Qff~ce of Educatiori Department of Health, Education, and Welfare BY THE COMPTROLLEIi GENERAL OF THE UNITED STATES f ., COMPTROLLER GENERAL OF THE UNiTED STATES WASHINGTON DC 20543 B- 164031( 1) To the President of the Senate and the Speaker of the House of Representatives This 1s our report on the improved admmlstratlon needed in New Jersey for the Federal program of aid to educationally deprived children This program 1s autho- razed by title I of the Elementary and Secondary Education Act of 1965 (20 U S G 241a) and 1s admmlstered by the Of- fice of Education, Department of Health, Education, and Welfare Our review was made pursuant to the Budget and Ac- countmg Act, 1921 (31 U S C 531, and the Accounting and Auditing Act of 1950 (31 U.S C 67) Copxes of this report are being sent to the Dxrector, Office of Management and Budget, the Secretary of Health, Education, and Welfare, and the Commlssloner of Education Comptroller General of the United States 50TH ANNIVERSARY 1921- 1971 COM?TROLLERGENERAL'S IMPROVEDADMINISTRATION NEEDEDIN REPORTT@ THE CONGRUS NEW ' JERSEY FOR THE FEDERALPROGRAM OF AID TO EDUCATIONALLYDEPRIVED CHILDREN Dfflce of Education, Department of Health,, Education, and Welfare B-164031(1) DIGEST ------ f, WHYTHE REVIEW WASMADE t \ This 7s the third in a series of reports by the G&era1 Accounting Office (GAO) on the manner in which the Office of Education, Depart- ment of Health, Education, and Welfare (HEW), 1s adrq~nlste&ng~~ts responslbllltles under the principal Federal program of aid to ch>l;, dren deprived of normal educational development The program, authorized under title I of the Elementary and Secondary Education Act of 1965, -rnvolves Federal expenditures of about $1 bll- lion a year and requires a high degree of coordination by Federal, State, and local agencies This report covers a review of the opera- tion of the program in New Jersey, where about $23 mllllon ln Federal money has been received each year under the program GAO concentrated its local review work in Camden, one of four local educational agencies in the State recelvlng over $1 mllllon in program money In each of fiscal years 1966 through 1970 FINDINGS AND CONCLUSIONS Annual participation In the title I program in New Jersey lnvilved from 85,000 to 131,000 children who were enrolled in about 90 percent of the States's approximately 570 school dlstncts The State educa- tional agency reported that new methods for teaching the disadvantaged had been developed, the children's educational achievement had improved, and children had developed a feeling that their parents as well as school officials were genuinely interested in their needs. (Seep 9) Proqmm %n. Ca??l&n . GAO belleves that a substantial part of Camden's title I program has provided general aid to the public and private school systems there rather than aid to educattonally deprived children as prescribed in the act (See pa 17 > Tear Sheet APRIL 7‘1971 The title I program speclfles that funds be used for proJects deslgned for educationally deprived children--1n both public and private schools--resldlng in school attendance areas having high concentrations of children from low-income families GAO estimated that more than $240,000 had been spent ln areas not designated by the Camden educa- tlonal agency as having such concentrations. (See p 13 ) School attendance areas were chosen for the title I program ln Camden on the basis ef a local offlclal's general knowledge of economic de- privation in the ~1 ty Contrary to Office of Education requlrements, the basis for selectl'on was not documented (See p 14 ) The Camden educational agency designed and conducted some title I protects for private and public school children on the basis that Camden's sch,o@ system, ln general, lacked the facllltles, services, equlpmen>AFti materials supplied under the projects This 1s contrary to th>'$oquirement of the Office of Education that the proJects meet t$e $peaal educational needs of educationally deprived children (See pp 17, 19, 23,and 26.) Physlcal edueatlon equipment was provided for all public school children ln some grade levels, audio-visual equipment was distributed to all public schools, and textbooks were made available to all elementary schools, Use P* 20 ) state ~~~OVQS procedures Recognlzlng weaknesses in the State's admlnlstratlon of the program, the State educational agency in fiscal year 1970 took action to improve procedures for --approving appllcatlons from local educatlonal agencies for title I pr OJects , --revlewlng local educational agency operations, and --using proJect evaluation reports prepared by local educational agencies GAObelleves that those improved procedures should help ensure that title I proJects will meet the special needs of, and ~111 be concen- trated on, educationally deprived children (See pp 30, 33, 32, and 34 ) OR SUGGESTIOiUS RECOMMEflDA-TIOzIlS The Secretary of HEWshould review those Camden proJects that appear to be lnconslstent with the obJectives of the 1965 act and should effect recoveries of, or make adJustments in, title I funds where warranted. (See P 28 ) 2 The Secretary should emphasize to the New Jersey State educational agency --the need to ensure that local educatlonal agencies select and document proJect areas in accordance with program crltena and ;;;centrate program aid in properly designated areas (see p 16) I v --the importance of requiring local educational agencies to ldentlfy the special needs of educationally deprived children--In both pub- lic and private schools-- and to design proJects that have reasonable promise of meeting those needs (see p 28). The Secretary should emphasize to all State educational agencies that --title I funds are not avallable for general educatlonal needs of local school systems but are available only for speclflcally lden- tlfled needs of educationally deprived children in properly deslg- nated areas (see p 28) and --proJect applications must be adequately reviewed, systematic pro- cedures must be followed in revlewlng local educational agencies' actlvltles, and local educational agencies' evaluation reports must be used to improve program effectiveness (see p. 34). AGENCY ACTIONSANDUNRESOLVED ISSUES The Assistant Secretary, Comptroller, of HEW said that GAO's findIngs clearly identified weaknesses in title I admlnlstratlon at the State level and that GAO's questions concerning proJect operation and man- agement by the Camden educational agency were valid He said also that GAO's recommendations would be implemented promptly by the Office of Education (See PP. 16, 28, 34,and 49 ) MATTERS FORCONSIDERATION BY THE CONGRESS This report 1s furnished because of interest expressed by committees and members of the Congress in Federal efforts to improve elementary and secondary education generally and specifically through the title I program Tear Sheet 3 Contents Page DIGEST 1 CHAPTER 1 INTRODUCTION 4 Responslblllty for program admlnlstra- tlon 4 Program partlclpatlon 6 2 PROGRAMADMINISTRATION 9 3 PARTICIPATION AND SELECTION OF SCHOOLAT- TENDANCEAREAS 11 Importance of determlnatlon of partlcl- patrng school attendance areas 11 Program requirements 12 Program was not llmlted to school at- tendance areas designated to partlcl- pate in the program 13 Documentation supporting selectlon of school attendance areas not malntalned 14 Conclusions 15 Recommendation to the Secretary of Health, Education, and Welfare 16 4 SOMEPROJECTS WERENOT DESIGNED TO MEET THE SPECIAL NEEDS OF EDUCATIONALLY DEPRIVED CHILDREN 17 Program requirements 17 Need to Identify children possessing special educational needs 19 Title I funds used to obtain relocatable classrooms and staff for regular school program 23 Payment of architectural and engl- neerlng fee unallowable 25 Need to include private school offlclals in program planning 26 Conclusion 27 Recommendations to the Secretary of Health, Education, and Welfare 28 CHAPTER Page 5 ADMINISTRATION OF THE TITLE I PROGRAMBY THE NEW JERSEY STATE EDUCATIONAL AGENCY 30 Action taken to strengthen SEA's re- view of proJect applications 30 Need for SEA to monitor LEA activities on a periodic basis 31 Need for SEA to utilize LEA evaluation reports to improve program 32 Conclusion 34 Recommendation to the Secretary of Health, Education,and Welfare 34 6 AUDITS OF TITLE I ACTIVITIES IN NEW JERSEY 36 7 SCOPE OF REVIEW 39 APPENDIX I Description of projects discussed in the report 43 II Number of children participating in Camden LEA's title I proJects 47 III Title I program funds received by Camden LEA 48 IV Letter dated December 21, 1970, from the Assistant Secretary, Comptroller, Depart- ment of Health, Education, and Welfare, to the General Accounting Office 49 V GAO reports on reviews of Federal program of aid to educationally deprived children 54 VI Principal officials of the Department of Health, Education, and Welfare having re- sponsibility for the activities discussed in this report 55 ABBREVIATIONS GAO General Accounting Offrce HEW Department of Health, EducatLon,and Welfare LEA local educational agency SEA State educatlonal agency COMPTROLLER GENERAL'S Il"'PROVED ADMINISTRATION NEEDED IN REPORT TO THE'CONGRESS NEW JERSEY FOR THE FEDERAL PROGRAM OF AID TO EDUCATIONALLY DEPRIVED CHILDREN Offlce of Education, Department of Health, Education, and Welfare B-164031(1) DIGEST --_--- WHYTHEREVIEWWASMADE This 1s the third In a series of reports by the General Accounting Offlce (GAO) on the manner in which the Office of Education, Depart- ment of Health, Education, and Welfare (HEW), 1s administering its responslbllltles under the principal Federal program of aid to chll- dren deprived of normal educational development The program , authorized under title I of the Elementary and Secondary Education Act of 1965, involves Federal expenditures of about $1 bll- lion a year and requires a high degree of coordination by Federal, State, and local agencies This report covers a review of the opera- tion of the program in New Jersey, where about $23 million in Federal money has been received each year under the program GAO concentrated its local review work in Camden, one of four local educational agencies in the State recelvlng over $1 mllllon in program money In each of fiscal years 1966 through 1970 FINDINGSAND CONCLUSIONS Par-h czpatzon m progum Annual participation in the title I program in New Jersey involved from 85,000 to 131,000 children who were enrolled in about 90 percent of the States's approximately 570 school districts The State educa- tional agency reported that new methods for teaching the disadvantaged had been developed, the children's educational achievement had Improved, and children had developed a feeling that their parents as well as school offlclals were genuinely interested in their needs (See p 9 1 Program %YlCwil&n GAO believes that a substantial part of Camden's title I program has provided general aid to the public and private school systems there rather than aid to educationally deprived children as prescribed in the act (See P 17 ) 1 The title I program specifies that funds be used for proJects designed for educationally deprived children--in both public and private schools--resldlng in school attendance areas havxng high concentrations of children from low-income famllles GAO estimated that more than $240,000 had been spent in areas not deslgnate?Sby ;he,ia;lden educa- tional agency as having such concentrations ee School attendance areas were chosen for the t?tle I program In Camden on the basis of a local offlclal's general knowledge of economic de- privation In the city Contrary to Offlce of Education requirements, the basis for selection was not documented. (See p 14 ) The Camden educational agency deslgned and conducted some title I proJects for private and public school children on the basis that Camden's school system, In general, lacked the facllltles, services, equipment, or materials supplled under the proJects This 1s contrary to the requirement of the Offlce of Education that the proJects meet the special educational needs of educationally deprived children (See pp 17, 19, 23,and 26 > Physical education equipment was provided for all public school children ln some grade levels, audio-visual equipment was distributed to all pub1 lc schools, and textbooks were made available to all elementary schools (See P. 20 ) State mproves proeedwes Recognizing weaknesses In the State's admlnlstvat~on of the program, the State educational agency In fiscal year 1970 took actlon to Improve procedures for --approving appllcatlons from local educatlonal agencies for title I proJects, --revlewtng local educational agency operations, and --using proJect evaluation reports prepared by local educatlonal agencies GAO belleves that those improved procedures should help ensure that title I proJects will meet the special needs of, and ~311 be concen- trated on, educationally deprived children (See pp 30, 37, 32, and 34.) RECOl4MENDATIONS OR SUGGESTIONS The Secretary of HEW should review those Camden proJects that appear to be inconsistent with the obJectives of the 1965 act and should effect recoveries of, or make adJustments in, title I funds where warranted (See P 28 ) 2 The Secretary should emphasize to the New Jersey State educational agency --the need to ensure that local educational agencies select and document proJect areas in accordance with program criteria and concentrate program aid in properly designated areas (see p 16) and I , --the Importance of requiring local educational agencies to identify the special needs of educationally deprived children--In both pub- llc and private schools-- and to design proJects that have reasonable promise of meeting those needs (see p 28). The Secretary should emphasize to all State educational agencies that --title I funds are not available for general educational needs of local school systems but are available only for speclflcally lden- tlfled needs of educationally deprived children in properly deslg- nated areas (see p 28) and --proJect applications must be adequately reviewed, systematic pro- cedures must be followed in revlewlng local educational agencies' actlvltles, and local educational agencies' evaluation reports must be used to improve program effectiveness (see p 34). &ZENCY ACTIONS AND UNRESOLVED ISSUES The Assistant Secretary, Comptroller, of HEW said that GAO's findings clearly Identified weaknesses in title I admlnlstratlon at the State level and that GAO's questions concerning proJect operation and man- agement by the Camden educatIona agency were valid. He said also that GAO's recommendations would be implemented promptly by the Office of Education (See PP+ 16, 28, 34,and 49 ) MATTER5 FOR CONSIDERATIONBY THE CONGRESS This report 1s furnished because of Interest expressed by committees and members of the Congress in Federal efforts to improve elementary and secondary education generally and specifically through the title I program 3 CHAPTER 1 INTRODUCTION The General Accounting Office made a review of the man- ner in whrch the Office of Educatron, Department of Health, Education, andWelfare(HEW), was admlnlsterlng its responsi- bilities under the Federal program of assistance to educa- tionally deprived children in New Jersey This program is authorized by title I of the Elementary and Secondary Educa- tron Act of 1965 (20 U S.C.241a) The act represents the largest single commitment by the Federal Government for strengthening and improving educa- tional quality and opportunity In elementary and secondary schools across the Nation. Title I authorizes Federal fi- nancial assistance for educational programs designed to meet the special educational needs of educationally deprived children living in areas having hxghconcentratlonsof chil- dren from low-income families. Such areas are referred to by the Office of Education as proJect areas This program was funded at about $1 billion annually for fiscal years 1966 through 1970, The State of New Jersey received about $23 million annually under the title I program during these years. Our review was made at the New Jersey State educational agency (SEA) and at the Camden local educational agency (LEA). An LEA 1s an agency which has admlnlstratrve control and direction of free public education up to and rncludlng, but not beyond, grade 12 In a county, township, independent, or other school district The Camden LEA was one of four LEAS 1.n the State which received over $1 million of program funds in each of fiscal years 1966 through 1970. We did not make an overall evaluation of the administration and results of the title I program in the State RESPONSIBILITY FOR PROGRAMADMINISTRATION The Office of Education is responsible for the overall admlnlstratlon of the program at the national level; SEAS are responsible for admlnrstration of the program at the State level. LEAS are responsible for developing and imple- menting the special educational programs to be operated within their Jurisdictions. Thus, effective implementation of the title I program requires a high degree of Federal, State, and local coordinatron. As part of its responsibilities in administerIng the# program, the Office of Education develops regulations and guidelines relating to the administration of the program and determines the maximum amounts to be allocated to eligible LEAS, pursuant to a formula prescribed in the act. Any State desiring to participate in the program is re- quired by title I of the act to submit, through its SEA, an application to the Office of Education for review and ap- proval. The SEA is required to include, in the application, assurances that itwill administer the program and submit re- ports in accordance with the provrsions of the act and"the Office of Education title I program regulations. The SEAS' major responslbrlities are to (1) approve project applications submitted by LEAS, upon a determination that the proposed projects are designed to meet the special educational needs of educationally deprived children in school attendance areas having high concentrations of chil- dren from low-income families, (2) ensure that title I funds are used only for projects which have been approved by the SEAS, and (3) adopt fiscal control and fund accounting pro- cedures necessary to ensure proper disbursement of and ac- counting for Federal funds received from the Office of Ed- ucation and, In turn, paid to LEAS to finance the approved projects. Title I of the act authorizes payments to a State to defray its costs of admrnistering the title I program and providing technical assistance to the LEAS, These payments in any fiscal year may not exceed 1 percent of the total grants for LEAS of the State for that year or $150,000, whichever 1s the greater. Payments to the State of New Jer- sey for administering the title I program averaged $234,000 a year for fiscal years 1966 through 1970. The LEAS are responsible for developing and implement; lng projects under the title I program. These responsibil- ities include (1) determining school attendance areas eli- gible for participation, (2) identifying the educationally 5 deprived children in these areas, (3) determining the special needs of such children, (4) submitting applications to the SEA for grants, and (5) carrying out the proJects in accor- dance with the approved application and applicable rules and regulations. PROGRAMPARTICIPATION The following graphs, which are based on statistics compiled by the Office of Education and the New Jersey de- partment of education, show the number of children who par- ticipated in the title I program, nationwide and in New Jer- sey, from fiscal year 1966 through fiscal year 1969. Infor- mation as to the number of children who participated In, and the amount of funds received for, title I proJects in Camden is contained in appendixes II and III, respectively. 6 MILLIONS ( CHILDREN PARTlClPATlON) *NOTE THE FIGURES RELATING TO THE NUMBER OF PARTIC- IPATING CHILDREN IN FISCAL YEAR 1468 CANNOT BE COMBINED AND COMPARED WITH OTHER YEARS BECAUSE SOME CHILDREN PARTICIPATED IN BOTH THE REGULAR 90 AND THE SUMMER PROGRAMS FOR THE OTHER YEARS THECHILDRENWERECOUNTEDONLYONCE FORTHE REGULAR AND SUMMER PROGRAMS 8 6 19” I:-.“- - P%CIPATED D”RIN&$R - PARTICIPATED DURINGSUMMER m - PARTICIPATED DURING REGULAR SCHOOLYEAR 7 THOUSANDS (CHILDREN PARTICIPATION) 200 STATISTICS OBTAJNED FROM THE OFFICE OF EDUCATION FOR NEWJERSEY 180 160 140 40 20 0 I 11966 1967 8 CHAPTER 2 PROGRAMADMINISTRATION Statistics provided to the Offlce of Education by the New Jersey SEA showed that from 85,000 to 131,000 children had participated in the title I program during the first 4 years of the program's existence in that State. The SEA's records showed that, during the 4-year period, title I as- sistance was provided to over 90 percent of the more than 570 LEAS in the State. In evaluation reports submitted to the Office of Edu- cation on the activities under the title I program in New Jersey and on the effectiveness of the program in enhancing educational opportunity and helping the educationally de- prived children in the State, the SEA stated that teachers had developed a greater awareness of the characteristics of these children and had begun to inltlate new methodology in their teaching aimed at correcting the unique problems of these disadvantaged children The SEA reported that, through participation in the title I program, the children developed a feeling that their parents and school officials had a genuine interest in their needs. The SEA, in its fiscal year 1969 evaluation report, stated that the title I proJects in the State which were most effective in improving the children's educational achievement were (1) reading instruction proJects, such as those that diagnosed an individual's reading level and pre- scribed individualized materials or tutorial reading, (2) comprehensive services proJects, such as those for the rndr- vidual diagnosis of health problems and their correctlon and those for cultural enrichment, and (3) proJects which provided services and lnstructlonal activities to preschool and early elementary school children. The Camden LEA, in its fiscal year 1969 evaluation report, stated that, as a result of its title I activities there had been an increased awareness of the needs of diiadvan- taged children on the part of the school officials and the community and an increased willingness of the teaching staff to experiment with new curricula, new teaching techniques, 9 and new curriculum organization, which would be of specific benefit to the disadvantaged child. The LEA stated also that a corrective reading proJect had resulted In the cor- rection of reading deficiencies of more than 3,600 children. We did not make an overall evaluation of the adminis- tration and results of the title I program in New Jersey or Camden which would have enabled us to confirm the validity of the above-cited conclusions. We did note, however, a number of areas of admrnistratlon In which there were oppor- tunities for strengthening management controls at both the State and local levels. Cur findings and recommendatrons pertaining to these matters are discussed in the followrng chapters of this report. 10 CHAPTER3 PARTICIPATION AND SELECTION OF SCHOOLATTENDANCEAREAS - The Camden LEA conducted title I proJects in all Its school attendance areas, some of which had not been desig- nated by the LEA as having high concentrations of children from low-income families. We estimated that title I funds in excess of $240,000 were expended in these areas Although the LEA gathered data on low-income families in the city, the data did not relate to school attendance areas. The LEA's title I coordinator informed us that the selection of school attendance areas for participation In the title I program was based primarily on his general knowl- edge of economic deprivation in the city. The basis for the selection was not documented although documentation was re- quired by title I regulations. As a result, the SEA and other parties having an interest in the program were not in a posltlon to know whether title I funds provided to the LEA were being spent on those children the program was in- tended to serve. IMPORTANCEOF DETERMINATION OF PARTICIPATING SCHOOLATTENDANCEAREAS The Elementary and Secondary Education Act of 1965 pro- vides that title I funds be used for proJects which are de- signed to meet the special educational needs of educationally deprived children in school attendance areas having high concentrations of children from low-income families, on the basis that educational deprivation usually exists In such areas. The Senate Committee on Labor and Public Welfare and the House Committee on Education and Labor, in their respec- tive reports on the legislation which was later enacted as the Elementary and Secondary Education Act of 1965, stated that It had been apparent for some time that there was a close relationship between conditions of poverty and lack of 11 educational development and poor academic performance. The Committees reported that testimony received during delibera- tions on the legislation illustrated that the conditions of poverty or economic deprivation produced an environment which, in too many cases, precludes children's taking full advantage of the educational facilities provided, It was the Committees' belief that these children had been so conditioned by their home environment that they were not adaptable to ordinary educational programs, Flx1st- ing environmental conditions and inadequate educational pro- grams, rather than lack of basic mental aptitude, were cited as being principally responsible for the failure of these children to perform adequately in the school system. Title I regulations define an area of high concentra- tion of children from low-income families as being a school attendance area where such concentration is as high as, or is higher than, the average concentrationof such children for the school district as a whole. Such areas of high con- centration are considered as being the program's "proJect area." Since the beneficiaries of the title I program are to be the educationally deprived children who reside in areas having high concentrations of children from low-income fam- ilies, it is evident that determining which school atten- dance areas are to participate in each LEA's program is one of the more important aspects of the title I program, if the limited program funds available are to be utilized for assisting the children the program is intended to serve. PROGRAMREQUIREMENTS In keeping with the concept that a correlation exists between the educationally deprived and the economically disadvantaged, Office of Education guidelines, which supple- ment the title I regulations, state that a school attendance area will be eligible to participate in the program if it has a concentration of children from low-income families which is equal to or greater than the average concentration of such children for the LEA as a whole, 12 The guidelInes state also that a school attendance area will be eligible to participate either if the percentage of children from low-income families in the area is equal to the percentage for the entire LEA or If the number of chil- dren from low-income families in the area 1s equal to the I numerical average of such children in the LEA. Beginning with fiscal year 1969, the Office of Educa- tion amended the guidelines to place a ceiling on the total number of school attendance areas that would be accepted for partxipation in the title I program in each LEA ThlS ceiling was to be determined on the basis of the highest num- ber of areas that would qualify under one of, but not both, the prescribed bases --percentage of concentration or numeri- cal average. The guidelines place in each LEA the responsiblllty for obtaxning data for identlfyzng low-income families in school attendance areas within an LEA's Jurisdiction. The gulde- lines do not specify the source data to be used in ldentlfy- ing children from low-income famllles rn each school atten- dance area or In an LEA as a whole but, rather, provide considerable latitude to an LEA, in this respect. Among the source data considered acceptable by the Office of Education are records on payments of aid to families with dependent children under title IV of the Social Security Act and other welfare data,health statistics, and data from school surveys containing lnformatron on or related to family income. In addition to the general guIdelines above, specific instructions have been issued by the Office of Education in regard to the preparation of an LEA's proJect application. These instructions provrde that the sources of the data used for determining the number of children from low-income fami- lies in an LEA be stated in the application, and that such data be made a part of each LEA's official title I records, PROGRAMWAS NOT LIMITED TO SCHOOLATTENDANCEAREAS DESIGNATED TO PARTICIPATE IN THE PROGRAM The Camden LEA designated 21 of its 29 school attendance areas to participate in the program in fiscal year 1966, 20 of 28 in 1967 and 1968, and 19 of 28 In 1969, Instead of conducting title I proJects only in those areas desjgnated as 13 having high concentrations of children from low-income fam- ilies, however, the LEA conducted various title I project activities in all its school attendance areas during each of these years. We estimated that more than $240,000 of title I funds were expended for items and services--such as audio-visual equipment, corrective reading instructors and textbooks, physical education instructors and equipment, and instructional aides--' in areas that the LEA had not designated as having high concentrations of children from low-income families. LEA officials informed us that they had been advised by SEA officials that it was permissible for the LEA to spend up to 15 percent of its title I funds in school atten- dance areas that had not been designated to participate in the title I program. These officials, however, were unable to furnish us with supporting documentation. SEA officials informed us that they were unaware of any State or Federal directive which permitted an LEA to spend up to 15 percent of its title I funds in school attendance areas outside the project area. We were informed also that the SEA had not given the Camden LEA permission to conduct title I projects in school attendance areas not designated to participate In the title I program. DOCUMENTATIONSUPPORTING SELECTION OF SCHOOLATTENDANCEAREAS NOT MAINTAINED LEAS are responsible for selecting school attendance areas to participate in the title I program and are required to maintain documentation supporting their selections, as part of their official program records. Office of Education officials have informed us that the LEAS' records are to contain sufficient documentation to enable the SEAS to ascer- tain whether the LEAS proceeded correctly in their selec- tions. These officials stated also that, in the event any members of the communities questioned the selections of school attendance areas for participation, the LEAS' records could be used to show that the selections were not deter- mined arbitrarily but were determined objectively by apply- ing selection procedures establlshed by the Office of Educa- tion. 14 . We discussed the Camden LEA's selectlon of areas to participate with its title I coordinator who informed us that, in determining the pro-ject areas for fiscal years 1966 through 1970, he used 1960 census data, a 1965 community actron program application prepared by the Camden Councrl, on Economic Opportunity; statistics on aid to families with dependent children; and, for fiscal year 1966 only, an in- come survey made by the Office of Economic Opportunity in the north section of the City We noted, however, that the data did not relate to lndlvldual school attendance areas but to the city as a whole or to other geographical break- downs such as census tracts. He informed us further that he applied his knowledge of economic deprivation in the city to the above data to determine the percentage of concentration of children from low-income families In each school attendance area. These percentage-of-concentration figures were then used to select the school attendance areas to participate in the program We noted that eight of these areas, each of which the title I coordinator had determined to have a concentration of 25.6 percent in fiscal years 1967 and 1968, were shown in the LEA's fiscal year 1969 title I proJect application as having concentrations ranging from 26.7 to 36.4 percent and in the fiscal year 1970 proJect application as having concen- trations ranging from 35.1 to 50 7 percent The title I coordinator, however, informed us that, from the beginning of the program rn fiscal year 1966, no documentation had been maintained by the LEA to support the method used to determine the percentage concentratrons shown In the title I proJect applications, although such documentation was re- qurred by the Office of Education CONCLUSIONS In each of the first 4 years of the Camden LEA's title I program operations, title I funds were expended in school attendance areas that had not been designated to participate In the program because LEA offrclals believed that it was permlssrble to expend up to 15 percent of the LEA's title I funds outside of prolect area schools. In addltlon, the LEA did not document the basis for selection of school attendance areas to participate in the title I program. As a result, Office of Education and SEA offlclals responsible for pro- gram admlnlstratlon were not In a posltlon to know whether 15 title I funds provided to the Camden LEA were being spent on those children the title I program was intended to serve. RECOMMENDATIONTO THE SECRETARY OF HEALTH, EDUCATION, AND WELFARE We recommend that the Secretary emphasize to the New Jersey SEA the need to ensure that LEAs (1) select and doc- ument project areas in accordance with applicable program criteria and (2) concentrate program assistance to the full- est extent in those school attendance areas designated as having high concentrations of children from low-income fam- ilies. HEW's comments on our draft report were furnished by the Assistant Secretary, Comptroller, in a letter dated December 21, 1970. (See app. IV.> The Assistant Secretary stated that the Department con- curred in our recommendation and that the Office of Educa- tion, in a letter to the New Jersey commissioner of educa- tion, would urge that the SEA strengthen its procedures for project review and approval and for program monitoring so as to preclude further deviations from program regulations governing selection criteria and from the terms of approved proJect applications. 16 CHAPTER 4 SOMEPROJECTS WERE NOT DESIGNED TO MEET THE SPECIAL NEEDS OF EDUCATIONALLY DEPRIVED CHILDREN The LEA designed and conducted certarn trtle I proJects for both public school and private school children on the basrs that Camden's school system, In general, lacked the facllltles, services, equipment, or materials which would be supplied under the proJects rather than on the basis that the proJects would meet the special educational needs of educationally deprived children rn areas having high con- centrations of children from low-Income famllles. In addl- tron, the services, equipment, and materials provided under these projects were, In several Instances, made available to all public school children In certain grade levels (physical education), to all public schools (audio-visual equipment), and to all children In all public elementary schools (textbooks). It appeared that the operation of a substantial part of the LEA's title I program did not result in a special educational program for educationally deprived children but in a program of general aid to both the public and private school systems which, according to Office of Education of- ficials, was contrary to the obJectives of the title I pro- gram. These proJects are described brlefly In appendix I. PROGRAMREQUIREMENTS Title I regulations require that each project be de- signed for those educationally deprived children in the proJect area who have the greatest need for special educa- tional assistance and that the LEAS' appllcatlons describe the special educational needs of such children. The reg- ulatlons require also that proJects should not be designed merely to meet the needs of schools, the student body at large in a school, or students in a speclfled grade in a school. Office of Education guidelines point out that, prior to the lnltlatlon of a title I proJect, the main actrvltles 17 or services proposed for any project should be related to specific characteristics of the educationally deprived children to be served. The guidelines point out also that sufficient resources should be concentrated on these chil- dren to ensure that their special educational needs will be significantly reduced and that the help provided will not be fragmentary. The following statement is included in the Office of Education policy manual governing the conduct of title I projects. "Title I of the Elementary and Secondary Education Act of 1965 does not provide general aid to edu- cation. Instead, Congress has made it a unique program of categorical aid. Unlike other Acts, Title I does not seek to stimulate the develop- ment of selected areas of the regular school cur- riculum but rather to provide special programs for selected children. The spirit of Title I, then, is one of extending educational help and related services to the children who most need this help. The children who enter schools with socioeconomic, physical, and cultural handicaps more often than not have school records showing cumulative retardation and maladjustment. Gen- eral aid to education may leave the educatlon- ally handicapped child in the same or in a rel- atively more disadvantaged position." 18 NEED TO IDENTIFY CHILDREN POSSESSING SPECIAL EDUCATIONAL NEEDS Our review of the LEA's project applications approved by the SEA during fiscal years 1966 through 1969 indicated that certain of its title I projects were deslgned to meet the general educatlonal needs of Camden's school system rather than specific identified needs of educationally de- prived children residing wrthin the project area. We estl- mate that about $1.2 million of title I funds were expended on these projects during the first 4 years of the LEA's title I program. We asked the LEcl officials whether the LEA had identl- fled the specific children who possessed special educa- tional needs that could be met by the LEA's physical educa- tion, communicative instructional facilities, supplemental resource materials, fine arts, and instructional aides projects. The LEA's title I coordinator informed us that the LEA had not identified the specific children with edu- cational needs that could be met by these prolects. He ex- plained that the need for these progects was determined on the basis of his belief that all children in Camden's school system were educationally deprived because the school system --did not have multiethnic textbooks which were con- sidered to be of value to the system; --did not have a physical education program in its elementary schools; --had a shortage of audio-visual equipment which, re- search had shown, helped children learn; and --lacked supplemental resource materials which, in the opinion of most educators, enable children to learn better. He expressed the opinion that, because so much of the school district was economically disadvantaged, almost all school children in the project area had a need for the tl- tle I protects because they were all educationally deprived in some way. 19 As a result of the manner in which the LEA determined the need for its title I proJects, the services, equipment, and materials were, in several instances, made available to all public school children in certain grade levels, to all public schools, or to all children in all public elementary schools, contrary to the title I program polrcy of concen- trating a variety of special services on those educationally deprived children having the greatest need for such assis- tance These instances are briefly described below. --Under the specialized physical education proJect, equipment was purchased and distributed in the ini- tial year of the program and physical education spe- cialists were employed each year to conduct physical education classes for all children in fourth, fifth, and sixth grade classes in all public elementary schools and rn six of the nine private elementary schools. The LEA estimated that from 2,800 to 5,600 children participated in this proJect each year. --Under the fine arts proJect, cultural activities were conducted in the lnltlal year of the program in eight of the nine private elementary schools and in all but two public elementary schools. In subse- quent years, teachers in music or In arts and crafts were hired to conduct classes in these areas in six of the nine private elementary schools and In all but two public elementary schools. All children in fine arts classes in these schools were permitted to par- ticipate in the proJect. The LEA estimated that from 12,000 to 16,000 students partlclpated in this proJect each year. --Instructional aides (teacher aides) were provided to all public elementary schools and to five of the nine private elementary schools, on the basis of one per school. The aides performed duties, as assigned, for any teacher In the school to reduce the amount of time teachers had to spend on clerical or non- , instructional duties and to make it possible for teachers to give more individual attention to stu- dents. The LEA estimated that over 15,000 students benefited from the services of the teacher aides each year. 20 --Under the communicative instructional facilities project, the LEA, in the initial year of the project, distributed various types of audio-visual equipment to all public elementary and secondary schools in the district and to all private elementary schools' The audio-visual equipment included items, such as slide and movie projectors, copying machines, and television sets. This equipment has been available to all classes In the schools, without restriction. According to an LEA official, almost all children in the school district benefited from the use of the equipment. --The supplemental resources materials project was de- signed to purchase and distribute, in the initial year of the project, resource materials, such as en- cyclopedias, atlases, science kits, globes, language kits, dictionaries, and handbooks. These items were placed on portable carts so that they could be moved from room to room. The carts and the material were distributed to all public elementary and all private elementary schools, where they were available for the use of all children. These materials were uti- lized by about 17,000 students during the first year of the project, according to an LEA official We were unable, however, to obtain estimates for subse- quent years. --Part of the corrective reading project included the distribution of multiethnic and cobasal (used for both regular and corrective reading) textbooks in the initial year of the project to all public ele- mentary and all private elementary schools, where they were available for the use of all children. The number of textbooks purchased and distributed was about 70,000 Although the equipment, materials, and textbooks dls- cussed in the last three examples were distributed in the initial year of the title I program, they were retained by the schools and have been available for use without re- striction since that time 21 We drscussed the operation of these projects with the LEA's title I coordrnator, who informed us that he believed that, from an educational viewpoint, there was nothrng wrong with the operation of the projects because there was a need for these projects in the school district and that, without the projects, all the children would have been educationally deprived. We drscussed the design and operation of the projects with Office of Education officials, who stated that the projects apparently had been conducted on a "program short- age approach"-- a lack of certain activities in the LEA's regular program-- rather than for the special educational needs of educationally deprived children. The officials stated also that, because these projects were not designed to correct predetermined special educational needs of the educationally deprived children, the SEA should not have approved the proJect applications. (The manner in which the SEA administered the title I activities in New Jersey 1s discussed more fully in ch 5 > These officials stated further that the projects were conducted in a manner which constituted general aid to both the public and private school systems and which is prohibited under the title I program. We were subsequently informed by an LEA official that the lnstructlonal aides project was discontinued after the 1969 project year and that, beginning with fiscal year 1970, the fine arts project was to be conducted with the LEA's own funds rather than with title I funds. He in- formed us also that the specialized physical education project was being phased out of the title I program and would be conducted entirely with local funds beginning with fiscal year 1971. With regard to the supplemental resource materials project and the textbooks distributed under the corrective reading project, we were informed by an LEA official that the LEA consldered these projects to be completed upon dis- trrbutlon of the lnstructlonal materials. We were informed also that the communicative instructional facllitles proj- ect was being continued under title I but that title I funds were being used principally for the salary of the person hired to supervise the LEA's audio-visual program. 22 TITLE I FUNDS USED TO OBTAIN RELOCATABLECLASSROOMSAND STAFF FOR REGULAR SCHOOLPROGRAM The SEA approved a fiscal year 1966 title I project for the LEA to acquire 19 fully equipped relocatable classrooms (temporary buildings) and the related teachers and janito- rial personnel, even though the project applicatron con- tained no indication that the project was designed to meet special educational needs of educationally deprived children as provided under the title I program. Title I funds were used m each year to support a program of regular elementary school instruction in these facilities at a total estimated cost through fiscal year 1969 of approximately $1.2 million rncluding the acquisition cost of the facilities. The objectives of this project as stated in the applica- tion were as follows: 1. To eliminate half-day, 4-hour programs for 600 pu- pils and restore full-day instructional programs for these pupils. 2. To relieve overcrowded classes in selected disadvan- taged areas by reducing average class size. (In this regard, the application stated that it was a desir- able goal for elementary classrooms to have an aver- age class size of under 30 children.) According to LEA officials and school attendance rec- ords, 38 classes were placed on half-day sessions at the be- ginning of the initial year of the title I program. There were no classes on half-day sessions prior to that time. The LEA officials informed us that the classes were placed on half-day sessions so that a more orderly transfer of children could be accomplished by transferring 19 of these classes to the relocatable classrooms when the relocatable classrooms opened Thus it appears that the half-day ses- sions, which were to be eliminated by the utilization of the relocatable classrooms, were established in anticipation of the acquisition of such classrooms 23 LEA officials informed us that the children in the 19 classes transferred to the relocatable classrooms were being taught regular school curriculum subjects and were not being given specialized instruction either before or after the re- locatable classrooms became operational. The director of Federal assistance programs at the SEA informed us that the LEA's initial application for this proj- ect was approved because the responsible SEA official at that time believed that the project's objective of reducing class size met with the title I regulations and guidelines. The director also informed us that, although he did not be- lieve that the LEA should continue to use title I funds to pay for the salaries of teachers and the upkeep of the re- locatable classrooms, he believed that, if the SEA refused to allow title I funds to be used to continue the project, the LEA would not be able to asslrme the cost and would close the relocatable classrooms In his opinion, this would force the children attending classes in relocatable class- rooms to be placed back into the regular classrooms and would overcrowd these classrooms In discussing this project with Office of Education of- ficials, we were informed that the SEA should never have ap- proved this project because it was not in accordance with title I regulations These officials commented that: 1. The objectives, as stated in the application, did not indicate that any predetermined needs of educa- tionally deprived children were to be met. 2, It appeared that two of the objectives--to eliminate half-day programs and to restore full-day instruc- tional programs-- were actually aimed at solving a problem which had been created by the LEA in Septem- ber 1965, in anticipation of receiving title I funds later that school year 3 The statement in the application that "a desirable goal for elementary classrooms is to have an average class size of 30 children" is a very commendable goal for any school district However, it does not demonstrate a preidentified need of educationally de- prived children. 24 4 There was no indication that the LEA even tried to show how this project would meet any special educa- tional needs of educationally deprived children These officials stated also that providing classroom space had been and still was the responsibility of the LEA and not of the title I program, unless it could be demon- strated that additxonal classrooms would meet the special needs of educationally deprived children. Payment of architectural and engineering fee unallowable , The LEA initiated action to retain the services of an architectural and engineering firm as a consultant in obtain- ing the relocatable classrooms more than 2 months prior to the date of submission of the project application to the SEA. Our review showed that the pqmentsforsuch services were charged to the title I program. Although no contract or ob- ligating document could be located by the LEA for the ser- vices provrded by the firm, an LEA official informed us that an obligation in the amount of $15,000 was incurred when the LEA initiated action to retain the firm. Title I regulations state that title I funds distrib- uted to LEAs shall not be available for use for obligations incurred either prior to the effective date of SEA approval of a project or the date the application was received by the SEA in substantially approvable form Since the LEA oblr- gated funds for the architectural and engineering services more than 2 months prior to either of the above-stated dates, payment with title I funds was not allowable SEA officials informed us that, although the payment of the $15,000 fee was in direct conflict with the regulations, they planned no action to recover the funds because the ser- vices of the firm were apparently necessary to get the relo- catable classroom project started. Office of Education offi- cials, however, stated that payment of the architectural and engineering fee was not in accordance with the applicable regulations and should never have been approved by the SEA 25 NEED TO INCLUDE PRIVATE SCHOOL OFFICIALS IN PROGRAMPLANNING Title I of the Elementary and Secondary Education Act provides that, to the extent consistent with the number of educationally deprived children In the school district of the LEA that are enrolled in prrvate elementary and second- ary schools, an LEA must provide special educational ser- vices and arrangements, under its title I program, in which such children can participate. We noted that the LEA, in its planning and design of title I projects, did not consult with private school of- ficials even though private school children were to partic- lpate In the projects. Office of Education guldelxnes point out that, before developing projects, It would be ad- visable for the LEA to consult with private school offl- clals to determine the special needs of educationally de- prived children In prrvate schools so that such needs may be provided for In the project plan. Title I regulations issued subsequent to the guidelines require that the needs of educationally deprived children enrolled in private schools, the number of such children who will partlclpate in the title I program, and the types of specral educational services to be provided for them, shall be determined after consultation with persons knowledgeable of the needs of these private school children. We were informed by the LEA's title I coordinator that he interpreted the title I legislation to mean that the LEA was to develop proJects for public schools and offer them to the private schools, Therefore, without ever determln- ing the needs of educationally deprived children in the private schools, the LEA designed projects to satisfy the needs of the public schools and asked the private school officials If they wished to have their schools participate In these projects. A private school system official informed us that he received an allocation of services, equipment, and materi- als from the LEA for those projects in which he desired children enrolled in his school system to participate. This allocation was based on the percentage of children from low-income families attendlng the private school system, 26 In discussing with SEA officials the manner in which the LEA provided for the participation of private school children in the title I program, we were informed by the SEA director of Federal assistance programs that the SEA believed that private school officials should be involved in the planning of title I projects and the conduct of the title I program. He stated that the SEA believed, if it were necessary to design different projects to meet the needs of private school children, then such proJects should be designed. The SEA director stated further that, as a result of a recent SEA review of the Camden LEA, the SEA had informed the LEA that private school offlclals must be (1) Included in the assessment of the special needsofeducatronally de- prived children enrolled in private schools and (2) actively involved In the planning of proJects to be conducted in private schools, Implementation of these directives by the LEA should, in our opinion, result in better determinations of the spe- cial needs of educatronally deprived children enrolled in private schools and in the design of projects to better satisfy these needs. CONCLUSION Although large numbers of chrldren participated in the title I projects conducted in Camden, the LEA's actions in designing and operating certain projects on the basis that the school system in general lacked particular facllltres, services, equipment, and materials were contrary to the title I program obJective that projects should be designed and conducted for the benefit of those educationally de- prived children rn the project area who had the greatest need for educational assistance. 27 RECOMMENDATIONS TO THE SECRETARYOF HEALTH, EDUCATION, AND WELFARE In vrew of the Camden LEA's responsibility to provide classroom space, services, equipment, and materials for general classroom instruction from other than title I funds, we recommend that the Secretary review the facts relacrng to the seven title I proJects discussed in this chapter and, to the extent warranted, effect recoveries or make appropri- ate adjustments for the title I funds deemed to have been expended m a manner not consistent with the objectives or provisions of title 1 of the Elementary and Secondary Edu- cation Act. We recommend also that the Secretary emphasize to the New Jersey SEA the importance of requiring LEAS, prior to SEA approval of project applications, to Identify the spe- cial needs of educationally deprived children--including those m private schools --and design proJects which will have reasonable promise of meeting such needs. Since title I projects in other States may also have included features which constitute general aid to the local school system and which are contrary to the objectives of the title I program, we recommend further that the Secre- tary emphasize to all SEAS the nonavailablllty of title I funds to support projects designed to meet general educa- tional needs of the local school systems, because the funds are intended for specifically identified needs of educa- tionally deprived children residing in title I project areas. The Assistant Secretary stated that the Department con- curred m our recommendations. He stated also that, with respect to the particular proJects of the Camden LEA wherein there was evidence of the use of title I funds for general educational purposes, the Office of Education, in conjunc- tion with SEA officials, would conduct a thorough review of project expenditures, including the funds previously ex- pended for the costs of staffing and operating the 19 re- locatable classrooms, and would effect prompt recovery or adjustment of all amounts found to have been expended for 28 purposes or in a manner inconsistent with title I obgec- tives or regulations. Furthermore, the Office of Educa- tron would instruct the New Jersey SEA to effect recovery of $15,000 for payments of architectural fees obligated prior to the date of proJect submission as this sum was not an allowable charge to the title I program, The Assistant Secretary stated also that the Office of Education would emphasize, in a letter to the New Jersey commissioner of education, the clear need for adoption at both the LEA and SEA levels, of more effective measures to ensure identifications of the special needs of educationally deprived children in both public and nonpublic schools and to lunrt title 3 project design and approval to proJects offering reasonable promise of success in meeting those special needs. He stated further that the letter would pn- struct the New Jersey commissioner to ensure that all LEAS, including Camden, were made aware of the appropriate provl- sions of the regulations regarding the use of title I funds and to have steps taken to provide for an adequate before- the-fact assessment of the special needs of educationally deprived children attending private schools. The Assistant Secretary also stated that a general revision of the title I regulations was being drafted. The revision will give particular attention to strengthening and clarifying those regulatory sections dealing with the requirements that title I funds be used exclusively for proJect activities specifically designed to serve the clearly identified special needs of educationally disadvan- taged children in title I proJect areas. 29 CHAPTER5 ADMINISTRATION OF THE TITLE I PROGRAM BY THE NEW JERSEY STATE EDUCATION&L AGENCY The Office of Education requires SEAS to provide assur- ances, In their formal applications for participation in the title I program, that title I funds will be used for proJ- ects which are designed to meet the special educational needs of educationally deprived children in school atten- dance areas having high concentrations of children from low-income families. TheSEAsare required to provide assur- ances also that effective procedures for evaluating, at least annually, the effectiveness of the projects in meet- ing the special educational needs of educationally deprived children will be adopted by the States' LEAS and that these procedures will provide for appropriate objective measure- ments of educational achievement. We believe that, if the New Jersey SEA had conducted adequate reviews of the Camden LEA project applications, monitored project operations, and utilized the LEA evalua- tion reports to improve program effectiveness, many of the weaknesses in the LEA title I program discussed in earlier chapters of this report could have been avoided. ACTION TAKEN TO STRENGTHENSEA'S REVIEW OF PROJECT APPLICATIONS Information contained in the Camden LEA project applica- tions approved by the SEA indicated that certain projects were not designed in accordance with title I program require- ments and should have been questioned by the SEA before It approved the proJect applications. We discussed this matter with SEA officials who stated that the weaknesses in the SEA's project review process allowed such projects to be approved and that action was being taken to correct these weaknesses. The SEA director of Federal assistance programs stated that, prior to fiscal year 1970, project applications were reviewed by State employees who were assigned to the SEA during the summer, who were not adequately trained in pro-J- ect application review, and who were unfamiliar with title I 30 regulations and guidelines. He stated also that, as a re- sult, many projects which should have been questioned or disapproved probably had been approved and that he believed that inadequacies In project design similar to those we found to exist in the Camden program may have existed in 6 approved projects of other LEAS throughout the State. The SEA official advised us that the State's review of project applications in fiscal year 1970 was substantially improved over reviews performed in prior years. A program operation section composed of four persons specializzng in the administration of title I program activities in the State was established under the director of the office of federal assistance programs. Such specialization did not exist in prior years. Thrs sectlon was made responsible for the review and approval of project applications for all LEAS that are eligible for title I grants of $20,000 and over. The State employees who formerly were assigned to the SEA in the summer to review proJect applications are responsible for reviewing and recommending for approval only those proj- ect applications from LEAS that are eligible for title I grants under $20,000. In addition, these persons have been given formal training In title I application review proce- dures and in applicable regulations and guidelines. An Offlce of Education official informed us that, on the basis of a visit he made to the SEA in March 1970, he believed that the new project application review procedures had resulted in significant improvements in the SEA's ad- ministration of the title I program. NEED FOR SEA To MONITOR LEA ACTIVITIES ON A PERIODIC BASIS SEA officials informed us that, from the rnceptlon of the title I program in the State in fiscal year 1966 through fiscal year 1969, the SEA made no regularly scheduled moni- toring visits to the LEAS. They stated that during that period the SEA's monitoring activities were performed on a limited basis and that visits were made only when the SEA, through its own contact or through newspaper publicity, be- came aware of a trouble area at an LEA. 31 The SEA director of Federal assistance programs advised us that one of the reasons for the lack of monitoring vis>ts was the SEA's reliance on assurances given by the LEAS in their proJect applications. He also stated that the lack of adequate monitoring could be attributed to the frequent changes in the SEA's title I staff and to the lack of full- time professionals assigned to that staff. During our review, the Camden LEA requested that the SEA make a review of the LEA's entire school system. Prior to that time, SEA officials had not made any field visits to the LEA for the purpose of monitoring the title I program. As a result of its review, the SEA recommended that the LEA reassess its entire title I program to concentrate its pro-J- ects on educationally deprived children and on developing appropriate hard data to enable more obJective determination of low-income family concentrations. Because the SEA's recommendations were made after the completion of our fieldwork at the LEA, we were not able to evaluate the effect these recommendations had on the opera- tion of the LEA's title I program. The SEA director of Federal assistance programs advised us that he planned to initiate a program in fiscal year 1970 which would provide for an annual review of the proJect activities of the 25 LEAS in the State that were receiving the largest grants of title I funds. NEED FOR SEA TO UTILIZE LEA EVALUATION REPORTSTO IMPROVE PROCM ProJect evaluation reports prepared by the Camden LEA and submitted to the SEA as required by Office of Education guidelines were not utilized by the SEA to help bring about improvements in the operation of the title I program at the LEA. Although the evaluation reports are received several months after the next year's proJect applications have been approved, we believe that such reports could be used by the SEA as a basis for improving existing proJects or as an in- dicatlon that certain proJects are unsuccessful and should no longer be funded. 32 We noted also that the LEA's evaluation reports for certain years did not include an evaluation of each of the LEA projects and did not, in several instances, include in- formation as to the LEA evaluation procedures used or the manner in which educational achievement was measured. The title I regulations and guidelines require that effective procedures, including appropriate objective mea- surements of educational achievement, be adopted by LEAS for evaluating, at least annually, the effectiveness of the projects in meeting the special educational needs of educa- tionally deprived children. The regulations provide also that the SEA must assure itself that each LEA has adopted effective procedures for evaluating its title I program. The Office of Education guidelines point out that ap- propriate evaluation procedures must provide for measuring changes in a child's achievement or behavior over a period of time. The guidelines emphasize that the effectiveness of title I projects depends, to a considerable extent, on the feedback that comes from good evaluation and that the evaluation process, if used correctly, should enable the SEAS to assist LEAS in improving the quality and effective- ness of their projects. The New Jersey SEA required each LEA participating in the title I program to submit an annual evaluation report on its program. The reports were to be prepared in a pre- scribed format designed by the SEA. Officials of the SEA stated that the LEAS' annual evaluation reports were used essentially to obtain information to be included in the SEA's annual evaluation report to the Office of Education. These officials informed us also that they did not use the LEAS' evaluation reports as means of determining the propriety of the manner in which project activities were conducted. According to the SEA offlclals, they did not use lnfor- mation contained in the LEAS' evaluation reports for the SEA review of subsequent project applicatxons. After we pointed out that the Office of Education guidelines emphasized the importance of using the results of the evaluation process to bring about improvements in proJect activities, SEA officials Informed us that they would begin utillzrng the LEAS' 33 evaluation reports to help improve program operation and to review applications for continuing projects. CONCLUSION It appears that, in the years prior to fiscal year 1970, the SEA did not employ effective practices for ensuring that the title I program was conducted in accordance with applic- able regulations and guidelines. We believe that the proce- dural changes initiated by the SEA in fiscal year 1970 to improve the application review process, the monitoring of LEA operations, and the use of LEA evaluation reports will, if properly implemented, help to ensure that projects con- ducted by LEAS are meeting the special educational needs of educationally deprived children and are being concentrated on children who are most in need of title I assistance. RECOMMENDATIONTO THE SECRETARY OF HEALTH, EDUCATION AND WELFARE Because similar weaknesses In program adminlstratlon may exist in other States, we recommend that the Secretary emphasize to all SEAS the need for (1) adequate reviews of project applications, (2) systematic programs of monitoring title I activities at LEAS, and (3) utilization of evalua- tion reports to improve program effectiveness. The Assistant Secretary stated that the Department con- curred in our recommendation and that our comments and find- ings regarding the administration of the title I program by the New Jersey SEA were of great concern to the Office of Education in its current effort to strengthen the adminis- tration of the program in all the States and at all levels of authority. He stated also that the Office of Education would reemphasize, in a letter to all State departments of education, the need for (1) adequate review of proJect ap- plications, (2) regular and comprehensive project monitoring on as broad a scale as possible and in as great depth as required for ensuring that proJects are carried out as ap- proved and in accordance with Federal requirements, and (3) development of strengthened procedures for evaluation of the effectiveness of the title I program, including 34 techniques for Incorporating more promptly the results of such evaluations into later project application review ac- 35 CHAPTER6 AUDITS OF TITLE I ACTIVITIES IN NEW JERSEY The title I regulations provide that all expenditures by LEAs or SEAs be audited either by State auditors or by other appropriate auditors, Offlce of Education guidelines, in expanding on this subJect, p rovide that such audits may be conducted as a part of local school audit procedures prescribed by State laws or regulations. The guidelines provide also that programs for audits at LEAs be developed In accordance with generally accepted auditing standards, glvlng due consideration to Federal policies governing the use of grant funds as well as to State or local policies and procedures. The guidelines point out that effective standards for local audits related to speclflc programs should Include, as a minimum 1. Sufflclent lnformatlon for the local auditor re- gardlng the requirements and limitations of the program to enable him to certify as to the ellgl- billty of the expenditures reported. 2. Specific information In the audit report sufflclent to permit reconclllation with amounts shown on the records In the State office and assurance that such reconciliation 1s actually made. 3. Assurance that exceptions reported by the auditor will be brought to the attention of offlclals In the State office responsible for the operation of the program and assurance that appropriate adJust- ments or other administrative actions will be taken by such offlclals. The guidellnes provide further that it 1s the respon- sibllity of the SEA to ensure that audits of LEA expendi- tures conform to State laws and practices and are adequate, In terms of the standards and conditions described in the guldellnes, whether the audits are conducted by the State auditors or by other appropriate auditors. 36 Each school district in New Jersey 1s required by State law to have Its accounts audited annually by a regls- tered municipal accountant or a certified public accountant of New Jersey who holds a license as a public school ac- countant. The New Jersey SEA issued guidelines for fiscal man- agement of title I funds to all local boards of education In the State. These guldellnes contain a section on audit and detail the specific matters to be consldered during the audit, as required by the guidelines issued by the Office of Education. We were informed by State officials that each school auditor had been made aware of the existence of the SEA guidelines and that it was the auditor's responsl- billty to obtain a copy of the guidelines from the local board of education using his services. Upon completion of a school audit, the auditor 1s re- quired to send a copy of the report to the SEA, The SEA is responsible for seeing that corrective action is taken on any exceptions noted by the local auditor, The SEA 1s responsible also for comparing the title I section of the audit report with the title I financial reports submitted by the local board of education and for resolving any dlf- ferences. In March 1969 the HEW Audit Agency issued a report on Its review of the New Jersey title I program. This review did not include the Camden LEA, One of the points In the HEW audit report dealt with the audits of local expendi- tures. HEW recommended that the SEA (1) establish review and follow-up procedures for all local audit reports and findings, In accordance with the Office of Education gulde- lines, (2) provide for audits of expenditures of State in- stitutions, and (3) expand the scope of the audit instruc- tions issued by the SEA to include speclflc lnstructlons on Federal compliance requirements. The SEA's reply to HEW stated that It would establish adequate follow-up procedures, would require audits to be performed of the State institutions partlcipatlng in title I, and would issue specific audit instructions re- garding Federal compliance requirements of the title I program. 37 Office of Education offlclals, in a subsequent reply to the SEA, stated that they had accepted the SEA's assurances re- garding the audit points noted and considered as adequate the specific audit instructions outlined in the SEA's re- vised guidelines for fiscal management and therefore con- sidered the audit point settled. At the trme we completed our fieldwork, we were unable to evaluate the effectiveness of the SEA's revised proce- dures because of the short time during which they had been in effect. The Assistant Secretary stated that future reviews of the New Jersey title I program would stress evaluating the effectiveness of audit procedures adopted by the State and that technical assistance would be made available, as re- quired, to the SEA by the Office of Education, to ensure adoption and implementation of any further procedures nec- essary to satisfy all Federal requirements in this area. 38 CHAPTER7 SCOPE OF REVIEW Our review was conducted at the LEA In Camden, New Jersey, at the SEA In Trenton, New Jersey, and at the Office of Education headquarters In Washlngton, D.C. We examined applicable leglslatlon and related legls- latlve documents, Federal regulations, Office of Education program pollcles and dlrectlves, project appllcatlons, re- ports, and other pertinent documents relating to the title I program. We lntervlewed offlclals having responslbllltles under the program at all the aforementioned locations. Our review was dlrected primarily toward an examination into (1) the procedures and crlterla used In selecting the particular areas within the LEA for partlclpatlon In the program, (2) the de sign and conduct of certain proJects by the LEA, (3) the provlslon for, and the partlclpatlon of, private school children In the title I program, and (4) the admlnlstratlon of the title I program by the SEA. 39 APPENDIXES APPENDIX 1 Page 1 DESCRIPTION OF PROJECTS DISCUSSED IN THE REPORT The following 1s a description of the seven proJects, conducted by the Camden LEA, which are discussed in chap- ter 4 of this report. RELOCATABLECLASSROOMS This project provided for the installation and malnte- nance of 19 relocatable classrooms and for the employment of 19 teachers, two janitors, and one matron. The objectives of the project were 1. To eliminate half-day, 4-hour programs for 600 pupils and to restore full-day instructional programs for these pupils. 2. To relieve overcrowded classes In selected disadvan- I taged areas by reducing average class size. CORRECTIVE READING INSTRUCTION Under this project corrective reading instruction was to be provided to those students who were readrng below their grade placement level but who, according to their re- cords, possessed the ability to read at a level equivalent to or above their present grade level. The anticipated re- sults from participation rn this project were that: 1. Every child would improve in the following under- standings and reading skills: a. Sentence meaning, b. Word attack skills. c. Word meaning and knowledge. d. Visual discrlmlnatlon. e. Listening skills. 2. Most pupils would advance, in total reading ability, 1 full year toward their expected reading level. 3. An improvement in a child's reading ability would re- sult an his manifesting a favorable attitude toward reading. 43 APPENDIX I Page 2 In the initial year of this proJect, textbook materials were introduced into all elementary schools and at all grade levels to further a sense of identification and understand- ing among urban population groups. SPECIALIZED PHYSICAL EDUCATION INSTRUCTIC~ The project application for the specialized physical education project provided that each child in the fourth, fifth, and sixth grades who attended public or private ele- mentary schools located in the defined attendance areas re- ceive lnstructlons in physical education for five half-hour periods a week. Two periods a week would be taught by a physlcal education specialist who would also act as a re- source person to the classroom teacher, and the remaining three periods a week would be taught by the classroom teacher. Various types of physical education equipment, such as broad-Jump mats, portable basketball standards, volleyball nets, and gymsters, were purchased and distrlb- uted to 25 public and six private schools. The objectives of this project were to (1) promote physical fitness through appropriate motor activities, (2) teach all pupils participating in the project a knowledge of basic rules, regulations, and skills required In selected organized games and athletics, (3) develop acceptable attl- tudes, social behavior, and rhythmic skills through the teaching of selected folk and square dances, and (4) develop skills in the performance of selected stunts and tumbling activities. DEVEIBPMENTOF A PROGRAMOF COMMUNICATIVEINSTRUCTIONAL FACILITIES The objectives of this project were to (1) develop spe- ciflc audio-visual aids which apply to specific teaching units and actlvlties which were already operable and to in- novate such aids, (2) improve audio-visual techniques in teaching, and (3) change positively the attitudes of pup1.1~ involved in the proJect toward the classroom activities. The audio-visual aids distributed consisted mainly of (1) overhead projectors, (2) slide projectors, (3) 16 mm projec- tors, (4) projector screens, (5) filmstrip previewers, (6) tape recorders, (7) record players, (8) photocopiers, and 44 APPENDIX I Page 3 (9) televisions. The project provided for the establish- ment of an audio-visual laboratory and for the employment of a full-time professional to supervise the audio-visual program. SUPPLEMENTALRESOURCEMATERIALS The purpose of this project was to establish, during the initial year of the title I program in each school de- signated in the application, a satisfactory resource center to be used interchangeably by all students in all class- rooms. The objectives were to (1) make available to stu- dents and teachers sufficient quantities of supplemental classroom resource and reading materials, (2) provide re- sources which would encourage independent study on the part of students so Inclined, and (3) encourage additIona outside-the-classroom reading by the students Involved, Such materials as encyclopedias, atlases, science kits, globes, language kits, and dictionaries were purchased and distributed to all public and private elementary schools. The materials were placed on portable resource carts which could be moved from room to room. EXPANDEDFINE ARTS INSTRUCTIONAL PROGRAM 1 Under this project music instructors and art instruFtors were employed to serve both public and private elementary schools and to act as resource persons to the classroom teachers. Experience-type activities in the music part of the project were to include singing, clapping, dancing, marching, playing simple musical instruments, and dramatiz- ing certain musical selections. Musical instruments were in- troduced to the children and guest artists were invited to the schools to give special demonstrations. Experiences In the art part of the project were to include (1) painting, (2) viewing displays, slides, and filmstrips, (3) modeling activities, including ceramics, and (4) other activities, such as drawing, pasting, weaving, and carving. 45 APPENDIX I Page 4 The objectives of the musrc part of this project were to: 1. Develop In each child the basic skills necessary for reading music as well as singing and for understand- ing the rudiments of rhythm. 2. Provide for the student a variety of musical expe- riences ranging from participation in musical acti- vities to attendance at concerts, 3, Introduce the student to the capabilities and llmlts of the entire family of musical instruments. 4. Determine, through a sampling of classes, what ef- fect, if any, instruction In music has upon the so- cial attitudes of elementary school children. The objectives of the art part of this project were to' 1. Provide ample opportunity for all children affected to experience working with as many materials as are feasible at a given grade level. 2. Stimulate the child to improve what is unattractive In his environment. 3. Determine, through a sampling of classes, what ef- fect, If any, lnstructlon in art has upon the so- cial attitudes of elementary school children. INSTRUCTlONAL AIDES This project was lnltiated to reduce the amount of time that a teacher spent on clerical or noninstructronal duties and to enable the teacher to give students the individual attention which many culturally or educationally disadvan- taged children need. The aides were expected (1) to oversee milk and student insurance programs, (2) to type and repro- duce tests and other materials, (3) to prepare audio-visual materials where possible and to deploy audio-visual equlp- ment, (4) to supervise lunch and playground perrods, (5) to assist with attendance-reporting duties, (6) to assist pri- mary grade teachers with getting wraps on and off students, and (7) to perform other duties as assrgned. 46 APPENDIX II NUMBER OF CHILDREN PARTICIPATING IN CAMDEN W'S TITLE I PROJECTS Fiscal year 1969 Project 1966 1967 1968 (note a> Relocatable classrooms 573 583 560 Corrective readrng Instruction 640 2,164 1,542 Extended special and medlcal ser- vices 5,909 7,805 12,947 Specrallzed physlcal education III- structlon 2,799 4,906 5,635 After school tutorial program and neighborhood school lnformatlonal meetings 1,421 6) (cl Development of a program of commu- nlcatlve lnstructlonal facilities 74,723 16,933 17,000 Supplemental resource materials (note d) 17,066 L . Expanded fine arts mstructlonal program 36,202 12,427 13,800 In-service programs (teachers only) - (b) (b) Instructional aldes 15,265 15,650 15,700 Data processing training 91 (b) Program of outdoor education 628 600 750 Total public school enrollment 20,426 20,500 20,555 20,529 Total private school enrollment 5,318 5,190 5,278 5,278 Total school district enrollment 25,744 25,690 25,833 25,807 aLEA offlclals were not able to supply us with the estimated number of chAdren,by proJect, partlczpatlng in the fiscal year 1969 pro- gram. b ProJect not conducted during fiscal year. 'Only the neighborhood school information meeting part of PrOJeCt was conducted L d The LEA considered this proJect to be completed after the drstrlbu- tlon of the materials in fzscal year 1966 We were Informed, how- ever, that the materials distributed In the mltlal year have re- manned at the reclplent schools We therefore belreve that at least the same number of children benefited from the prolect In each subsequent year 47 APPENDIX III TITLE I PROGRAM FUNDSRECEIVEDBY CAMDENLEA Fiscal year Project 1966 1967 1968 1969 Total Relocatable classrooms (Includes admfmlnlstratlve expenses) $ 352,412 $ 368,601 $ 390,694 $ 275,680 $1,387,387 Corrective readqg lnstructlon 193,612 203,934 242,155 258,334 898,035 Extended specral and medlcal services 134,763 205,892 167,300 218,027 725,982 Specrallzed physrcal education instruction 78,859 68,944 85,747 84,341 317,891 After school tutorial program and neighborhood school lnformatronal meetings 28,064 (a> 3,275b (a) 31,339 Development of a program of communl- cative lnstructlonal facilities 131,066 20,874 19,293 14,421 185,654 Supplemental resource materials 126,137 cc> (cl (cl 126,137 Expanded fine arts instructional program 39,686 84,924 90,505 93,537 308,652 In-service programs (teachers only) 8,072 a4ld (a) (a> 8,913 Instructional aides 15,747 45,920 44,601 75,669 181,937 Data proc sslng trarning 1,463 8,491 (a) (a> 9,954 Program of outdoor educatron 84,077 120,891 179,663 86,067 470,698 Total $1,193,958 $1,129,312 $1,223,233 $1.106,076 $4.652.579 aProject not conducted durrng fiscal year bOnly the neighborhood school informational meeting part of project was conducted durang fiscal year 'LEA considered this project completed after the dlstrlbution of materrals rn fascal year 1966 d Although this project was not conducted during fiscal year 1967, the expenditure was for de- veloplng a vocational currlculwn In the summer of 1966 48 APPENDIX IV Page 1 DEPARTMENT OF HEALTH, EDUCATION AND WELFARE WASHINGTON D C 20201 OFFICE OF THE SECRETARY DEC 21 1970 Mr. Phlllp Charam Associate Dxrector United States General Accountzng Office Washmgton, D.C. 20548 Dear Mr. Charam: The Secretary has asked that I reply to your letter of September 30, 1970, with whxh you forwarded the draft report of the General Accountxng Offxe review of OE admxnlstratlon of the Txtle I, ESEAprogram m the State of New Jersey. We apprecxate the opportunity to revzew and commenton the findings and recommendatxons. The fmdmgs clearly ldentlfy certain weaknesses 1n Tztle I program administration at the State Education Agency level and valxU.y question several matters of pro3ec-t operatxon and managementby the local educational agency whose actlvxtles were revlewed. The recommendations offered are well calculated to produce needed remedial action and they will be promptly unplemented by the Office of Education. Detalled commentson the fmndmgs, together with statements of actlon to be taken to implement the related recommendatxons, are set forth in the enclosure hereto. They are the product of review, by cognizant Departmental and Office of Education staff, of your report and the responses thereto submitted by the State and local educational agencies concerned. Sincerely yours, Assistant Secretary, Comptroller Enclosure 49 APPENDIX IV Page 2 Department of Health, Education, and Welfare Comments Pertinent to the Draft of Report to the Congress of the United States by the Comptroller General of the United States on the Admmlstratlon of Certain Aspects -- of Federal Program of Assistance to Educationally -- Deprived Children m -- New Jersey Selection and Partlclpatlon of School Attendance Areas We recommend to the Secretary that he emphasize to the New Jersey SEA the need to ensure that LEAS (1) select and document project areas lraccordance with applicable program cxlterla and (2) concen- trate program assistance to the fullest extent m those school attendance areas deslgned as having high concentrations of children from low- income famille s. Department Comment We concur m this recommendation. The U.S. Ofhce of Education, In a letter to the New Jersey Cornmlssloner of Education, will urge that the State educational agency (SEA) strengthen even further its procedures for proJect review and approval and for program monitorlng3 so as to preclude further deviations of this sort from program regulations governmg selectlon crlterla and from the terms of approved project appllcatlons Some Projects Were Not Deslgned to Meet the Needs of Educationally Deprived Children We recommend that the Secretary (1) review the. facts relating to the Title I proJects dlscussed and, to the extent warranted, effect recoveries or make appropriate adjustments in Title I program funds deemed to have been expended m a manner not consistent with the objectives or provlslon of Title I of the Elementary and Secondary Education Act, and (2) emphasize to the New Jersey SEA the Importance --of requlrlng LEAS, prior to SEA approval of proJect applications, to Identify the special needs of educatlonally deprived children--including those m private schools--and design projects which will have reasonable promise of meeting such need. 50 APPENDIXIV Page 3 We also recommend that the Secretary emphasize to SEAS generally thenonavallablllty of Title I funds to support projects designed to meet general educatlonal needs of the local school systems rather than specific ldentlfled needs of educationally deprived - children resldmg U-I Title I proJect areas. Department Comment We concur m this recommendation. As mentioned in our response to the prior recommeadatlon, the Office of Education 1s sendmg a letter to the New Jersey Commlssloner of Education. It will emphasize the clear need for adoption, at both the LEA and SEA levels, oJ more effective measures to assure ldentlflcatlon of the special needs of educationally deprived children In both public and nonpublic schools and to limit Title I project design and approval to proJects offering reasonable promise of success m meeting those special needs A general revlslon of the Title I, ESEA regulations presently 15 m progress. In the course of that actlon, the Office of Education 1s glvlng particular attention to strengthening and clarlfymg those regulatory sections dealing with the requirement that Title I funds be used exclusively for proJect actlvltles speclflcally deslgned to ~ , serve the clearly ldentlfled special needs of educatlonaily disadvantaged children 1.n Title I proJect areas. This same matter was dealt with extensively durmg a series of regional conferences among State educatlonal agency and Offlce of Education offlczals, held In Washrngton and Denver during late November and early December of this year. ,, Wzth respect to the particular proJects of the Camden LEA wherein there 1s evidence of use of Title I funds for general educatlonal purposes, the Office of Education, in conJunctlon with SEA offlclals, will conduct a thorough review of project expenditures and effect prompt recovery or adJustment of all amounts found to have been expended for purposes, or Ln a manner, mconslstent with Title I ObJectiVeS or regUk3tlOnS. The Office of Education posltlon regarding the expenditure of Title I funds to defray the costs of staffing and operating 19 relocatable classrooms is set forth in the GAO report. In the APPENDIX IV Page 4 aforementioned letter to the New Jersey Commlssloner of Education, it will be stressed that, unless there 1s clear evidence that those classrooms are bemg utlllzed In a project speclflcally designed to meet the special needs of educationally deprived children, the use of Title I funds in connection with those classrooms must be terml- nated. The question of possible recovery of adjustment of Title I funds previously expended for costs related to the relocatable classrooms also will be discussed and resolved in conJunctlon with the SEA. Wxth reference to payments of architectural fees prior to the date of proJect s ubmls slon, the Offlce of Education will instruct the SEA to effect recovery of $15,000 as this sum was not an allowable charge to the Title I program Regarding the partlclpatlon of private school children in the Title I program, the Office of Education will instruct the State Commlssloner to ensure that all LEAS, including Camden, are made aware of the appropriate provlslons of the regulations regarding use of Title I funds and have taken steps to provide for an adequate before-the-fact assessment of the special needs of educationally deprived children attending such schools Admlnlstratlon of the Title I Program of the New Jersey Educational Agency We recommend that the Secretary emphasize to the SEAS the need for 11) an adequate review of proJect applications, (2) a systematic program of monltormg title I actlvltles at LEAS and (3) utlllzatlon of evaluation reports to Improve program effectiveness. DeDartment Comment We concur in this recommendation. The comments and fmdmgs In the review relative to the admmlstratlon of the Title I program by the New Jersey SEA have been reviewed and 52 APPENDIXIV Page 5 they are of great concern to the Office of Education ln connection with its current effort to strengthen the admlnlstratlon of the program in all the States and at all levels of authority. The Office of Education will re-emphasize In a letter to all State departments of education the need for (a) adequate review of project appllcatlons, (b) regular and , comprehensive proJect momtormg on as broad a scale as possible and m as great depth as 1s required to ensure that projects are carried out as approved and m accord with Federal requirements, and (c) development of strengthened procedures for evaluation of the effectiveness of the Title I program, mcludmg techmques for mcor- poratmg more promptly the results of such evaluations Into later project application review activities. The Office of Education wzll continue to stress to the New Jersey SEA the need for perlodlc audits of Title I expenditures, with followup action taken on a tunely basis where correction 1s required. Future reviews of the New Jersey Title I program will stress evaluating the effectiveness of audit procedures adopted by the State. Technical assistance ~111 be made avallable to the SEA, as required, by the Offlce of Education to ensure adoption and lmplementatlon of any further procedures necessary to satisfy all Federal requirements m this area 53 APPENDIX V GAO REPORTS ON REVIEWS OF FEDERAL PROGRAMOF AID TO EDUCATIONALLY DEPRIVED CHILDREN Report title B-Number Date issued Opportunltles for Improving Admlnlstratlon of Federal Program of Ald to Educa- tlonally Deprived Children In West Virginia B-164031(1) March 5, 1970 Improvement Needed In Admlnlstratlon of the Federal Program of AId to Educationally De- prived Children m Ohlo B-164031(1) December 28, 1970 54 APPENDIX VI PRINCIPAL OFFICIALS OF THE DEPARTMENTOF HEALTH, EDUCATION, AND WELFARE HAVING RESPONSIBILITY FOR THE ACTIVITIES DISCUSSED IN THIS REPORT Tenure of office From To - SECRETARYOF HEALTH, EDUCATION, ANDWELFARE: Elliot L. Rlchardson June 1970 Present Robert H Finch Jan. 1969 June 1970 Wilbur J. Cohen Mar. 1968 Jan. 1969 John W. Gardner Aug. 1965 Mar. 1968 Anthony J. Celebrezze July 1962 Aug. 1965 ASSISTANT SECRETARY(EDuCACION): Vacant June 1970 Present James E, Allen, Jr. &Y 1969 June 1970 Peter P. Muirhead (acting) Jan. 1969 &Y 1969 Lynn M. Bartlett July 1968 Jan. 1969 b Paul A. Miller July 1966 July 1968 Francis Keppel Oct. 1965 &Y 1966 COMMISSIONEROF EDUCATION. Sxlney P. Marland, Jr. Dec. 1970 Present Terre1 H. Bell (acting) 1970 Dec. 1970 James E. Allen, Jr. &Y 1969 June 1970 Peter P. Muirhead (acting) Jan. 1969 *Y 1969 Harold Howe II Jan. 1966 Dec. 1968 Francis Keppel Dec. 1962 Jan. 1966 U S GAO Wash, D C 55
Improved Administration Needed in New Jersey for the Federal Program of Aid to Educationally Deprived Children
Published by the Government Accountability Office on 1971-04-07.
Below is a raw (and likely hideous) rendition of the original report. (PDF)