2.2.4 Extension of ESEA/Consolidation. The National School Boards Association urges the President and the Congress to reauthorize the Elementary and Secondary Education Act, and related programs, but with greater recognition for the appropriate role of each level of government. For the purposes of meeting community needs, encouraging efficient management, and reducing unnecessary federal and state bureaucracy, existing authorities should be deregulated and consolidated with the following conditions: A. B. C. D. and E. certainty that consolidation will not result in cuts establishment of one comprehensive local plan for the a funding distribution to local school districts on a due process rights for local school districts to appeal due process rights for students in accordance with state With respect to the specific programs to be consolidated, NSBA supports the notion that funds should not be drawn away from ESEA Title I in order to fund other local priorities. However, as set forth later on in our statement, we do believe that Title I should be substantially de-regulated. In the area of the education of the handicapped, recognizing that such legislation is not within the immediate jurisdiction of this subcommittee, we urge the merger of the various grant programs. Especially since 8504 of the Rehabilitation Act of 1973 mandates that school districts must provide all appropriate services, sub-earmarkings for those same purposes appears to be an unnecessary complication. Finally, we would urge the complete consolidation of various of the general instructional supply and curriculum line items--including those relating to textbooks, guidance and counseling, audio-visual equipment, nutrition and health, alcohol and drug abuse, environmental education, reading education and metric education. In terms of satisfying local needs within the range of federal priorities, consolidation in these areas makes particular sense. Further, the burdens of multiple applications to the state and federal level would be substantially eliminated. As members of the Committee know, S. 1780, the Domenici/Bellmon bill has received considerable informal discussion in the Senate as a The approach taken by S. 1780 is vehicle for program simplification. attractive on a number of fronts. First, the consolidation which it presents can fit within the realities of current funding levels. That is, it consolidates minor programs but provides a special local spending priority for the major programs: ESEA Title I, P.L. 94-142, and the Bilingual Education Act. It should be emphasized, however, that NSBA does not support local flexibility to redirect ESEA Title I funds into the other programs. Unfortunately, S. 1780 does contain one other serious flaw which does not permit our support for it--as drafted. Specifically, the bill encourages the growth of state bureaucracy to substitute for federal bureaucracy. More precisely, while S. 1780 reduces federal red tape, it provides state departments of education four funding sources for administration: a) existing levels for administration, b) a new line item equal to 1% of total program money, c) another new line item equal to 1% for comprehensive planning, and d) funds from the minor program consolidation title. Operationally, local school officials are concerned by the growth of state bureaucracy, and philosophically we are concerned that the federal government already funds one to two-thirds of most state department operations. However, if the problems of protecting ESEA Title I funding and of eliminating over-administration at the state level are resolved, S. 1780 would have broad appeal to local school officials. Mr. Chairman, at this stage we would like to turn to a discussion of a separate Department of Education. C. Cabinet Level Department of Education Rather than redevel Committee jurisdiction aside, the organization of the administering agency is vital to any discussion addressing the delivery of federal programs. As the members of the Committee know, NSBA has long supported a separate Cabinet level Department of Education. oping all of the arguments, there is one point that we wish to stress at this time. As departmental status has been debated within the Administration and by members of Congress, from time to time the option of a subcabinet department has been raised (such as a Department of Army within the Department of Defense). While that particular option would resolve many of the mechanical problems which school officials have in dealing with multiple agencies, it should be rejected on the larger question that education would not be elevated as a national or federal priority. On the other hand, a cabinet head who 1) has close access to the White House, 2) enjoys the highest stature within the Congress, and 3) has the attention of the mass media, can better represent the needs of education than either a Secretary with multiple responsibilities or an executive of sub-cabinet ranking. For example, the opportunities for school district participation in this and the previous Administrations' economic recovery programs, e.g., public works or general revenue sharing, would have improved with the strength of a Secretary of Education. As a final point on this issue, we recognize that President Carter is pledged to streamlining the federal bureaucracy. And, while a separate Department of Education may give the appearance of adding one more agency, we do not feel that that end is inconsistent with the President's goal. Indeed, the time is ripe to analyze the federal government's organizational priorities in terms of the change in national needs over the years. III. FEDERAL PAPERWORK Mr. Chairman, throughout our testimony today we have emphasized the frustration which school officials are experiencing with the burdens of Perhaps the growth of federal paperwork has been the over-regulation. most striking symbol of that frustration. The result of seemingly unmanageable increases in federal paperwork has affected school district operations in several ways. Small district superintendents find that they spend unjustifiable amounts of time (and federal funds) working with federal forms--at the expense of other responsibilities. While larger districts can hire grant specialists with their federal funds, the growth of central office staff is becoming a matter of local political concern--especially in the face of declining enrollments. But most importantly, time is being taken away from the educational duties of central office staff, school principals, and classroom teachers as they are becoming increasingly bogged down by the cumulative impact of comparability reports, forms 101 and 102, IEP's, etc. To help remedy unnecessary regulations, our organization was quite pleased when the O'Hara amendment was passed as a part of the 1974 amendments. That provision permits Congressional disapproval of proposed regulations. Likewise, we were pleased when the Biaggi amendment was passed as a part of the 1975 amendments. That particular provision requires federal officials to publish in the Federal Register proposed data collection forms and time estimates for the completion of such forms. Clearly, Congress and especially this committee understood our frustrations. Unfortunately, the bureaucracy managed to bypass the legislative purposes of both provisions. Only twice did members of the Committee attempt to challenge the bureaucracy's voluminous regulations. One such occasion, which arose with respect to the Impact Aid equalization regulations, finally resulted in no changes--regardless of documented Congressional intent to the contrary. Likewise, with respect to the Biaggi amendment, HEW officials do not feel bound to publish forms in the Federal Register; and compared to NSBA sponsored surveys, HEW's data collection estimates are greatly underestimated. To remedy the problem of paperwork we recommend legislative action 3. 4. when data collection formats are changed. Especially within the same year, do not change data col lection requirements. Eliminate data collection or reporting requirements which |