children above the number for whom services had been planned originally or enrollment in a non-project school. It is therefore recommended that full-funding of the migrant program be continued so that migrant children can benefit from the services which it is able to provide.

MSRTS AS A BASIS FOR PROGRAM CONTINUITY AND PROGRAM FUNDING

The potential of the Migrant Student Record Transfer System as an instrument for supporting continuity of educational programs for migratory children should be cultivated and used to the optimum. Program reporting should be developed which will make it easier for classroom teachers and migrant project personnel to build upon past experiences and achievement of the migrant child. Data collected by the System should also be continued as the basis for program funding.

SUPPORT OF FORMERLY MIGRATORY AMENDMENT

The North Carolina Migrant Program takes a strong stand for including formerly migratory children in the migrant education program. Status reports in reading and mathematics achievement have been included in North Carolina's annual evaluation report for several years. These results are based upon standardized test scores obtained from the migrant education projects in the State. Comparing achievement in reading and mathematics with national and state norms and with the scores derived from the regular Title I compensatory education program shows that the migrant child is the most educationally deprived child in the testing sample. Further analysis of test scores point out that the scores used in the status reports are those of students in the regular school term projects which have a high precentage of formerly migratory children enrolled as compared to the number of currently migratory children.

The test scores point out the increasing deficit which this migrant population faces as it continues in school. Our experience shows that it takes a number of years to erase the deficiencies which are brought about by constantly moving from one school to another. It is therefore recommended that the provisions for including formerly migratory students in the supplementary educational programs for migrant children be continued in order to help them eliminate the deficiencies which have occurred because of their previous migratory life style.

DETERMINATION OF SEA ADMINISTRATIVE COSTS

Under the Elementary and Secondary Education Act a State Educational Agency is allowed 1% of the allocation to cover administrative costs. This allocation is not adequate to carry out the administrative requirements mandated in the migrant education regulations.

In the Migrant Education Program the SEA has responsibilities parallel to those of an LEA in addition to those normally carried out at the State level. Additional requirements of the program relating to (1) records, (2) reporting, (3) interagency coordination, (4) interstate cooperation and (5) program continuity tend to increase the amount of funds required for administering the program.

It is therefore recommended that the administrative costs of the program be budgeted in the State plan submitted to the U. S. Office of Education, that the U. S. Office of Education review State application and determine the amount of funds allowable for program administration, and that the approved Application for Program Grant be used as the basis for expending program funds for the administration of the program in each state as indicated in 116d.10.

DELETION OF SEMI-ANNUAL PERFORMANCE AND FINANCIAL REPORTS

Regulation 116d.6(c) and section 100b.432 of the General Education Provisions Act requires the SEA to prepare and submit semi-annual performance and financial reports. These reports serve little purpose in the program and are ineffective in program administration. They require administrative staff time to prepare which could be used more effectively in other areas of administrative responsibilities.

It is the strong belief of the North Carolina Migrant Program that the annual monitoring visit by the U. S. Office of Education, an annual performance and financial report and the annual evaluation report submitted by the State Educational Agency should satisfy all the requirements necessary for effective program operations and administration.

DELETION OF THE REQUIREMENTS TO SUBMIT COPIES OF APPROVED PROJECT AMENDMENTS

The State Educational Agency is required to submit to the U. S. Office of Education copies of all local project applications and local project amendments which have been approved by the SEA (116d.6). It is the position of this office that submitting copies of approved project applications and project amendments is a duplication of effort and an infrigment upon the responsibility of the SEA.

The State Educational Agency is awarded a grant to establish and administer, either direct or indirectly, educational programs and projects for migratory children of migratory agricultural workers and migratory fishermen and to coordinate these programs and projects with similar programs and projects in other states. Where the program is administered indirectly through a local educational agency it is the responsibility of the State Educational Agency to review and approve project activities to be carried out at the local level and to ascertain that such projects and activities are compatible with the state plan as approved by the

U. S. Office of Education. In light of this, it seems to be a duplication of effort to submit to the U. S. Office of Education a project application or a project amendment which has already been approved by the agency which is responsible for administration of the program, including the approval of project application.

The requirements to submit copies of approved project applications to the U. S. Office of Education causes extra expenditures of program funds and personnel time to prepare and transmit them while at the same time producing a volume of paperwork which is of questionable value, which U.S. Office of Education is in no position to give a meaningful review, and which they have no authority to approve, modify or disapprove. It is therefore recommended that the requirement to send copies of approved local project applications and amendments to the U. S. Office of Education be discontinued.

Mr. FORD. Thank you very much.

This is Mr. Winford M. Miller, Director of the Migrant Student Record Transfer System. If there is anybody in the country who doesn't know who this is, I would be very much surprised; everybody knows who Joe Miller is.

STATEMENT OF WINFORD M. MILLER, DIRECTOR, MIGRANT STUDENT RECORD TRANSFER SYSTEM, MSRTS

Mr. MILLER. Mr. Chairman and members of the committee, and guests at the hearing, I am most appreciative and most happy to come before you and be a voice for the migrants of this nation, as I have before. I am most appreciative to speak to you about the migrant school record transfer system, since I believe it to be the most innovative and functional vehicle for the development of continuity in migrant education and other areas of education.

I would ask you to please include my entire text in the record, sir. It has already been mentioned what we work under as a definition of a "migrant child", that being a migrant child of a migratory agricultural worker or a migratory fisherman who has moved from one school district to another during the past year with parents or guardians who were seeking or acquiring employment in agriculture or fishing activities, including all related food processing activities. This I believe to be the case of all children who have been placed in the migrant student record transfer system.

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Why was there a need for MSRTS? As you very well know, back in the early days of the program we who were in migrant education at that time faced a gigantic problem and that was the rapidity with which many children of migratory farm workers moved at that time from school to school, in terms of being able to acquire their health or academic records from the school which they just left. Many people have recognized this to be a problem for many years.

We have recorded efforts to establish a transferral system back as early as 1940; however, not until the passage of 89-750 as an amendment to 89-10 in 1966 was there unified effort in this country to accumulate and distribute pertinent academic and health data on migratory children.

It became obvious that neither an individual State nor a region of States could, upon self-initiative, make and sustain an adequate system of transferring student data.

There is still a great problem to be resolved in this country. Many school districts that are not actually serving migrant children at the present time face the same problem. This we realized had to be a national effort, so in 1966 Congress demonstrated its recognition of the interstate nature of farm migrancy by mandating in Public Law 89-750, Section 103 (C) (1) (A), that there would be a transferral or transmittal of pertinent information with respect to school records of migratory children.

We moved expeditiously to fulfill your mandate, Mr. Chairman. Following a conference in Arizona in 1968, a committee called the Record Transfer Committee, was organized to develop a system and a document to be used in transferring data from school to school. At first we started on a manual basis. All work was done physically. However, it was soon discovered we were working in the same mode that had been the case in past years. It became evident that an automated system had to be implemented if we were going to fulfill and meet the needs of the children that we were serving. The MSRTS was the first massive interstate cooperative effort instituted with Public Law 89-750 funds.

More recently, Public Law 93-380 provided that migrant children of migratory agricultural and migratory fishermen should be deemed to continue to be a migrant child for a period not in excess of five years during which he resides in the area served by the agency carrying on the project.

This expansion provides some 15,000 schools and thousands of users of the system a cohesive structure within which they may cooperatively devise and implement programs of education and health care for some 520,105 migrant students as of September 21, 1977.

The system became a defined concept in 1968, a project in 1969, an operational instrument in 1970, and a national reality in 1971. As a concept, this system is unprecedented. As a working success it is unprecedented. It interacts with thousands of people as users of the system. It shapes and is shaped by that same environment. It assists administrators, counselors, aides, clerks, teachers, nurses and medical doctors in new dimensions of migrant education and hence it helps them uncover new informational needs to support the decision-making processes so necessary to those new dimensions.

These discoveries, in turn, require the system to be responsibly responsive to its users and to ensure that the newly emerging needs are met.

There are three basic components in MSRTS-the school, the teletypewriter and the computer. The school initiates all information that goes into students' academic and health records, and the