oversight

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)

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