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Additional difficulties with the pull-out model occur because local districts must try to coordinate the project offered with Title I funds with other categorical programs such as ESEA, Title VII, or ESAA. Since children deficient in one area are frequently deficient in others, multiple supplemental programs focus on the same disadvantaged students. Target students are not only "pulled out", they may be pulled in several directions by multiple programs. Student disorientation and excessive loss of class time result. In many cases, coordination problems caused by "pull out" and multiple programs may result in "supplanting" rather than a supplementing of the regular program. In one sense, it is impossible to avoid "supplanting" of the regular basic educational program unless the project is offered after school, in the summer, or to pre-school children.

The "pull-out" model leads to educational problems even though it does insure that Title I program and projects follow the intent of the law. New York State has examined alternative options to deal with these problems, but the alternatives seem to run in conflict with the current statute. We are concerned with the educational impact of the present approach and believe that the legislation drives project implementation toward unintended and less effective consequences. 2. Local Designs of the ESEA, Title I, Project

The current ESEA, Title I, legislation provides flexibility in regard to who in a local district develops a project proposal. The law does indicate that the various levels of advisory councils be involved in the process, but is not explicit regarding the differential roles of the various levels of councils.

Indications exist that articulation of Title I projects with local programs might be improved if building principals and building Parent Advisory Councils provided greater input to the district proposal which is approved by the school board. Provision for greater contributions from principals in the design of their respective building projects could better integrate a given project with the respective school instructional program and more effectively accommodate differences in the principal's operating style, needs for instructional materials, and type of staff needs.

3. Selection of Title I Students

The present legislation requires that "objective" criteria be used in selecting those students with the greatest need for projects. To meet the intent of the law and to protect against audit "exceptions" all New York State districts use standardized tests for selecting project participants. They also select only those students who are below the national norm for that grade.

The use of these ground rules has resulted in the following consequences:

a.

Since there is a problem of availability of standardized tests for use

in kindergarten and first grade, districts have generally been reluctant to serve students in those grades because there is no "objective" method of selecting student s most in need. Some school personnel believe this is not sensible on the grounds that teachers can determine which students are most in need. They also believe that starting programs in the earliest grades is most important because

a sound start is better than remediation.

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b.

Local school personnel also express concern with the criteria of

"below norm" because of the imprecision of the tests used. Guessing

by an individual student on the test can result in that student being excluded from a program when teachers know that the individual has a different level of need.

4. Desegregation

In those instances of voluntary, mandatory or court-ordered desegregation of school districts, selected Title I regulations have a "chilling effect" on achieving an agreeable plan. Regulations on target areas, target schools, attendance areas and residence of children have a deleterious influence on "follow the

child" concepts. They tend to deny services for the child and restrict planning options to effect desegregation. Of current practices proposed to solve the dilemma of desegregation, only the "campus plan" is immune from problems caused by Federal Title I regulations. Myriad other plans and combinations, including magnet schools, open and optional enrollment, paired schools, busing, and others, are wrought with problems caused by Title I legislation.

All Title I regulations affecting the delivery of services to Title I children eligible for services the year prior to the implementation of an approved desegregation plan should be waived for a period of three consecutive years. 5. Operational Recommendations

a.

b.

Considering the range of difficulties accompanying the prevailing
"pull-out model," the statute should provide flexibility to the States
and local education agencies to assure Title I resources are used to
supplement state and local funds in services integral to and least
disruptive of the regular school program.

The statute should allow the States responsibility for determining
whether the building principal and Parent Advisory Council should
have a specified expanded role in project design.

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C.

In the light of continuing difficulties in selecting those children, especially in kindergarten and first grade, who would benefit most from program participation, provision should be made for greater flexibility on the part of local school personnel in identifying and selecting participants.

d. Considering the impact of unintended consequences accompanying the implementation of the "pull-out" model, consideration should be given to allowing Title I funds to be used to support the entire school building instructional program under an appropriate plan when the number of potential participants in categorical programs in that building exceeds the percentage of such children for the state and

e.

for other buildings in the district.

Provisions should be included in Title I to allow, in mandated desegregation situations, Title I services to "follow the child" for at least one year. Thereafter, the non- Title I school involved should be eligible for ESAA funds for a determined period of time. There should be some coordination between Title I and ESAA in

this regard (See III. Emergency School Assistance Act).

C. Evaluation of ESEA, Title I, Effectiveness

Another important group of Title I issues focuses on evaluation. These issues include the criteria for success, representativeness of samples, appropriateness of tests, methodological problems with analysis and interpretation of test results, and definition of the Federal role in evaluation. The net result

of evaluation difficulties is the lack of a clear consensus regarding effectiveness

of Title I.

Current evaluation requirements regarding testing can hinder program

effectiveness.

Mandatory pre- and post-testing locks students into a full year program and precludes assistance to students who need short-term help. Few appropriate tests exist for bilingual students, and math tests dependent upon certain reading skills are inappropriate measures of math achievement. There is a need for longitudinal studies and for follow-up, since annual evaluation alone cannot determine effectiveness without considering long-term growth. In

addition, more appropriate tests are required.

Public Law 93-380, which amended ESEA to require the U.S. Office of Education evaluation models for Title I, was, in part, a response to lack of compliance at the state and local levels and to legislative and regulatory ambiguities. With the completion of the first decade of ESEA, a more effective Federal/state/local partnership has been established for accomplishing national goals. Clarification in legislation and in operating rules set forth by USOE have produced a higher degree of under standing of goals of ESEA. Although further