Agencies are required to prepare source documents in a standardized format (primarily local projects).

Statutes

It is difficult to discuss the regulations without reference to their relation to the existing and proposed statutes.

If the Quie Bill is still under consideration, the task force would like to go on record as being opposed to it because it would appreciably reduce the educational opportunities for the settled-out migrant children.

The Lehman Bill is considered as a favorable bill because it would encompass some of the migrant preschool children and provide the funding to more adequately serve the children presently being served.

Since the issue of eligibility is a great factor in who is served and by whom they are served, it is very, very necessary that the U.S. Office of Education Title I migrant branch must specify criteria for each of the three types of movement permitted by this statute and must issue such fegulations within 120 days of enactment of this law.

In order to address problems of migrant children who drop out of school, it is recommended that:

1. USOE develop national objectives to:

a) Decrease the high dropout rate.

b) Significantly increase the percentage of migrant high

school graduates.

2. USOE assume a leadership role in these areas and mount a national

thrust to achieve these objectives.

3. State applications be required to list objectives designed to
decrease dropouts and to describe services to be provided to
meet these objectives.

4.

The proposed interim regulations be expanded to include emphasis
on the need for objectives and services designed to meet the
needs of children 14 and above.

5. USOE explore the possibility of developing a legislative change
that would compensate migrant families on a needs basis for the
loss of family income from children ages 14 and above attending
school in lieu of working in the fields.

Interstate Coordination

The ECS task force further recommends that the U.S. Office of Education encourage and facilitate the following:

1. Migrant programs must look at other sources of support, including financial, training and technical assistance, and personnel support.

2.

The U.S. Office of Education should develop and promote procedures for interstate reciprocity for any person needing licensing or certification in their profession that is part of comprehensive services for the migrant worker and their families.

If the above items are not already in the legislation, they should be put in. Further recommendations in this area are that:

1. USOE establish a leadership role in the area of interstate program

coordination.

2. State applications for migrant program funds be disapproved until the application provides concrete evidence of plans for interstate program coordination over and above participation in the Migrant Student Record Transfer System.

3.

The proposed interim regulations be expanded to place more emphasis on the need for the planning and development of state migrant programs on a coordinated interstate basis.

4.

The proposed interim regulations include a requirement that

each sending state provide each receiving state with a copy of its annual state needs assessment as a part of interstate coordination.

Adjustment of Appropriations and Ratable Reduction

The task force wants to reaffirm the fact that we want the appropriation taken off the top and to remain at 100 percent for all three categories: interstate, intrastate and settled-out. This would override the present move toward

ratably reducing the settled-out migrant.

Based on the review of the enabling legislation, the legislative issues seem

to be:

1.

Duplication of effort among federal programs serving migrants.

2.

Lack of program coordination.

3.

Lack of any means of communicating between federal agencies, states and agencies within states.

4.

Lack of clear direction for the full range of possible students;

i.e., early childhood, public school age and postsecondary.

Other Administrative Considerations

"The whole Title I migrant program of 10 years is run strictly on directives and memos" is an observation made by one of the state migrant directors. Following is a list of general comments, some not applicable necessarily for comments regarding the regulations, but may be applicable elsewhere:

1. The national migrant education goals and objectives need to be

revised.

2. There needs to be emphasis for SEA's within migrant streams to
work together in the development of the unified, coordinated
application possibly to adopt a unified approach through several
states in a given geographic area.

98-491 - 78-7

3.

The program needs the support and increased involvement of the chief state school officers.

4.

There needs to be a national policy and definition regarding migrant education conferences in terms of personnel who may attend and their specific functions.

5.

The 505 Management Guide needs increased USOE emphasis in order to improve program administration by utilizing this management

tool.

6. The MSRTS committee needs to be officially established and the structure changed.

7.

The day care regulation creates problems. An example is that it is okay to serve a preschool child in a day care center if it enables his sibling to attend school. However, there is no definition for approval for preschool children without siblings in school. These children need care also, as well as their parents need to be worry free to work in the fields.

8.

Supposedly in the regulations, the director of the State Education Agency is authorized to make a decision and judgment relative to the determination of a guardian. That is very difficult to do for SEA's and, therefore, they need more direction or guidance.

9.

There is a conflict in the General Education Provision Act and the regulations regarding retention of records. GEPA, it is believed,