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allocation for territories and possessions is $330,000. Our proposal to include these jurisdictions in the allocation of formula grant funds merely recognizes that they should be entitled to the same guarantee of formula funds as are the States and the District of Columbia. This amendment

would also have the effect of releasing the discretionary funds now used to fund projects in these jurisdictions for truly discretionary distribution. In conclusion, we believe these proposed changes, taken together, would help improve administration of the IPA.

I cannot overestimate the importance of sound personnel management to effective government performance, particularly at the State and local levels. The size of the State and local workforce, excluding teachers, is almost three times the size of the Federal workforce. The quality of this workforce and how well it is managed can make a real difference in the quality of government programs in this country.

With your permission, I should like to have Chairman Hampton's letter to Vice President Rockefeller on our proposed amendments placed in the record.

Mr. Chairman, this concludes my statement on the IPA and the amendments proposed in S. 957. I would now like to provide to the Subcommittee the Commission's views on certain additional amendments to the IPA which are being considered in the House Post Office and Civil Service Committee. We expect that this Subcommittee will be asked to consider similar amendments. The amendments in question are contained in the Subcommittee print of H. R. 4415, a bill "To amend the Intergovernmental Personnel Act of 1970 (P.L. 91-648) to provide more effective means to improve personnel administration in State and local governments; to correct certain inequities

in the law; and to extend coverage under the law to the Trust Territory oi the Pacific Islands", as approved by the Subcommittee on Employee Political Rights and Intergovernmental Programs on March 20, 1975.

We are pleased that the Subcommittee print of H. R. 4415 adopts the amendments proposed by the Commission and which appear in S. 957. However, we are deeply concerned with five of the amendments proposed by the House Subcommittee which go beyond those included in S. 957. We are strongly opposed to those amendments which would:

o establish an obligated service agreement of a minimum of one year

for an employee accepting a mobility assignment;

o authorize grants for training to employee organizations;

o require States to notify interested employee organizations of
programs or projects approved under the IPA, and to furnish to
employee organizations upon request copies of all data and products
resulting from such programs;

o authorize grants to associations of elected Federal, State, or
local government officials for up to 75 percent of the salary of a
State or local government official on temporary assignment to such
association; and

o establish an appropriation authorization totalling $102 million
through Fiscal Year 1977.

We believe these additional proposals would not strengthen the IPA program, and, in fact, represent an undesirable departure from the present Our specific reasons for opposing such amendments are as follows:

law.

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1. The first amendment of concern to us would amend section 3372(a) of title 5, United States Code, relating to general provisions regarding assignments to and from States, and would provide that an employee serving on mobility assignment must sign a written intent agreement to remain in the employ of the agency from which assigned, upon completion of the mobility assignment, for a period of at least one year, or for a period equal to the length of the assignment.

We believe this amendment is undesirable for three reasons.

First,

mobility assignments under the IPA are not restricted to a minimum length of one year. In fact, mobility assignments cover varying periods of service, ranging from a few weeks up to several years. Short-term mobility assignments, which could contribute significantly to improving specific aspects of management in an agency or State or local government may be jeopardized by a minimum obligated service agreement of a full year. Second, the Federal government benefits from the services of an employee returning from a mobility assignment, whether the employee remains with the executive agency with which he was employed prior to such assignment or returns to another executive agency. In some cases, the mobility assignment may prepare the employee for a position in an agency other than his employing agency which is more beneficial to the Federal government. Third, we seriously question the propriety of Federal legislation imposing on State and local governments the stipulation that State or local employees must return to that State or local government upon completion of a temporary assignment to a Federal agency under the IPA. We feel this should be a matter left to the discretion of the State or local government concerned.

Accordingly, we oppose this amendment unless it is modified to

(a) permit the assignee to return to any Federal employer; (b) require

a period of obligated service equal to the length of the assignment or
one year, whichever is shorter; and (c) restrict the applicability of the
amendment to Federal assignees.

2. A second proposed amendment in H. R. 4415 which we strongly oppose
would add a new subsection to section 304 of the IPA (Grants to Other
Organizations), authorizing the Commission to make grants to employee
organizations to pay up to 75 percent of the costs of providing training
to officers and employees of employee organizations. We strongly oppose

this amendment for the following reasons:

Even the

o The IPA was enacted to provide assistance to State and local
governments in improving their management competence. This is
its unique purpose. The IPA is almost the only source of such
specialized assistance to State and local governments.
Act's provisions for grants to organizations other than State and
local governments are carefully prescribed to ensure that such
training grants are made for and only on request of State and
local governments. This amendment would equate labor organizations
which have no governmental responsibilities with State and local
governments for which the Act was specifically designed.

o The present administration of the IPA provides sufficient program
flexibility and latitude to include direct opportunity for repre-
sentatives of employee organizations who are State or local
employees to participate in appropriate training programs under

the Act.

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3.

o Expanding the IPA to provide direct financial assistance to labor organizations would take this program into areas far beyond those contemplated by the Congress in passing the Act. In our opinion, extending financial assistance to labor unions and employee organizations requires a policy determination which should be considered

in depth outside the context of the IPA.

We also strongly oppose a second proposed amendment to section 304 which would authorize the Commission to make grants to an association of elected Federal, State, or local government officials for up to 75 percent of the salary costs of State and local employees on temporary assignment to such organizations.

We do not think this proposed amendment is consistent with the objectives of the IPA or represents sound use of Federal financial assistance. The purpose of the IPA is to provide assistance to State and local governments to improve their personnel management and training capacity. Grants authorized by the proposed amendment could presumably be used to support any kind of program, e.g., housing, environmental, consumer affairs, etc. There already exist Federal assistance programs which can fund such programs undertaken by public interest groups. Also, we can see no need or rationale for the Federal subsidization of the payroll costs of any category of non-governmental organizations.

We also urge elimination of the proposed amendment in H. R. 4415 to section 202(b) of the Act, relating to personnel administration grant applications, which adds new paragraphs (6) and (7) to this section.