Mrs. REIBMAN. Thank you. My testimony is based on a policy statement on compensatory education and specifically on Title I of the Elementary and Secondary Education Act adopted at the ECS annual meeting in June of this year. The ECS policy statement was developed in cooperation with the National Governors Association, the National Conference of State Legislatures, the National Association of State Boards of Education, and the Chief State School Officers.

The National Governors Association has requested that I indicate its full support for this testimony, and I request, therefore, that the National Governors Association policy statement on Title I be a part of the record of this hearing.

Mr. QUIE. Without objection, it is so ordered.

Mrs. REIBMAN. Thank you. Because the focus of ECS is on State policy and the effect of Federal programs on it, my testimony focuses on the need for modifications in Title I which will facilitate better use of Federal and State money to meet the needs of disadvantaged students. My statement focuses on four interrelated problems which I believe should be addressed in the reauthorization of Title I: Number one, the need for additional Federal funding for Title I; two, the special problems of school districts and school buildings with high concentration of disadvantaged children; three, the need to eliminate barriers in Federal law to development of State compensatory education programs and to State level interrelation of Federal and State compensatory education programs; four, the application of Federal funds at a district and school level to provide compensatory education for children excluded from present programs.

I will touch briefly on each of these with a particular emphasis on the second point, that is, the special problems of school districts and school buildings with high concentrations of disadvantaged children.

Funding concerns about appropriation levels should, I understand, be addressed to the Budget and Appropriations Committees, but since several of the problems we address result from adjustments necessary because of inadequate funding, I feel that it is important to emphasize the issue before this subcommittee as well. Let me say that ECS' position, and my own personal position, is that compensatory education services should be provided to every child in need of such help. So long as we tolerate inadequate educational services for any child, we are cheating not only that child, but the future economic and social well being of the Nation as a whole. Accordingly, we are disturbed that large numbers of needy children are excluded from Title I because of inadequate funding. The answer, we believe, lies first in substantially increased funding for Title I, and, second, in a series of changes in Title I to make more efficient use of not only Federal funds but also State funds aimed at meeting the needs for compensatory education.

Children in schools with high concentrations of disadvantaged children: The declaration of policy in section 101 of Title I makes profoundly good sense, but, because of the inadequate funding and the current means of distributing funds and determining program ligibility, the policy is not well served by the present Title I

program. In my prepared statement I illustrate how a large number of children in need of compensatory education are excluded from Title I because of the anomalies of the current system of allocating funds to local education agencies and within the LEA's to schools with high concentration of economically disadvantaged children. To illustrate, the Title I program has a basic internal conflict. It speaks of concentrating funds in districts with high concentrations of disadvantaged children while providing money to 85 percent of the school districts in the country.

Title I reaches 68 percent of all elementary schools. To accommodate the shortfall in appropriations under the ratable reduction provision of Title I, the U.S. Office of Education has prescribed by regulation a process which dictates how LEA should allocate funds to schools under their jurisdiction. Essentially that process requires an LEA to determine the districtwide percentage of economically disadvantaged children. Any school which has a higher incidence of economically disadvantaged students is eligible for Title I funds.

The LEA may commit Title I funds to all such schools, but must do so in descending order of concentrations. Within a school district this is a quite rational means of concentrating Title I money. Within a State, it is not consonant with the expressed objective of the legislation for the simple reason that the incidence of lowincome students varies enormously among LEA's in any given State, and, as a result, there are wide variations in target school levels among districts.

We have not been able to develop comprehensive data for the country on this point, but we do have information from several States which is instructive. The process is most clearly illustrated by a State which has a county unit school system, such as Maryland and Florida, and attached to my prepared statement are tables which indicate the target school levels determined in accordance with Federal regulation for all districts in these two States and for selected districts of Texas, and my home State of Pennsylvania. These tables indicate the districtwide average of low-income students, the schools which are eligible for Title I and the schools with Title I programs in place.

Examination of this data indicates that in Maryland, for example, a school with 4.4 percent of its pupils in its area defined as low income, may be defined as a target school to be eligible for Title I funding, while a school in Baltimore City would have to have a 30percent concentration of low-income children in its area to be a Title I target school.

In the Commonwealth of Pennsylvania, the districtwide averages range from a low of 4 percent to a high of 40 percent. The statewide average concentration is approximately 15 percent, but the vast majority of the LEA's, with the notable exception of the large cities, have districtwide averages considerably below 15 percent.

Essentially, a poor child in a relatively affluent district has a better chance of being in a target school and of getting services funded under Title I than does a similar child in the district with the high percentage of disadvantaged students.

The ECS policy position is that the most direct solution to this problem would be to allocate Title I funds by State rather than by

districts, using the current system of defining economically disadvantaged students and to authorize States to allocate funds to high concentration schools utilizing a uniformly applicable system based on indicators of either education or economic deprivation. Funds would be allocated to schools with the highest concentrations of disadvantaged students determined on a statewide basis. In the absence of substantially increased funding, adoption of the ECS position with respect to the basic Title I program would undoubtedly redistribute funds from schools and districts with low concentrations of disadvantaged children to schools with higher concentration, primarily isolated rural schools and urban schools.

Another option not in the ECS policy statement, which would be less disruptive than a major change in the basic Title I program, would be to establish a new supplemented program aimed specifically at the areas of the Nation with large numbers of disadvantaged children. Under this approach all appropriations for Title I in excess of the fiscal year 1978 appropriations, perhaps adjusting them for inflation, could be allocated to States on the basis of economic criteria and within the States on the basis of the concentration of disadvantaged children.

Participation of a State in such a program could be contingent upon approval by the U.S. Commissioner of Education or a State plan setting forth a uniformly applicable formula for allocation of supplemental funds to districts with higher concentrations of disadvantaged children.

A major ingredient of such State plans could be a statewide strategy appropriate to each State's unique circumstances for addressing the problem of high concentration districts and school buildings.

With regard to State compensatory education programs, we believe that Title I should be amended to encourage the development of State programs designed to serve disadvantaged children not served by Title I. Since Superintendent Riles did testify to this effect, I will omit that.

In my statement we also recommend that Title I be amended to permit the development of joint Federal-State programs for compensatory education.

Finally, we make three specific recommendations for changes designed to make more effective use of Title I funds at a local level. First, we recommend that the LEA's be authorized to serve children in need of compensatory education in nontarget schools provided the concentration of disadvantaged children in such schools is above the statewide average and that the highest concentration schools are served first.

Second, to counter the negative impact of pull-out programs in schools with high concentrations of disadvantaged children, we recommend that high concentration schools be permitted to use Title I funds for developing this program for the school building as a whole, provided assurances are given that the children with the greatest needs are given the highest priority for services, and, lastly, we recommend that Title I funds follow the child to nontarget schools in desegregated districts, provided the concentration of disadvantaged children in the nontarget school exceeds the statewide average.

I have tried to define several distinct problems created by the current law and regulation which, if corrected, could lead, I believe, to more effective use of both Federal and State funds to support compensatory programs. The alchemy which can convert dollars to learning exceeds our ability as legislators to construct such a process by statutes and regulations. What we can do, though, is to make such money as is available and apply it in schools where the problems are the greatest and the opportunities for students most limited. We can remove barriers to innovative practices and try to encourage administrators and teachers to do the job.

We continue to pay a painfully high price in this country for the failure of students to master basic information and skills necessary to survive and contribute in our society and economy. There are no magic answers, but we at the State level stand ready to work with you in trying to find ways to do better.

Thank you.

Chairman PERKINS. Let me compliment you on your testimony. I personally feel we have had some excellent testimony here this morning.

In view of the fact we have an 11 o'clock committee meeting, I will limit my questions. I would like to ask each of you a few questions, and I am going to start out with Mr. Shanker. I certainly applaud you, Mr. Shanker, and the other members of the panel, for urging us to avoid problems in connection with the formula and instead focus on ways to improve the education programs being offered in Title I.

I am likewise interested in your proposal for an add-on grant to school districts with high concentrations of poor children to be used for basic skills.

Could you suggest some ways of defining this concentration? I would like to hear you elaborate on that, to some degree. Mr. Shanker?

Mr. SHANKER. This is more of an idea rather than a program that has been specifically worked out. I think we would go about it by looking at the concentrations that are now served in terms of Title I and try to find some cutoff with schools with concentrations that are much above the average within a State. We are looking at that now, and we will have a subsequent proposal for you.

As to the use of such funds, we have been very much impressed by a recent work of Benjamin Bloom at the University of Chicago, which indicates what the effects are on students who fall behind at the beginning and that falling behind becomes cumulative throughout a semester and a year and then as the years go on. We believe that if there were intervention rather early in these target areas, which would include rather frequent testing programs within the school to see whether students had developed certain skills and acquired the knowledge that they were supposed to, and for those who had not, to develop tutorial programs which would involve teachers and paraprofessionals and also include some training of parents as to how to help their own children at home in these basic skills.

Beyond these general ideas we have not gone, but we hope we will have something more specific that we will submit to you soon.

Chairman PERKINS. I certainly want to thank you, Mr. Shanker, for those suggestions. You think you can get the information and submit it for the benefit of the committee within the next 2 or 3 months?

Mr. SHANKER. Yes.

Chairman PERKINS. We want to get on this bill as early as possible next year. We are going to hold many hearings in Washington, and some field hearings. I don't know yet where we will go. We may even come to your State, but we are going to hold some field hearings and try to write the best possible legislation with only one thought in mind, namely, to benefit the children that need it most. Now, Dr. Riles, I gather that you feel the States and local school districts need more flexibility in the Title I administration. If we should provide more flexibility, what features and restraints contained in the present program would you do away with?

Dr. RILES. Mr. Chairman, first, I want to say that the benefits of Title I and the aims of the program and the concepts I totally agree with, that is, to meet the needs of these disadvantaged youngsters, get them off to a good start, so they will achieve-I am totally committed to that.

The frustration that I experienced-and, as you know, I happen to have started out with Title I in our State as director of that program-has been one that our legislature and other lawmakers in the State bought the concept and then tried to make a commitment, and we find certain kinds of restrictions in Title I, which apparently assumed that the Federal Government was going to do it all. Now we find ourselves hamstrung because we are trying to do the same thing the Federal Government is trying to do.

What I would like to see happen is that once a student who needs Title I help is identified, that both State and Federal efforts can be used together to meet that need. I am not talking about general funding that goes to all youngsters, but we find it almost impossible to apply the educational disadvantaged funds to meet more students because of Federal regulations that just prohibit us from working together on it. That would be something that I would like to see flexibility given to.

Chairman PERKINS. I know that your State, like my State of Kentucky, has had some problems with the Federal auditors in connection with Title I programs. What is your view of the audit procedure, and what has been your experience as to how it works, both from a fiscal and programmatic standpoint?

Dr. RILES. We have had very wide experience. I don't know whether it is because the auditors really are coming to try to find out something, or whether they just want to visit California, but in my case

Chairman PERKINS. More than likely the latter.

Dr. RILES. but we have one a week from someplace.

The problem with the audits is that it seems to me that the auditors don't talk to the program people. I would like to see, and this is a process, that someone audit the programs in accordance to what are the aims and goals of the legislature and the extent to which it is met. I think the fiscal people ought to come to determine whether or not money is going and being spent in the way that the Congress intended.