a reporting format may also involve a major
change in terms of how the data is compiled in the individual
classroom and individual school level. Changes should not be made
lightly and they should never be made without giving due notice to
the people involved.
I think we are very much in agreement that there is a need for at
least lead time from January 1 of a particular calendar year, from
that point until the reporting date, which usually falls in the fall of
the year.
How do we get that 9 months' lead time? It can only be done, in
my judgment, if it is done through some legislative enactment that
speaks to the issue of data collection for educational programs and
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assigns responsibility and provides support to a particular group of
people.
As to the Assistant Secretary for Education, insofar as education-
al data is concerned, I think Congress made a very wise decision in
placing the National Center of Education Statistics under the
Assistant Secretary. I think a followup step to that that would be
most helpful would be to provide more specific responsibility for
coordination to the Assistant Secretary and provide support for the
organization that is going to implement that for the Secretary.
I would like to commend the persons in Congress who are respon-
sible for legislation that results in certain programs being imple-
mented through a state plan concept. The flexibility that was very
apparently intended by Congress in providing for such a concept
has to some degree been thwarted by the construction of planned
formats by program administrators within the office. That means
that plans now have become quite voluminous documents. They are
not the clear, concise statements of objectives and strategies and
evaluation procedures that the Congress intended, but have become
rather verbose documents.
Title IV of the Elementary and Secondary Education Act is
somewhat a case in point. This was a consolidation of their former
programs and the single state plans should have meant more
flexibility to local states and thereby local agencies. To some degree
we have lost it in terms of the amount of material that are involved
in the state plan format. The North Carolina state plan for Title IV
is some 68 pages long, and that seems to be rather voluminous.
We would suggest that the state plan concept that is now em-
bodied in some educational legislation be expanded but that it
provide for the submission of a full state plan in the first year of
operation and provide for amendments to that state plan for gener-
al users of operation, rather than a second and a third and fourth
state plan that contains about 90 percent of the material that is in
the original plan with certain amendments thereto. We think that
would go a long way toward eliminating the paperwork burden.
The annual performance and progress reports should be valuable
to Congress, to USOE, in determining program effectiveness. We
think they are to the degree that the data items that are to be
reported and the reporting format is available to the people who
actually generate the data in the school district. If they know about
it early enough, these are valid data that should be very useful to
Congress and the USOE.
The civil rights surveys and other civil rights data have posed
recent problems not because there is any reluctance on the part of
any state to provide civil rights data; the problem seems to be one of
providing that data which is needed for operational effectiveness.
We have a proposal to make with regard to that particular thing.
The data that is needed in the civil rights area we have now and
will be able to generate in the future.
This applies not only to OCR but to other monitoring agencies. It
is our belief that the monitoring agencies whose primary concern is
compliance with civil rights of all types need to get into the routine
data collecting basis, into the enforcement, and data needs to be
provided to them. Rather than surveying 16,000 school districts to
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obtain data that may or may not be used, they selectively get data
through a central coordinating agency, which we would suggest
would be the National Center for Educational Statistics in the
Assistant Secretary's office.
There is one new concept we are using with some success in
North Carolina, the so-called zero-based reporting. We are looking
at every form that goes out of North Carolina state agency and
asking some questions about it. We think it would be completely
appropriate for the same kinds of questions to be asked at the
Federal level. The first question we ask is, can this report be
eliminated? We have found some that can be eliminated.
The second thing is if it can't be eliminated, can it be amended
and reduced in scope, because the information is available else-
where in the state agency or elsewhere in the Federal agency, if
that is what we are talking about.
I think that would cut out a tremendous amount of reporting if
there was some cross-fertilization so far as data already available in
one agency or another.
Finally, can the response burden be justified in terms of the value
of the information sought? We have done some sampling of costs
estimates. I will give you only one example. We are certain that
OSR Forms 101 and 102 cost the State of North Carolina just under
$300,000, and that does not include any expense at the Federal level
at all.
Chairman PERKINS. Let me thank you and Mr. Peek for your
appearance here. I know your school superintendent in North
Carolina; give him my good wishes.
Let me compliment you all. I will start with you since you
completed the testimony, Mr. Peek.
Yesterday the superintendent from the State of Arizona told us
that she has cut back by 60 percent on paperwork in Federal
programs. Have you studied that effort and tried to do the same
thing in your state? I would like all of you to respond to that
question.
Mr. PEEK. Yes, sir, I can respond for North Carolina. We have
perhaps not been as successful as the Arizona superintendent. We
have cut back approximately 40 percent on what we were formerly
doing, and we did that because we collected it one time and then
transferred it to various state agencies, who in turn reported it to
their counterparts in USOE.
Chairman PERKINS. You go ahead and answer the same question,
Ms. Eldridge.
Ms. ELDRIDGE. In terms of the National Center's efforts on reduc-
ing the burden on the forms that are out in the field which have
passed the review, the major thrust has been achieved in our state
assistance and personnel exchange programs, where we are at-
tempting to make available to the states the expertise that other
states have developed in data processing and systems so that they
can improve their own capabilities.
The long-term goal is to reduce the amount of paper to the extent
that we can have the states provide the data to us in automated
fashion. We have no problem whatsoever in accepting tapes which
we can utilize. As long as the tapes are fully documented, there
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need not be specific pieces of paper transmitted. This is not some-
thing that is going to happen overnight, but this is one of the major
goals of our state assistance program.
Chairman PERKINS. Go ahead, Mr. Frazier.
Dr. FRAZIER. We could not claim the results Arizona did, although
we did many of the same measures. I think our reduction in
Colorado was about 16 to 20 percent, which was still substantial,
but fortunately for us it came at a time that that new law was being
implemented on handicapped which jumped it up, but we went
back.
Chairman PERKINS. I am going to ask the minority counsel here if
he has a question.
Mr. RADCLIFFE. Ms. Eldridge, do you have any percentage figure
or any guess as to the percent of data requests that are being
generated by the Office of Civil Rights?
Ms. ELDRIDGE. Are you referring to what has been imposed by the
Office of Civil Rights?
Mr. RADCLIFFE. Yes.
Ms. ELDRIDGE. That is really all we can talk about. I do not have
it in terms of percentage but I do have some figures which I have
received from the 0MB. You will recall that the responsibility to
review the OCR data collection efforts was not in force when the
spring 1976-77 survey hit the field this year. The figures I have on
the 101, which involved 16,000 districts-that was the universe
study for 1976-77-was estimated by the Office of Civil Rights to
involve 3 hours per state. That is an average that is used. When you
aggregate that, it is roughly 48,000 man-hours of burden on the 101.
On the Form 102 which went to about 47,000 schools, in a sample
of some 3,700 districts, the burden was estimated at an average of
about 5 hours per school, which aggregated about 235,000 man-
hours' burden. Therefore, the combined burden of the Forms 101
and 102 for the 1976-1977 survey would come to about 283,000 man-
hours.
Mr. RADCLIFFE. Are there any other surveys on the man hours
required for the total request of the Office of Education?
Ms. ELDRIDGE. I would like to ask Mr. Stolzenbach to address
that. He has the tables which we are submitting into the record.
Mr. STOLZENBACH. In the tables I have submitted for the record,
for the elementary-secondary school system the estimated man-
hour burden is approximately 1.2 million man-hours.
This breaks down into 56,000 man hours for state agencies,
760,000 man hours for local agencies and 370,000 for other miscella-
neous types of state and local respondent agencies and institutions.
Mr. RADCLIFFE. Is that an aggregate of about one million man
hours?
Mr. STOLZENBACH. Yes, and this is just for the Office of Education.
Actually NCES represents about .7.5 percent of the total man hours
of the entire burden on the elementary-secondary school system
and NIE about 2.5 percent. Of the OE data collected, program
management, including applications, and evaluation data, represent
90 percent of the total burden on the elementary-secondary school
system.
Mr. RADCLIFFE. It comes from OE?
PAGENO="0367"
363
Mr. STOLZENBACH. Yes.
Mr. RADCLIFFE. How soon will the Education Data Acquisition
Council be able to clear all forms by January 1st for the collection of
data? At what point will you arrive at a position, where in January
1, 1978, you will have all the forms cleared that are going to be used
in the school year beginning in September?
Ms. ELDRIDGE. I believe they are pretty much there now. We have
respected the request of the Council of Chief State School Officers
to give them nine months' notice. This is, of course, not possible in
the Office for Civil Rights, and again, I reiterate, the 1976-77 survey
didn't come through EDAC. It is a continuous process. I don't think
we will ever come to one hundred percent because crises do arise.
Mr. STOLZENBACH. I estimate that, with the momentum achieved
since the beginning of EDAC operations last April, by this time next
year we will have reviewed practically all of the reporting activities
of the Education Division; and while I don't really know what the
volume of activities coming from the Office for Civil Rights will be, I
don't believe, in terms of numbers of forms and reporting require-
ments it is going to loom large.
It is interesting to note in this connection that, of the OE forms
that are placed on the elementary-secondary school system, it is the
first 20, in terms of man hour burden ranked in descending order,
that account for 80 percent of the total OE burden.
We are certainly going to get to all of those, probably within the
next 6 to 8 months.
Mr. RADCLIFFE. I would imagine a large part of the problem rests
in the varying demands made in Federal legislation, one piece of
which originates in one subcommittee and one in another. Some-
times they are not at all well coordinated, particularly in terms of
data demands and that sort of thing.
Are you reviewing the legislation and in order to be in a position
where the Department can make recommendations for consolidat-
ing these demands, cleaning them up and reducing them where
they are unreasonable?
Mr. STOLZENBACH. The last paragraph in Subsection 406(g), which
you enacted last year, invites that kind of inquiry, and we are
certainly going to do it. We are going to first start with the
regulations which contain reporting requirements and determine
those areas in which the program managers find they don't really
use information called for by regulations written years ago. Certain-
ly we have it within our own powers to initiate modifications or
elimination of those regulations.
You are quite right, there are duplicating and overlapping and
sometimes conflicting legislative requirements and the President
has directed the Department to look at such situations and make
recommendations to the Office of Management and Budget for
corrective legislative proposals.
Mr. JENNINGS. If I could point out in that regard, on February 8th
Congressman Perkins sent a letter down to Secretary Califano
asking for assistance from the department in giving us suggestions
on how the career education bill could be better drafted to elimi-
nate any duplicative requests for information that might result.
PAGENO="0368"
364
On February 26th the Secretary sent back a letter saying he
would be more than pleased to do that and he directed the National
Center to give us a memorandum by March 1st. We reported the bill
in March. It was passed on the House floor in April and we have yet
to receive anything from the National Center for Education Statis-
tics regading suggestions for how that type of legislation could be
improved to avoid duplicative requests. I think there was an at-
tempt on the Chairman's part with that particular bill to try to do
away with any legislative requirements that might cause unneces-
sary paperwork and we have yet to receive anything even though
now the House has passed the bill.
Ms. ELDRIDGE. That is a very difficult thing for me to respond to.
Mr. JENNINGS. I know it is difficult. I just want it to be on the
record that in this instance Chairman Perkins did try to cooperate
with the department ahead of time in order to do away with any
legislative requirements that may impose unnecessary requests and
we did not get cooperation from the department, for whatever
reason.
Ms. ELDRIDGE. Are you telling me that at no time, as of this date,
you have received a response on that?
Mr. JENNINGS. That is correct. I hope the Senate is able to receive
something before they mark up their bill.
Mr. RADCLIFFE. Well, that is a problem.
Mr. PEEK. May I add one thing to what has been said about the
impact of OCR reports as compared to OE reports? The estimates
given of the respondent time for OCRs, they would have been, I
think, valid and accurate estimates if the lead time that I referred
to earlier had been given.
In view of the fact that many of the questions asked had been
totally unanticipated by the persons responding to the report, the
estimates themselves are invalid. I would say it is more like three
times the amount of time that they are talking about.
We did some sample surveys to try to assess respondent time and
it came out more than three times the amount of time involved that
was given in the OES.
Mr. JENNINGS. May I ask a couple of questions?
Let me apologize to you all first of all for the absence of the
members this morning, but the House went into session at ten
o'clock. Because of the new budget act all the authorizing bills have
to be reported from committee by May 15th and then the House and
Senate. have to finish all their work over the summer. They have an
avalanche of bills facing them in the House and they have to go in
early every day and stay late to get those enacted.
There are also two other subcommittees meeting this morning
which present some competition also. But the printed hearing
record will be very valuable in this regard.
Let me ask you two questions having to do with particular
amendments. As I see it, there is some concern about particular
program requirements, whether resulting from legislation or result-
ing from regulations, and there is also a concern about administra-
tive practices ~vhich seem to build up on their own and cause
unnecessary requests.
Would anybody have any problem with an amendment which
would in fact require that any data requests have to be announced
PAGENO="0369"
365
by January 1st before they could go into effect for the succeeding
school year? Are there any practical problems with putting that
into legislation and then possibly putting in a waiver provision for
extraordinary circumstances or emergency situations? Ms. Eldridge,
if you could respond first.
Ms. ELDRIDGE. I am thinking hard and fast about that in terms of
implications. We are currently trying to abide by that with regard
to the nine months lead time. I would prefer that it not be
specifically legislated, but we would certainly attempt to conform as
best we can.
Mr. JENNINGS. It would be appreciated if you could submit a
memorandum for the record.
Ms. ELDRIDGE. I will be glad to do that.
Mr. JENNINGS. There may be some problems.
[The information requested of Ms. Eldridge follows:]
Affording respondent's a nine-month lead-time has been our goal; however, it is
not always practically possible-particularly in the case of a new program requiring
an extensive hearing process before the regulations can be issued, or, in the case of
evaluation studies that require a contract effort to design the survey and for which
contracts can't be awarded until appropriations are enacted. If the Congress wishes
to assure such a lead-time, it would be preferable to make it a specific stipulation in
each legislative authorization and in each appropriation.
Mr. STOLZENBACH. I would only see two areas in which it might be
a problem. First, where the Congress enacts a new program, say in
late summer or early fall, and it is expected that this program will
be put into effect as soon as possible. Second, in the case of some of
the extensive evaluation studies, for which the money is not appro-
priated until late in the year, the time required to crank up the
evaluation study and let a contract puts the Office of Education in a
very difficult time-bind.
If you were to consider such legislation, I think these two prob-
lems should be recognized.
Mr. JENNINGS. Are there further comments?
Dr. FRAZIER. I think that is a sound direction in which to go. Your
suggestion of a waiver I think might cover the kind of things Mr.
Stoizenbach would be talking about.
I think it would tend to force agencies to justify anything short of
the 9 months warning and at least allow us a chance to present our
case to somebody as to why this is going to pose a problem and also
the problem discussed in the validity of the data they are going to
get. It would give us a hearing, I think, with the kind of provisions
you are talking about, that would not now exist.
Mr. PEEK. I would endorse what Dr. Frazier is saying. I would add
to that that with a waiver provision it might very well be a valuable
tool for EDAC and NCES, in that it would speak to program
administrators who are sometimes a little slow in preparing materi-
als which you need to evaluate. I think that might be a plus from
their point of view.
Mr. JENNINGS. My second question on amendments has to do with
applications. I think the tables just brought up this morning are
very valuable. I hope people are able to study these a little bit but
from what I understand, the third table you have here shows the
total number of-is it man hours?
91-860 0 - 77 -- 24
PAGENO="0370"
366
Mr. STOLZENBACH. Yes.
Mr. JENNINGS. Consumed in data collection. 767,000 out of
1,190,000 man-hours are consumed with the application procedure,
261,000 for program management, and 162,000 for evaluation
activities.
Now, if the application procedure consumes this much time,
which I guess is almost 65% of the amount of time consumed in
data collection, possibly some attention should be directed towards
the application process.
One thing which has been suggested at several meetings is that
possibly in some programs such as Title I of the Elementary and
Secondary Education Act, instead of requiring an annual applica-
tion there would be an application which would be good for two or
three years. In particular, it has been suggested that the needs
assessment required by the legislation does not necessarily have to
be done every year, but rather it can be done every two or. three
years.
I would like to know whether any of you have any comments on
that type of amendment which would loosen up the annual applica-
tion requirements and make applications good for two or three
years in certain types of ongoing programs.
Mr. PEEK. I spoke partially to that in talking ~about the state plan
concept and the fact that we would very definitely favor an initial
state plan or initial application that could be amended by simple
amendment rather than by the initiation of a completely new plan,
or application.
Ms. ELDRIDGE. You undoubtedly noticed in the Washington Post
yesterday that Secretary Califano has killed the Basic Opportunity~
Education Grant application form. This action, of course, is not
reflected in the data we are presenting here. It is that sort of thing
that I think has to be looked at very carefully.
Mr. STOLZENBACH. We are trying, in EDAC, to squeeze out of
these applications all of the data they are asking for that are not
absolutely required in order to ascertain eligibility for the grant.
Needless to say, with 125 different programs, and with a body of
regulations which has been built up over a long period of time, this
is not an easy matter. We are trying to bear down very hard on this.
Dr. FRAZIER. We would like to just indicate support for what you
are saying. I think the Chief State School ~Officers have been
concerned that until we get to where we have three-four year long-
range plans with only submitting amendments to this that it is one
thing that is preventing us from getting to the third item on this
agenda and that is the evaluation.
In my own department, I spend so much time on the application
that when I come back to press for discussions and evaluation and
the progress being made, and changes based on those things I am
frustrated in getting the time devoted to that which goes to the first
so when you connect the two I think what you are suggesting is
very important.
Mr. JENNINGS. The only problem I see to it is assuring there is
enough of an audit trail so that there is no problem when the
auditors come in later for any type of review to assure that the
funds were spent for those purposes. But, from what I understand,
PAGENO="0371"
367
in many instances local school districts now just Xerox their needs
assessments from the prior years and keep them going forever. It
doesn't seem as if that requirement is resulting in much right now,
and possibly some thought should be given to changing it, as long as
an accountability is kept in there for use of the funds.
Mr. RADCLIFFE. Back under EDAC, I don't understand Table 1.
What is a data acquisition activity?
Mr. STOLZENBACH. This is a term that you used in Section 406(g).
We had previously called them data acquisition systems. Any form,
survey, instrument or reporting requirement that is subject to the
Federal Records Act of 1942.
Mr. RADCLIFFE. Secondly, on the status of these, you have the
terms proposed and approved and you seem to have more approved
than proposed. I don't understand.
Mr. STOLZENBACH. This is the plan for the next fiscal year. We
have a Form ASE 1000 on which we ask sponsors to describe all of
these data acquisition activities. In the spring of each year, we ask
for those they intend to use in the ensuing fiscal year. These 94
proposed ones are in our inventory for the fiscal year 1978, but the
sponsors have not yet come forth with the specific details so that we
can review them.
Mr. RADCLIFFE. So if all of those are approved, you will increase
the number by about one-third?
Mr. STOLZENBACH. I should add, over the years I have observed-
looking back at some of the statistics there seems to be about 100
new forms every year. Some of the 351 are one-time surveys or
reports, so that it doesn't mean there are 351 continuing ones, but
once we get caught up, the annual review of new activities will
probably be on the order of 100 a year; maybe somewhat more than
that when we start getting into the OCR ones.
Mr. JENNINGS. Ms. Eldridge, you pointed out you had in fact
turned down some data requests for the first year and you tried to
explain that in terms of the number of man hours which would
have been consumed. What percentage of the total data requests
made to you did you turn down during the first year?
Ms. ELDRIDGE. We turned down seven out of 156 reviewed and we
modified 17.
Mr. STOLZENBACH. I might add that the modifications reflect a
much more important amount of burden reduction than the ones
that were actually killed.
Mr. JENNINGS. Did I understand your statement correctly when
you seemed to imply that during the second year you thought you
would have much better control over the situation and would in
fact be turning down more requests and modifying more requests?
Mr. ELDRIDGE. I believe we are learning as we are working
through the system.
I should also mention that there is certainly a reasonable data
burden reduction that we will never measure in that the mere
presence of EDAC has imposed on the program sponsors a greater
sensitivity to answering the questions of necessity, redundancy,
etcetera, which are the criteria that they must meet to pass through
EDAC. So I believe there is a much stronger front-end effort on the
part of the program sponsor in terms of presenting to us what they
PAGENO="0372"
368
think will pass the EDAC review. That, of course, we cannot
measure, but I think it is there.
Mr. JENNINGS. Are you also looking at the entire clearance
procedure within the Administration? As I understand it, there is
an internal Office of Education review of data requests and then
there is a review by your council, and then there is also a review by
the Office of Management and Budget. So there tend to be three
reviews and sometimes reviews within those reviews.
I have been told that for a typical evaluation request from the
Office of Education it can take up to 17 months for the usual
request to go through from the initiation stage tO final approval by
0MB. Now, is that statistic accurate for most requests for data and,
secondly, are there any duplicative steps in this procedure? Are
there too many reviews, should there be a centralized review
somewhere in the process?
Ms. ELDRIDGE. There are three reviews. I can't verify the figures
that you cited as being the valid ones at this point.
Let us talk about the process in the Office of Education, some-
thing external to NCES. The Office of Education has its own
clearance officer who has the responsibility to negotiate with 0MB.
There have been discussions dealing with this process. We are
currently considering the possibility of merging those functions into
EDAC. It is not at all clear at this point whether that is a wise
thing to do at all.
Mr. JENNINGS. Merging the 0MB review and yours?
Ms. ELDRIDGE. That is correct. It is not clear at this time, and I
am not taking any position on that other than to say we are looking
at it very carefully.
In terms of the redundancy with 0MB, the Associate Director of
0MB, Mr. Duncan, sits on our EDAC Council as an active partici-
pant and is extremely supportive of EDAC and conceives EDAC as a
very important front-end review which does minimize the review
that has to take place at 0MB.
If EDAC functions properly, then all the redundancy problems
within the Education Division presumably will be handled and the
0MB then needs only to look at redundancies with other agency
requests.
Dr. Duncan has been extremely supportive of the EDAC oper-
ation. I do not believe there is a redundancy between the EDAC and
0MB
Mr. JENNINGS. Another complication has to do with other re-
quests in other agencies of the Federal Government with regard to
educational institutions. We were left with the impression yester-
day from the testimony of Congressman Horton of the Commission
on Federal Paperwork that the Office of Management and Budget
was considering not only giving your review council more responsi-
bilities as regards the 0MB review, but also expanding your respon-
sibilities so that possibly you would be reviewing other requests
from other agencies outside the education division. Do you know
anything about that?
Ms. ELDRIDGE. The Council of Chief State School Officers passed a
resolution last year to the effect that they would like to see the
National Center for Education Statistics be the focal point for all
data collection efforts.
PAGENO="0373"
369
I believe the provision in 94-482, which gives us the responsibility
to oversee the Education Division, and has expanded it now to OCR,
is a step in that direction. But with the current staffing level and
the budget which we have, I would not welcome that expansion at
this point.
Mr. JENNINGS. Do you believe that you have sufficient staff right
now to fulfill the duties given you by the Education Amendments of
1976?
Ms. ELDRIDGE. No. We are hiring temporaries in lieu of people to
fill permanent slots. The EDAC review function is currently sup-
ported through review groups who do this on a part-time basis once
a week. However, I believe they are not able to do as thorough a job
as they could do if we had a dedicated staff?
Mr. JENNINGS. Ho many people do you have charged with this
responsibility within the National Center?
Ms. ELDRIDGE. We now have four full-time people.
Mr. STOLZENBACH. The major part of the review process is per-
formed by the some 30 people from the agencies who serve on the
EDAC review groups.
Mr. JENNINGS. How many people do you anticipate you would
need to do this job?
Ms. ELDRIDGE. I would be glad to submit that for the record.
[The information requested of Ms. Eldridge follows:]
At present there are only four full-time NCES staff assigned to EDAC review
functions-one senior professional and three administrative and clerical. To enable
us properly to interact with project sponsors and to do a thorough technical review of
each proposed data activity would require a minimum of three additional permanent
full-time professional staff and two additional administrative/clerical positions.
Mr. JENNINGS. If I could ask you one last thing, I notice in your
statement that you cited this study which you are having done on
data requests and data needs, and one of the preliminary findings
you cite in your statement is that possibly the Federal Government
ought to share in the cost of data collection.
Do you have any comments on that? Statistics have been cited
already showing how much it costs per data item, but do you have
any further information about such funding?
Ms. ELDRIDGE. We currently have a feasibility study in the field
on the Common Core of Data. Twenty states have responded. As I
indicated in my prepared testimony, the estimates of the cost, the
incremental costs to respond to common core of data system, are
extremely variable. They range from $3,000 for one state to $1.5
million in another state. The costs depend to a great extent on the
sophistication of the system the state has in place and what data
the state is currently collecting.
Mr. JENNINGS. If I could ask one other question: This last table
you have, table 4, is fascinating in that, as I understand it, it shows
the percentage of the total man hours consumed in data acquisition
within the Office of Education for each of the various education
programs. One program, the Migratory Education Program under
Title I, if I understand the table correctly, consumes 13.1 percent of
the man hours within the Office of Education for data collection.
PAGENO="0374"
370
The thing that strikes me right away is the lack of congruence
between the amount of money involved in funding these programs
and the amount of time used in collecting data on them. The
Migratory Education Program is not a very significant program in
terms of funding and number of students as compared with the
regular Title I program. Yet all these other programs such as the
Title I Migratory Program, and the Community Education Program,
which is a very small program, rank ahead of the first reference, to
man-hours consumed in the regular Title I program. This reference,
which deals with Title I comparability, is probably the most de-
tailed information required in the Title I program, and ranks near
the bottom of the list. Title I comparability consumes 3 percent of
the man hours in the Office of Education, and yet it is a $2.4 billion
program. If you compare that with community education which
consumes almost the same amount of time, 3.4 percent, and which, I
think, has no more than $3.5 million as an appropriation, so you see
there is really a disproportion in the amount of time spent on these
programs as compared to their appropriation.
Dr. FRAZIER. I think there is a feeling on the part of the states
that as we get materials presented to you on the estimated cost of
compiling some of the data, that probably these estimtes are really
quite low in terms of the backup~we know has taken place at the
local level and at the state level. In the prepared testimony there is
a suggestion that perhaps through the Center's work, or others, that
there is kind of a systematic sampling of the cost.
In our state we send a simple card out on sample forms and a
district is asked to report back the amount of time down to a half
an hour that certificated people participated in the studies, clerical
people and others, and finally for an estimate dollar cost.
That is attached to the form that comes back to us with the data.
This gives us a chance to monitor the cost/benefit of the informa-
tion used and so forth. I think somehow at the Federal level just on
some sample basis if you did the same thing states would have a
chance to express to you the actual cost of this. There is talk about
that, but we could encourage that.
Ms. ELDRIDGE. We are currently considering the possibility of
including at the end of every questionnaire that goes out a request
for the estimated man-hours spent and the associated costs so we
will have a better handle on the initial estimates. I think all of us
are quite aware that the burden estimates are rather soft.
Mr. STOLZENBACH. I must reiterate the fact that these estimates
are only the estimates of the project sponsors.
Mr. JENNINGS. Ms. Eldridge, I want to say the congressmen were
impressed with the way you took charge of the National Center and
reorganized it. You put it in much better shape than it had been
before. When they came to considering methods of trying to control
paperwork, they felt you were the person and the National Center
was the organization they could rely upon to at least get the task
started. So I don't think you should take any criticisms which have
come up this morning as personal criticisms. They are criticisms of
the entire process. It is just that the congressmen are very con-
cerned about this problem and they definitely want to do some-
thing. I believe that unless something is done administratively you
PAGENO="0375"
371
are going to have something done legislatively. I think the Congress-
men look upon this control of paperwork amendment which passed
in 1976 as the beginning of an effort to get a better control on
paperwork and I think they would like to build from there. So the
criticisms are meant to try to spur the Administration to get a little
better handle on this type of problem.
Ms. ELDRIDGE. I accept that.
Mr. RADCLIFFE. I would agree with that statement.
I think you are getting this assignment as a result of having done
an excellent job.
Mr. JENNINGS. We will continue at 9:30 tomorrow morning. I
would also like to inform Ms. Eldridge that the Chairman will be
sending her a letter of additional questions we did not have time to
pursue at today's hearing, and, at the Chairman's request, her
response will be inserted in the record.
[Whereupon, at 11:15 a.m. the subcommittee was recessed, to
reconvene at 9:30 a.m., the following day, Thursday, May 26, 1977.]
[Information requested of Ms. Eldridge follows:]
PAGENO="0376"
372
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE ASSISTANT SECRETARY FOR EDUCATION
WASHINGTON, D.C. 20202
2 0 NATIONAL CENTER FOR
JUN 1977 EOUCATION STATISTICS
The Honorable Carl D. Perkins
Chairman, Corrmittee on
Education and Labor
House of Representatives
Washington, D. C. 20515
Dear Hr. Chairman:
This is in response to your letter of June 8, 1977 requesting that we
expand on the information provided at your recent hearings on paper-
work problems in Federal elementary and secondary education programs.
The information shown on the tables furnished at the hearing is based
on an estimate prepared in each program office and submitted to HCES
for use in the EDAC review process. However, any analysis focusing
exclusively on Federal forms is inherently misleading. This is
because some of the laws and regulations governing the various pro-
grams place primary administrative responsibilities on the States,
which in turn generate their own forms requiring no Federal approval.
The program offices at the present time have no knowledge of the magni-
tude of the pass-through effect of these statutory requirements at the
local agency level.
A prime example of this is the diverse way in which two programs under
Title I of the Elementary and Secondary Education Act of 1965 are admin-
istered.
For the ESEA Title I-Migrant program, a Federal application form, the
OE-312, is completed by each applying state, which may, in turn, require
local agencies to submit the same form to them.
In the Title I-LEA program, although there is no Federal application form,
regulations (45 CFR Part 116) issued in accordance with the statute require
States to develop their own application forms that are completed by local
agencies. The States merely assure the Office of Education that the re-
quirements of the law will be met. Thus the usual tabulations of overall
manhour reporting burden do not account for what is iH reality a Federally
generated burden imposed on local agencies. Estimates quickly elicited from
a small sample of States suggest that the State administered Title I-LEA
application process may require from 150 to 400 manhours annually per local
agency, or a national total of approximately 4.5 million manhours.
In addition to such differences in the form of program administration,
another problem in interpreting manhour figures is the fact that
these figures are merely estimates, and in many instances very rough
estimates indeed. It is evident that there are a variety of perceptions
as to what manhours are to be included.
PAGENO="0377"
373
The Honorable Carl D. Perkins
Page -2-
Until the recent upsurge of concern about paperwork, these figures were
used primarily by the Office of Management and Budget in compiling broad
measures of the impact of Federal reporting requirements. Now, with the
President's Reporting Burden Reduction Program, greater attention is
being given to the accuracy and meaning of manhour burden data.
Attached is a chart setting forth the additional information you requested
on Office of Education elementary and secondary education programs, as
calculated from program estimates.
Sincerely,
Marie 0. Eldridge
Administrator
Attachment
PAGENO="0378"
Page 1 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TINE FOR COMPLETING FEDERALLY REQUIRED FORMS,
AND THE FISCAL YEAR 1977 (REGULAR) APPROPRIATIONS FOR SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
Type of Assistance
Authorizing Legislation
Number
(DOOm)
Manhours
Percent
of total
Cumulative
percent
Appr
Dollars
(millions)
opriation
Percent
of total
Cumulative
percent
1.
Programs for migratory
Elementary and Secondary Education Act,
255V
19.7
19.7
131
2.8
2.8
children (0MB 13.429)
Title I, Sec. 122
2.
Programs for disadvantaged
Elementary and Secondary EducationAct,
V,OV
17.8
37.5
1,721
36.8
39.6
children (0MB 13.428)
Title I
,
3.
Vocational education - basic
programs (0MB 13.493; 13.494;
Vocational Education Act of 1963,
Parts B, F, G, H J, and Sec. 102(b)
181
13.5
51.0
535
11.4
51.0
13.495; 13,499; 13.501;
and 104
13.558)
4.
School maintenance and
School Assistance in Federally Affected
121
9.0
60.0
768
16.4
67.4
operation (0MB 13.478)
Areas (PL 81-874)
5.
Indian Education
Indian Education Act (PL 92-318)
88~'
6.5
66.5
25
.5
67.9
(0MB 13.534; 13.551)
*Estimated by OE Program Offices
1/ Figure includes 156,000 manhours to complete the Federal application form, OE-3l2, which is used by an estimated 1,900 local agencies.
2/ Figure includes 164,000 manhours for a one-time evaluation study required by the Education Amendments of 1974 (PL 93-380); not included
are an estimated 4.5 million manhours spent by local agencies using State-administered application forms pursuant to Federal law and
regulations% Figure also includes 72,000 manhours for the ESEA, Title I Comparability Reports.
3/ Figure includes an estimated 75,000 manhours to complete the Indian Student Enrollment Certification form OE-506. This form is completed
one time only by parents of approximately 300,000 Indian students.
PAGENO="0379"
Page 2 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COKPLETING FEDERALLY REQUIRED FORMS,
AND THE FISCAL YEAR 1977 (REGULAR) APPROPRIATIONS FOR SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
Number
(000s)
Manhours
Percent
of total
Cumulative
percent
Appr
Dollars
(millions)
opriation
Percent
of total
Cumulative
percent
6.
Desegregation assistance
Emergency School Aid Act, Title VII
82
6.1
72.6
275
5.9
73.8
(0MB 13.525; 13.526; 13.528;
(PL 92-318) and Civil Rights Aët of
13.529; 13.530; 13.531;
1964, Title IV
13.532; 13.405)
.
7.
Supplementary educational
Elementary and Secondary Education Act,
82
6.1
78.7
20
.4
74.2
centers and services,
Title TV-C
guidance counseling, and
testing for the handicapped
(0MB 13.519)
8.
Education for the handicapped
Education of the Handicapped Act,
65
4.8
83.5
111
2.4
76.6
(0MB 13.444; 13.445; 13.446;
Parts C, D, and F
13.450; 13.451; 13.452)
9.
Community schools
Education Amendments of 1975, Special
54
4.0
87.5
4
.1
76.7
(0MB 13.563)
Projects Act, Sec. 405
10.
Bilingual education technical
Elementary and Secondary Education Act,
34
2.5
90.0
4
.1
76.8
assistance coordination
Title VII
(0MB 13.403)
*Estimated by OE Program Offices
PAGENO="0380"
Page 3 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED FORMS,
AND THE FISCAL YEAR 1977 (REGULAR) APPROPRIATIONS FOR SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
Number
(000s)
Manhours
Percent
of total
Cumulative
percent
Dollars
(millions)
Appropriation
Percent
of total
Cumulative
percent
11.
Bilingual education
Elementary and Secondary Education Act,
34
2.5
92.5
98
2.1
79.9
(0MB 13.403)
Title VII
12,
Women's educational equity
Education Amendments of 1974, Special
20
1.5
94.0
7
.2
79.1
(0MB l3..56S~)
Projects Act, Sec. 408
13.
Career education
Education Amendments of 1974, Special
19
1.4
95.4
10
.2
79.3
(0MB 13.554)
Projects Act, Sec. 406
14.
Ethnic Heritage Studies
Elementary and Secondary Education Act,
17
1.2
96.6
2
-
79.3
(0MB 13.549)
Title IX
15.
Gifted and talented children
Education Amendments of 1974, Special
10
.7
97.3
3
.1
79.4
(0MB 13.562)
Projects Act, Sec. 404
CAl
*Estimated by OE Program Offices
-Less than one-tenth of one percent
PAGENO="0381"
Page 4 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED FORNS,
AND THE FISCAL YEAR 1977 (REGULAR) APPROPRIATIONS FOR SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
Number
(000s)
Manhours
Percent
of total
Cumulative
percent
Appr
Dollars
(millions)
opriation
Percent
of total
Cumulative
percent
16.
Adult education
(0MB 13.400)
Adult Education Act
8
.6
97.9
81
1.7
81.1
17.
Follow Through
Community Services Act (PL 93-644)
7
.5
98.4
59
1.3
82.4
(0MB 13.433)
Title V
18.
Indian education
Indian Education Act (PL 92-318)
5
.4
98.8
4
.1
82.5
(0MB 13.536)
Title IV, Part C (Sec. 314 Adult
Education Act)
.
19.
Educational innovation and
Elementary and Secondary Education Act,
4
.3
99.1
185
4.0
86.5
support (0MB 13.571)
Title IV-C
20.
Programs for the handicapped-
Education of the Handicapped Act,
3
.2
99.3
200
4.3
90.8
aid to states (0MB 13.449)
Part B, as amended by PL 94-142
- -
21.
Teacher Corps
Higher Education Act, Title V
3
.2
99.5
38
.8
91.6
(0MB 13.489)
*Estimated by OE Program Offices
PAGENO="0382"
Page 5 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED FORMS,
AND THE FISCAL YEAR 1977 (REGULAR) APPROPRIATIONS FOR SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
Number
(000s)
Manhours
Percent
of total
Cumulative
percent
Appro
Dollars
(millions)
priation
Percent
of total
Cumulative
percent
22.
Programs for children in state
Elementary and Secondary Education Act,
3
.2
99.7
29
.6
92.2
institutions for the neglected
Title I, Sec. 123
and delinquent (0MB 13.431)
23.
Library and learning resources
Elementary and Secondary Education Act,
2
.1
99.8
147
3.1
95.3
(0MB 13.570)
Title VI-B
-
24.
Right to Read
Education Amendments of 1974, National
2
.1
99.9
~
26
.6
95.9
(0MB 13.533)
.
Reading Program, Title VII (PL 93-380
as amended by PL 94-194)
25.
Indian education
Indian Education Act (PL 92-318)
2
.1
100.0
13
.3
96.2
(0MB 13.535)
Title IV, Part B
26.
Programs for the handicapped in
Elementary and Secondary Education Act,
1
-
100.0
111
2.4
98.6
state-supported schools
Title I, Sec. 121
`
(0MB 13.427)
*Estimated by OE Program Offices
-Less than one-tenth of one percent
PAGENO="0383"
Page 6 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED FORMS,
AND THE FISCAL YEAR 1977 (REGULAR) APPROPRIATIONS FOR SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
Number
(000s)
Manhours
Percent
of total
Cumulative
percent
Dollars
(millions)
Appropriation
Percent
of total
Cumulative
percent
27.
Incentive grants
Elementary and Secondary Education Act,
1
-
100.0
25
.5
99.1
(0MB 13.512)
Title I, Part B
28.
State administration of ESEA,
Elementary and Secondary Education Act,
1
-
100.0
21
.5
99.6
Title I programs
Title I
(0MB 13.430)
29.
State equalization grants
Education Amendments of 1974, Title
0
-
100.0
11
.2
99.8
(0MB 13,572)
VIII, Part D, Sec. 842
30.
Packaging and dissemination
Education Amendments of 1974, Sec. 402,
0
-
100.0
10
.2
100.0
(0MB 13.553)
Special Projects Act and the General
Education Provisions Act, Sec. 422(a)
.
31.
Metric education
Education Amendments of 1974, Special
0
-
100.0
2
-
100.0
(0MB 13.561)
Projects Act, Sec. 403
*Estimated by OE Progrsm Offices
-Less than one-tenth of one percent
TOTAL 1,344
4,676
PAGENO="0384"
Page 1 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED APPLICATION, PROGRAM MANAGEMENT,
AND EVALUATION FORMS USED BY THE OFFICE OF EDUCATION FOR COLLECTING DATA RELATING TO SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
*Estimated by OE Program Offices
1/ Figure includes 156,000 manhours to cosplete the Federal application form, OE-3l2, which is used by an estimated 1,900 local agencies.
2/ Figure includes 164,000 manhours for a one-time evaluation study required by the Education Amendments of 1974 (PL 93-380); not included
are an estimated 4.5 million manhours spent by local agencies using State-administered application forms pursuant to Federal law and~
regulations. Figure also includes 72,000 manhours for the ESEA, Title I Comparability Reports.
3/ Figure includes an estimated 75,000 manhours to complete the Indian Student Enrollment Certification form OE-506. This form is completed
one time only by parents of approximately 300,000 Indian students.
.
Manhours
(000a)
Type of Assistance
-- --
Authorizing Legislation
.__~_ *___.*_*.__*___ .___ --- *. ----- ._*____*__._. ._ --~~ ._.
~___.__._~__
Application
*_._____
Program
Management Evaluation
.* ~ ._*._____ *__. ~____~*__ --- .*
Total
._~_**______
1.
Programs for migratory
Elementary and Secondary Education Act,
156
99
0
255~'
children (0MB 13.429)
Title I, Sec. 122
2.
Programs for disadvantaged
Elementary and Secondary Education Act,
.
0
76
164
240~'
children (0MB 13.428)
Title I
3.
Vocational education - basic
Vocational Education Act of 1963,
150
28
3
181
programs (0MB 13.493; 13.494;
Parts B, F, G, H, J, and Sec. 102(b)
13.495; 13.499; 13.501;
and 104
13.558)
4.
School maintenance and
School Assistance in Federally Affected
61
60
0
121
operation (0MB 13.478)
Areas (PL 81-874)
.
5.
Indian Education
Indian Education Act (PL 92-318)
78
3 .
7
88~
(0MB 13.534; 13.551)
-
-
cx
PAGENO="0385"
0
Page 2 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED APPLICATION, PROGRAM MANAGEMENT,
AND EVALUATION FORMS USED BY THE OFFICE OF EDUCATION FOR COLLECTING DATA RELATING TO SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
.
Application
Manhours
(000s)
Program
Management
Evaluation
Total
6.
Desegregation assistance
Emergency School Aid Act, Title VII
47
35
82
(0MB 13.525; 13.526; 13.528;
(PL 92-318) and Civil Rights Act of
.
13.529; 13.530; 13.531;
1964, Title IV
13.532; 13.405)
.
.
7.
Supplementary educational
Elementary and Secondary Education Act,
0
82
-
82
centers and services,
Title IV-C
guidance counseling, and
.
testing for the handicapped
.
(0MB 13.519)
8,
Education for the handicapped
Education of the Handicapped Act,
49
16
-
65
(0MB 13.444; 13.445; 13.446;
Parts C, D, and F
13.450; 13.451; 13.452)
,
9.
Community schools
Education Amendments of 1975, Special
40
14
0
54
(0MB 13.563)
Projects Act, Sec. 405
10.
Bilingual edOcation technical
Elementary and Secondary Education Act,
34
0
0
34
assistance coordination
Title VII
(0MB 13.403)
1*
*Estimated by OE Program Offices
-Less than 500 manhours
PAGENO="0386"
Page 3 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED APPLICATION, PROGRAM MANAGEMENT,
AND EVALUATION FORMS USED BY THE OFFICE OF EDUCATION FOR COLLECTING DATA RELATING TO SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
c/J
Type of Assistance
.
Authorizing Legislation
Application
Manhours
(000s)
Program
Management
Evaluation
Total
11.
Bilingual education
Elementary and Secondaty Education Act,
34
0
0
34
(0MB 13.403)
Title VII
12.
Women's educational equity
Education Amendmenta of 1974, Special
20
0
0
20
(0MB 13.565)
Projects Act, Sec. 408
13.
Career education
Education Amendments of 1974, Special
-
19
0
19
(0MB 13.554)
Projects Act, Sec. 406
14.
Ethnic Heritage Studies
Elementary and Secondary Education Act,
8
9
0
17
(0MB 13.549)
Title IX
,
15.
Gifted and talented children
(0MB 13.562)
Education Amendments of 1974, Special
Projects Act,. Sec. 404
10
0
0
10..
*Estimated by OE Program Ottices
-Less than 500 manhours
PAGENO="0387"
Page 4 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED APPLICATION, PROGRAM MANAGEMENT,
AND EVALUATION FORMS USED BY THE OFFICE OF EDUCATION FOR COLLECTING DATA RELATING TO SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
Application
~,,
Manhours
(000s)
Program
Management
.,
Evaluation
Total
16.
Adult education
Adult
(0MB J3.400)
Act
0
8
0
8
.
17.
Follow Through
Community Services
(0MB 13.433)
(PL 93-644)
Title V
6
1
0
7
18.
Indian Education
Indian Education
(0MB 13.536)
(PL 92-318)
Title IV, Part C (Sec. 314 Adult
Education Act)
2
3
0
5
19.
Educational innovation and
Elementary and
.
support (0MB 13.571)
Secondary Education Act,
Title IV-C
4
0
0
.
4
20.
Programs for the handicapped -
Education of the
aid to states (0MB 13.449)
Handicapped Act,
Part B, as amended by PL 94-142
2
1
-
3
21.
Teacher Corps
Higher Education
(0MB 13.489)
Act, Title V
3
0
0
3
-Less
than 500 manhours
PAGENO="0388"
Page 5 of 6
NUMBER OF ESTIMATED* MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED APPLICATION, PROGRAM MANAGEMENT,
AND EVALUATION FORMS USED BY THE OFFICE OF EDUCATION FOR COLLECTING DATA RELATING TO SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
c,J
Manhours
(ODDs)
Type of Assistance
Authorizing Legislation
~
Application
Program
Management
Evaluation
Total
22.
Programs for children in state
Elementary and Secondary Education Act,
0
1
2
3
institutions for the neglected
Title I, Sec. 123
and delinquent (0MB 13.431)
.
23.
Library and learning resources
Elementary and Secondary Education Act,
0
2
-
2
(0MB 13.570)
Title VI-B
24.
Right to Read
Education Amendments of 1974, National
0
2
0
2
(0MB 13.533)
Reading Program, Title VII (PL 93-380
as amended by PL 94-194)
.
25.
Indian education
Indian Education Act (PL 92-318)
2
0
0
2
(0MB 13.535)
Title IV, Part B
26.
Programs for the handicapped
Elementary and Secondary Education Act,
0
-
-
1
in state-supported schools
Title I, Sec. 121
(0MB 13.427)
.
*Estimated by OE Frogram Offices
-Less than 500 manhours
PAGENO="0389"
Page 6 of 6
NUMBER OF ESTIMATED* `MANHOURS OF RESPONDENT TIME FOR COMPLETING FEDERALLY REQUIRED APPLICATION, PROGRAM MANAGEMENT,
AND EVALUATION FORMS USED BY THE OFFICE OF EDUCATION FOR COLLECTING DATA RELATING TO SELECTED ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
(Continued)
Type of Assistance
Authorizing Legislation
.
Application
Manhours
(000s)
Program
Management
Evaluation
Total
27.
Incentive grants
Elementary and Secondary Education Act,
-
0
-
1
(0MB 13.512) `
Title I, Part B
28.
State administration of ESEA,
Elementary and Secondary Education Act,
-
-
0
1
Title I programs
Title I
(0MB 13.430)
29.
State equalization grants
Education Amendments of 1974, Title
0
0
0
0
(0MB 13.572)
VIII, Part D, Sec. 842
30.
Packaging and dissemination
Education Amendments of 1974, Sec. 402,
0
0
0
0
(0MB 13.553)
Special Projects Act and the General
Education Provisions Act, Sec. 422(a)
.
`
31.
Metric education
Education Amendments of 1974, Special
0
0
0
0
(0MB 13.561)
Projects Act, Sec. 403
TOTAL**
707
459
178
1,344
*Estimated by OE Program Offices
-Less than 500 manhours
**Totals include those categories with less than 500 manhours
PAGENO="0390"
PAGENO="0391"
PART 2: PAPERWORK PROBLEMS IN ELEMEN-
TARY AND SECONDARY EDUCATION
THURSDAY, MAY 26, 1977
HOUSE OF REPRESENTATIVES,
SUBCOMMITTEE ON ELEMENTARY, SECONDARY,
AND VOCATIONAL EDUCATION,
COMMITTEE ON EDUCATION AND LABOR,
Washington, D.C.
The subcommittee met, pursuant to recess, at 9:30 a.m. in Room
2175, Rayburn House Office Building, Hon. Carl D. Perkins (chair-
man of the subcommittee) presiding.
Members present: Representatives Perkins, Weiss, Kildee, and
Heftel.
Chairman PERKINS. The committee will come to order.
A quorum is present for the purpose of taking testimony.
I am delighted to welcome here this morning our colleague,
Congressman Levitas, from the great State of Georgia. I am delight-
ed to welcome you here this morning, Mr. Levitas.
Your school superintendent, Jack Nix, perhaps has contributed as
much as any other superintendent in the whole country from the
standpoint of the welfare of the school children throughout Amer-
ica. I note that you are following right in his footsteps. I understand
that he has a representative by the name of Mr. Ellis Bateman here
this morning.
If you want to come around, Mr. Bateman, and sit beside Mr.
Levitas, we will hear you after hearing the congressman. It is
always a pleasure to welcome you here.
Mr. LEVITAS. Thank you, Mr. Chairman.
Chairman PERKINS. I want to thank you for your great work and
contributions that you have made in the whole area of education
ever since you came to the Congress. Go ahead in any manner you
prefer.
STATEMENT OF HON. ELLIOTT H. LEVITAS, A REPRESENTATIVE
IN CONGRESS FROM THE STATE OF GEORGIA, ACCOMPANIED
BY ELLIS BATEMAN
Mr. LEVITA5. Thank you, Mr. Chairman, and members of the
committee.
(387)
PAGENO="0392"
388
I appreciate, first of all, the kind words you have said about me
and also am grateful for your generous remarks about Dr. Jack Nix,
who is the superintendent of our State school system and a personal
friend of mine, a man I have known personally and professionally
for many years. I can tell you that I share your esteem. He has done
for the school children of our state, and by that model for school
children elsewhere, an outstanding job.
It is a pleasure to be appearing before this great committee.
When I was in the State Legislature, Mr. Chairman, I had the
opportunity serve on the Education Committee of our State Legisla-
ture and work closely with the needs of the people in Georgia in
this area. In fact, when I first got to the legislature, this might be a
matter of interest, I was on the House Education Committee. We
had a young state senator from Plains, Georgia, who was on the
Senate Education Committee. We worked closely-who will go
nameless for the moment-but we worked closely on education
matters. My interest has not in any way slackened in this matter.
Indeed, it has increased through the years.
I appreciate the opportunity to appear before the Subcommittee
on Elementary, Secondary, and Vocational Education to testify on
some of the difficulties with paperwork experienced in federally-
assisted programs for education.
Mr. Chairman, Members of the Committee:
I certainly appreciate the opportunity to appear before the House
Subcommittee on Elementary, Secondary, and Vocational Educa-
tion to testify on some of the difficulties with paper work exper-
ienced in federally assisted programs for education. Before mention-
ing specific problem areas, I wish to state that the Federal
assistance available for education has been a great help to Georgia
as a supplement to our state efforts, and has enabled us to do
certain things that would not have been otherwise possible with the
limited state and local resources available. Educators of the state
are appreciative of your efforts to improve the quality of education
available in this nation for all citizens, and have strived to utilize
the Federal aid available in an efficient and effective manner.
Unfortunately, due to many of the specific detailed mandates in
new Federal statutes and the stringent interpretation of these
statutes by the Executive Branch's rules and regulations, educators
have in fact at times been hampered in their efforts to efficiently
and effectively use Federal aid for the benefit of school age youth.
In fiscal year 1967, the State Board of Education in Georgia
received $80.0 million in Federal grants for the public schools of
Georgia. During this same year, the Georgia General Assembly
appropriated $291.3 million for the education of children of this
state. By fiscal year 1977, Federal grants received by the State
Board of Education had more than doubled to $174.4 million,
accompanying an almost two and one half times increase in State
appropriations for education to $691.8 million. These figures do not
include the local school systems' financial contributions, nor do
they include direct Federal grants, such as impact aid, made to the
local school systems of the state.
Over this ten-year period, the reporting and record keeping re-
quirements imposed at the Federal level on state and local officials
PAGENO="0393"
389
have far outstripped the two-fold increase in funds. Much of this
increase is due to the ever-increasing detail and specificity of
congressional Acts, while much can be attributed to an overzealous
interpretation of congressional mandates by the Executive Branch
through its rules and regulations. Funds originally intended to help
the children of our nation have been slowly diverted to fulfill
reporting requirements, most of which have little or no bearing on
the child in the classroom. With the committee's permission, I have
included as Appendix A, a listing of the forms required by the State
Department of Education, or directly of Georgia school systems, by
the U.S. Office of Education for Federal educational activities in
Georgia. This is Appendix A. However, I should point out that this
listing represents a 24-pound, 11-inch stack of forms and instruc-
tions for programs under the Office of Education. It does not
include state-imposed reporting on local systems which directly or
indirectly is the result of mandates by Federal agencies. Apparent
from the length of this list alone, much of our time and money is
expended in reporting information to the Federal level and not
directly affecting quality educational changes in Georgia.
Dr. Jack P. Nix, the Georgia State Superintendent of Schools,
estimates that over 20,000 man hours are consumed yearly report-
ing to the U.S. Office of Education by his staff alone. If each local
school system in the state spent only half the time in Federal
reporting as does the State Department of Education, over 930 man
years requiring an expenditure in excess of $9,000,000 is required in
Georgia to satisfy Federal reporting dictates. This estimated cost
represents over 5.2% of the total Federal commitment for education
in Georgia for fiscal year 1977. Please note, Mr. Chairman, that this
represents only the information collected by the U.S. Office of
Education. If forms required by the Department of Labor's CETA
activities, the Department of Agriculture's Child Nutrition Activi-
ties, the Office of Civil Rights, and the other Federal agencies that
impact education were included, this mass of documents would be
increased substantially.
Data requirements imposed with most Federal grants have
reached the extreme point where many applicants will not apply for
small levels of funding. The Georgia Department of Education uses
a rule of thumb of $5,000 on grants from Federal agencies. If the
possible award is less than $5,000, the State estimates it would lose
money in the paperwork process associated with the application
accounting and evaluation procedures necessary for accepting the
grant. The State of Florida in their A-95 clearing office likewise
normally will not submit grant project applications under $5,000,
unless it is a dire emergency associated with the grant award.
Projects only slightly exceeding that amount are seriously ques-
tioned to determine if the cost of the paperwork does not exceed the
anticipated grant level.
I am personally aware of some of the difficulties encountered
with paperwork and specifically with the proposed rules and regula-
tions governing the duties of the State Advisory Council for Title
IV, Consolidation of Programs, under public law 93-380. As present-
ed by the U.S. Office of Education, the proposed regulations implied
that the State Advisory Council mandated by PL 93-380, the Educa-
PAGENO="0394"
390
tion Amendments of 1974, would approve each local school system's
application for assistance. This, I felt, was not the intention of
Congress, and represented a serious erosion of the duties and
responsibilities of the Georgia State Board of Education.
On May 5, 1975, at the request of Dr. Nix, I wrote then USOE
Commissioner Bell expressing concern over the implied role of the
Advisory Committee as well as other concerns with the proposed
regulations. I am happy to report that in this instance the public
comment period allowed on proposed rules and :regulations was
effective, and that the final regulations as published on November
18, 1975, in the Federal Register clarified the role of the State
Advisory Council in offering advice to the State Board of Education
on the types of local applications the Council deemed approvable.
A further example of problems experienced by state and local
educators is the proliferation of a 9-page enactment of Congress,
Title IV of PL 93-380, designed to consolidate and simplify certain
categorical education programs, into 10 pages of executive rules and
regulations, plus a proposed guideline book over 200 pages long.
This information was distributed by USOE in 175 as "training
material." In addition to these, a 19-page document was distributed
on August 23, 1975, purported to be the minimu:m data require-
ments needed by USOE for Title IV. Commissioner Bell, in response
to concerns of educators over the mass of data to be collected for a
program designed to simplify State-Federal relations, pointed out
USOE could have required over 4,000 items of information for this
title alone. The Commissioner indicated further that the 19-page
document of August 23 represented the minimum requirements of
402 pieces of datum and that further reductions by USOE had
brought the proposed list down to only 239 items. With your
permission, I have included as Appendix B this list and the resul-
tant correspondence.
This is typical of the almost daily struggle State and local
education officials undergo in trying to cope with the Federal
bureaucracy. Almost constant legal counsel is needed to interpret
proposed regulations and their relation to existing Federal and
state statutes. The vast expansion of the detail and specificity in
statutes, requirements of Federal rules and regulations, and the
explosion of requests for information at the Federal level has
caused an almost complete loss of sight of the end product of
education, which is a well-adjusted and productive citizenry. Educa-
tors have become rule appliers and form completors.
In addition to problems with regulations and data collection, the
consolidation provided in Title IV has caused state and local school
officials other administrative difficulties. Although consolidated,
separate accounting for administrative funds for Parts B and C is
required; this has increased the record keeping requirements sub-
stantially at the state level. The concept of a single application as
present in PL 93-380, Title IV, is an excellent idea. Unfortunately,
in this case, it has tended to increase the administrative problems
and delay funding for local school systems. With Part B being
basically a formula entitlement for local school systems and Part C
a project approval program, the single application has hampered,
rather than enhanced,the efforts of the local school system to
PAGENO="0395"
391
receive funds. If separate applications were permissible at the
option of the local school system, Part B funding could be released
prior to the development, submission, and review of the Part C
projects of a local school system.
I certainly hope this committee will closely examine this Title
and the Special Projects Act in PL 93-380 to effect a true consolida-
tion of the multitude of categorical grant programs for local school
systems that will simplify applications for funding with a minimum
of paperwork and regulation. The seven areas identified in the
Special Projects Act-metric education, education for the gifted,
community schools programs, career education, consumer educa-
tion, women's equity in education, and arts in education-could be
folded into the innovation and support area, Part C of Title IV,
allowing local systems to apply for projects in these areas using the
same forms and regulations applicable to other projects under Part
C. Not only would seven sets of regulations be eliminated, but quite
likely seven separate groups of bureaucrats in Washington could be
redirected to provide additional services to the States and local
school systems of our Nation.
Although not directly a concern of this subcommittee, PL 94-142,
the Education for All Handicapped Children Act, again involved the
Federal level excessively in the details of administering a state and
local program. In reviewing the proposed regulations and the speci-
ficity of the statute, I feel that this act may prove to be one of the
most burdensome federally assisted programs in existence. The
proposed details of the individual education plan for each child, the
records t~ be maintained by local school systems to assure due
process, the possible considerations of comparability, the excess cost
concept, and the child count conducted twice a year will place
almost insurmountable paper requirements on teachers and school
officials of this nation. Realizing the need to provide adequate
educational opportunities to all our handicapped children, I strong-
ly supported the passage of 5. 6. However, now looking at the
paperwork that most certainly will be required to obtain the $7.3
million in Federal aid to supplement our $68.8 million state aid
program for the handicapped in our state, I wonder if support of
this particular measure, in the end on my part was justified. Dr.
Nix has informed me that the State Board of Education in Georgia
will submit a plan to the Office of Education for education of the
handicapped that is consistent with the State Constitution and
State statutes. This is the plan, just this document right here is the
plan we are talking about [indicating], recently approved by the
State Board of Education, that will be submitted to the U.S. Office
of Education. If this plan is unacceptable, Georgia may very well
not apply for the small portion of funding available from the
Federal level, but will rely on State sources to provide educational
opportunities for the handicapped with a minimum of paperwork
and regulatory activity. The losers in this case will not be the State
of Georgia but will be the handicapped persons who could have been
educated with these funds.
In viewing existing Federal aid programs for the handicapped, it
seems that we have, through special set-asides in many program
areas, fragmented the support for comprehensive efforts to offer
PAGENO="0396"
392
educational opportunity to all children. ESEA, Title I, contains
special funding for handicapped children in state institutions, ESEA
Title IV, Part C requires a 15% expenditure of funds for children
with specific learning disabilities and other handicapped children,
the Vocational Education Act requires a 10% expenditure for the
handicapped in addition to a 20% set-aside for the disadvantaged,
and PL 94-142 purports to offer funding for the education of all
handicapped children. It seems to me that educators could design
more effective programs with less paperwork and regulatory restric-
tions if all funding for handicapped children could be placed under
one statute and one set of administrative requirements. I certainly
hope this committee will consider this possible simplification of
programs of aid to handicapped children during your deliberations
so the money can be channeled to where it is needed and not to hire
people to fill out more forms.
One of the most serious abuses of the executive rulemaking
authority occurred in August 1975. A memorandum was distributed
from the Department of Health, Education, and Welfare, Office of
Civil Rights, pertaining to record keeping requirements on student
discipline problems. This memorandum, received by state school
officials the last week in August, imposed changes for school year
1975-76, which had already begun in many school systems and was
scheduled to begin the first of September in others. The detail and
volume of information required of local school systems were quite
unrealistic, and a national protest arose over the timing and con-
tent of this document. I am certain that many of you are familiar
with this situation through the reaction to these unrealistic de-
mands by state and local school officials.
In the original memorandum the Office of Civil Rights used
regulation 45CFR80-6 (B) as justification for its mandate of the
record keeping procedure. This regulation reads:
"Each recipient shall keep such records and submit to the respon-
sible department official or his designee timely, complete and accu-
rate compliance reports at such times, and in such form and
containing such information, as the responsible department official
or his designee may determine to be necessary to enable him to
ascertain whether the recipient has complied or is complying with
this part . . .".
In my opinion, a ". . .responsible department official . . ." could,
under this regulation, even require the teachers of this nation to
delineate the rest room requests of students by racial and ethnic
groupings and give reasons for approving or disapproving these
requests. The power to reach into a classroom-or indeed the
restroom-and cause disruption of schoolroom activities is a power
that should be reserved only to the elected officials of our govern-
ment who are directly responsible to the citizens.
The August 1975 memorandum has been revised and made appli-
cable to only the 3,000 school districts with the most minority
students and the effective date of implementation was postponed
until the 1976-77 school year. These 3,000 school districts have been
burdened with an excessive record keeping activity which in my
opinion will have little effect on improving the instructional pro-
grams of our Nation's schools, or even eliminating discrimination. I
PAGENO="0397"
393
have correspondence from several school systems in Georgia that is
indicative of the paperwork problems caused by OCR 101 and 102.
The Dalton City schools, and this is a very small school system in
North Georgia, spent over 40 man-hours completing these forms for
its 4,000 students. The Baldwin County Board of Education, a
medimum sized system with only 5,500 students, estimates that it
spent over $26,000 to comply with this request, and the Fulton
County Schools were presented with a 56-pound, 21-inch high stack
of forms representing over 5,016 pages of materials for its 79
schools.
Mr. Chairman, Members of the committee, I believe that this is
an example of one of the great concerns of the citizens of this
Nation. When a Federal agency can issue requirements that have
such a broad impact with little opportunity for those affected by the
requirements to be heard or to appeal, something is drastically
wrong. I am most pleased that you are listening to the outcry of the
average man against the bungling bureaucracy we have created in
many areas of our government.
With your permission, Mr. Chairman, I would like to submit as
Appendix C the August 1975 memorandum relating to record-
keeping on student discipline procedures and its subsequent revi-
sion, along with correspondence from several of the local systems of
Georgia relative to Forms OCR 101-102.
I would further like to direct your attention to this mass of
computer forms on the table before me and in front of you. The
State of Georgia has already expended over $9,000 for computer
processing alone to assimilate the statistical data required by PL 94-
482, the Education Amendments of 1976, for its state plan for
vocational education, which I have already referred to. This mass of
detailed information must be attached to a narrative description of
the state plan, estimated to exceed 400 pages and forwarded in five
copies to the USOE regional office in Atlanta. Georgia estimates
that the total state plan, including these detailed computations, will
exceed 2,100 pages in length. The printing estimate, just the print-
ing estimate alone, for the required distribution of this plan within
the state exceeds $35,000. I understand that Georgia is not the only
state experiencing considerable difficulties with details of the state
plan mandated under PL 94-482. The Minnesota plan, I am told,
and Minnesota is a state very similar to Georgia in the operation of
vocational programs, reportedly exceeds 5 feet in height, consider-
ing all five copies, and the South Carolina plan, already over 461
pages in length, is not complete nor acceptable by USOE.
The planning concept and process established for vocational edu-
cation in PL 94-482 is exceptional. The paperwork mandated to be
forwarded to the Federal level is outrageous. Surely, the Congress
and the Administration can find other solutions to problems per-
- ceived in legislation without requiring the reporting of masses of
detailed statistics to the Federal level.
In conclusion, Mr. Chairman, I think this is the positive note of
recommendation, I would like to bring your attention to a pilot
program begun in Georgia with five of our local school systems last
year. Basically, this pilot, called Local School Systems Comprehen-
sive Planning, requires that the local school superintendent and his
PAGENO="0398"
394
staff develop an educational plan of operation suited to local needs.
This lcoal plan describes what is to be accomplished, how it is to be
accomplished, what resources will be required, and how the accom-
plishments will be measured and evaluated. Under this comprehen-
sive plan the local superintendent and the local Board of Education
agree to meet the intent of all Federal and state statutes in this
operation and to chair a planning team of local, state, and Federal
personnel.
In turn, the State Department of Education agrees to design ways
to fund and implement the system's plan and to advise the local
superintendent in the implementation of the plan and on any legal
or regulatory matters. U.S. Commissioner of Education Bell, rather
the former commissioner, likewise had agreed to provide entitle-
ment Federal funds based on this comprehensive plan and to
remove, insofar as the statutes will permit, regulatory restrictions
on the use of these entitlement funds. I hope Commissioner Boyer
will continue to honor this agreement. Both USOE staff and state
staff will monitor the implementation of the plan and audit the
outcomes of implementation to determine effectiveness.
A system similar to this where states would, through an annual
plan, define their educational needs and steps necessary to fulfill
these needs could possibly result in the reduction of paperwork and
regulatory requirements now placed on local education agencies.
The Office of Education could, much as done in the five pilot
systems in Georgia, assist each state in developing its plan to fulfill
statutory requirements, and then could find funding sources from
the Federal level to help implement these individual state plans.
Through monitoring and audit, progress in implementing the states'
comprehensive plans could be followed and reported to the Con-
gress, the Executive Branch, and the public.
In addition to the annual plan concept, the U.S. Office of Educa-
tion could, under existing statutes, simplify the paperwork load on
state and local education agencies by simply requiring only one set
of assurances from each project applicant. Now each project appli-
cation must be accompanied by a set of assurances that are basical-
ly the same for each program. If each state and local school system
could file these assurances only once with USOE, the amount of
paper generated by each project application could be greatly re-
duced. The Office of Education could verify for each project applica-
tion that the set of assurances was on file for the applicant, thereby
reducing the number of forms containing redundant information
required for each proposal that comes forth.
Since our economic situation remains clouded, we must strive to
make more efficient use of every available dollar for education, and
forms and information which have little or no bearing on changes
in the classroom must be curtailed.
The madness of mandating specific detailed requirements for
each federally assisted educational activity must stop. Congress
should establish national priorities, provide funds for states to
achieve these priorities and provide a mechanism to evaluate the
effectiveness of state efforts toward these goals, rather than man-
date on each state how it should structure its educational enter-
prise, what data it must collect and report, or how local educational
PAGENO="0399"
395
activities must be performed. Let states receive broad national
direction from the Congress in carrying out their specific State
responsibilities, and provide a monitoring mechanism for the Con-
gress and the public to gauge the progress of States to this end.
Thank you, Mr. Chairman, for your interest and concern for the
children of our nation, and that of this committee.
I extend to you an invitation to visit the educational programs
and schools in Georgia in order that our efforts to build more
productive and successful citizens may be more closely coordinated
with those at the state and local level, resulting in a stronger
America.
Chairman PERKINS. Do you have time for us to hear Mr. Bateman
right now?
Mr. LEVITAS. Yes. He would like to supplement.
Chairman PERKINS. Yes. I see that this is the call of the House.
They are going into session.
Mr. Bateman, without objection your prepared statement will be
presented into the record.
Mr. BATEMAN. I do not have a prepared statement or comment
other than, on behalf of Dr. Nix, to thank you and this subcommit-
tee for your interest in the children of our Nation and the wonder-
ful job you have done in the past in terms of improving the
educational programs of the nation.
[Appendixes A, B, and C follow:]
PAGENO="0400"
396
APPENDIX A
Partial List of Data Collection Forms which Impact on
Georgia State Department and Georgia Schools
State Education Agency List as of February 1976
Local Schools List as of May 1976
PAGENO="0401"
397
I 1101' 5/11 "1 (iN lilt
(021(1(1111 "[`Ill 0 DIII II 11(11,1 la- i;iic:ii'i' iou
I. Al'i'l.iCTi'iTONS
Estinate of Department Man-
Hours by Report by Year
Vocational Education State Plan 4,951.0
OE 3176 Vocational Education Applications (6) 4320.0
Title lV State Plan 912.0
OE 323-1 Non Commercial Eclucal' ion Broadcasting Application 320.0
OE 362 Title I - Migrant Application 200.0 -
Adult Education, Title III, P. L. 91-230 160.0
USDA School lunch Application 160.0
05 208 Title III Application 160.0
OE 4439 Title V - A Application (503 & 505) 160.0
OE 296 Title IV Civil Rights Act (Equal Education Opportunity) 160.0
OE 9037 handicapped - Application 161.0
05 295 Right to Rcad Applciation 120.0
OE 4533 Title V - C (Local SysLcms Planning ad Evaluation)
Application 80_I
Alliance for the Arts Education 56.0
HEW College Work-Study Program 48.0
HEW BEOG Application 40.0
05 4553 Pollee Through Program Applicatien 40.0
OE 4133-1 Title V - C Intent to Apply 40.0
OE 335 EPDA Application 36.0
HEW Veterans Cost of Instruction Prograass 24.0
OE 347 School Health & Nutrition Program Application 24.0
OE 4473 Follow Through - Hcadstart Title III 16.0
ISA DC 75-
2637 Outline for Program Performance Reports (LFDA) 16.0
91-860 0 - 77 --26
PAGENO="0402"
398
irate of Department San-
fours by Report by Year
OE 323 lioncerercia] Elect in hr lost q - lr~ql icatiOn 15.0
OE 3118 SEA - College leibriry Resource Prcqram Tj~lication 10.0
Title I (Seeral ip;i Cation - Stat flu lu1rleltl 8.0
OE 417 Getirral ipjl tulle I lit tfy Stelti Jr-es of
Participation iii ISfA 1.0
CE 4453 Summary for Grant - State Insti tutiiiiu for lIrtlecttd antI
Delinquent Cli ldrrti 1.0
Title II State Plan 1.0
ND1~A Title 111 StIr PIn 1.0
p~I ft GtORCJ {uiJCOtulCfE 1151)
CE 267 Indian Education Application
CE 298 Teacher Corp Application
CE 328 ESIVi - tSP Program Application
CE 4384 Distribution of funds to local t State Arncict for Programs
Under Title I, ESEA
CE 4510 Application - Special. incentive Grunts - liStS Title I, Part B
HIGIIER EDUCASION FORDS iliiCO;1P[Cilf lIeS)
CE 336 Library Resources ati Demonstration - ff11 - Application
CE 3095 lEA - Education ii librarianship
PAGENO="0403"
399
11. LII 1 it, `IC 1.11< . :;o:: ,~,, /f . `I l/t. /C/I t'LiIiOPJ'.AICE)
II;'. `.m.'.t e of Deport.mrrtt lOin-
II rn; by Poport by Scar
05 1297 Title 11 Fit trio I Itotun; tleprrt. 32.0
05 4376 . Ar'.nt'.ol Survey of tlrj.t en tot not tot sot'. L Child'. ott
in 51.7; Opt". atonl 5'.'.:; Ii'. ti'.u;s.'.rin Atoll. Cc'.rrr:t ion;'.l
It'.sti Luf jot;:; - Till'.' 1 32.0
05 4376-1 Annual Survey of lout nrl.o'l non lj~1 ito/most (Itt lire'.'.
fl 1.0001 TonI.'. tat. bits or it'. Ct'.ir `ct `.ini] hot it Ut'. OIlS -
I/SEA Title 1 31.0
05 360 Vot'at:ionnl t'tucot ii'.; I. t30'A, Ii `.o'.mnint l'..'rfo'.".eunce Report 24.0
OE 1298 NOt/A, Ttt 1' III - 7;, ii s'.'.t':int RI,'.'. a:; I-~tt'.t t 24.0
Vetersr;s Cot of toot riot tot; - ~".nr I it 1".' On otto's t Report 24.0
AD 626 Letter of Cr'.':tit (IC/CIA) 16.0
05 376 EnS low Tb noutjt'. Tn:t:It'.;i oat Assi ::t 0'.'.CO t;'.'l:ort 16.0
OE 3115 lISA - Ant;lc'l l".'.slr tn id t.mj'.:'.;s': Retort -
College t.ibrnry So'ottroe:; 16.0
11100 - flunrlerly Plot I of t/sio'.'.:;r:; 16.0
0118 40-R3688 Qua'. terly Ilrvr.loj,e('ntal Proj'.'ots Payinot'ts 10.0
OE 365 Adult, fducntion - ti ie'.ttcial St;tut' IC/port. , 8.0
OE 365-1,2 Adult Edut:'.;tiott Att'.;'.'. at Itt C/n note'.' Sopor L 8.0
DE 9039-1 ITo not i on lOrd - li otto: i.;t St no.' I/e,'.etr I - tort 13, EllA
FL 89-313, IC/IA 8.0
USDA Agreement Form for tlSDA 8.0
DE 1298-2 501/A, Title 111 - A - Fit'..'.nciot Sl.'.l'.'.t; Report (C.;rryover( 8.0
Veterutis Coot, of tt;sttuctio'.'. - I'i:;to'.] l';'.tsti'.'.'i 5' `1UOst 8.0
BlOC". - Ln;t of Year `inca] ``port. 8.0
BC/DC'. - t'ro'jrntu I*'utt't it<'.j SC/ott 4.0
College i'lork-SL'.'.dy - t'r'.'.tr.t'.u t'.IOlit'.(l IC'.".1u(n'.t 4.0
College Library lteso,'.rors t".r,trotn - Pro'lr,'.:e t't'.telingRequist 4.0
05 4535 Follow Through Comprn'l;rnt;ive 10.0111'. lore ions çluestionnaire 2.0
Veternttt; Cost, of lust rt'.r tiot'. Ii tiC/nt 2.0
PAGENO="0404"
400
II t:r:s 0: `03:0 30,005' .3,:-;. `.5.') 51 ,0~7i `o 1071 zoo PLROCOOJIICE)
Intimate of Department Ran-
louts by Report by Year
FNS 10 - Lunch, Brc:a(:fast and lonfood Assistance 111505) 2,112.0
ENS 28 Special 1311k Roport (11105) 2,112,0
05 346-1 Vocational Education Seport on Activities 360.0
OE 385-2 Title III State Aqencl'intm:mal Report 320.0
Os 4439-1 Title V-A (503 & 505) Financial Statement and
Performance Report 320.0
ENS 360 Program Outlay (0eom-~tap(ica) Outlay) (ilDi) 200.0
OR 345 Vocational Education Financial Status RepOrt 160.0
OE 363 Right to Read Financial ala) (`erfotoanco Rcpott 160.0
OE 9016 Handicapped - Desctiptinn of Frojcct ictivatics 120.0
OE 9039-2 (landicapped - )`etfotnance Ecpor t Fart B, hIll,
PL 89-313, ESEA 94.0
05 9037-1 Handicapped - Financial t. Performance Report 88.0
FNS 13 Income and Em:pense Repurt (LIDS) . 88.0
05 4533-2 Title V-C Financial Status Feport Petfotnunee Report 80.0
05 380-1 Title I Financial and Perfotnance Rei'nrt 60.0
College Work-Study - Fiscal Seport of Expenditures 60.0
AD 627 Letter of Credit (USDA) 48.0
OE 381 Title III Financial and Perforounce Report 48.0
OE 380-1 Title I Financial Petfornancc )3c~.ort 40.0
OE 1297-1 Title SI Performamice Report 40.0
OE 1298-1 NOES, Title 525-A, l'crfr,rnane': Report 40.0
ENS 47 Annual Report of Food Sct~'ico (USD11) 40.0
FNS 24 City School Feedin'j (USD1) 40.0
OE 362-1 32.0
OE 385-1 32.0
Title I - Migrant - Financial and Per fornance Report
Title III Financial Status Ri-cart - State Plan
PAGENO="0405"
401
I11HLR J11~T1~i( ( 1.1
OE 3096 906 - ;nrol In~nt 1) a Plor L - ic ic i Ii cci ship
OE 3097 916 - Pus 1 Ii cii lcport - Ecs 1 i ni Lii sr snship
OE 3141 906 - Tinnal iiaPraliv' 11cr I icr Fduction ii Librarianship
06 3164 1161 - Fiscal Sport, `I ri ininq in iii risslip
OE 3600-1 HOT - Projct Corpiction IPport
PAGENO="0406"
402
riitc of Department ian-
tiuro by Seport by Year
CE 346-3 Enrollments in Vomaticual td;o.tio jasu 360.0
CE 346-4 Placeent of Procrac Comoletiors it Jrcationai Education
Prrcrans 80.0
CE 2350-12 ELSEG1S VII - Part `-lb tlcsc;tary t; S:aen'tar'.' Statistics 60.0
CE 2350-11 ELSEG1S VII - art 1-2.u EIcrs°:iara' a Scoctry Statistics 45.0
CE 365-2 Adult Education Stilt rant Iroran - Supplcrt:ary
Performance Retort 40.0
CE 2350-7 ELSEGIS VU - Part f-i - State Fall Smart ru IncuS
Housing 40.0
CE 2350-9 ELSEGIS V - Part 1-3 - all frtioate of EsT:sdjt;tes
and Salary fata 35.0
CE 346-2 Saber of Teachers, Status of Teacher Trainic and Local
Administrative lt:aff in Vroatio:,aj Sdcatio 32.0
CE 395 ttotnfacaton of fopoitnent of Silt Etum;tio State
1dsisorv Council 32.0
CE 2350-5 (ELSEG1S till) Pitt ft - 1 - State fat] toost ott Staff
and Pupils 24.0
CE 2350-6 ELSEGIS VI - Port 1-2 iluatcil SLftt 20.0
CE 4218 Education Sroadcasti: Facitit icc 19.0
CE 4517 Title I Irvesticatic; Import cc fdci ristratiot of Title I
Procram Activities 16.0
Semiannual Seport - State fdminiszcred Sessarch and
Develomoert Activities 16.0
CE 235-1 EISA - Transmittat torn for SLIt Comet 8,0
CE 2349-1 Library General Inforcatirn Sutvcv 8.0
CE 4524 Title 1 Comparability tertuirccctits Retort 3.0
PAGENO="0407"
403
cf Dcriartcent tan-
learn by Report by Year
OPBE Field Tent of Title I Eaaln,itoin lelels 160.0
OE 4552 ` Sharing Education luceons - Title Ill (valilal.iisn) 124.0
OE 398-2 Questionnaire for Special E'l'c:atiou DeparLeent 80.0
OE 424 Study of Imnact of etc Fsndins of Elementary
and Secondary Federal `in (2Cr ion `rosin' n SiLl 80.0
lIE Regulations Survey 24.0
OE 398-3 NEALRC 1974-75 Sotvi'y of Services - F"q ion 9 16.0 -
CE 2383 Survey of SEA on l'o:;"vs 51s'ctc'a l,aeited English
From Nonfi~1isli Dominant F-ectnround 12.0
CE 434 Evaluation of Title 111 National t(ifi'amioc/?cD,ltion
Netinork Facilitator Cuestionsaire 8.0
CE 9054-1 Survey of Education end Social Prepares lrveilelrlm to
Institutionalized Osotisnalle Liisturle'ri Cl:iilrem (hymn) 8.0
CE 434-2 Evaluation of Title Ill Satirical Dnffusien/Alr'etnon
Network StI/DRP f!ucse'reraire 4.0
CE 9052 Annual Survey of Ai(Ji of llandica~:sed Chidiee in SEA Schools 4.0
CE 9054-2 Socvcy of Education and Sociel Frocree'; liii laDle to
Institutionalized Emotionally Disturbed Children Prog Dir) 2.0
CE 398-1 Questionnaire for Director- of S;ccial t'racatic'u 1.0
CE 434-1 Evaluation of Title 711 National Diffnsiom/Tnior-tion
Network Adoeter Questionnaire 1.0
CE 9043 Clarification Survey for Roadiog/i,anyuerc l'riorities (Deaf) 1.0
OR 9054-3 Survey of Education and SeemS Fnoqraes i;'ictahle to
Institutionilizod Emotionally Dietetic-I CCfl,li'em (Sorter) 1.0
CE 9054-4 Survey of Education and Social Proarame lvii (idle to
Institutionalized Emotionally Distor('oc, Cii ldrcn (Outside) 1.0
CE 10,000-1 Questionnaire on Eriucetion Statistics: `evens Use (ICES) 1.0
CE 399-2 NI' Learning Resource Center - iderkshop Evaluation Fern .25
CE 9044 Requesters Technical Assi stance Evaluation Form -
NW Learning Fesouroes System . 25
CORE LIES Title I srmnly mci I conic for 1:-rime;', ~l -rm;'; Del ancient
Children in State Insti 1st ions
PAGENO="0408"
404
FCi~5 THAT DC' Ci ;~:: ~~i- 1~,
OH 440 - BVT StLtc ç~-esti-~-irc `i-Hi `,L,,cCij,i,.)l Tralig)
004484-3 Stu3yC'fiteCrvL"i~it1r);i'iL'ou)ti'-i',)73CI-'1R
NIH Survc',' rH Leo
PAGENO="0409"
405
Fedrul Sport imp Eq i rc:-~eets that Impact on
Georgia School l)istricts
PORN NUMBER PORN lANE
116-1 Application for Federal Assistance (Nonconstruction Programs)
for ESAA Title Vii, FL. 92-318, As Amended FL. 93-380:
instructions and Supplemental Questionnaire
116-2 Financial Status Report and Performance Report, EEOP
116-2-1 District-Wide Advisory Committee Final Report
116-2-2 Student Advisory Committee Final Report
190-22TH8U29 . Longitudinal Evaluation of ESAA Pilot and Basic Prograns -
Observation, Interview and Questionnaires
208 Application for Federal Assistance (Noncenstruction) Under
ESRA Title III, Section 306 - Instructions and Supplementary
Quest ionna ire
226-1 Supplementary Instructions and Supplementary Questionnaire for
0MB No. 80-80185
226-2&3 Financial Status and Ferforeance Report - National Drug Education
257 Quarterly Program Progress Report
268 American Indians Enrolled in Public Schools
272 Applications for Federal Assistance - Instructions for Indian
Education Program
295 Application for Federal Assistance - (Nonconstruction Programs)
Instructions for the Right to Read Program
296 Application for Federal Assistance (Nonconstruction) for Title IV,
Civil Rights Act - Desegregation of Public Education - Instructions
and Supplementary Qucstinnnaire
298 Applicatinn for Federal Assistance (Noncenstruetion) Teacher Corps
305-4THRU1O Longitudinal Evaluation of the ESAA Pilot and Basic Programs:
Student/Teacher Roster and Student Attendance and Exposure Log
323 Fm-Application for Federal Assistance - (Construction Programs)
Non-Commercial Educational Broadcasting Facilities Programs
323-1 Application for Federal Assistance - (Construction Programs)
Non-Commercial Educational Broadcasting Facilities Programs
PAGENO="0410"
406
FORM NUMSER FORM LANE -
326 Environreslal Education Progran/lnstructioms for Application
for Federal Assistance (Nonconstruction Programs)
326-1 Application for Federal Assistance (Short Form)/Instruction
for Environmental Edocation Minigrant
335 Educat ion Professions Development Program: Application for
Federal Assistance (Noncoestruction Program)
335-1 A-102 Program Performance Report for the Career Opportunities
Program
343 Application for Federal Assistance (Nonconstruction) Instructions
for Education Development Centers -
347 Health and Nutrition Programs, Instructions for Application for
Federal Assistance (Nonconstruction Programs)
347-1 Financial Status Report and Performance Report - Health and
Nutrition Programs
349 Instructions for A-102 Application: Ethnic Heritage Program
355 Pre-Apphication for Financial Assistance for Public School
Construction
355-1 Application for Federal Assistance (Construction) FL. 81-815
(SAFA)
156 Application for a Grant Under the Mutual Eschamge Program
156-1 Confidential Reference fc:r Applicant
356-2 Administrative Approval for Applicant
356-4 Personal Data on Applicants for Grants
360 Financial Statu s and Per formamee Reports for Discretionary Grants:
Vocational and Education Professions Development Program
361 Instructions for Right to Read A-102 Financial and Performance
Report
362 Application for Federal Assistance (Nomconstruction) for Progran
Grant Educational Programs for Migratory Children, ESEA
364-2THRU5 Longitudinal Evaluation of the ESAA Pilot and Basic Programs:
School Climate Instrument for Elementary and Secondary Students
10
PAGENO="0411"
407
FiRM NUMBER P0111 lAME
375 Survey of Foreigo language Enrollments in i'ublic Secondary
Schools
376 Financial Status end Performance Reports - Follow Through Programs
381 Financial States and Performance Reports for Discretionary Grants
Under Section 306, Title 115, ESEA
387 Financial States and l'erforoance Reports for Eovironnental
Education Projects
392-1THRUS Evaluation of the Field Test of Project Information Packages:
Instructional and Administrative Staff Questionnaire
394-1THRU5 An Evaluation of the School fran Approach for Drug Abuse
Prevention and Early Inte:vention: School Coordinators,
Team limber, Tean Group, Administration, Student
396-1THRU3 Conditions and Practices of Effective School Desegregation:
Quest ionna ices
396-4 Conditions and Practices of Effective School Desegregation:
In-Depth Guide
398-3 NEALRC Survey of Services
399-1 Learning Resource Center Service Data: Northwest Area Learning
Resource Center
399-2 Northwest Learning Resource Center Workshop Evaluation Porn
399-3 Northwest Area Learning Resource Center: Client Perception
of LRC Services
400 Area Resource Learning Centers - Survey of Special Education
Materials/Information Services within SMSA
406 The Public View of the Reading Crisis in America
408, 408-1 Interview Report Format - Placement, Follow-Up, Vocational
Education - Handicapped
410 Placement Services Training Curriculum Development Project
Evaluation Plan and Forms: Information Inventory (Porn A & B)
419 Planning and Teaching Procedures
420 Adequacy and Usefulness of the Career Awareness and/or Career
Exploration in Agribusiness Curriculum Guides
11
PAGENO="0412"
408 -
F(IRM dIAllER FORM NAME
421 Adequacy and Usefulness of the Career (Vocational) Preparation
in Agribusiness Curriculum Guides
430-1 Student Questionnaire (Bilingual Education)
435 Survey of Career Education in Public Schools of the U. S.
440 An Inventory of Bilingual Vocational Training Programs
448, 448-1 & 2 An Assessment of the Vocational Education Programs for
Disadvantaged Students and Special Target Groups
454 A Description of the Nature and Variety of Compensatory
Education Programs in the Elementary Grades - Principal -
Quest donna ire
455 Evaluation of Right to Bead State Reading Programs
1156-2 School's Application for Federal Loan Insirance Cooprehennive
Certificate
1186 Application for Admission to an Institute, Short Term Training
Program or Special Project V-E, P.L. 90-35 (EPDA)
1196 Seport em Current Upward Sound Students
1197 Report on Former Upward Sound Students
1214 Upward Bound high School Senior College Applications and
Test Scores
1225 Report on College Retention of Former Upward Bound Students
1227 Upward Bound Quarterly Financial Report
1229 Special Services for Disadvantaged Students in Institutions
of Higher Education (Student Information Report)
1231 Educational Talent Search Program Project - Statistical Report
2349-2 Library General Inforoation Survey - LIBCII 1: Public School
Libraries/Media Centers
2371 National Assessment of Education Progress
2375,2375-1THRU3 Survey of Athletic Injuries and Deaths
2378 NCES User Needs Evaluation Questionnaire and Mailing List
2379 Fast Response Survey System
PAGENO="0413"
409
f0l2 1121118
2180 St ely of ir ocher Tn roomer
ii 76 InSt roe tonS for Vorat j ()Ofl tel oat ion l'rograms
4019 Appl eat on for School Assistanc e in Federally Affected Areas
(Title I of FL. 81-874)
4019-2 Request for Assistance Under Section 3(1)
4019-3 Supplenental Application for School Assistance in Federally
Affected Areas (Title I of FL. 81-874)
4037 Report for Determining Final Payment Pursuant to Title I of
Public law 81-814
4038 Report of Contract warded
4218 Icquest for Final P yment of P0doral latching Crant for
Construction of Noncommercial, Pdurational Broadcasting
Faci lit irs
4376-1 Annual Survey of Chi]dren in Local Institutions for Neglected
or Dclioquent Children in Correctional Institutions
4473 Application for Federal Assistance Follow Tttrough
4485 Classroom Roster and Related Information
4485-I Follow Through Parent Interview Form
4524 Report ((0 ESEA title I Comparability Requirements
4524A, 4524B ESEA Title I Cotaparahility Report - General Information and
School Data
4532 Follow Through Teacher Qnestionnaires
4532-1 Follow Through National Evaluation Teaching Staff Questionnaire
4532-2 Follow Through Teacher Aide Questionnaire
4533 Application for Federal Assistance (Nonconstruction) Instructions
for Comprehensive Planning 4 Evaluation, Title V, Part C, ESEA
4533-1 Statement of Intent to Participate
4533-2 Financial Status Report and Performance Report, ESEA Title V
Part C
4535 Follow Through Comprehensive Health Services Planning
Questionnaires
13
PAGENO="0414"
410
PORN SIllIER P0111 NAIlS
4536 Follow fl:rough Cuuprchcnsivc Services End-of-Sear Report
4552 Sharing Educat aenol Success: A Handbook for Vol idation of
Educational Practices (Title Ill, ESEA)
4561 Bilingual Education Program, Instructions for Application for
Federal Assistance
4561-i Financial Status and Performance Report - Bilingual Education
7603 Annual Exchange Teacher's Report on Teaching Experience in
the US.
9037 Application for Federal Assistance, Education for the
Handicapped: Instructions and Supplementary Questionnaire
9037-i Financial Status Report and Performance Report - Bureau of
Education for the Handicapped
9037-2 Financial Status Report and Performance Report - Handicapped
Children's Early Education Program
9044 Requester's Technical Assistance Evaluation Fore - Northwest
Learning Resource System
EEOC168 Elementary-Secondary Staff Information (EEO-5) Public School
Systems-Districts and Schools)
F-l3 Survey of Local School District Finances: School Year
HEW6O1T (405) Financial Status Report
HEW6O1T(525) Financial Status Report
NYAOO2 Consolidated Accounts
NYAOO5 Cognitive and Emotional Growth of Children with Learning
Disabilities
NYAOO6. Final Report for Title IV of the Civil Rights Act of 1964
NYAO16 Statistical Survey of Secondary School Students - Pretest
NYAO25 National Register for Deaf-Blind Persons
NYAO26 Adult Education Participation Fore
NYAO29 Survey of Recent College Graduates -
NYAO57 Evaluation of lnformation Services
PAGENO="0415"
411
FORd ElIlFiER FORN
NYAO7I Effectiveness of Adult Education Special Projects Program
NYAO93 Area Learning Resource Center Profile information:
Target Coverage
N1A094 Area Learning Resource Center Profile Information:
Source of Services
NYAO95 Area Learning Resource Center Profile Information:
Inventory/Ut ilizat ion
NYAO96 Area Learning Resource Center Profile Information:
ALRC Transactions
NYAO97 Area Learning Resource Center Profile Information:
Training Activities Quarterly Report
NYAIOO Pretest, Statistical Survey of LEA Programs
NYA111 Fast Res pon so System (Post Card) Request
NYASI9 Pilot Survey of the Preparation of Education Personnel
NYA124 Follow-Up Evaluation of FT `75 School Team Apprnach tn Drug
Educat ion
NYA1A1 LEA lnterview on State and Local Programs in silingual
Education
NYAS42 LEA Follow-Up Qnestionmaire
NYA143 Administration Qnestionmaire
NYA145 Follow Through Classroom Observation Instrument
NYA146 Scales to Assess Progress in rho Affective Domain for Sampled
Grades K-4 Children Yet to be Selected
NYA147 An Instrument fnr Collecting Cost and Benefit Information
for Follow Through Program
NYA148 Standardized Basic Achievement Tests Will Be Selected for
Testing A Sample of Grades K-i Children
IYA1S3 A Study of the impact of Student Financial Aid Programs
NYA1SS An Assessment of institutional Procedures of Federal
Eligibility and Consumer Protection
NYAI57 Employer Benefits from Cooperative Education Program -
Employee Benefits from Work
15
PAGENO="0416"
412
PORN NUNBER PORN NINE
NYA165 Educat ion of the Handicapped Art Porn
NYA169 Survey of Bilingual Vocational Education
NYA172 Common Core of Data - Elementary/Secondary Field lest
NYA173 Survey of Special Preschool Programs Report
NYAE74 Survey of Special Preschool Programs Report
NYA179 Evaluation of the Diffusion/Adoption Network:
Diffusion/Adoption Network Participation Questionoaire
N1A204 Roche Test of Basic Concepts
16
PAGENO="0417"
413
APPENDIX B
DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE
OFFICS OF EDUCATION
WASHINGTON. 0 C. ?O~OZ
ocr o& 975
Bonorable Jack P. Nix
Superintendent of Schools
State Department of Education
Atlanta, Georgia 30334 .
Dear Jack: .
Thank you for your letter of September 25. I ~_yourconcernabou~tt~~
* nofdataco]ectiop* re~u~en~~ ~ U. S
~ Accordingly, with the ESEA
* Title IV program, ~ *~91ke4..~2 ~
* ~most_v4uable informationievying~the~~S9Ql~dAi..
In fact, we calculated that under current categorical prograns which were
consolidated (excluding in this count Health and Nutrition and Dropout
Prevention) we collected 392 pieces of financial/statistical data. Our
* analysis of the universe of data that could be collected for Title IV
Indicated 4,000 data bits. Originally (the docuent you revie~;ed) we
`called for 402 pieces of data.
Since that time, we have worked with the CEIS group, and the currant
proposed data lists n~anber 239. On October-21-23, we will be attending
the Semi-Annual CEIS meeting to garner final recoendaticns. At the
same time, the material will be presented to the. Title IV State program
coordinatprs and Title IV State Advisory Council Chairpersons in Hyannis,
}Iassachusetts.
This ç tpLopc~alh.aa1spJu~Jteen** ~
~ Perhaps, you have received yours by now.
~ It seems highly unlikely that
will suggest an increase in ~
- review.
Thank you, as always, for your candid expression of concern. I think you
.will find that we are carefully considering the financial costs and man-
agement burden of data collection for Title 1V and that we want to be
responsive. * *
- . . .. . . Sincerely,
T. B. Boll
U.S. Commissioner
- of Education
91-860 0 - 77 -- 27
PAGENO="0418"
414
STATE OF GEORGIA
DEPARTMENT OF EDUCATION
OFFICE OF THE STATE SUPERINTENDENT OF SCHOOLS
STATE OFFICE BUILDING
ATLANTA 30334
JACK P. NIX
State Superiotcadent of School*
September 25, 1975
* Honorable Terrel H. Bell
* Commissioner of Education -
* U. S. Office of Education
* . 400 Maryland Street
* Washington, D.C. 20202
* Dear Ted: -
I have received and carefully reviewed a memorandum with enclosures
of August 22, 1975, from Mr. Thomas J. Burns relative to the data
requirements under Title IV of PL 93-380. This 19-page document
* causes grebt concern in that it supposedly represents the minimum
4ata requirements of the U. S. Office of Education for Title IV.
1 have serious questions over the necessity or desirability of.
USOE collecting this vast amount of information on this one title
in addition to that required elsewhere in PL 93-380 for all
- education programs. Some of the items of information, such as
the FY 1973 expenditures for administration, should already be
available in USOE while others are not specifically required
* by the law nor have any real apparent value. For example, the
information requirements relative to dissemination activities
under Section 403 (a) (b) do not seem to be supported by the
wording of the statute.
The costs of collecting and reporting data have escalated greatly
in the past few years. As administrators of educational programs,
we must assure that the maximum benefit is derived from each
dollar available at the state, local, and federal levels. I
* * strongly feel that the collection of unnecessary data detracts
from funds that could be better spent helping the children of
this nation, and I solicit your cooperation in working with the
* * CEIS group of the CCSSO in assuring each item- of information
PAGENO="0419"
415
Honorable Terrel H. Bell
September 25, 1975
Page Two
collected is essential to the legal or managerial requirements of
the program.
With warm personal regards, I am
Sincerely,
Jack P. Nix
State Superintendent of Schools
JPN:lf
cc: Mr. James E, Mitchell, President CEIS
Mr. Mark Shedd, Connecticut Co~issioner of Education
Mr. Thomas J. Burns
PAGENO="0420"
416
DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE
0)-i-CL OF rr~uca 1 ION
August 22, 1975
MEMORANDUM TO CHIEF STATE SCHOOL OFFICERS .
SUBJECT: P.1. 93-380, Title IV Information Analysis -.
Over the past few months, we have been working to identify the
information needs associated with the administration~fl~~3-38~
Title IV. These needs will have to be met through reporting
mechanisms, on-site monitoring and evaluative studies.
Naturally, our attention is drawn to unde and in this law's effects.
Specifically, the authors of this law perceived that the efficiency
and effectiveness of the administration of these programs could be
improved if the locus of decision making were to be closer to the
recipients of the programs and services to be prov.ided. Moreover,
decentralized decision making, it was believed, could result in a
better matching of Federal dollars with State and local needs. This
is the focus of what we need to know about in the next three years.
our internal effort~ two analyses have been prepared
~fgSJn the ext rerses on the continuum of data needs for Title IV:
one end indicating the maximum data requirements tha~can~justified
in accordance with the legislative intent; and, o~the other end, an
a~T~TfT~h~iimum essential data. - __________________
Over the next two weeks, the OE staff will be working to review these
with some State representatives; including some CEIS ~embeç~,_~nd~
~ This work group will prepare
the corpus of the Annual Report that will be submitted for 0MB
clearance which can take up to three months. The final report
will call for more data to be collected than would the enclosed
needed
cons I de ra t on s as ~náT~t~ThT ~ a
comparability with that from the past will be reviewed by the work
group. It is expected that they will call for additional material
to be add~ ~ `.-.----------. -~ ----~-~
PAGENO="0421"
417
MEMORANDUM TO CHIEF STATE SCHOOL OFFICERS 2
In addition,, these work groups will have identified certain areas
needing special evaluative studies or inclusion in our monitoring
visits. Again, over ~
with State representatives tofnalize u monitoring design and
evaluat,o~~teie~.. As the result of all these efforts are
available, I will communicate them to you.
An a~d~dTti~p,~aJ copy.Qf.tke r~nJ~Ur~ datanalysi iencJoSQd_for_y~j~~
clistrbution to the person in your de~partment responsible fo
administerinpJitJe~l,V.. If as a result of your review ypu have~
~E,orm11ents, please forward them to me no latr than S~p ernbeaJ2ih~
* Thomas J. Burns
Acting Associate Commissioner for
* - State & Local Educational Programs
Enclosure
PAGENO="0422"
418
PREFACE
The following analysis is the ~ we Feel at
the preliminary stage to be unquestionably justified by P.L. 93-380..
As such, j rce ~ r-
formance, flnancial, and statistical) which will b e uested in the
~
Pages 1-3 consist of applicable definitions drawn from proposed regulations
and current standards. Pages ~-l8 consist of interrelated performance,
financial, and statistical information requests developed to provide an
integrated perspective in the analysis of Title IV programs. This request
provides essential information on the comparison of program goals with
actual accomplishments, reasons for slippage, program accomplishments
and management control systems as well as quantitative data on the
use and impact of Title 1V funds. The specific data elements were included
for their abilitytQ answer specific questions drawn from the legislation
and potential users. Pages 1~-8 consist of performance questions arrayed
and cited by pertinent legislative authority. Pages 9-18 consist of fi-
nancial and statistical data elements arrayed and cited by pertinent -
legislative and regulation authority.
Legislative and regulation citations have been provided to stress the
legitimacy of the request as well as to prevent any confusion arising
as to the specific nature of the data requested. (For example: data
sought under l314b.lO(c) "remedial instruction and services" refers to
"remedial instruction, and school health, physical
education, recreation, psychological, social work,
and other services designed to enable and encourage
persons to enter, remain in, or reenter educational
- programs, including the provision of special educa-
tional programs and study areas during periods when
schools are not regularly in session."
The current array is in no way indicative of the final format which the
Annual Report will take. The final format will, of course, be con-
sistent with 0MB regulations. Divergence from and additions to the data
presented inthis analysis will result from the OlIB clearance process.
Consideration of data requested in the past under categorical programs
which still has legislative significance will also beconsidered.
PAGENO="0423"
419
DEFINITIONS - TITLE IV
1. "Academic subjects" includes, but is net linited to, the following ele-
mentary and secondary school subjects" The arts, civics, ~cOnornics,
English, geography, history, the humanities, industrial arts, math-
ematcs, modern foreign languages, reading, and science.
2. "Children with specific learning disabilities" means those children who
have a disorder in one or more of the basic psychological processes
Involved in understanding or in using language, spoken or written,
which disorder ray manifest itself in imperfect ability to listen,
think, speak, read, write, spell, or do mathematical caiculations.
Such disorders include such conditions as perceptual handicaps, brain
Injury, minimal brain dysfunction, dyslexia, and developmental
aphasia. Such term does not include children who have learning problems
which are primarily the result of visual, hearing, or motor handicaps,
of emotional disturbance, or of environmental disadvantage.
3. "Cultural and educational resources" includes: State educational
agencies, local educational eqencies, private nonprofit elementary arid
secondary schools, insti tutions of higher education, public and non-
profit agencies such as libraries, museums, musical and artistic or-
ganizations, educational radio and television, and other cultural and
educational resources.
14, "Elementary School" is a school classified as elementary by State and local
practice and composed of any span of grades not above grade 8. A pre-
school or kindergarten school is included under this heading only if it
is an integral part of an elementary school or a regularly established
school system.
5. "Handicapped children" means mentally retarded, hard of hearing, deaf,
speech impaired, visually handicapped, seriously emotionally dis-
turbed, crippled or other health impaired children who by reason
thereof require special educ~ation and related services. The tarm
includes children ~ith specific learning disabilities to the extent
that such children are health impaired children who byreason thereof
-require special education and related services.
6. "Local educational agency" means a public board of education or other pub-
lie authority legally constituted within a State for either administrative
control or direction of, or to perform a service function for, public
elementary or secondary schools in a city, county, township, school dis-
trict, or other political subdivisi5n of a State, or such combination of
school districts or counties as are recognized in a State as an admin-
istrative agency for its public elementary or secondary schools. Such terr
also includes any other public institution or agency having administrative
control and direction of public elementary or secondary school.
PAGENO="0424"
420
-2-
7. "Hinor remodeling" means minor alterations which are (a) made in J pC; -.uSly
completed building used or to be used as a laboratory or clausroon: for
Instructional subjects, and (b) needed to make effective use of equip-
ment in providing instruction. The term does not include building
construction, structural alterations to buildings, or building esaintenance
repair, or renovation.
8. "Nonprofit" as applied to a school means a school owned and operated by
one or more nonprofit corporations or associations, no part cf the net
earnings of which inures, or may lawfully inure, to the benefit of any
private shareholder or individual.
9. "Occupational education" as used in Part S encompasses "occupational ed-
ucation" and `career education." "Occupational education" is designed
primarily to prepare pupils for im-vediate employment in an bccs'estion sr
cluster of occupations. "Career education' is a comprehensive K-l2 p0-
gram that introduces every child to the world of v:ork end prerares hi-s For
a place in it~
10. "Other instructional materials" are the same types of printed end undiosisnal
materials as are defined in "school 1 ibrary resourcds," but they ore s-ct
processed and organized for use. -
11. "Personnel" (LEA) are employees of an LEA or any persons under the super-
vision of the LEA who are eligible for t-;orkrsen's compensasior, Federal
Insurance Contribution Act, and wage or salary tax withholdecs. In-
cluded are persons who volunteer their services. (IVR) (CEA) Either sos-
ployces of the State departmmnt of education or nenbevu of a State board
of education.
12. "Private school" means a nonprofit school not under public supervision or
control.
13. "Private school children" refers to children v:ho are enrolled in pris'ete
non-profit elementary and secondary schools.
114. "School library resources" are books, periodicals, documents, pamphlets, re-
productions, pictorial or qraphic works, musical scores, naps, charts, alobes,
sound recordings, including but not limited to those on discs and tapes;
processed slides, transparencies, films, filmstrips, kinescopes, and s'ideo
tapes, or any other printed and audiovisual materials of a similar nature
made by any method neat developed or hereafter to be developed, and which
are processed and organized for use by elementary or secondary school chil-
dren ~nd teachers. The term includes those printed and published materials
which are suitable for use and are to be used by children end teachers
In elementary or secondary schools and which with reasonable care and use
- may be expected to last more than one year. The term does not include
furniture or equipment.
15. "Secondary school" is a school comprising any span of grades beginning with
the next grade following an elementary or middle school and ending with
or below grade 12.
PAGENO="0425"
421
-3-
16. "Short-term training sessions" for persons engaged In guidance and counseling
In elementary and secondary schools are sessions conducted or contracted for
by local educational agencies to provide developmental activities which
expand or strengthen guidance and counseling programs in elementary and
secondary schools. The length of the sessions is such that the absence of
local school guidance personnel from their professional responsibilities
wIll not prevent their performance on a regular and nearly full-time basis.
17. "State advisory council" means the advisory councIl established under Sec-
tion ~O3(b) of the Act.
18. "State educational agency" means the State board of education or other
agency or officer primarily responsible for State supervision of public
elementary and .secondary schools.
19. "Teacher" includes any person who is engaged in carring out the instruc-
tional program of an elementary or secondary school, including a prin-
cipal, guidance counselor, school librarian/media specialist, or other
member of the instructional or supervisory staff.
20. "Testing" means the use of test, aptitudes, educational achievement, or
interests, pertaining to an individual's educational or career develop-
21. `Textbook" means a book, reusable workbook, or manual, whether bound or in
looseleaf form, intended for use as a principal source of study materials
for a given class or groups of students, a copy of which is expected to be
available for the individual use of each student in such class or group.
PAGENO="0426"
422
PERFORMANCE - TITLE IV
Part A. General Administration
`1. Describe briefly the implementation of the administrative
procedures and activities set forth in the Annual Program
Plan for administering and supervising the Title IV pro-
gram duriig the year.
2. If the administrative procedures and activities could not
be fully implemented, what were the reasons?
3. What was the cumulative effect of these procedures and
activities on Title IV program administration?
4. `Assess the extent to which the respective Title IV programc
have contributed to the attainment of educational goals in
- the State.
1i03(a)(2): Describe any deviations from the program set forth
in compliance with Section `403(a) (2).
`403(a)(3): Describe any deviat'ions from the assurances made
in compliance with Section 403(a) (3).'
Li03(a)(4): Describe a~y deviations from the assurances made
and specific criteria developed in compliance with
* Section `403(a)('4).
403(a)(5): Describe the impact of local discretion in the use
Part B funds in meeting the needs of public and pri-
vate school children for school library resources,
* . textbooks, and other instructional materials; equip-
ment and minor remodeling; and counseling, guidanèe,
and testing programs. - - * -
403(a)(G): .1. - Was the evaluation design included in the Annual
Program Plan followed? if not, detail nature and
reason for divergence.
2. Describe the extent of attainment of the proce-
-dures and calendar set forth in the Annual Program
Plan for dissemination of the results of State Advisory
Council evaluation and other information. If the
procedures and calendar planned could not be fully
carried out, what were the reasons? *
PAGENO="0427"
423
-5-
3. What methods of disseminat'ion were used for
Part 8? For Part C?
li. To what extent has the SEA disseminated evalua-
tion findings `in a form and language that the
community, legislature, and potential adopters can
understand?
5. To what extent has the SEA employed effective
procedures for the identification and adoption of
* promising educational practices developed through
* innovative programs supported under Part C? What
are these procedures?
L~O3(a)(7): Describe the effects of the adoption of the single
application requirement. Give particular attention
to this requirements effect on reducing the a~ount
of paperwork of the State and local levels.
1403(a)(8): (Reference financial/statistical material attached.)
1i03(a)(9): Describe any deviations from the assurances made in
compliance with Section 1403(a)(9).
1i03(a')(lO): Describe any deviations from the policies/procedures
set forth in compliance with Section ~O3(a)(lO).
L~O3(a)(ll): Describe any deviations from the assurances made in
compliance with Section 1403(a)(ll).
1403(b)(l): I. Describe the extent and manner in which the Advisory
Council advises on the preparation of the Annual Program
Plan.
2. * Describe the extent and-manner in which the Advisory
Council advises on policy matters arising in the
administration of the Annual Program Plan.
3. Describe the extent and manner'in which the Advisory
* Council was involved in the development of the Part B
`Formula and the Part C criteria for the distribution of
* * funds and the approval of projects for funding under
Title (V.
- (Reference statistical material attached.)
PAGENO="0428"
424
-6-
403(b)(3): (Reference statistical material attached.)
~O3(b)(14): (Reference statistical material attached.)
1406: 1. ~Does each application submitted to the SEA'adequately
provide information indicating:
a. the number of private school children in
the school district of the LEA,
b. the number of private school children to
be served by Title IV projects and the
basis on which such children were selected,
c. the manner in which and the extent to which
"appropriate private school officials" were
consulted,
d. the placed at which and the times during which
private school children will be served,
e. the differences, if any, in the kind and
extent of services to be provided public and
private school children and the reasons for
such differences,
f. the adjustments (if any) which the LEA has
made with respect to average expenditure
equity per child, and the basis on which such
adjustments were made.
2. Are there adequate provisions to avoid the separation
of participating children by school enrollment or religious
affiliation in any project to be carried out in public
facilities which involves joint participation by chil-
dren enrolled in private and public schools?
3. Ta what extent has each appropriate public agency
administered and controlled the funds, materials, equip-
ment, property, and services and maintained title to
such materials, equipment, and property as provided
for private school participation?
(Reference statistical material attached.)
PAGENO="0429"
425
F'art B. Administration - Libraries and Learning Resources
1. a) Describe briefly the extent of implementation of
* the procedures and activities set forth in the
Annual Program Plan to accomplish the program pur-
poses of Part B. Attach any appropriate exhibits.
b) If the procedures and activities could not be
* fully implemented, what were the reasons?
c) What was the cumulative effect of these procedures
and activities on participating local educational
agencies and the public and private school participants
within the jurisdiction of these agencies?
2. Describe any critical problems that have arisen in the
administration of Part B.
3. Assess the extent to which Title IV has contributed to the
attajnment of educational goals in the State, in view of
the fact that the local educational agencies have complete
discretion in the choice of purposes for the use of Part B
funds.
4. Describe the most urgent reeds still unmet in your State
for a) materials and equipment; and b) guidance and coun-
sel ing, and testing programs.
5. Indicate Statewide trends in the types of materials and
equipment being acquired, and in guidance and counseling,
and testing programs.
421(a), 421(b):.. (Reference financial/statistical material attached.)
Part C. Administration - Education Innovation and Support
1. For each objective in the approved Annual Program Plan,
describe the activities actually conducted toward achieving
the objective; identify the kinds of data used to evaluate
results. Attach any appropriate exhibits such as samples
of evaluative instruments, publications, and materials.
2. For each objective describe the results and benefits derived
by agencies, individLial participants and/or affected
populations.
PAGENO="0430"
426
* * -8-
3. For each objective not met, provide information as to the
degree of achievement and the reasons activities under-
taken were not successful in accomplishing the objective.
Irs each case where an objective was not met, describe
* what actior~ has been taken which should lead to the attain-
ment of that objective.
1~, Describe the most urgent needs still unmet in your State
for (a) learner needs, (b) SEA and LEA strengthenTng/leader-
ship.
143l(a), 431(b): (Reference financial/statistical material attached.)
PAGENO="0431"
427
-9-
FINANCIAL/STATISTICAL - TITLE IV
1403(a) (8) (A):
1403(a) (8) (A):
403(a) (8) (A):
403 (a) (8) (A):
1403(a) (8) (A) :~
1403(a) (8) (A):
1403(a) (8) (B):
total Part B expenditure:
total Part B expendi ture for administration
total Part C expenditure:
total Part* C expenditure for administratiOn
total Section 43l(a)(3) expenditure:
total expenditures from Federal sources (listed below)
for administration in FY 1973 for:
--ESEA II
--NDEA III
--ESEA III
total Title IV, Part C $ spent on programs/projects
for handicapped children and children with specific
learning disabilities:
PAGENO="0432"
428
-10-
1~O3(a)(8)(A): Total FTE positions supported by Part B administrative
funds:
1i03(a)(8)(A): Total FTE positiotissupported by Part C administrative
funds:
1403(b)(l)(C): if of programs and projects fully evaluated by Advisory
Council and brief description of type of evaluation
method used:
1~O3(b)(L4) : Total $ expended by State Advisory Council:
$ expended by State Advisory Council for evaluation:
Lffl6 : I of private elementary school children enrolled:
I of private secondary school children enrolled:
I of public elementary school children enrolled:
I of public secondary school children enrolled:
I of private elementary school children participating
in Title IV programs/projects:
I of private secondary school children participating
in Title IV programs/projects:
I of public elementary school children participating
in Title IV programs/projects:
I of public secondary school children participating
in'Title IV programs/projects:
PAGENO="0433"
033 00
00 0-3 000
C t4-.~ C C t.3-~ C
0 `4 0.0 0 `~ .~- `3
o. `~ -.i o.. C.? -~ 0.
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00 0-.4~Uo-.~-o
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-.4 C 1 0. C3 0. 0. 04 r~ 0.
0J~-4 C: 04(10-0.41 ~ o. 0r~
* `3'430.r3 0.0.C) 0.
* I 0.'3'-O. ~0C 0.1/5
.-40.U-~C /01/3 1-05
.,4 U 04 .`-I 0- 0 -~ 0. 0 0- C C)
0- `~`0 0-.-'0.~ C) U.C
0-040 0-,-i'0-.l.- (JO (3 U
(3 0- 0. 5 .4 ,-i C -`4 (3 0 C) (3
coo 0.~-'UOC4c5.4Q
C3.1/) 0.0 U.C) oi
03 `-41/3 U.-' .4.4
`0) ,-4 03 0 - - 0 `-4 `-4 0 .-4
0) 0,-4000.-4000-0O
`0 00.0000.0000_0
C .0OU.0.00U.0.000C
`0~ UC4flUU.C/flUU.0V30
0)44.41/0030 /5050 /5050 (.3
`0 C VS). U)), lU).
* CVS'-4)~ ))-. 4)4), 34>%
`40- 0-0.
* 0.0(3(10-04(3410-040(31404(1
3< C) 0.~ (3 C'0 `40 00 (3 C'0
0-3-~~-,-i C'0 C) C C'0 C) C S C) C
000)CVS0C)CEOC)C030
V5 14~4 030000300 U 03000
0- 0.440) U `-4 00 U `-4 C) C) U .-4 C)
.403030)03 0)05 0)03
0)0) 0)0 5.3/5)
* 0(3 00040400 JUU"'4
00- ~->)~,-l~>.-~,-,)>
~- 0~~.04~4~).-4.-4
H 1410 ~ 01.414000- 1~ 001.0.
0.0.0.0.0.0.0.0.0.0.0.0.
* ~4 `41.4444 `40-i `4 `4040-40-40-404040-4
4J00000000000000
*1~. ~1/. ~ ~. ~ ~ ~. ~ ~. *~ ~
LEARNING RESOURCES
School Library Resources, Textbooks, and other Instructional Material __________________________
(not including that used by Occupational Education) Total ____________________________
Sc~oo1 Library Resources
Textbooks
Other Printed and Published Materials
134(a) (10) School Library Resources, Textbooks, Instrucional Materials -`(Occupational Education)" Total _________________________
Instruction ,
Orientation
Cuidance/Counselirig *
LIB?.ARIES A\~D
421(a) (1)
~j iii I 1111111
:11 i-u ii i iii iii
0
PAGENO="0434"
Instructional Equipment and Minor Remodeling Total
Laboratory Equipment
Audio-visual Materiala and Equipment (academic subjecte)
Other Special Equipment.
Minor Remodeling of Laboratory or other Space for Instructional Equipment
421(a) (3) (A) Testing
421(a) (3) (B)
423(a) (3) (C)
Counseling and Cuidamce Total
Short-term Training Seasions (counacling and guidance)
Other Counseling and Cuidance Programs
Expanding/Strengthening Counseling and Cuidance Total
Leaderéhip Activities
Other programs
cO)U CU~
-r.- c. 0-0 0-1.
0. n 4 -i .e -~ 0 U U 0
.m
on u.c uuu
0 0O.00000000O
o
00
e n> a>. a>.
oa,~- ~ L)>~ ~>
o o~ ecu no ac-u nor. CO
noenCCOC~CCOO
ounCU000uOUCeo
a U~ n on un 0 u uC o n u
U 0-UO u,a on u-u on
~ on Cr0 OU u.U OO~
no no no
00-
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U UW a a U U 0 0 U U 0 0 U.
0-0.0.0-0-0.0-0.0-0.0.0-
~OOOQOOOOOOOOOO
en en ~. en en en en en en en en en ~ en
]iiiii{~
*r-[i Ii~LJ
r1I1i~~iIIII1ii
fl'l 1 H ~-~-1 H~1
~ ftTLL
PAGENO="0435"
0:~t~ 2
.0 -4a0~-4.o 0-~-~ 0~--~U
S 0,-4000~000~O00>-~
.0 O0C000~000~C-~'~
c .C0U.C.COUO.COU.m o~.
~ ~ x U U.0 a u u.a a U 0 C 2.
.0 0 C5-~ a>~ a>~ ~.cC
0Cd~ i~;-)~ ~> I'~OC0
0.'-~ 0 00 00.0 `0 C'D.0.~0
,-4E00. 05 50
on ~
`~ ~ ~
S
50 0 00 0000 0000000 0
no no ~. ~. no no no
EDUCATIONAL INNOVATION AND SUPPORT [-~.--
431(a) (1) Supplementary Educational Centers and Services - Tots~] I 1 i I i I I
Inservice Training
134(b) (10) (A) Planning and Pilot Projects
134(b)(l0)(3) New ahd Exemplary and Innovative
134(b) (10) (C) Remedial Instruction and Services
* Continuing Adult Education
Occupational Education
Specializad Instruction
Improved Education Technology and Special Personnel
Radio and Television
Critical Educational Needs
Special Services to Rural and Isolated Areas
Encouraging Cocusunity Involvement
Programs for Gifted and Talented
Other
PAGENO="0436"
(J~ `I.
C..-.
c-_c- c~--
~_cej. c:
C..-
.. C..- C..~ C.
urc~_cCc_~cC..r. c~ c.-
r~ c-c: - c.-
~_c~c..'_cc-c: `.C~i-C..
r~*~4 c_cu U I.. `j~~ .. C C. C
cc u~~-~'-c ccc. c.ic
L C.L-s~.C.~ ~- 1 `_c I-
eD-c, ~
ic c-i.c-u~ uD-~ c.
tie - u-c c-...
e c:.-ieoe'- o-- C-'
cc
u `.coo.:ooo.C.occ..o
C
.e~ u.cc.Cu.~iu~ec_c
O'utiCc-4CU UVI(.J CVU
cc c:rc uc~,cn cc~, cc>.
c:cc'-~c:>.. ~. >~ u>..>- u>,
,`CJuuOu>,e u>..r3uu>-~cu
c-un-cic~,ec c,cur3c~uut
cc e.c.c c_i r r. ~ c~ !.~_c
ti~-~-~-~c c3 c:e ti'~ CC. C_c C C3 J C
ouuccCDCccCEcccao
-a-
-icicic cia ccc
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OCC uUUuuUUuuUUc_iu
DC >.-4.-1 > >.-c.-4 > >.-4.-. > >
~-j uL~ U U U U U ~ U U
c--a ~c-c-a.c-
0)
,-~ Ic__c ~_c c__c c__c D, ~_c 1_c U_c U_c U_c U- U-
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
f-i `ic, ~ `c~ Dc_ `~ ~ ~
431(a) (2) Nutrition and Health Demonstration Projects (LEA) Total
431(a)(2)(A) Coordinating Nutrition and Health Service Resources
431(a) (2) (B) Supplementary Health Services
Mental Health Services
Nutrition Services
Food Services
431(a)(2)(C) Nutrition and Health Training Programs
Evaluation of Nutrition and Health Projects Assisted with Part C Funds
431(a) (2) Nutrition and Health-Other fl 0
~I1.~t
:
iLL
i-i
LW
11
iJ~
HTJ
PAGENO="0437"
.,o
u
S
~:
`a co.
`~ c ~ o
a. U r~
xsa.
~ `~,-4 S
ouc
LA
-400.5
00 0
* *
S
,-4 4~.4 ~
4.J000
Strengthening Leadership Resources of SE/L and Assisting SEA's - Total * ri iijJ~J
Personnel ~` 0
i,34(b)(30) * Statewide Educational Planning and Evaluation Programs
Data Information System Programs
Dissemination Programs
* Research, Development and Demonstration Programs
Publication and Distribution of Curriculum Materials .
Teacher Preparation Programs
Programs to Encourage Use of Paraprofessionala
Educ~cional Financing Studies
Programs to Measure Student Educational Achievement
Staff Development Programs _______
Providing LEA's with Technical Assistance .
* SE/Lother *
PAGENO="0438"
0
CJ .0
.0 C)
* 430
`0 CO.
CU)-4 0.
0 U)
XC) 0.
(4
ou c
U) 4~ `4 0
I~ 0. ~
(4 `... 4~ 4J
U) U)
C 0.4)
0(4 0
~ 0.
Ca'
~. 0
CI)
)~
C.) -4
CC
4)
)44~)
CCCI)
C,))
*.
U
*o CD
a;)
`C)
CC
a ,C)
C U)
+4,-D
Ot~
C)-4
~
m
n
o
0
t
n
Ca
5. Ia schaol eXcillaDvc)y
handicap
6. Number of voc ed
programs
0
7, Architectural barrier
to the handicapped
8,9. Count of children
needing special accom
modations or transix,
0~
0~
-
10. Count of pupils
transported
11,12. Count of pupils in
specific academic!
vocational courses
sex
0
~
.
- - - -
.
-
13. Count of membership
by race and sex
*
0
44
0
*
0
*
0
*
14.' Count of dropouts by
race and sex
15.' Count of graduates by
race and sex
0~
16. Count of non-English
speaking
*
0
0~
0~
17. Count of ESL or bi-
lingual courses
0
~
0
*
18. Count of discipline
by race, sex & type
19, 20. Special ed by rae
and type
0~
0
.
20. Special ed by type
and sex
0
20. Special ed by type
and tiac in insoiation
0~
0
0
.
.
21. Special ed teacher by
type
0
*
0
.
23. Pupil grouping by
race and sex
PAGENO="0523"
(1)
z
~) CD
-`3
-`3W
0
0
p
0
p
~ ;~
PAGENO="0524"
srii:i_, `~Thr forms look like
lishitig expedition that can pl acva well-
ixteutioved school dtstr&ct in jeopardy.'~
The nasty little twist is that sclibbl
boards are being asked to turn over in-
formation that nay blat be used against
thorn. Furthermore, a recent low en-
actvd by Congress permits courts to
auard attorney fees to groups or in-
diniduals that win certain kinds of
lascsuits. So the prospect seems to be
that the federal government svill gather
information from school districts, make
the information a matter of public rec-
ord, and spawn the creation of a new
breed of ambulance chaser--the un-
scrupulous lasvyer ssha will comb
through ho information in search of
anything that looks like d violation of
federal law in order to sveane a lawsuit
in behalf of an alleged victim of school
board discrimination. And if the lawyer
ssins its behalf of his clinnt, thu school
board can be ordered to pay attorney
fees along with damages.
Understandably. schaol people are
scary. In fact, they've sent letters and
telegrams to Washington, protesting the
frderal gacernment's action. Sa far
their complaints have gone unredressed.
Arizona's Carolyn Warner, a former
school board member and now that
state's chief school officer, has refused
outright to distribute the federal forms
to school boards in Arizona until the
President responds to school district
objections. Three other stales have
joined Warner in the boycalt, and the
sentiment is rapidly spreading. In the
opinion of many school people, this
time theFed has gonetoa far.
lint this is sshere political realities
may come into play. Jimmy Carter first
came to national attention as a politi-
cian who took a harsh view of the in-
trusion of burenucrats into the oper-
ation of stale and local governments as
swell as in the lives of individual citizens.
The bueeauccacy can and most be con-
trolled, he told us. lint at the same time,
Mr. Carter is a southern President, and
a man who must carefully anoid taking
atty action that sooutd indicate anything
short of a full commitment to cicit
it the meantime, school boards antI
administrators ave farad scith three tin-
comfortable choices. Thry can: comply
Ito feckral reqnest, gather the in-
fwv:ativ:t antI send it lv u.c'.n by tim
catty Fzbrtr:rry deadline; collect lie data
bat rzfnsa to mad the forms;
tiv.usrylblJ
or simply igroer the goxeenment's re-
quest for info::na:iou and wail-prob-
ably at their peril-to see ssl:at happens
(sxhich could baa lasesnit against them,
filed by the Jnslire Dcpaetmeut).
The picture was complicated the maca
last month schen, in a parting shot, the
Ford Administration turned down the
request of slate education officials for a
year's delay in complying with the
federal demand. The Administration
allowed, however, that Hew, jI pre-
pared to negotiate soith school boards
that haoe not kept goad records of the
iuforwr:tic:n hat Washington scents.
Things. itt any case, scam headed for
- a;sho:cdo'.an. the fcdzval fuseenmect,
000CC side of the line drawn is the dirt,
is demanding that school districts spend
time and tnooey to collect data sailboat
any clear indication of horn the iufor-
motion is to housed or why it is needed.
Ott the olhor side are school peuple soho
mast decide sshethee they will comply
maith the request, or ignore thequestion-
rairzs and face the possible conse-
quences. hVe'll soon sen saho blinks
first.
520
PAGENO="0525"
521
Chairman PERKINS. Proceed in any manner you prefer.
STATEMENT OF MS. PHYLLIS McCLURE
Ms. MCCLURE. I would be glad to respond directly to the state-
ment that Mr. Gluckman made to the effect that so many papers
are compiled under title IX and title VI and sent to the Office for
Civil Rights, who could ever read them, and then he says, "All too
often according to the civil rights groups, themselves, very little
enforcement of the law has taken place."
That is directed to the legal defense fund. We have been one of
those organizations most critical of the lack of civil rights enforce-
ment. But I would say, Mr. Chairman, there would be no enforce-
ment without any doubt.
STATEMENT OF PAUL SMITH
Mr. SMITH. Thank you, Mr. Chairman. I am Paul Smith of
Children's Defense Fund. I was struck by three things, and I would
like to mention them briefly.
The first was the analogy offered to us as an alternative for civil
rights compliance enforcement. It suggested that the alternative to
a regulatory approach which depended upon forms and bureaucrat-
ic review might be that of the traffic laws. I was struck by that. If I
understand the way traffic laws are enforced, they are enforced by
having officials, policemen, physically present at the time when the
supervised operation occurs; that is, there are traffic officers right
there on the road when driving happens.
If I carried that analogy over to the enforcement of the civil
rights laws, rights not only of the blacks but linguist minorities, and
sex and handicapped groups, the enforcement in the public schools,
acting as contractors for Federal programs, that would mean that
the principal would meet as he comes to his office `in the morning
not a Federal form but a Federal face, and I am not sure that that
analogy has been thought through, and I am not sure that its
acceptability to the principals and school superintendents of Amer-
ica will be as popular as it might seem. That is my first point.
I think there are reasons why compliance mechanisms of a
specific kind occur in different areas of government operations. I
think while there is much to fault in the present civil rights
enforcement strategies of the Federal Government, the idea that
the basic approach is wrong, that we need traffic cops in the schools
rather than Federal forms once a year, is probably wrong.
The two other points are smaller, and I offer them only because
perhaps there has been confusion. One is the picture of the civil
rights survey, which is, I think, at the heart of this controversy,
would not quite be accurate. Let me just make a comparison. Let
me go back to the strategy when only title VI, that is, the race
discrimination and national origin provision of the Civil Rights Act
of 1964, was enforced. This would be the period from 1968, say,
through 1974.
At that time, the Office of Civil Rights had an annual survey in
even-numbered years. Approximately 8,000 districts received forms.
PAGENO="0526"
522
They received both forms, the 101 for the district total, the 102 for
each individual school. As a result, 80,000 forms, that is, individual
school responses, were ifiled out, plus there are on the average 10
schools per school district in the survey.
On off years about 3,000 districts again received both kinds of
forms. Now I don't thi~ it is clear today that there has been a
change. There is a new survey plan. That survey plan emerged
because the responsibifities now included handicapped discrimina-
tion and sex discrimination, but it also emerged out of an attempt
to reduce the paper required.
Today, in the 1976 survey and every even-numbered year there-
after under the current plan, it is true that 16,000 districts will fill
out the abbreviated district totals, but only about 3,600 districts will
have the school-by-school forms. The actual number of responses in
the major survey years has been cut about in half.
Further, the off-year survey, the survey in odd-numbered years,
has been much reduced in scope. The current extent of a 1977
survey is in doubt, but no proposal abroad today suggests that we
will ever approach the size of the previous off-year surveys.
So the sense that there is some growing survey which is out of
bounds is just not true. There has been a tremendous reduction of
workload.
My third and final point goes to some technical matters that are
constantly being broached, and I hope they are clear. One can see it
in the past statements. One is told two different things. Random
samples may lighten the workload. Separately, that some school
districts with very low minority percentage of enrollments are
filling out iorms. Well, there is a connection because a random
sample is used. Of course, as they broaden the responsibilities from
minorities only under title VI to the new provisions of title IX in
section 504, the Handicapped Act, and since handicapped children
and women are distributed relatively equitably all across the Na-
tion's schools, the new survey does take a random sample of all
school districts to ifil out the 102's.
The effect of that is that some school districts with very low
percentages of the identified racial and national minorities will fill
out the forms, but, of course, Mr. Chairman, those districts have
women and have handicapped students, so that much of the criti-
cism involves not looking at what is actually done, not recognizing
previous accommodations, the need to reduce workload and not
recognizing how the survey functions as an enforcement tool, and
that it does contain-and it is a very complex research tool, compli-
ance tool, in terms of its design-that it does contain many of the
features that you hear recommended today.
Thank you for this opportunity.
Chairman PERKINS. Do you have anything in response, Mr.
Gluckman?
Mr. GLUCKMAN. Only briefly.
Chairman PERKINS. Just summarize it.
Mr. GLIJCKMAN. Yes, I think Mr. Smith and Ms. McClure present
well-reasoned statements, and I think there is room for finding fine
lines here where you know we might be wrong on a point, and they
may be wrong on another point.
PAGENO="0527"
523
But I think the real problem is, for one thing, there are some
facts here that are unknown, because I know from personal exper-
ience that we get calls from school districts, from principals in the
school district, where they had very minute representation of mi-
nority groups which were apparently not supposed to receive 102
forms, but they did, and I said perhaps it is a mistake, why don't
you contact the local Office of Civil Rights and ask them. The
answer was, "If you got them, it was no mistake." That kind of
response is not helpful. That kind of reaction just doesn't help you
solve the problem.
Everyone is capable of some mistakes. I may have been certainly
guilty of one, myself, on the analogy that Mr. Smith mentioned. I
said there may be better methods.
I think we really have to bear in mind, though, that if you set up
a method of collection of data and analysis, and if it doesn't result
in enforcement, we had better look at some other method.
I did want to mention one other fact that came in after we
prepared our testimony. We conduct a survey every year of our
members on certain things. One of the questions is, "What are your
major sources of frustration in your work?" And in 1973, state and
Federal red tape as a general category was in seventh place. By
1976, it moved up to fourth place on this list, and it followed only
such fundamental matters as student attendance, student disci-
pline, and lack of time, and I would submit that lack of time might
certainly be related to Federal and state red tape as frustrations. So
I think it has been increasing.
I don't know if it is necessarily coming from OCR, because that
was a lumped kind of thing, and that is another reason why
perhaps such devices as block grants might be helpful in reducing
that paperwork burden.
Ms. MCCLURE. A couple of other things before Mr. Gluckman
leaves.
I noticed in his testimony, as in the previous testimony, reference
was made to the numbers of hours required to fill out Federal
forms. What has struck me about this whole debate over Federal
paperwork is that many of the objections to Federal paperwork are
taken totally out of context, it seems to me.
In Mr. Gluckman's testimony he says, in effect, that the times on
the OCR pre-test report on the OCR 101 and 102 were underestimat-
ed. The times that the OCR pre-test figured were six hours for the
102 and 5.5-3/4 hours for the 101 were the average time, the
average completion time, for all the districts included in the pre-
survey. What I decided to do was figure out what percentage that
six hours took out of the total time that principals and teachers
were involved in the total school year. What I decided to do was to
take a school of 10 people, one principal, and nine teachers, and to
figure out exactly what the total time involved was.
If you take the 10 people on the staff in the school and you figure
that they work eight hours a day, that is 80 person-hours a day. You
multiply the 80-person hours a day times 180 days in the whole
school year, and you get 14,440 hours. Now, one form takes only six
hours out of that 14,440. I don't see where the burden is there. That
is a very, very infinitesimal proportion of the total school year
involved in filling out that form.
PAGENO="0528"
524
Mr. GLUCKMAN. I think it is interesting, but I don't think it is.
really very applicable to the real problem, because, as I mentioned,
first of all the teacher time is relevant to that because the teachers
are not being asked to fill out the forms. You might as well include
the janitorial . time and get a lower percentage. It is not relevant.
Most of it, as I said, is unfortunately administrative time so the
percentage would be higher. But that is one form besides and, as
was indicated by the experience in the State of Georgia, they did a
study including all kinds of forms, and this is just one, of course, of
a multitude.
Ms. MCCLURE. Also, I could make another point, Mr. Chairman.
Very often in the debate over Federal paperwork, the purposes and
the reasons for collecting these data are overlooked. These data do
not only serve the purpose of the Office for Civil Rights in setting
enforcement priorities in deciding where to look; the statistics in
and of themselves are not proof of discrimination; they simply help
the Office for Civil Rights determination where they are going to
put their resources depending on what the data show.
There are also many other forms filled out by schools because of
funding programs. The institutions that receive Federal financial
assistance for delivery of particular educational services are and
should be accountable to the Federal Government for the use of the
taxpayer's dollar. But the Office for Civil Rights and the Office of
Education are not the only ones that use these data.
For example, this committee, itself, has called upon members of
the Executive Branch to come and testify before it. For example, in
the consideration of the Vocational Education Act in 1975, there
was testimony by the Office of Education on a number of factors,
administrative costs, program enrollments, program completions,
allotments, and expenditures.
The Commissioner of Education was able to testify to you about
these matters because he had collected data through the vocational
education reporting system.
Another example was when this subcommittee held hearings on
sex bias and sex stereotyping because of its concern to amend the
Vocational Education Act. The Office of Education did not have any
statistics about the enrollment of women in various vocational
programs, but, the Office for Civil Rights did, because it had con-
ducted a survey in 1974 of area vocational schools, enrollment by
race and sex.
Because of that special survey conducted by the Office for Civil
Rights, the Federal Government was able to inform this committee
as to the nature and the extent of sex bias and sex segregation in
vocational education.
The Department of Justice, the Civil Rights Division, also uses
the 101's and 102's. Under section 405 of title IV of the Civil Rights
Act, the Attorney General is empowered to bring lawsuits if he
receives a complaint of denial of equal protection of the law. How
can the Justice Department evaluate the validity of complaints and
decide to put the tremendous resources of the Federal Government
in such a lawsuit unless it has some basic data by which it can
evaluate the validity of the complaints?
PAGENO="0529"
525
The OCR 101 and 102 surveys contain data that are nowhere else
available in the country, and very often they are relied upon by
researchers, by journalists, by others who are involved in debates
about current subjects in the public forum.
I give you one example. There has been a great deal of research
in the 1970's on the issue of white flight and school desegre~ation.
All of those researchers got their data from the 101's and 102 s, and
they were able to make historical comparisons because the Office
for Civil Rights has been keeping that data since 1968.
So I would like to bring to your attention that the use of the
forms are valuable to different parts of the Executive Branch and
particularly how valuable they are in keeping Congress and this
subcommittee informed as to the progress or lack of progress in
implementing statutes and programs passed by Congress, and par-
ticularly the effectiveness of educational programs.
I give you another example, the title I comparability
requirements.
As you know very well, Mr. Chairman, when title I was first
passed, there was no requirement that school districts receiving
that money had to account for school-by-school expenditures. But
the Congress in the early 1970's in the Office of Education found out
that the effectiveness of title I was being undermined by widespread.
supplanting. Congress then authorized the Office of Education to
implement comparability requirements to ensure that title I funds
were spent in a supplementary and compensatory manner and not
to supplant state and local expenditures.
Chairman PERKINS. Let me thank all of you. You have been very
helpful to the committee, and we will continue with these hearings,
and we will be calling on you from time to time.
Thank you very much.
Counsel, do you wish to ask any questions?
Mr. RADCLIFFE. No, Mr. Chairman.
Chairman PERKINS. Mr. Heftel, did you have any questions?
Mr. HEFFEL. No, sir.
Chairman PERKINS. Thank you. Thern subcommittee is adjourned.
[Whereupon, at 10:52 a.m., the subcommittee adjourned, subject
to the call of the Chair.]
[Material for inclusion in the record follows:]
PAGENO="0530"
MAYBETH CHRISTENSEN
120 FR5EBAI~BU*I~60I9
MPBIRD'6US 50401
612-725-2173
3601 P~sc C..ssER 0661.60450
ST. Louis PosE 55416
612-925-4540
The Honorable Carl D. Perkins
Chairman
Education and Labor Conmittee
B346-C Rayburn HOB
Dear Chairman Perkins:
I am enclosing copies of statements I received from two of
the school districts of my Congressional District in Minne-
apol is, Minnesota.
I would appreciate it if these statements could be included
in the record of hearings on the subject of `Federal Paper
Work" before the Subconmittee on El~nentary, Secondary and
Vocational Education.
Best regard
Bill Frenzel
lember of Congress
BILL FRENZEL
Toss OsToer. MososofA
1026 Loue&osrs 55111.6510
22-225-2571
RICHARD 0.660.1.055
526
Congre~ of the ~tniteb ~tate~
~ou~e of ~epre~entatibe~
a~bin~ton,~.C. 20515
May 26, 197T
BF:pb
end.
PAGENO="0531"
527
NAY 13, 1977
TESTIMONY OF VINCENT C. CARLSON, INDEPENDENT SCHOOL DISTRICT 281
BEFORE
THE ELEMENTARY, SECONDARY, AND VOCATIONAL EDUCATION SUB COMMITTEE,
EDUCATION AND LABOR tOMMITTEE,
UNITED STATES HOUSE OF REPRESENTATIVES
MR. CHAIRPERSON AN]) OTHER MEMBERS OF THE SUB COMMITTEE * ON BEHALF OF
INDEPENDENT SCHOOL DISTRICT 281, ROBBINSDALE, MINNESOTA AREA SCHOOLS,
AND MYSELF, VINCENT CARLSON, I WOULD LIKE TO EXPRESS APPRECIATION FOR
THE OPPORTUNITY TO OFFER TESTIMONY BEFORE YOUR COMMITTEE. MY POSITION
WITH THE ROBBINSDALE AREA SCHOOLS IS THAT OF DIRECTOR OF RESEARCH AND
COORDINATOR OF FEDERAL PROGRAMS.
ONE OF MY PRINCIPAL RESPONSIBILITIES IS THAT OF COLLECTION, SECURITY
AND DISSEMENATION OF DATA - - MUCH OF IT MANDATED BY VARIOUS FEDERAL
AGENCIES. AS YOUR COMMITTEE DELIBERATES AREAS OF REFORM WITH REGARD
TO FEDERAL LEGISLATION AND REGULATIONS IN THE FIELD OF PUBLIC EDUCATION,
I WOULD LIKE TO ADDRESS MYSELF TO THE LOCAL EFFORT INVOLVEMENT WITh
FEDERAL "PAPERWORK."
I WOULD SPECIFICALLY LIKE TO REACT TO THE HEW, OFFICE OF CIVIL RIGHTS
SCHOOL SYSTEM SUMMARY REPORT: FORM OS/CR 101, AS AN EXAMPLE OF THE PAPER
WORK BURDEN. THE PAST YEAR THE OFFICE OF CIVIL RIGHTS REVISED ITS DATA
ACQUISITION SURVEY FORM FOR PUBLIC SCHOOL DISTRICTS. A NOTICE OF THE
PROPOSED CHANGE WAS PUBLISHED ON PAGE 17182 OF THE FEDERAL REGISTER OF
THURSDAY, MARCH 31, 1977. PUBLICATION IN THE FEDERAL REGISTER WAS TO
PAGENO="0532"
528
-2-
COMPLY WITH THE `CONTROL OF PAPER WORK AMENDMENT." MANY FACETS OF THE
SURVEY ARE NOTED IN THE FEDERAL REGISTER SUCH AS THE LEGISLATIVE AUTHORITY,
METHOD OF DATA COLLECTION, NUMBER OF LOCAL AGENCIES AND NAN-HOURS INVOLVED.
THE TIME INVOLVEMENT FOR COMPLETING THE OS/CR 101, LOCAL EDUCATION AGENCY
REPORT FORM, ACCORDING TO THE OFFICE OF CIVIL RIGHTS SHOULD AVERAGE
APPROXIMATELY THREE (3) HOURS PER RESPONDENT. IT IS DIFFICULT TO KNOW
WHAT MIGHT BE. CONSIDERED AN AVERAGE SIZE SCHOOL DISTRICT, BUT DISTRICT
281, ROBBINSDALE AREA SCHOOLS, ENROLLS 23,000 PUPILS HOUSED IN 26 BUILDINGS.
ON THE BASIS OF A VERY CAREFUL ESTIMATE, BY BREAKING-DOWN THE REPORT INTO
ITS VARIOUS COMPONENTS AND CONSIDERING THE PERSONNEL INVOLVED, I HAVE
ESTIMATED 482 NAN-HOURS OF ENDEAVOR ON THE PART OF DISTRICT 281'S STAFF
MEMBERS. FOR LARGER SCHOOL DISTRICTS THE NAN-HOUR INVOLVEMENT NAY BE
MANY TIMES AS MUCH.
IT MUST BE REMEMBERED THAT THE TINE INVOLVEMENT IS NOT LIMITED TO THE
WORK OF A TYPIST TO PREPARE THE REPORT FOR MAILING. TO TOOL UP INTERNALLY
TO COLLECT THE INFORMATION REQUESTED NECESSITATES MEETINGS WITH PRINCIPALS
AND STAFF, DEVELOPMENT OF PROCEDURES, FORMS, CONTINUAL MAINTENANCE OF
DATA, AGGREGATING DATA AT THE BUILDING LEVEL, AND FINALLY AGGREGATING
ALL THE BUILDING DATA SO THAT A SCHOOL SYSTEM REPORT NAY BE PREPARED.
MEMBERS OF THIS CONGRESSIONAL COMMITTEE, THIS IS NOT A THREE (3) HOUR
TASK. IT BECOMES A MONUMENTAL EFFORT THAT DIVERTS TEACHER AND ADMINIS-
TRATIVE TIME FROM THEIR MAIN FUNCTION, THE INSTRUCTION OF STUDENTS, TO
"PAPER SHUFFLING", RECORD KEEPING, SAND REPORTING -- MUCH OF IT COMPLETELY
UNNECESSARY IN MY OPINION.
PAGENO="0533"
529
-3-
THE OS/CR 101 REPORTING FORM INCLUDES THE FOLLOWING FIVE (5) MAIN AREAS
OF DATA COLLECTION:
1. TOTAL PUPIL MEMBERSHIP BREAK-DOWN BY SEX AND RACIAL-ETHNIC
CATEGORIES.
2. TOTAL PUPIL ENROLLMENT IN VOCATIONAL EDUCATION PROGRAMS BY
SEX AND RACIAL-ETHNIC CATEGORIES. PUPILS MUST BE COUNTED
ONLY ONCE REGARDLESS OF THE NUMBER OF PROGRAMS THEY ARE
ENROLLED IN. THIS PARTICULAR REQUIREMENT COMPLICATES RECORD
KEEPING CONSIDERABLY.
3. NUMBERS OF PUPILS SUSPENDED AT LEAST ONE SCHOOL DAY DURING THE
PREVIOUS SCHOOL YEAR BY SEX AND RACIAL-ETHNIC CATEGORIES. AGAIN,
THE PUPIL COUNT MUST BE AN UNDUPLICATED ONE.
4. NUMBER OF PUPILS IN THE SYSTEM WHO HAVE A PRIMARY HOME LANGUAGE
OTHER THAN ENGLISH, AND THE NUMBER WHO ARE ENROLLED IN ENGLISH
AS A SECOND-LANGUAGE PROGRAM. THESE PUPILS MUST ALSO BE IDEN-
TIFIED AS TO RACIAL-ETHNIC MEMBERSHIP.
5. NUMBERS OF PUPILS PARTICIPATING IN SPECIAL EDUCATION PROGRAMS.
THREE (3) CATEGORIES OF THESE PUPILS MUST BE IDENTIFIED BY
RACIAL-ETHNIC COUNT. EIGHT (8) OTHER BREAK-DOWNS OF SPECIAL
EDUCATION PUPILS ARE BY TOTAL NUMBERS ONLY, AND ONE (1) QUES-
TION PERTAINS TO THE NUMBER OF FULL-TIME AND PART-TIME SPECIAL
EDUCATION TEACHERS. PUPILS ENROLLED IN MORE THAN ONE OF THESE
PROGRAMS MUST BE REPORTED ONLY ONCE. THIS REQUIREMENT PRESENTS
A LOGISTICAL PROBLEM THAT INVOLVES CONSIDERABLE EFFORT CONSIDER-
ING THE SCHOOL DISTRICT ENROLLS MORE THAN 1,400 PUPILS IN ONE
OR MORE OF ITS SPECIAL EDUCATION PROGRAMS.
PAGENO="0534"
530
-4-
SPECIFICALLY, THE TIME REQUIREMENTS, BASED ON WHAT I WOULD CONSIDER TO
BE A CONSERVATIVE ESTIMATE, ARE AS FOLLOWS:
PUPIL MEMBERSHIP:
INDIVIDUAL SCHOOL CAMPUS EFFORT (26 SCHOOLS X 6 HOURS) 156 HOURS
DISTRICT LEVEL EFFORT 12 HOURS
VOCATIONAL EDUCATION:
INDIVIDUAL SCHOOL CAMPUS EFFORT ( 3 SCHOOLS X 8 HOURS) 24 HOURS
DISTRICT LEVEL EFFORT 8 HOURS
PUPIL SUSPENSIONS:
INDIVIDUAL SCHOOL CAMPUS EFFORT (7 SCHOOLS X 6 HOURS) 42 HOURS
DISTRICT LEVEL EFFORT 3 HOURS
PRIMARY LANGUAGE OTHER THAN ENGLISH:
INDIVIDUAL SCHOOL CAMPUS EFFORT (26 SCHOOLS X 1 HOUR) 26 HOURS
DISTRICT LEVEL EFFORT 10 HOURS
SPECIAL EDUCATION:
INDIVIDUAL SCHOOL CAMPUS EFFORT (26 SCHOOLS X 6 HOURS) 156 HOURS
DISTRICT LEVEL EFFORT 45 HOURS
* TOTAL HOURS: 482 HOURS
FORTUNATELY, DISTRICT 281 SCHOOLS WERE NOT ANOM THE 47,000 SCHOOLS IN
SELECTED LEA' S THAT WERE REQUIRED TO COMPLETE OS/CR 102, THE INDIVIDUAL
SCHOOL CAMPUS REPORT. THIS WOULD LIKELY `HAVE TRIPLED THE NAN-HOUR
INVOLVEMENT Al THE LOCAL LEVEL.
PAGENO="0535"
531
-5-
MY TESTIMONY HAS INCLUDED COMMENT ON BUT ONE REPORTING REQUIREMENT FROM
ONE FEDERAL AGENCY. THERE ARE MANY OTHER MANDATED RECORD KEEPING AND
REPORTING REQUIREMENTS FROM VARIOUS OTHER AGENCIES.
BOTH PRESIDENTS FORD AND CARTER HAVE EXPRESSED CONSIDERABLE CONCERN
ABOUT THE PROLIFERATION OF FEDERAL PAPER WORK. TO MY KNOWLEDGE ATTEMPTS
TO MINIMIZE THE FLOW OF PAPER HAVE NET WITH COMPLETE FAILURE. THE
FEDERAL BUREAUCRACY BECOMES MORE DEMANDING WITH EACH SUCCEEDING YEAR.
LOCAL EDUCATION AGENCIES, FACING SEVERE FINANCIAL PROBLEMS AS MOST OF
THEM ARE, ARE NOT IN A POSITION TO EMPLOY THE NECESSARY MAN POWER TO
"SHUFFLE" PAPERS AS MANDATED BY THE FEDERAL BUREAUCRACY. AT A TINE WHEN
EDUCATIONAL PROGRAMS ARE BEING CURTAILED AND THOUSANDS OF TEACHERS ARE
BEING TERMINATED FOR LACK OF FUNDS, DOES IT NOT SEEM ABSURD TO DIVERT
EVEN MORE RESOURCES TO "BEEFING UP" OFFICE STAFFS FOR PURPOSES OF
COMPLYING WITH FEDERAL REPORTING REQUIREMENTS? HOW LONG WILL IT TAKE
BEFORE WE COME TO OUR SENSES AND ESTABLISH SOME REALISTIC PRIORITIES?
I HONESTLY HOPE, THAT THE MEMBERS OF THIS SUB COMMITTEE, SERIOUSLY
ADDRESS THEMSELVES TO WHAT MANY OF US CONSIDER TO BE ONE OF THE MOST
DISCOURAGING AND FRUSTRATING PROBLEMS FACING THE SCHOOLS TODAY - - THE
UNNECESSARY FLOW OF PAPER DEMANDED BY AN INSENSITIVE FEDERAL BUREAUCRACY.
I AM SINCERELY APPRECIATIVE AND GRATEFUL FOR THIS OPPORTUNITY TO TESTIFY
BEFORE THIS CONGRESSIONAL COMMITTEE.
PAGENO="0536"
532
`K'ich field `P~ui~ Schools
Independent School District No. 280
70th & Harriet Avenue * Richfield, Minnesota 55423
Bruce R. Anderson
Superintendent Telephone: 1612) 861-7511
May 18, 1977
Honorable Bill Frenzel
Member of Congress
House of Representatives
Washington, D.C. 20515
Dear Bill:
The amount of time taken away from the child in the classroom by new state
and federal regulations and forms has caused a real hardship in meeting
the needs of handicapped children. As an example, I estimate that the due
process procedures in P.L. 94-142 have taken 20% of the time of special
class teachers and specialists. It has also removed regular teachers from
the classroom for significant periods, and has consumed large portions of
their prep time.
As far as paper work is concerned, our principals estimate that Title I re-
quires an average of 175 to 250 hours per year per building. Title IX forms
have consumed somewhere in the neighborhood of 400 hours on the part of ad-
ministrative personnel. The form 101 paper on minority students about 100
hours of staff time. Much of this time was taken from direct service or
planning for kids. Much of the Title I time is related to planning for
students and needs assessments but many hours have been spent in adminis-
trative forms.
The real cost of the paper blizzard is in time spent with students. Your
concerns in this area are greatly appreciated.
Sincerely yours,
~ ~.
Bruce R. Anderson
Superintendent
BRA:lcs
PAGENO="0537"
533
K1~1__NATiONAL 501001 BOARDS ASSOCIATK)N
BA 1055 Thomas Jefferson Street, N.W. * Washington, D.C. 20007
(202) 337-7666
STATEMENT ON BEHALF OF THE
NATIONAL SCHOOL BOARDS ASSOCIATION
on
PAPERWORK PROBLEMS IN
ELEMENTARY AND SECONDARY EDUCATION PROGRAMS
submitted for the record to the
Subcommittee on Elementary, Secondary and Vocational Education
U. S. House of Representatives
June 10, 1977
91-860 0 - 77 -- 35
PAGENO="0538"
534
Introduction
The National School Boards Association is pleased to have this
opportunity to submit a statement to the Subcommittee on the subject of
federal paperwork in the public schools. The National School Boards
Association is the only major education organization representing school
boards members -- who are in some areas called school committees or
school trustees. Throughout the nation, approximately 100,000 of these
individuals are Association members. These people, in turn, are responsible
for the education of more than ninety-five percent of the nations public
school children.
Currently marking its thirty-ninth year of service, NSBA is a
federation of state school boards associations, with direct local school
board affiliates, constituted to strengthen local lay control of education
and to work for the improvement of education. Most of these school board
members are elected public officials. Accordingly, they are politically
accountable to their constituents for both education policy and fiscal
management. As lay unsalaried individuals, school board members are in
a rather unique position of being able to judge legislative programs,
purely on the standpoint of public education, without consideration to their
personal professional interest.
Association policy is determined at the NSBA annual convention at
which representatives from across the nation translate policies and
resolutions into ongoing programs.
PAGENO="0539"
535
On behalf of of the nation's 16,000 school boards, the Association
strongly commends the Subcomittee's efforts to investigate the proliferation
of federal paperwork. In addition, we were pleased to see the passage of
the Biaggi Paperwork Control amendment during the Education Amendments of
1976. We certainly hope that these hearings and an evaluation of how
the Biaggi amendment is being implemented will result in further Congressional
action to reduce paperwork.
PAGENO="0540"
536
Recommendations
Before turning to a general discussion of the reasons for the
paperwork problem in elementary and secondary education programs, it
might be helpful to first list our recommendations with a brief
explanation of each.
Biaggi Paperwork Control Amendment
While the Biaggi Paperwork Control amendment (Section 406 of GEPA)
represents a significant attempt to reduce paperwork, the amendment
could be improved in the following ways.
First, section 406(g)(2)(B), which provides for a 30 day public
comment period, does not specifically require that the actual data
collection form be made public (i.e., published in the Federal Register)
during the comment period -- although common sense would seem to require
that the public have access to the data collection form in order to make
any meaningful comment. Under current practice, the National Center for
Educational Statistics does not print the actual form in its notice to
the public. Without the actual data collection form, meaningful comment
from interested parties is discouraged. Accordingly, we recommend tha~
language be added to require that the data collection form be published
in the Federal Register and be subject to public comment for 30 days
thereafter.
Second, section 406(g)(2)(A) requires (i) a justification of how
the information will be used and (ii) an estimate of the man-hours
PAGENO="0541"
537
required to complete the request for information. The Association
recommends that language be added to ensure that the justification
includes an operational or management oriented description of which
government unit will engage in what kind of activity using what part of
the collected information. Without this type of justification, management
decisions required to coordinate data acquisition will be hampered. To
state simply that requested information is *required to carry out a
particular law is not a management oriented or operational justification.
Related to managment oriented justification statements areman-hour
and cost estimates. Section 406(g)(2)(A) requires man-hour estimates,
but it does not require that the estimates be based upon actual experience.
In other words, man-hour estimates for the purposes of this section can
be developed totally within the halls of HEW. Also, there is currently
no requirement for cost estimates to be associated with the man-hour
estimates. The Association recommends that language be added to require
man-hour and cost estimates be based upon a pre-test of the form or upon
data obtained from similar forms. The example of man-hour estimates for
OCR Forms 101 and 102, where estimates were understated by a factor of
800 to 1,000 per cent, should not continue. No valid management decision
can be made about curtailing paperwork unless there are reasonably
accurate estimates of man-hours and costs.
Review Existing Paperwork Requirements
Just as Congress mandated that all federal education regulations be
reviewed, opened to public comment, and associated with specific legal
PAGENO="0542"
538
authority, so should all existing paperwork requirements be reviewed,
opened to public comment, and associated with specific legal authority.
The Association recommends that language be added to GEPA to require a
review of all paperwork with the intent of eliminating any reporting
requirement that is not absolutely essential to the administration or
evaluation of federal education programs. Such a review could reduce a
number of federal reports which are currently being compiled but are
seldom, if ever, used. In addition, existing report forms could be
simplifical and consolidated, and recommendations could be made to
simplify or clarify existing statutory mandates.
Role of States
One concern of school board members is that a reduction in federal
reporting requirements should not be an invitation to increased state
reporting requirements. While the state departments of education can
play a constructive role in lessening the burden of federal paperwork,
school board members are concerned that this `cure may be worse than the
disease." Accordingly, any action to reduce federal paperwork must, at
the same time, avoid encouraging or requiring substantial increases in
state reporting requirements.
Establishment of Procedures
Procedures for the collection of information should be established
in law. Adequate lead time, fixed repOrting dates that conform with
local practice, advance notice of changes in existing reporting forms,
PAGENO="0543"
539
and prior consultation with local program administrators should all be
set forth. The recommendations of the Commission on Federal Paperwork
in this area provide a good base from which specific procedures could be
developed.
Reviewing Agency
The Association supports the concept of a paperwork reviewing
agency which has no vested interest in the requests for information
submitted to it. In this manner reporting requirements could be care-
fully scrutinized, and, taking into consideration the time, cost, and
expected benefits of such requests for information, priorities would be
established. The reviewing agency might also be empowered to recommend,
in certain cases, that federal funds be~ used to cover all or part of the
cost of the data acquisition activity. The reviewing agency might also.
waive certain procedural requirements in cases of a one time emergency
request for information.
PAGENO="0544"
540
Paperwork: The Problem Defined
In the eyes of many local school officials, "paperwork" has become
to mean any activity not related to improving education but required as
a precondition for receiving federal funding. While this definition
may not be in the dictionary, a recent report on education by the Federal
Paperwork Commission found among local educators an increasing hostility
and resistance to federal reports, surveys and forms.
Why has the resistance been growing? Quite simply because educators
and administrators are wondering whether federal assistance is still worth
accepting. After completing each federal paperwork requirement, local
educators quite naturally do a quick cost/benefit assessment: Was this worth
the effort? Are the educational programs in my district better off now
that the paperwork has been done? Unfortunately, these common sense
cost/benefit assessments seem to indicate that federally mandated paperwork
carries a considerable cost without a commensurate benefit.
Excessive Paperwork: Symptom or Disease?
What has caused extensive federal reporting requirements? Can paper-
work, alone, be reduced without changing the current system of federal aid
to education? Stated somewhat differently: Is paperwork the problem or
simply the symptom of a larger phenomena.
It appears that the growth of paperwork has been made possible by several
factors -- some related to the current system of federal aid, and others
PAGENO="0545"
541
totally unrelated to the system of federal aid. In other words, excessive
paperwork is partly a symptom of the whole federal aid structure and
partly a growing "disease" apparent in all aspects of our society.
The Sym~ç~
As a symptom of federal aid to education, paperwork has become more
burdensom as the number of different federal aid programs grows. Con-
solidation of programs or a shift towards general aid would reduce
federal reporting requirements. In addition, public schools have been
the vehicle of a variety of civil rights reforms. While our Association
has supported equal educational opportunity for minorities, women, and
bilingual and handicapped individuals, we have become increasingly con-
cerned with the manner in which information is requested, sometimes on an
"after-the-fact" basis, sometimes without sufficient lead time, and.
sometimes without a *clear justification for the cost of the information
compared to the benefits of its intended use. Better management and
coordination, increased involvement of local educators, uniform definitions,
cost impact statements, and pp~rational descriptions of how the collected
information will actually be used are all factors which could reduce the
paperwork burden and, at the same time, improve civil rights enforcement.
The Disease
The advent of the computer and the growth of federal bureaucracy have
also contributed to the paperwork problem. The computer greatly faciliates
PAGENO="0546"
542
the processing very large quantities of information. However, the computer
does not facilitate the actual collection of data, and, to a certain
extent, the American public is caught trying to supply enough information
to satisfy the immense data processing capabilities of government computers.
The ease of processing information, once collected, has led to the "nice-to-
know' syndrome. Once basic information is in a computer bank it is always
tempting to gather a little extra data "here and there" to satisfy human
*curiosity. Wouldn't it be nice to know if X is related to Y? The fact
that the relationship between X and Y is not essential to the administration.
of a federal program is somehow forgotten.
The growth of the federal bureaucracy has also contributed to the
increase in paperwork. As the government grows more demands are made for
accountability. How does the government know what it is doing? The only
way a bureacracy can become accountable for its performance is to document
everyth~ng it does. Congress often requires federal agencies to collect
information solely to demonstrate that the agency has, in fact, properly
administered a federal aid program. The larger the bureaucracy, the more
likely the demands for accountability, and, consequently, the greater the
need for information to document that programs are properly administered.
Accountability at the local level occurs through a systematic evaluation
of how well program goals are achieved. Accountability at the federal
level occurs by elaborately documenting that local programs are administered
according to federal guidelines -- totally without regard to whether the
local programs are achieving their goals. Consequently, the federal agencies
require local school districts to make detailed reports, often on a school
to school basis, to demonstrate conformance with federal guidelines which
may or may not contribute to the overall success of the local program. In
PAGENO="0547"
543
addition, a bureaucracy under attack from Congress, the Courts, or public
interest groups may engage in information "over-kill' in order to protect
itself. The agency must be prepared to answer any question anyone could
think of asking. In addition, by baraging its critics with floods of
statistical reports, the bureaucracy attempts to increase its own
credibility and, at the same time, divert criticism on how well is the
agency functioning to less damaging criticism about the accuracy of its
statisti cal reprots.
Finally, the size and complexity of the federal bureaucracy has led
to increased reliance on outside contractors to design specialized survey
instruments. The agencies have found that it is quicker and cheaper to
contract for specialized data collection .services than to obtain those
services from existing governmental units. As a result, federal officials
with some knowledge of the operation of local programs write a work state-
ment for a data collection contractor who, more often then not, has little
or no interest in or understanding of local programs. The development of
resulting survey instrument is, consequently, twice removed from the
situation in which it will be used. In addition, the contractor's only
obligation is to fulfill his detailed work statement -- and not to
accommodate the concerns of local educators. When program officials object
to unreasonable data requests, they must object to federal officials. When
the federal officials, in turn, object to the contractor, the contractor
can simply maintain that the terms of the work statement have been fulfilled
and that federal officials must either correct the situation themselves or
rehire the services of the contractor.
PAGENO="0548"
544
An Example: OCR Forms 101 and 102
The most recent Office for Civil Rights Fall Survey of Elementary
and Secondary Schools provides a good example of how federal paperwork
can go beyond the realm of reasonableness. The Office for Civil
Rights expanded the scope of its Fall Survey forms, but did so in
such a manner as to evoke hostility and resistance among many local
and state school officials. The Commission on Federal Paperwork reports
in detail on the development and administration of OCR Forms 101 and
102.
Several factors, however, should be highlighted because they
illustrate many of the points in the preceeding discussion. The OCR
survey forms were developed by an outside contractor who had previously
prepared OCR survey forms. Some consultation with local and state
school officials did take place. But, despite previous experience of
the contractor and the consultation, the survey instrument was very
severely criticized by local and state officials. Evidently, the con-
tractor did not fully understand the practical difficulties of gather-
ing student data in such newly surveyed areas as disciplinary action,
drop-outs, and bilingual populations. Consultation with local
administrative officials did not seem to have a major affect on revising
the survey.
The man-hour estimates obtained from the pre-test were quite different
from actual experience. The pre-test group of approximately 50 districts
was not adequately representative of the types of districts which had to
PAGENO="0549"
545
respond to the surveys. For instance, no pre-tests were performed in
districts with enrollments of over 25,000 pupils. In another instance in
New England states, no pre-tests were made in the states having a high
percentage of minority enrollments. Thus, New Hampshire, with about 1%
minority enrollments, was the site of a pre-test but Massachusetts was
not.
It is not surprising, therefore, that the pre-test results would
misleadingly indicate that approximately 100,000 man-hours would be
needed for the nation's schools to complete the survey forms. Estimates
based upon a more representative survey conducted by our Association
among 141 school districts which completed the forms indicate that
approximately 800,000 man-hours were devoted by the nation's schools to
completing the forms. The indicators in the OCR pre-test survey were off
by a factor of eight. our study also indicates that the OCR Forms 101
and 102 cost school districts about $7.5 million this year.. (Our study
is appended to this statement.)
In addition to the time and cost factors, the OCR surveys were
poorly administered. The `Fall" survey was released just prior to the
Christmas vacation period and instructions were given to return the
forms by February first. Lead time was non-existant and the deadline
was unrealistic for the over 10,000 school districts which had never
before~received OCR survey forms. In addition, most districts collect
their pupil enrollment data during the fall. Sending the forms out at
mid-year required a new set of data collection activities not normally
undertaken.
PAGENO="0550"
546
Concerning the usefulness or appropriateness of the survey, it
does not appear that OCR will be able to actually use the information.
The forms do not provide swfficient information to determine a violation
of the civil .rights statutes. In addition, because there are no standards
established to determine compliance based upon the information requested,
school districts are not able to use the surveys for the purpose of
self-evaluation. The only possible purpose of the form is to icoate
districts which may, by some as of yet undetermined standard, be in
violation of the law. However, OCR has already identified the 3,000
school districts which comprise 90% of the nation's minority enrollments.
An annual spot check of 10 to 20 percent of those districts each year
would probably result in more effective enforcement than spending one or
two years analyzing data which could possfbly indicate non-compliance as
of one or two years in the past.
PAGENO="0551"
547
NAflONAL SCHOOL B&\RDSASSOCIATION
B ~ 1055 Thomas Jefferson Street, N.W. . Washington, D.C. 20007
~4~J (202) 337-7666
APPENDIX
March 10, 1977
COSTS OF COMPLETING OCR FORMS 101 & 102:
RESULTS OF AN NSBA SURVEY
Sum~~
In order to determine the time and cost involved in completing OCR
Forms 101 and 102, the National School Boards Association mailed approx-
imately 420 questionnaires to school districts across the country. As
of March 4, 1977, a total of 141 usable responses have been analyzed.
Among the school districts, an average of 1.1 minutes per student was
required to fill-out the forms at an average cost of $0.17 per student.
Applying these averages to the nation's 44.2 million public school
students, the OCR forms required a national total of 810,000 manhours at
a cost of $7,514,000. Table 1 shows the survey results by size of
school district. Table 2 shows the data received from seven school
districts with enrollments over 25,000.
PAGENO="0552"
School
District Number of
Size Responses
0- 4,999 100
5,000- 9,999 20
10,000-14,999 7
15,000-24,999 7
Above 25,000 7
TOTAL 141
Percent
Completing
Both Forms
101 & 102*
28
20
83
71
100
33
*Most smaller districts were required only to complete Form 101;
most larger districts were required to complete both Forms 101 & 102.
COSTS Cost
(dollars) Staff Hours Per
Per Pupil Pupil
Non-Personnel Personnel Total (minutes) (dollars)
1,659 32,410 34,069 1.77 0.140
2,817 15,150 17,967 0.612 0.131
252 11,780 12,032 1.05 0.159
2,340 29,365 31,705 1.24 0.235
5,235 57,287 62,522 0.89 0.172
12,303 145,992 158,295 1.13 0.165
TABLE I -- COST OF COMPLETING OCR FORMS 101 AND 102 BY SCHOOL DISTRICT ENROLLMENT SIZE
STAFF HOURS
Enrollment
In Sample
___________ Distircts Professional Non-Professional Total ______________
244,100 5,561 1,674 7,235
137,300 818 594 1,412
77,500 805 492 1,297
135,100 1,615 1,182 2,797
362,500 3,602 1,782 5,384
956,500 12,401 5,724 18,125
C.T~
PAGENO="0553"
0
TABLE 2 -- COST OF COMPLETING OCR PORMS 101 AND 102 FOR SEVEN DISTRICTS ABOVE 25,000 ENROLLMENT
0
School District
(Name of Major City/County)
Pasedena, California
Evansville, Indiana
South Bend, Indiana
Montgomery, Alabama
Enrollment
25,700
28,000
30, 300
35,500
78,000
80,000
85,000
Professional
90
275
301
329
985
796
826
STAFF HOURS
Non-Professional
555
149
155
141
198
403
181
Ann Arundal Co., Maryland
Indianapolis, Indiana
Decatur, DeKalb Co., Georgia
Total
645
424
456
4?0
1,183
1,199
1,007
COSTS
(dollars)
Non-Personnel Personnel Total
100 4,376 4,476
41 4,203 4,244
43 4,118 4,161
67 3,709 3,776
4,100 15,797 19,897
17,362 17,371
7,722 8,597
TOTAL
Staff Hours Cost Per
Per Pupil Pupil
(minutes) (dollars)
1.50 .174
0.909 .152
0.902 .137
0.78 .106
0.910 .255
0.899 .217
0.710 .101
362,500
C.~i
3,602
875
1,782
5,384
5,235
57,287 62,522
0.891
.172
PAGENO="0554"
550
NATIONAL SCHOOL BQARDSASSOCIATION
1055 Thomas Jefferson Street, NW. . Washington, D.C. 20007
(202) 337-7666
March 10, 1977
Methodology
On November 29, 1976, NSBA mailed out questionnaries to 420 school
districts across the country. The sample population was selected to be
representative of one school district in each congressional district.
The sample population constituted districts which the individual state
school boards associations had previously designated to represent the
education interests of the state before their federally elected repre-
sentatives. - ,Several state associations sent questionnaires to more than
one school district in each congressional district. The sample was not
randomly chosen for the purposes of this survey, and the sample distri-
bution (see Table 3) is slightly biased toward larger districts. (This
bias is explained in part, because very few districts under 300 enroll-
ment were included in the NSBA survey; however, on the national level,
these smaller districts comprise 28% of all districts and 1.2% of all
enrollments.)
Of all responses received as of March 4, 1977, 18% were either
incomplete or obviously in error. No attempt was made to contact these
respondents. However, several districts did discover errors and sent in
corrected questionnaires.
School districts were asked to account for the staffhours and non-
personnel costs involved in completing OCR Forms 101 and 102. Large
districts were asked to survey at least 1 out of every 5 schools, but
perferably all schools, in determining total staffhours. Estimates
accurate to ±25% were acceptable from any district, however, most res-
pondents appeared to have reported actual data.
Personnel costs were computed after the questionnaires were re~-
turned by multiplying staffhours times average hourly wage reported for
each of four reported salary categories: central office professional
and non-professional staff, and school building professional and non-
professional staff. Non-personnel costs were simply added together.
PAGENO="0555"
TABLE 3 DISTRIBUTION OF OPERATING LOCAL PUBLIC SCHOOL SYSTEMS AND NUMBERS OF PUPILS BY SIZE OF SYSTEM
(FALL 1975) COMPARED TO DISTRIBUTION OF NSBA SURVEY SAMPLE POPULATION
PUBLIC SCHOOL SYSTEMS PUBLIC SCHOOL PUPILS
National NSBA Survey National NSBA Survey
Sizeof
School System Number Percent Number Percent Number Percent Number Percent
O-~ 4,999 14,138 88 1 100 70 9 15,807,523 35 7 244 100 25 5
5,000- 9,999 1,126 7 20 14.2 7,820,441 17.7 137,300 14.3
1O,ÔOO-24,999 555 3.5 14 9.9 8,070,851 18.2 212,600 22.2
Above 25,000 187 1.2 7 5.0 12,533,059 28.3 362,500 38.0
TOTAL 16,006 100 141 100 44,231,874 100 956,500 100
PAGENO="0556"
552
Statement by
Ewald B. Nyquist
president, The University of the State of New York
and Commissioner of Education
Submitted to the
Subcommittee on Elementary, Secondary and Vocational Education
Coimmittee on Education and Labor
U.S. House of Representatives
Friday
June 24, 1977
Washington, DC
PAGENO="0557"
553
New York State Education Department
Data Systems and Networks: A Success Story
New York State has taken revolutionary and successful steps to eliminate
paper burden both within the State Education Department and for local education
agencies reporting data to the State Education Department. The campaign to
limit the paper burden has two major foci: the development of the Information
Center on Education (ICE) within the New York State Education Department, and
the development of the New York State School Computer Services System
(NYSSCSS) at regional computer centers throughout the State.
Historical Development
The early 1960's stimulus of Federal funding coupled with growing infor-
mation demands from teachers' unions, the Governor's Office, and the Legis-
lature spurred the State Education Department to a proactive stance on data
services.
Although its programs now serve as models for other States, State
Education Department data collection in the early years was a paper-and-pencil
operation accomplished through the Bureau of Statistical Services. Every
State Education Department program unit also collected information to meet its
own needs. The result was unreliable, unrelated and untimely data- -primarily
because duplicative state requests overburdened the LEAs and lengthened the
time necessary to get data returns.
PAGENO="0558"
554
-2-
Two efforts at improvement began almost simultaneously. State Educa-
tion Department personnel began to pursue an in-house data revolution, which
ultimately produced the Information Center on Education. A committee of
Assistant Commissioners was established to review forms and data requests.
The Bureau of Statistical Services (BSS) was the committee's administrative
arm.
With only two staff persons (eventually four), the BSS began designing a
data system to meet state, local and Federal needs. The system was, based
on an information network that led to and from a central point in the State Educa-
tion Department. The underlying concept was that less-detailed information
would be required by the State Education Department than by a school district.
All State Education Department requests were reviewed, analyzed for useful-
ness, and integrated `or dropped. Development of the Basic Educational Data
System (BEDS), a unit record system of public school professional staff, was
begun in 1965. BEDS was implemented in the Fall of 1967. At the same time,
the Information Center on Education (ICE) was established in response to a need
for additional personnel to provide data services.
Almost simultaneously, the State began a long-range effort to relieve LEA
paper burden by using Board of Cooperative Educational Services Centers'
(BOCES) regional computers located throughout the State. A computer network,
the New York State School Computer Service Sy~ems (NYSSCSS), was formed
to serve State data-gathering needs. This arrangement to cut costs, error and
paper burden would allow the most complicated and lengthy LEA reports to be
computer-generated at BOCES. The data would be collected by the NYSSCSS
PAGENO="0559"
555
-3-
centers from the LEAs in normal accounting throughout the year. The pre-
pared reports then would be sent to LEAs for review and signature. This
process would eliminate massive and duplicative reporting from the districts.
Initial participation of the districts in the NYSSCSS network was to be voluntary.
The Current Situation
The Information Center on Education is now comprised of two units, the
Bureau of Statistical Services and the Bureau of Educational Data Systems.
ICE is responsible for the identification, implementation and operation of data
systems in all areas øf education. It also coordinates all data collection
procedures within the State Education Department.
From its several data systems, ICE produces descriptive reports to
State Education Department personnel, and statistical reports for the Department
and for LEAs. Subjects range from elementary, secondary and higher education
to nonpublic, vocational and continuing education. ICE responds to special
information requests from Department staff, the Governor's Office, the Legis-
lature, researchers, LEAs and the public. ICE also approves and coordinates
State Education Department data requests going to LEAs to avoid duplicative and
unnecessary reporting. Appeals from ICE decisions on these matters are
handled by the Executive Deputy Commissioner. ICE also develops new data
* systems in response to emerging needs such as the education of handicapped
children.
The Basic Educational Data System, the keystone for elementary/secon-
dary information, utilizes machine-readable forms collected directly from over
180, 000 teachers and administrators on a single day in the fall of the school
PAGENO="0560"
556
-4-
year. Data collection is standardized and carefully controlled. Input is almost
error free. Detailed information is collected, maintained and disseminated on
students, curriculum, staff and school characteristics. ICE also has access
to financial and attendance data stored in the computer by NYSSCSS.
Currently, 80 school districts throughout the State are submitting computer-
taped attendance data directly to the State through the NYSSCSS system. Fifty
additional districts are submitting financial data on tape through NYSSCSS.
These districts were selected for a pilot program because they presently have
the capacity to produce the needed data through a BOCES. About 500 additional
districts participate in the network for at least part of the available services.
Participation is voluntary. Services are purchased from BOCES along with
other cooperative educational services. By 1978, however, districts not
belonging to the computer network will be required to submit financial data on
magnetic tape to the State Education Department.
Ways In Which ICE and NYSSCSS Beat the Paper Burden
The Information Center on Education relieves the paper burden on the
State Education Department, on local education agencies and on institutions of
higher education in a variety of ways.
At the State level, costly and time-consuming key entry processes are
eliminated by the use of machine-readable forms for data collection. Paper
burden and errors caused by hand tabulation are almost eliminated.
Timeliness of data is greatly improved by high-speed computer production
of summaries of basic and derived data. Information obsolescence costs are
removed. Data needs can be met more rapidly, more efficiently, and in
PAGENO="0561"
557
-5-
greater depth from a central computer clearinghouse. Moreover, data
collected on elementary and secon4ary schools since 1967 have been merged
into a consolidated data base. This merger taps the tremendous potential for
interrelating data elements and cuts response time on various data aggregations.
Units in the State Education Department have the data needed for planning and
problem-solving, when they need it, from a single central source. -
Annual updating of the file is equally efficient. Since certain items of
information are stable (such as sex, date of birth), and since other items (such
as experience) can be calculated automatically, annual updating takes consider-
ably less time than initial data collection.
The paper burden upon reporting LEAs is also eased since most of the
information for the year is collected at a single stroke. Duplication and
multiple requests have been slashed. In the first year, four forms replaced
the 22 state forms previously required to gather data from schools. LEA paper
burden is further trimmed because the data system provides state-level
responses to a wide variety of recurring outside agency-reports. These
agencies include: New York State United Teachers,- the U. S. Office of Education,
the National Education Association, the National Center for Education Statistics,
the Bureau of the Census, and other professional associations. Without the
system, - LEAs would have to complete reports requested by. such agencies, often
calling for similar information. The same capabilities are used to respond to
legitimate requests for research information, again relieving, the burden on
LEAs. All requests are governed by a strict policy concerning the confiden-
tiality of personally- identifiable information. - -
PAGENO="0562"
558
-6-
The New York State Education Department has also reduced the paper
blizzard in 250 colleges and universities within the State. To do this, the State
Education Department has combined its information needs with those of the U. S.
Office of Education. The State Education Department uses forms developed by
USOE, adding brief supplements where required. ICE further trims paper-
work at these institutions by mailing, receiving, editing and returning all of
these USOE forms to Washington, assuring the presence of identical data at
State and Federal levels.
The NYSSCSS network is equally prolific in remedying the paper problem.
For example, NYSSCSS generation of LEA reports--particularly the lengthy
annual attendance and financial reports- -can eliminate a great deal of duplica-
tive work for local districts. The annual reports will be sent on computer tape
through the BOCES to the State Education Department.
This year, the new program has more than cut in half the number of
separate financial items which districts must report. It has done this by
combining certain forms and eliminating repetition in figures which must be
reported to the Department of Audit and Control and to various offices within
the State Education Department which have responsibilities for overseeing the
financial reports of local school districts.
For example, the number of items of information to be reported on the
1976-77 annual financial report, which must be filed by all school districts
this summer, has been reduced by 46 percent--from 4, 723 items to 2, 544
items. Similarly, the information items requested on the annual independent
auditors report has been reduced by 78. 5 percent--from 4, 723 items to 1, 017
items.
PAGENO="0563"
559
-7-
Currently, the State Education Department is testing calculations of State
aid for districts directly from district financial statements. This will eliminate
at least three forms previously required from LEAs, cutting LEA staff costs
and calculation time.
Beneficiaries
The Basic Educational Data System (BEDS) and NYSSCSS systems provide
tremendous benefits to New York education by reducing the paper burden. The
prime beneficiaries are our students. For example, new programs such as the
middle school can be readily identified for further study. Similarly, curriculum
trends can be located and followed closely. Moreover, summary data can
provide individual school districts with meaningful comparisons to help measure
their own particular needs. In short, New York State students are studying
under an educational system that can make the most of current and past exper-
ience in creating policy for the future.
For the educator, New York's Basic Educational Data System provides
a sound starting point for decision-making and planning. The system's
potential application in these and other areas is limited only by the educator's
innovative ability. Paper burden relief provided by BEDS and NYSSCSS allows
time for such planning activity. The researcher also not only avoids duplica-
tion of effort and saves valuable time for the schools, but he or she is also
assured that samples are reliable and up-to-date.
Without question, BEDS and NYSSCSS provide more and better educational
information than has ever been available. Consequently, the Board of Regents,
the Commissioner of Education, the Legislature and the Governor's Office have
PAGENO="0564"
560
-8-.
added assurance that their educational programs and legislative proposals
meet educational needs that are current, vital, and objectively determined.
Generally, then, the systems help the public official maintain New York State's
strong governmental support of quality education and assure continued progress.
Finally, the Federal Government benefits from New York State's efforts,
The production of high quality educational data for New York State use also
means that such data are available to Federal policymakers. In this period of
educational crisis, timely, accurate and comprehensive data are an invaluable
tool at Federal levels.
Recommendations
Recently, representatives from 44 States and Territories attended a
conference in Albany, New York, to learn about the implementation of educa-
tional data systems by the New York State Education Department. The confer-
ence, co-sponsored by the State Education Department and the National Center
for Education Statistics, resulted from multiple requests by States wishing to
visit the State Education Department to learn about its data systems. Partici-
pants came from as far away as Saipan.
It is important to remember that successful solutions to data problems
must be particularistic ones. The BEDS and NYSSCSS programs serve New
York's educational data needs, but these systems are not universal solutions.
There are, however, some points about the implementation and operation of
data systems which are generalizable. These are contained in Appendix A.
The paper blizzard points out the need for adjustments at Federal levels.
First, the Federal Government should seek accurate assessments from the
PAGENO="0565"
561
-9-
States regarding data capacities to avoid legislation imposing data requirements
which are impossible for States to meet.
Secondly, States are exhibiting an obvious interest in relieving the paper
burden by improving the capacity of their educational data systems. The
potential Federal benefit from such state capacity-building has already been
mentioned, while the growing demand for a reliable data base for Federal
planning and policy-making is even more evident. States, however, have
committed all they can to this effort. For example, for the 1976-77 year, New
York State's total spending on automated information systems to cut paperwork
was nearly three and one-half times the Federal contribution for that year
(See Table A). New York is not unique in that regard.
TABLE A
EXPENDITURES BY SOURCE FOR THE DEVELOPMENT, *
OPERATION AND MAINTENANCE OF
STATISTICAL AND AUTOMATED INFORMATION SYSTEMS
New York State Education Department
1976-77
Information Data
Expenditures Cent~ ProcessinK Total
State $499,334 $647,576 $1,146,910
Federal 173,048 l60,~~ 333,472
Total $672,382 $808,000 $1,480,382
*Development refers to 1976-77 developmental budget only.
PAGENO="0566"
562
-10-
Current levels of Federal assistance are sadly inadequate. If States are
to make significant improvements in their information systems capability..-
improvements which will ultimately benefit the Federal statistical systems and
assist in reducing the paper burden on local education agencies--they mustS
have help. A vehicle for providing such help already exists.
The National Center for Education Statistics has been mandated in Public
Law 93-380 to 1assist state and local educational agencies in improving and
automating their statistical and data collection activities. To date, the assis-
tance program of NCES has been woefully underfunded. It needs immediate
support in the form ofadditional Congressional appropriations.
PAGENO="0567"
563
APPENDIX A
ORGANIZATION DEVELOPMENT PRINCIPLES
RELATED TO THE IMPLEMENTATION SUCCESS OF
THE NEW YORK STATE EDUCATION DEPARTMENTS DATA SYSTEMS
~~managernent made a firm commitment to the project, leading to succes~4
~~p1Lementati2P~
Presentation of the data systems project to top management earned a
firm commitment to the project consistent with the leadership's proactive
planning orientation for educational progress.
~ from a variety of NYSED staff and flexibility for responding to legitimate
information needs helped to make the projects succes~4.
The project plan was presented to, and discussed with, staff of various
divisions prior to implementation. Although data requests were reviewed
against strict criteria of potential utility and actual use, flexibility for re-
sponding to legitimate data needs was built into the system.
Skills in spanning organizational boundaries were possessed by data systems
~~gement personnel. These personnel were critical elements in the
2~pgrams' succ~~.
Many attributes of our data systems management personnel contributed
to the success of the program. Among them were:
--wide social science background and extensive training as professional
educators;
- -intensive working knowledge of the goals, functions and data needs of
PAGENO="0568"
564~
-2-
personnel in other departments
- -ability to relate MIS data capacities to the data needs of various
departments; and
--leadership and human relations skills.
Freedom to perform an educational service role has aided~ program success.
ICE has been given service responsibilities only. Itdoes not collect.
evaluation data, Federal program applications (except tocheck for com.mon~~
ality in data elements), data on SEA payroll or personnel, or individual student
information Neither does it monitor program compliance
High quality service and a service philosophy contributes to success.
Commitment to accuracy, efficiency, and service characterize this
division. Data are collected to be given away.
Adaptability is essential.
ICE is in a state of contin~l development adaptation and growth to meet
new needs. This means not only~ establishing new services, but refining
current services.
PAGENO="0569"
565,
The University of the State of New York
THE STATE EDUCATION DEPARTMENT
Albany, New York 12234
- APPENDIX B
INFORMATION CENTER ON EDUCATION
The Information Center on Education was established in 1967, and
is composed of two units--the Bureau of Statistical Services and the
Bureau of Educational Data Systems~ It is charged with the responsibility
for the identification, implementation and operation of data systems in
all areas of education as well as the coordination of all data collection
procedures within the State Education Department.
The Bureau of Educational Data Systems:
1. develops, implements and operates educational data
systems.for the purpose-of assembling information in
all areas of the State's educational enterprise;
2. advises and assists Department units and school
authorities in procedures for the implementation and
use of data systems;
3. coordinates all data collection procedures within the
Department;
* - - 4. advises and assists Department units in the design and
use of forms and survey Instruments.
The Bureau of Statistical Services:
1. analyzes, interprets and disseminates data relating to
public and nc~npublic elementary and secondary schools as
we~l as colleges and universities of the State;
* 2. recommends policies and procedures for processing
statistics;
3. plans, supervises and conducts special statistical
surveys and studies;
4. advises and assists other Department `nits and school
authorities on the conduct and design of experiments as
well as the statistical analysis of experimental data;
5. prepares projections and estimates.
The following paragraphs provide a capsule review of these
activities.
91-860 0 - 77 -- 37
PAGENO="0570"
~66
-2-
It will be apparent that the developments listed were not, and
could not be achieved by the Information Center alone. None would have
been possible without the cooperation of local educational agencies and
the many operating units of the Education Department who worked, and
continue to work diligently with Information Center staff members to
initiate and improve Department information systems. While the many
Department units involved will not be enumerated here, special note must
be made of the contributions of the Division of Electronic Data Processing
which has shared equally with the Information Center the responsibility
for and effort expended in bringing about the developments noted.
BASIC EDUCATIONAL DATA SYSTEM
In the fall of 1967, and after two years of development, a
completely new and comprehensive information system on public elementary
and secondary schools was implemented--the Basic Educational Data System.
Through this system, most of the information needed by the Education
Department on public elementary and secondary schools is collected or a
given day in the fall of each year and, by the use of machine-readable
forms and automatic dataprocessing, various outputs are produced which
provide timely information for multiple purposes. They include:
1. Descriptive Reports--Reports are produced for the various
general and subject supervisory units of the Department and are of two
basic types:
- Comprehensive school reports are produced for the Bureau -
of Elementary and Secondary School Supervision. These
reports (one for each public elementary and secondary
school in the State) include: enrollment by grade, daily
session data, instructional room inventory, distribution
of last graduating class (if secondary school), number of
dropouts, special programs or acti!ities (including
participation in regional programs, closed or open circuit
television, programmed learning, prekindergarten program,
flexible or modular scheduling and others), class size
data, teacher load data, a complete faculty listing (with
information about each individual, e.g. degree status,
cartification status, experience) and selected salary data.
- Subject faculty reports are produced for the subject
supervisory bureaus. These include: enrollment by grade,
daily session data, instructional room inventory and
detailed information about faculty in a particular subject
area including name, degree status, certification status,
years of experience (4 categories), type of appointment,
title of each course taught, number of pupils in each
class, grade level, type of pupils (e.g. below average,
average), number of periods the class meets a year.
-- These reports are the major source of information the
bureaus have about the schools and their programs.
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-3-
II. Statistical Reports--A wide variety of statistical analyses
of characteristics of public school professional staff are produced,
including such factors as salaries, degree status, certification status,
experience, sex, age and racial/ethnic characteristics. Summaries of
various factors are available by school, school district, county,
geographic region and for the total State.
In addition, several pupil statistics are also generated including
* enrollment by grade, racial/ethnic characteristics and course registration
data as well as student staff ratios, class size and student load. *These
data are also available at various levels of aggregation.
Copies of these reports are regularly returned to school districts
and are used by the districts and teacher groups in contract negotiations.
It should be noted at this point that the information contained
in the personnel file of the Basic Educational Data System is covered by
a strict policy of confidentiality. That policy is shown as Attachment A.
The Basic Educational Data System has enabled more rapid
summarization of a greater quantity of information about the public
schools in New York State than was previously possible ano, at the same
time, has substantially reduced hand tabulation, duplication of effort
and multiple requests for the same data in the Education Department.
During the first year of the Department's consolidation of data collection
activities over 20 annual reporting forms were eliminated from use. It
is, of course, not possible to determine the number that have been
eliminated (or prevented) since then due to the ability of the ~nformation
Center to respond to information requests which would normally have
required a special survey or new form.
The number of requests for information going but to the schools
is further reduced because the system is able to respond, at the State
level, to a wide variety of recurring reports f rum outside agencies that
otherwise would have been sent to local school districts. These agencies
include: New York State United Teachers, the U.S. Office of Education,
the National Education Association, the U.S. Office for Civil Rights,
the Bureau of the Census and other professional associations.
III. ~pecial Request Repp~~--Each year, a wide variety of informa-
tion is supplied from the Basic Educational .Data System to users both
within and outside of the Education Department. In addition to data
regularly distributed to Department units and that returned to school
districts as standard output, the Information Center handles literally
hundreds of special requests each year. The requests vary from those which
can be handled quickly, by phone or reference to a publication, to those
of a very complex nature requiring special analysis aid computer programming.
The nature of these files are such that complex interrelationships among
data elements can be obtained along with a longitudinal record of the
progressof education in the State. Lacking such a broad based information
system, the Department would be unable to answer these very legitimate
requests for information. In addition, both the Department and the school
districts would be called upon to file duplicative data requests which are
now available quickly from a single source.
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-4-
Listed in Attachment B are a few examples of the kinds of
information generated from Information Center files which highlight the
decision making utility of the System.
INTEGRATION OF DATA FILES
Since 1967, the Information Center on Education and the Division
of Electronic Data Processing have developed an integrated information
system of some magnitude for elementary and secondary schools. In
addition to the student, curriculum~ staff and school characteristic data
contained in the Basic Educational. Data System, detailed informatior. on
public school district finance and attendance, as well as on nonpublic
schools, has been available in machine readable form and interrelatable
through a common coding structure. The Pupil Evaluation Program,
developed in the Regents Examination and Scholarship Center, also uses
this common coding structure.
In the past, each of these files have been maintained independently,
in a sequential mode on magnetic tape, and the ability to interrelate the
data elements contained therein has depended mainly on the availability
of systems analysis and programming time- -and personnel- -in the Division
of Electronic Data Processing. While it is clear that this information
has been by no mear.s wastedand has served well all facets of the
educational and political enterprise, it is also evident that the tremendous
potential for interrelating these data elements has never been realized.
In addition, it has been found that it is virtually impossible to
anticipate the many and varied interrelationships and aggregations of data
that are requested throughout the year.
To meet these problems, the Information Center on Education and
the Division of Electronic Data Processing have designed a Consolidated
Data Base (CDB) which merges the data from several different files into
one. The combined file is maintained on random access disc storage for
easy retrieval.
The availability of a Consolidated Data Base will cause the
information regularly received by the Education Department to. be better
utilized and its customers better served.
HIGHER EDUCATION DATA SYSTEM
The Information Center on Education also has responsibility for
data collection and coordination in the area of higher education. As
with elementary and secondary schools ICE has attempted to reduce the
reporting burden placed or. the 250 colleges and universities of the State.
To that end, the Education Department has, since 1966, combined its
information needs with those of the U.S. Office of Education. Basically,
the Department uses the forms developed by U.S.O.E. --the Higher Education
General Information System (HEGIS)--adding brief supplements where
required. Information is received in the areas of enrollments and
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-5-
admissions, faculty, degrees awarded, institutional characteristics,
student migration, libraries and finance. The data are entered into a
computerized system and are available at various levels of aggregation.
The Information Center coordinates the data collection for the
Federal government by mailing, receiving, editing and returning all
HEGIS forms to Washington thus assuring the presence of identical data at
both the State and Federal levels.
NONPUBLIC SCHOOL REPORTING
The Information Center also collects data on nonpublic schools in
a form compatible and interrelatable with that collected on public schools.
The revised reporting procedure was used for the first time in the fall
of 1969.
CONTINUING EDUCATION REPORT
This annual report was developed in conjunction with the Division
of Continuing Education and includes data on enrollments, teachers and
fees associated with continuing education programs operated by public
school districts and BOCES.
SURVEYS
As a part of the total information system concept a number of
indepth surveys are scheduled each year for the various program units of
the Education Department. These surveys are designed to provide in-depth
information for the program officers not available from data gathered in
the regular reporting stream.
EDUCATIONAL MANPOWER INFORMATION SYSTEM
Utilizing already existing Department files, thereby obviating
the need for additional data collection, the Information Center has
developed an elementary/secondary Educational Manpower Information System
designed to serve as a base for the planning and development of professional
education manpower training programs in the colleges and universities of
New York State. Specifically, the System will provide precise and timely
information in the following areas:
1. the existing educational manpower in public elementary and
secondary schools;
2. the potential pooi of educational manpower produced by teacher
training institutions;
3. the potential pool of educational manpower not currently
employed in a New York State school district;
PAGENO="0574"
570
-6-
4. the turnover rates of educational manpower in all sectors of
the public education system.
DATA COORDINATION
The Information Center has been chargad with the coordination of
all data collection with the Department. As a part of that responsibility,
the Information Center reviews and approves all data collection instruments
to be sent by Education Department units (or those prepared by contractors
to the Education Department) to any institution or person within the
University of the State of New York. If the Information Center withholds
clearance of any form, the decision is appealed to the -Department's Executive
Deputy Cnmxnissioner.
DATA ANALYSIS AND DISSEMINATION
As a service unit, -the Information Center on Education is called
upon daily to analyze, interpret and disseminate information to offices
and agencies both within and outside the State Education Department.
The Information Center advises and assists other Department units in the
design -and conduct of experiments and in the statistical analysis of
experimental data. It also has responsibility for the preparation of
projections and estimates. -
Menticned earlier are types of. information requests answered
directly through automated files. In addition, however, five to six -
recorded man years of clerical effort are annually expended in answering
information requescs. As a part of its analysis and dissemination effort
the In~ornation Center also publishes a number of annual and special
documents which are listed in Attachment C. -
PAGENO="0575"
571
THE UNIV~R3ITY OF THE STATE OF NEW YGRK
The State Education Department
information Center on Education
Albany, New York 12224
THE NEW YORK STATE EDUCATION DEPARTMENT'S OPERATING POLICY
CONCERNING INFORMATiON CONTAINED IN THE PERSONNEL FILE
OF THE BASIC EDUCATIONAL DATA SYSTEM
1. The Director of the Department's InfOrmation Center on Education,
subject to the general provisions of this Statement, will be
responsible for the Personr.el File of the Basic Educational Data
System.
2. Statistical summary data, involving no problems of confidentiality,
will be made avaf labia to users within and outside ~f government
upon request, and subject to the limitations of time and manpower.
3. The social security number of an individual will not be used
outside the Department's file and will not be released for use
by any other agency, public or private.
4. Names of individuals will be released to bona Lide professional
organizations and for purposes of serious, educationally related
research.
5. Demographic information and professional characteristics associated
with names of individuals will be released only for purposes of
serious, educationally related research and only after the person
or perscns requesting it has obtained prior permission, from each
individual, for its use. In addition, information so supplied
must be treated confidentially, and may not be released to any
other person or agency, public or private.
PAGENO="0576"
572
~tttacnnent m
EXAMPLES OF SPECIAL REQUESTS FOR `INFORMATION
GENERATED FRO I FILES Mni\TAI\ED BY THE
INFORMATION CENTER ON EDUCATION
- The State University of New York at Buffalo':has used longitudinal c~ata
on public school administrators, to determine whether the University's
programs in educational administrat~On and supervision are"diz~ected at
areas of need. `:. , ,::~ "
- A detailed analysis of staffing ratios in the public schools was
undertaken for the Governor's Office to assess the feasibility and
impact of tying state aid payments to such ratios.
- in 1972, the New York State. Commission on the Quality, Cost and
Financing of Elementary and Secondary Educatior produced a tlree
volume report based in large measure on information contained in files
maintained by the information Center on Education. In a letter from
the Commission's Director of Research he stated: "First, in our work
as a commission, we have found BEDS invaluable. To make the point
even more forceful, we could not have done our, work without , it
Fortunately, BEDS has been deveioped long enough that we, have, been
able to use a wide variety of data not only for obtaining a static
profile of primary and secondary education in this State, but also to
evaluate how various things have changed'.over*tirne..'
"Secondly, the needs of the Commission aside, the demand for, such a
data bank as BEDS for a wide variety of educational policy decisions
is beyond question. It is our estimate that BEDS surpasses the
educational data banks in any other state.. . This is not : to suggest
that other states don't need similar systems. On the contrary,. it
seems to us that the complexities of the public education enterprise,
if not the present, and likely to recurring, fiscal problems,
require such information as BEDS can provide for informed decision
making."... . ~` .. . `. `: . ` ` .... , . `
A detailed a'ialysis of the characteristic~ of occupationsl educa ion
teachers across the State'was undertaken. for'the Cornell Institute, for
Occupational' Education.. The information willbe..utilized to'..form. the
basis of a Needs Assessment Study of Occupational. Educational Personnel
in New York State. ` `` ... ` `
A special analysis of New York City public school professional staff
has been undertaken for the City's Bureau of Personnel.
A special analysis has been undertaken for the New York State
Association.of School' Nurse Teachers. The information will be used in
conjunction with development of legislation, permitting an assessment
of the fiscal impact of such legislation.
PAGENO="0577"
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-2-
Detailed characteristics of eaLh school in New York City have been
provided, on tape, to that City's Vice-Chancellor.
- A comprehensive set of data has been supplied to the Department's
Office of Occupational Education Planning for use in fulfulling
Federally mandated reporting requirements as well as in the
development of their statewide master plan
The City University of New York is using extensive inforration from
the files in a comprehensive research study of New York City high
schools
- Researchers at Cornell University are using BEDS and related
information in a study of the administrative structure of schools as
it relates to achievement. .
- The New York State Department of Audit and Control has requested and
received information on nonpublic schools in relation~to their audit
function of state aid payments.
June 13, 1975
PAGENO="0578"
574
Attachment C
ANNUAL PUBLICATIONS OF THE
INFORMATION CENTER ON EDUCATION
Title Explanation
1. Education Statistics Estimates 1. Produced in September of each
school year, this one page sheet
provides current year estimates,
plus four years of trend data,
of key educational statistics
including enrollments, staff,
graduates and expenditures.
2. Education Statistics, New York 2. A pocket size booklet, this
State, Prepared Especially For publication is made available
Members of the Legislature to legiil~tors and their staffs
at the opening of the legislative
session to provide a brief over-
- view of the condition of education
in the State. It cortains past,
current and projected data, along
with brief written analyses of
educational statistics.
3. Survey of Enrollment, Staff 3. A detailed presentation of public
and Schoolhousing school enrollment and staff data
for each public school district
for the current school year, this
publication is available in the
- spring of each school ycar. It
is used as both an historical
time series and for comparative
research purposes.
4. Nonpublic School Enrollment 4. Data are presented in suarsary and
and Staff disaggregated form (by county and
religious affiliation). The
publication is available in the
spring of each school year and is
used as both an historical time
series and for comparative research
purposes.
5. Racial/Ethnic Distribution~of 5. Historical and current disaggregated
Public School Students and Staff data (by school district) are
presented in this publication which
is available in the spring of each
school year. It presents the
racial/ethnic composition of the
State's public schools and serves
as an historical time series and for
comparative research purposes.
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6. Code Manual for Public School
Districts in New York State
6. The single source for school
district codes used by the field
and all units of the Education
Department which receive reports
from the schools of the State.
7. Available in the spring of each
school year this publication
*shows historical and current
disaggregated data (by county)
for both public and nonpublic
high school graduates. It is
widely used by both elemenlary/
secondary and college administra-
tors for planning, as an historical
time series and for comparative
research purposes.
9. Projections of Public and
Nonpublic School Enrollment
and High School Graduates in
New York State
10. Directory of New York State
Public Schools and
Administrators
8. This publication continues an
annual tirnu series begun in the
early 1900's: It presents
pertinent statistics for a current
school year and trends for earlier
years. While emphasis is placed
on summary tables and figures,
individual school district data
are shown for revenues, expenditures,
property value and attendance- -the
only place these data are published.
it is used as an. historical time
series and for comparative research
purposes.
9. Presents 20 year projections by
grade within geographic region.
Published periodically, this report
is widely used for planning purposes
by both elementary/secondary and
college administrators.
10. Published in the early fall, this
is the sole reference available
which shows names, addresses and
telephone numbers of chief school
officers and school principals.
it is in exceptionally high demand.
After an initial distribution
within the Department and to school
administrators, additional copies
are sold on request.
575
-2-
7. Distribution of High School
Graduates and College Going
Rate
8. Annual Educational Summary,
Statistical and Financial
Summary of Education in
New' York State
PAGENO="0580"
576
-3-
11. Directory of Nonpublic Schools 11. Published in the early fall, this
and Administrators is the sole reference available
showing names, addresses and
telephone numbers of nonpublic
school principals. It also shows
the registration status of
nonpublic high schools and is in
exceptionally high demand.
12. College and University 12. Published in the early winter of
Enrollment (Preliminary the current academic year, this
Report) publication presents opening fall
* enrollment data to the higher
~ducation comm~inity for planning
purposes.
13. College and University 13. Published after the close of the
Admissions and Enrollment academic year, this report presents
a detailed analysis in summary
and disaggregated (by college) form.
It is used as.both an historical
time series and for comparative
research purposes.
14. College and University Degrees 14. Published after the close of the
Conferred academic year, this report presents
a detailed analysis in sumr.ary
and disaggregated (by college and
subject area) form. It is used as
both an historical time series and
for comp~rarive ~esearch purposes.
15. Employees in Colleges and 15. Published after the close of the
Universities academic year, this report presents
data on the number and salary
levels of college and university
employees by type and level of
position, type of institution and
sex of the employee. It is used
both as an historical tine series
and for comparative research
purposes.
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PADUCAH
U PUBLIC
SCHOOLS
Halter C Jetton Boulevard
P.O. Box 2550
Paducah, Kentucky 42001
Phone: 442~6121
David Whitaheed
Superintendent
Richard B. Brown
Assistant Superintendent
Patricia Koch
Assistant Superintendent
Board Menthers
Harry Abel!. Jr. M.D.. Dtairrnan
JoeA. Powell~ Vice Chairman
Lawrence Albritton
Robert L. Harriford
Rev. Tim Taylor
Peggy Tripp. Secretary
June 27, 1977
577
The Honorable Carl Perkins
U. S. House of Representatives
Washington, D. C.
Dear Congressman Perkins:
During this past school year much discussion has been devoted
to the problems and the necessity of completing Office for
Civil Rights Forms 101 and 102. We recorded the amount of
time necessary to complete these forms for the Paducah School
District. The Paducah Schools currently have an enrollment
of 4,439 which is approximately 30% black students. During
the past school year, we spent in excess of 2,000 hours gather-
ing information and completing these forms. Most of this time,
because of the nature of the information needed, had to be spent
by principals, assistant superintendents and directors of pupil
personnel. The direct cost of completing these forms in our
school district exceed $15,000 or more than $3.00 per student.
Any effort which you can take to eliminate these forms and
other needless data gathering by OCR or other federal agencies
would be appreciated by all of us in Paducah.
Sincerely,
David Whitehead, Superintendent
PADUCAH PUBLIC SCHOOLS
DW: csr
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578
Education Commission of the States
300 LINCOLN TOWER. 855 LINCOLN STREET
(303) 8935200W DENVER. COLCRADO 80203
June 27, 1977
The Honorable Frank Horton
Chairman, Commission on Federal Paperwork
Rayburn House Office Building, Room 2229
Washington, DC 20515
Dear Honorable Horton:
Having followed the hearings held by the Commission on Federal Paperwork,
the National Assessment of Educational Progress (NAEP) has two concerns.
First, it appears that no distinction was made during the hearings between
mandatory and voluntary studies. With a mandated study, school officials
must respond to the survey, regardless of the impact, unless they are will-
ing to face the possible loss of funds; with a voluntary study, school officials
have the option of considering the impact of participating and making a de-
cision on this basis. Secondly, it appears that the hearings did not address
the attenspts that some projects have made to minimize the impact upon
schools, school officials, and students. The Commission is urged to consider
these two points as it is asked to make recommendations for legislation re-
garding the future collection of educational data.
Participation in the National Assessment of Educational Progress is on a
voluntary, rather than mandatory, basis. The cooperation rate for selected
sample schools has varied from 92 to 95% for the eight years that NAEP has
collected data. National Assessment believes that it has maintained this high
E1~ rate of participation because it has designed its data collection procedures to
minimize the impact upon participating schools and students. The procedures
were developed and have been refined to insure the voluntary cooperation of
selected schools and to standardize the information collected.
NATIONAL ASSESSMENT OF EDUCATIONAL PROGRESS
PAGENO="0583"
579
2.
Within a participating school district, the principals of the schools
selected for participation are each asked to complete a two to four page
principal's questionnaire. The questionnaire takes approximately 20
minutes to complete and is designed to provide school level information,
such as the type of community the school serves, that will be used to re-
port the data. National Assessment makes a concerted effort to limit
the amount of information collected at this level.
The selected schools are~ also asked to complete a student listing form of
all age eligible students. Although it is possible for the NAEP field staff
to complete the student listing form themselves, National Assessment pre-
fers to have the schools complete the form as the information is often taken
from individual student records. if this creates a burden on the school
staff, the field staff are instructed to complete the form themselves (with
the school's permission) or to reimburse the school for the extra time and
effort required in completing the form.
It should be noted that for most school districts in the United States, a re-
quest to participate in the assessment occurs only once in a four-year time
span. For the school districts within the 13 largest metropolitan areas of
the country, NAEP has drawn its sample so that individual schools are in-
cluded in the sample only once in a four-year time span. Thus, both the
sampling procedures and the information collected at the school level have
been designed to minimize the impact upon participating schools.
While it would be ideal from a measurement viewpoint for each student to take
all six hours of assessment materials, National Assessment realized that
this would place an unreasonable burden on both students and their schools.
Instead, the six hours of assessment materials are divided into 10 or more
booklets at each age level and students are asked to respond to only one book-
let. The booklet requires approximately 50 minutes of the students' time.
NAEP also hires local field staff to administer the assessment materials to
the students so thRt ~ borden is not placed upon teachers or local adminis-
trators. These steps were taken to minimize the impact upon both students
and schools.
The NAEP sample has been designed so that a sample of 2,200 to 2, 500
respondents to a booklet allows the project to reliably estimate the perform-
ance of the entire age group population to the questions contained in that
booklet. Each year, approximately 80, 000 students participate in the assess-
ment; their participation allows National A ssessment to reliably estimate the
performance of 12 to 13 million students.
PAGENO="0584"
580
3.
As the Federal Commission on Paperwork concludes its work and prepares
to make recommendations to Congress, National Assessment would en-
courage the Commission to make a distinction in the recommendations
between voluntary and mandatory studies. While it may be necessary to
limit the magnitude of data collected as a part of mandatory studies, such
restrictions should not necessarily be required for voluntary studies.
Hopefully, the lack of restrictions on voluntary studies would encourage
such studies to place realistic limits upon the demands made on school
officials and respondents. If not, school officials would have the option of
refusing to participate in voluntary studies--which would provide added
Incentive for such studies to limit the respondent burden.
If you I~avc any questions or if I can be of assistance to you, please do not
hesitate to contact me.
Sincerely,
Roy H. Forbes
Director
RHF/eps
cc: Mr. Jack Jennings
House Subcommittee on Elementary,
Secondary, and Vocational Education