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') PAGENO="0003" 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) PAGENO="0004" 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) PAGENO="0006" 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 PAGENO="0007" 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. PAGENO="0008" 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. PAGENO="0009" 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 PAGENO="0010" 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 PAGENO="0011" 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 PAGENO="0012" 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 PAGENO="0013" 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. 1-2 PAGENO="0014" 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 PAGENO="0015" 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 PAGENO="0016" 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 PAGENO="0017" 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 PAGENO="0018" 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 PAGENO="0019" 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 PAGENO="0020" 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 PAGENO="0021" 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 PAGENO="0022" 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 PAGENO="0069" 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 PAGENO="0073" 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 PAGENO="0074" 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 PAGENO="0075" 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 PAGENO="0091" 87 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. 111-2 PAGENO="0092" 88 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 111-3 PAGENO="0093" 89 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 111-4 PAGENO="0094" 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 111-5 PAGENO="0095" 91 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. III-6 PAGENO="0096" 92 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 111-7 PAGENO="0097" 93 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- II 1-8 91-8600-77--7 PAGENO="0098" 94 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 111-9 PAGENO="0099" 95 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. ` 111-10 PAGENO="0100" 96 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 111-11 PAGENO="0101" 97 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- 111-12 PAGENO="0102" 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 II 1-13 PAGENO="0103" 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 ij 1-14 PAGENO="0104" 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 111-15 PAGENO="0105" 101 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 II 1-16 PAGENO="0106" 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 111-17 PAGENO="0107" 103 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." II 1-18 PAGENO="0108" 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 111-19 PAGENO="0109" 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 PAGENO="0110" 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 111-21 PAGENO="0111" 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 111-22 PAGENO="0112" 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 111-23 PAGENO="0113" 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 91-8600-77--8 PAGENO="0114" 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- 111-25 PAGENO="0115" 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 iil-27 PAGENO="0116" 112 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. 111-28 PAGENO="0117" 113 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 IV-l PAGENO="0118" 114 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 PAGENO="0119" 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. IV-3 PAGENO="0120" 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 IV-5 PAGENO="0122" 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 PAGENO="0123" 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 PAGENO="0124" 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 PAGENO="0125" 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 PAGENO="0127" 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 PAGENO="0128" 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 PAGENO="0129" 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 PAGENO="0136" 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 PAGENO="0137" 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 IV-22 PAGENO="0138" 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 PAGENO="0139" 135 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 PAGENO="0140" 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 PAGENO="0141" 137 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 PAGENO="0142" 138 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 PAGENO="0143" 139 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 PAGENO="0144" 140 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 PAGENO="0145" 141 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 91-860 0 - 77 -- 10 PAGENO="0146" 142 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 PAGENO="0147" 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 PAGENO="0148" 144 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 PAGENO="0149" 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 PAGENO="0150" 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 PAGENO="0151" 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 PAGENO="0152" 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 PAGENO="0153" 149 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 PAGENO="0154" 150 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 PAGENO="0155" 151 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 PAGENO="0156" 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 PAGENO="0158" 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 PAGENO="0159" 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 PAGENO="0160" 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 PAGENO="0161" 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 PAGENO="0162" 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 PAGENO="0163" 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 PAGENO="0164" 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 PAGENO="0165" 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 PAGENO="0166" 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 PAGENO="0167" 163 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 PAGENO="0168" 164 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 PAGENO="0169" 165 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 PAGENO="0170" 166 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 PAGENO="0171" 167 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 PAGENO="0172" 168 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 PAGENO="0173" 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 PAGENO="0174" 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 PAGENO="0175" 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 PAGENO="0176" 172 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 PAGENO="0177" 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. V- 24 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 PAGENO="0179" 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 PAGENO="0180" 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 PAGENO="0182" 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. V-29 PAGENO="0183" 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 V-30 PAGENO="0184" 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 - B-l PAGENO="0186" 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 PAGENO="0187" 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" 201 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 PAGENO="0206" 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" 204 -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. PAGENO="0209" 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 PAGENO="0210" 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 PAGENO="0212" 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" 212 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" (1) fi _________________ __ 0 ___________________ U ______________________- fi ___________________ o __________________ c ___________________ -J ___________________ ___ a 0 ______ II ~ t LU Ut ___________________________________________________ ~ I- ~ z III LU »=U) 3U~t~ .~ .tEEEE~a :-~_ UA:EEEEE~_J ~ W D.~ ~ & ~ w .39 ~ I ~ i- Ea+~ XXXXXXXXXXXX 3-Al (L~L L~ iiiii~?~ A X X A A A 3333)13 A A AAA.~ 3 v~ g AAAU -.------------------------------------------~-----. ~ ~XXX~ AAXAAXX AAAAAAA ~AAAA XAAXxA ?I~P~ )< ~XAAA 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. PAGENO="0301" 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 PAGENO="0302" 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" 303 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. PAGENO="0308" 304 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" 305 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. PAGENO="0310" 306 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" 307 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" 308 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" 310 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. . ~L~New~ &~~i ~ ~3 ~ t&~. - P~oc~y It3~New~ - ~ ~CiJ~wI-L~'.*d.~ ~~MW ~.a ~ 1 C. }t~t ~ - ~~jy -~--- ~ ~ ~ April ~ ~L CQ2.~C~O~) ~ z~4 S -~ ~ .~ ~ ~ ~ ~ ~i - -_., 4~ C...d4.'4.4...~.ia ~ Th9 !X~Cert /(~ ~ * AS L!~WL~ C~OLL put it, the weJrua m~a~s.~ys hL~ year at-s ~ half en the ~ ~pt3 the eroa~t w're ~ en t.e ~u_. o~ ta toe a r~a r~t -~ * W~ to s~e ~nd~ quen~ities ol ~IeOCO ~Va eves' ~tL~*' has had to a~- S ~.ar~L en ecu~a f~r4rawcr ~iIr~g eauii~t ~.e ~i~n.s In ~ mr `~f ~st so - ~.. ~ ~i~tNl da `i.n ~- v~a sir .-~ c 1" r.~o..th t~ tr. ct~_~ ~ t~_~yc~m1d Mew nus~ths ~,the n~Manar~.a-. S - r~iL ard i3ud~et rrcor~i skit. a!Lkiu~ Tho c ~±n1er, o~v aniy a reaH~t~ th~ ~ aerma U~i~n~ ~ a 0 L tezr t~. rrlYO L.~ .~i -O.rt~I1 n-r 1W 1~ d ~iLte rc~er.t. ~ `-OmaF' ~- reast. ~r~t t~ TO I r LI * trer~s t~orc e. quamrCtias of ~and, 1t~ I ~ 11 a'-m `ac tz Ucram 0. 5~~~'t TO 2130d r~rV- e*iit £~tyLmLIt t~ Fedara~ ~at~erv~cr~z ~.imm o~tc cesrary t~aperwor~s bu~anm* Tha sr~aa: ~w pr~ranis. more s~onme in `fl~-e aemmission wee sat m W15 eio ~r ranru. arid - worst ~I - * f~rmrPi~iski~FodardReaim - tocu~ ~~mereJadve~yeimfon~einto ~crrn en p~p~rwot. erpecLally (erm~ fewer husfer e Umo-con.~tuiiing 1on~ar ~i~rh'atu critizna arid b oer~ea must onee- Uosit~~ Lab idyencici;~ie4ty presicu~p,t ~hacernmLcaion is due to go ttit ef h~ui- * * * * nasa an Oct~bei'. Dased en the record to edar~b~rreauct~eybeina~whatttis. data. wW !t have maria rnrith cf a dent ima ~ Lae ~parwrirk thme'! LLCe the * nm:i-ia hmhtit. and jeir, him in thcdd~ng a bit- * The first thing it mild w~s to hire 2t~t3 em- tot tear thout the woy ~hin~z are. aoiie tn ~loj~'s. buy thore shiaticotsd eccying Wathinl4. ~ em~i is now riiccoed~-d In di~ast. ~ig I-ta enuru 11 imilirin bu~ictct ii~iiil~ * - * * * * a ~hri new th:ne of p:pzT- * * * - - ** * S * rlsof its O~1~ ~~ar!d t~thc m~u.riin!t~ : * oc::-~a~owonLahksioe. * * * S * (roTa * -- - CLf~icLe w~;1~ -ieeiils arneil t~w-ire1e. 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 PAGENO="0352" 348 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. PAGENO="0353" 349 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 PAGENO="0354" 350 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 PAGENO="0355" 351 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" 352 -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 PAGENO="0357" 353 -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. PAGENO="0358" 354 -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 PAGENO="0359" 355 -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 PAGENO="0360" 356 -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 PAGENO="0361" 357 -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 PAGENO="0362" 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. PAGENO="0363" 359 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 PAGENO="0364" 360 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 PAGENO="0365" 361 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 PAGENO="0366" 362 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. -.4 0. U `4 0. 0 -4 00 0-.4~Uo-.~-o ci) C 00 ..4 0 `4 ~-4 -`-4 U " -.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- ~ 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 ciCJ Ccc Citi 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. PAGENO="0571" 567 -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. PAGENO="0572" 568 -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 PAGENO="0573" 569 -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" 573 -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. PAGENO="0579" 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. PAGENO="0581" 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 PAGENO="0582" 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