oversight

Reevaluation Needed of Educational Assistance for Institutionalized Neglected or Delinquent Children

Published by the Government Accountability Office on 1977-12-19.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                            DOCUMENT        ESUME

04251 -    B3554814]

Reevaluation Needed of Educational Assistance for
Institutionalized  eglected or Delinquent Children. HPD-78-11;
B-164031(1). December 19, 1977. 39 pp. + 8 appendices (28 p?.).

Report    to the Congress; by Elmer    B.    Staats,   Comptroller General.

Issue Area: Federally Sponsored or Assisted Education Programs
     (3300); Law Enforcement and Crime Prevention (500);Law
    Enforcement and Crime Prevention: Effectiveness of
    Correctional Programs (514).
Contact: Human Resources Div.
Budget Function: Education, Manpower, and Social Services:
    Elementary, Secondary, and Vocational Education (501); Law
    Enforceiment and Justice: Federal Correctional and
    Rehabilitative Activities (753).
Organization Concerned: Department of Health, Education, and
    welfare; Department of Justice.
Congressional Relevance: House Committee on Education and Lor;
    Senate Committee on Human Resources; Congress.
Authority: Elementary and Secondary Education Act of 1965, ti* le
    I   20 U.S.C. 241a). Child Abuse, Prevention, and Treatment
    Act (42 U.S.C. 5101). Juvenile Justice and Delinquency
    Prevention Act of 1974 (42 U.S.C.   601). 45 C.F.R. 116.

          In recent years, the Office of Education's educational
assistance program for neglected or delinquent children has
emphasized     'c skills instruction. Older children generally do
not contini       soling once outside of institutions; younger
children, h         ,g   more likely to return to school following
release. The              unique because it provides assistance
annually to o._        '.nstitutions, but it needs to be
reexamined in reA       .o the broader national iss'es of
juvenile delinqlu      i child abuse and neglect. Eaucaional
assistance may         he top priority for institutionalized
youth. F.indingt/.   _usions: A nationwide survey of institution
administrators to de:ermine the importance of academic
educational needs in comparison with other problems faced by
youth in institutions indicated that the administrators consider
academic education important but secondary to mental health
needs. Responses to other questions raised concerns as to
whether academic educational needs shoald be the exclusive or
top priority e a Federal service program. Funds for the program
should be distributed on a more selective basis than at present,
but to do so, existing legislation would have to be amended.
Recommendations: The Congress should irect the Department of
Health, Education, and Welfare and the Department of Justice to
examine the ppropriateness and/or exclusiveness of academic
educational services as the top priority of Federal assistance.
Such an undertaking is consistent with the need for a responsive
Federal effort to address the national issues of juvenile
delinquency and child abuse and neglect. (Author/Sc)
                     REPORT TO THE CONGRESS

<r   .     ~:. ;BY          ~THE COMPTROLLER GENERAL
o        ,,4' ':OF          THE UNITED STATES




                     Reevaluation Needed Of
                     Educational Assistance For
                     InstitutionAlized Neglected
                     Or Delinquent Children
                     In recent years the Office of Education's ed-
                     ucational assistant program for neglected or
                     delinquent children has emphasized basic
                     skills instruction. Older children enerally do
                     not continue schooling once outside of insti-
                     tutions; younger children, however, are more
                     likeiy to return to school following release.
                     Greater progress could be made if funds were
                     distributed more selectively to longer term
                     institutions arid those that serve younger
                     children.

                     The program is unique because it provides as-
                     sistance annually to over 2,000 institutions,
                     but it needs to be reexamined in relation to
                     the broader national issues of juvenile delin-
                     quency,and child abuse and neglect. Educa
                     tional assistance may not be the top priority
                     for institutionalized youths.




                     HRD-78-11                                DECEMBER 19, 1977
               COMPTROLLER GrNERAL OF THE UNITED STATES
                          WASHINGTON. D.C.   2OMU




B-164031(1)




To the President of the Senate and the
Speaker of the House of Representatives

     This report describes the problems faced by institu-
tionalized neglected or delinquent youths and suggests ways
to enhance the effectiveness of Federal educational assist-
ance made available for them.

     The report also questions the appropriateness of
academic educational services as the exclusive service or
top priority of a Federal service program. The service pro-
gram is administered by the Office of Education, Department
of Health, Education, and Welfare.

     Our review was made pursuant to the Budget and Account-
ing Act of 1921 (31 .. C. 53), and the Accounting and Audit-
ing Act of 1950 (31 U.S.C. 67).

     We are sending copies of this report to the Acting
Director, Office of Management and Budget; the Secretary,
Department of Health, Education, and Welfare; and the
Attorney General.




                                     mptroller General
                                   of the United States
COMPTROLLER GENERAL'S                     REEVALUATION NEEDED OF
REPORT TO THE CONGRESS                    EDUCATIONAL ASSISTANCE FOR
                                          INSTITUTIONALIZED NEGLECTED
                                          OR DELINQUENT CHILDREN


             DIGEST
             Financial assistance to meet special
             educational needs of neglected or delin-
             quent youths in institutions is authorized
             by the Elementary and Secondary Education
             Act. In fiscal year 1976, $41 million was
             provided under title I of the act to assist
             youths residing in more than 2,000 institu-
             tions throughout the country.
             This report examines the program from an
             educational standpoint and how it relates
             to the broader social issues of juvenile
             delinquency, and child abuse and neglect.

             The legislation expresses the Congress
             desire that participants make substantial
             progress. According to the Office of Educa-
             tion, te majority of then; are 3 to 4 years
             below normal expectations in reading and
             mathematics. Given the severity of these
             deficiencies, along with the wide range of
             social, emotional, and behavioral problems
             that many have, substantial progress will
             be difficult to achieve.  (See pp. 7 to 10.)

              The program can be more effective if avail-
              ab e funds are concentrated on those youths
              likely to receive educational services over
              a longer period of time.
              Services under the program are restricted
              to the period of time that the youths are
              in residence in an institution. It appears
              that neglected youths, as a group, have the
              greatest opportunity to achieve substantial
              progress because their average residence is
              more than twice as long as delinquent youths--
              about 22 months compared to 10 months.   (See
              pp. 10 and 11.)


Tar Sheet. Upon removal, the report
cover date should be noted hereon.    i                     HRD-78-11
Actual exposure to program services is even
less according to an Office of Education-
contracted study of State institutions.
This showed that about 70 percent of youths
(1) in institutions for the delinquent and
(2) in adult correctional facilities are en-
rolled in the program for 6 months or less.
Conversely, about 60 percent of the students
in institutions for the neglected remained
in the program for 10 months or more.

Beyond the institution, it appears that the
younger a youth is, the more likely the
youth will enroll in school following release.
GAO's tracking of 170 participants after
their release from institutions showed this
to be true.  The tracking also showed that
the younger the youths were, the more likely
they would be regularly attending school
about 15 months later.  (See pp. 12 to 15.)

Older youths, for the most part, appear to
be more interested in obtaining employment
rather than continuing their schooling.
(See pp. 18 and 19.)

Institutions need only meet basic require-
ments to receive assistance under the pro-
gram (see pp. 3 and 4.)   Funds should be
distributed on a more selective basis; but
to  o so, title I legislation would have to
be amended to provide for the awarding of
grants by State education agencies on the
basis of criteria to be established by the
Office of Education.   In particular, the
criteria would give priority consideration
to institutions that serve ounger youths
Ind provide services to individual youths
over a longer term.  (See pp. 22   nd 23.)

The Department of Health, Eucation, and
Welfare disagreed with GAO, citing various
reasons, e.g., younger children should not
be given priority consideration at the ex-
pense of older children.  (See pp. 23 to 27.)




                     ii
 The criteria should also make provision for
 addressing the need for adequate transi-
 tional services to insure that youths, to
 the extent possible, receive appropriate
 educational services following their release
 Lrom institutions. GAO found that institu-
 tions were doing little to assist youths in
 their transition from the institutions to
 schools in the community. (See pp. 19 to 21.)
 The title I program is the only Federal
 service program of its kind. Funds are made
 available annually for institutions to meet
 a particular need of institutionalized
 neglected cr delinquent youths. Accordingly,
 GAO conducted a nationwide survey of insti-
 tution administrators to determine the im-
 portance of academic educational needs in
 comparison with other problems faced by
 youths in institutions.

 Results show that administrators consider
 academic education important, but second to
 rental health needs. Responses to other
 Jurvey questions raise concerns as to whether
 academic educational needs should be the ex-
 clusive service or top priority of a Federal
 service program. (See pp. 29 to 36.)
 The Congress should direct the Department of
 Health, Education, and Welfare and the Depart-
 ment of Justice to examine the appropriateness
 and/or exclusiveness of academic educational
 services as the top priority of Federal as-
 sistance. Such an undertaking is consistent
 with the need for a responsive Federal effort
 to address the nationul issues of juvenile
 delinquency, and child abuse and neglect.
 (See p. 39.)
 The Department of Health, Education, and
 Welfare was against such an undertaking,
 but the Department of Justice supported
 it.  (See pp. 37 to 39.)




TearSheet
      ~     ~   ~     ii
                        Contents
                                                          Page

DIGEST

CHAPTER

   1       INTRODUCTION                                     i
               Program administration                       2
               Program funding                              4
               Scope of review                              5

   2       MORE SELECTIVE FUNDING OF PROJECTS NEEDED        7
               Problems faced by target population          7
               Exposure to title I services often
                 limited                                  10
               Unsuccessful return to school and
                 community                                11
               Inadequate back-to-school transition
                 services                                 19
               Conclusions                                21
               Agency comments and our evaluation         23
   3       SHOULD ACADEMIC EDUCATIONAL ASSISTANCE FOR
             INSTITUTIONk.LIZED YOUTH BE THE HIGHEST
             PRIORITY FOR FEDERAL ASSISTANCE?             28
               1974 legislation                           28
               Nationwide survey of problems of
                  institutionalized youth                 29
               Conclusions                                36
               Agency comments and our evaluation         37
               Recommendation to the Congress             39
APPENDIX

   I       Descriptive information on   institutions
             included in review                           40
  II       Questionnaire sent to title I institutions     44
 III       Additional information on questionnaire
             methodology and results                      49

  IV       Recommended revic    . to section 123 of
             title I, shoulL     be determined that the
             provision of a    mic educational services
             is the appropriate program thrust for
             institutionalized youths                     52
                                                              Page

APPENDIX

      V    Section 123 of title I of the Elementary
             and Secondary Education Act of 1965,
             as amended                                        55

     VI    Letter dat-ad A. ust 1, 1977, from the
             Inspector General, Department of Health,
             Education, and Welfare                            56

 VII       Letter dated AuguFt 8, 1977, from the
             Assistant Attorney General for Adminis-
             tration, Department o  Justice                   64

VIII       Principal officials of the Department
             of Health, Education, and Weltare
             responsible for activities discussed
             in this report                                   67


                         ABBREVIATIONS

GAO        General Accounting Office

HEW        Department of Health,   Education,   and Welfare

OE         Office of Education
                          CHAPTER 1

                        INTRODUCTION

     Title I of the Elementary and Seconidary Education Act  f
1965 (20 U.S.C. 241a) authorizes Federal financial assistance
to expand and improve educational programs which contribute to
meeting the special needs of educationally deprived children.
Title I regulations define "educationally deprived children"
as children who (1) need special educational assistance to
raise their educational attainment to that appropriate for
their age and (2) are handicapped.

     Title I programs are aimed at several different popula-
tions and were funded in fiscal year 1976 at the following
levels, excluding special incentive grants and administrative
co3ts.

                Target group             Funding

                                        (millio-s)
          Educaticnally deprived
            children from low-income
            families                     $1,612
          Migrant children                   97
          Handicapped children               96
          Neglected or delinquent
            children in institutions         41

              Total                      $1,846
     This report discusses the operation of the program for
institutionalized neglected or delinquent children.  More
specifically, the report examines the program in an educa-
tional context, and how he prog am relates to the broade:
issues of juvenile delinquency, and child abuse and neglect.

     We previously reported on the administration and opera-
tion of the program for (1) educationally deprived children
from low-income families in December 1975 1/ and (2) migrant
children in February 173. 2/

l/"Assessment of Reading Activities Funded Under the Feder.l.
  Program of Aid for Educationally Deprived Children"
  (B-164C3(1l), Dec. 12, 1975).

2/"Impact of Federal Programs to Improve the Li ing Conditions
  of Migrant and Other Seasonal Farmworkers" (B-177486, Feb. 6,
  1973).

                               1
PROGRAM ADMINISTRATION

     The Office of Education (OE), Department of Health,
Education, and Welfare (HEW) administers the title I program
at the national level.  OE is responsible for

     -- allocating funds,

    -- developing regulations and guidelines,

    -- monitoring the program,

    -- providing technical assistance to States, and

    -- evaluating and reporting to the Congress on overall
      program effectiveness.

     At the State level, the State eucation agency's respon-
sibilities include

    -- applying to OE for funds,
    -- offering technical assistance,

    -- approving and monitoring title I projects,
    -- maintainivg fiscal records, and

    -- preparing evaluations and other reports required by
       OE or the law.

    A State agency--such as a department of corrections,
which is responsible for providing free public education to
institutionalized youths in State institutions--is eligible
to receive funds under section 123 of title I. Also, under
section 103, local education agencies are eligible to receive
title I funds for children at locally operated institutions.
Sepdrate regulations have been developed for each section.

     The State and local agencies or applicant agencies are
responsible for

    -- determining special educational needs,
    -- designing and submitting title I projects to the State
       education agency for approval,
    -- implementing and supervising projects,



                                 2
      -- maintaining fiscal records, and
      -- preparing annual evaluations of their title I
         programs.
      In the late 1960s, OE allowed program funds to be used
for a wide variety of services, including projects directed
toward rehabilitating the children and improving their self-
image. In recent years, however, OE has stressed providing
basic reading and mathematics instructions, and a recent OE-
contracted study has shown that nearly 70 percent of title I
funds in State institutions were being spent on reading and
mathematics services.

     Institutions included in our review generally used
title I funds for basic skills instruction. Some, however,
provided other services, such as vocational and educational
counseling, and diagnostic services. Additional information
on the projects we reviewed is provided in appendix I.

      The act equires that title I services supplement those
educational services already available to institutionalized
children. For the most part, institutions for delinquents
and adult correctional institutions provide this basic educa-
tional program ongrounds. while institutions for the neglected
oftein send their youths to public schools. For those institu-
tions we visited, title I services were generally provided
ongrounds no matter where basic educational program services
were provided.

     Locally administered institutions eligible to receive
title I funds are defined by the regulations as follows: 1/

       'Institution for neglected children' means a
    public or private residentiai faciiity (other
    than a foster home) which is operated primarily
    for the care of at least ten children who have
    boen committed to the institution, or volun-
    tarily placed in the institution pursuant to
    applicable State law, because of the abandon-
    ment of or neglect by, or death of. parents or
    persons acting in the place of parents.
    (45 CFR 116a.2) Underscoring supplied.]

1/In 45 CFR 116c.2, State institutions are defined somewat
  differently, with eligibility requirements including that
  children be in residence for an average of at least 30 days.



                              3
     " 'Institution for delinquent children' means a
     public or private residential facility which is
     operated primarily for the care of children who
     have been adjudicated to be delinquent or in
     need of supervision. Th term also includes an
     adult correctional institution in which children
     reside."  (45 CFR 116a.2) [Underscoring supplied.]
     The size of institutions and the age of children in
residence vary considerably. The average number of youths
under 21 years of age in institutions for the neglected,
delinquent, and adult corrections is 70, 86, and 151, respec-
tively.  In institutions for the neglected, about 50 percent
of the population is under 14 years of age, with about
45 percent being in the 14 to 17 age group. About 85 per-
cent of delinquent youths are 14 or older, with the majority
being in the 14 to 18 age group. In adult correctional insti-
tutions, the majority of inmates are over 21 years of age;
for those under 21 years of age, about 85 percent are in the
18 to 21 age group.

PROGRAM FUNDING

     Title I assistance for institutionalized children totaled
$41 million in fiscal year 1976. Funds were allocated for
115,000 children living in more than 2,000 State and locally
administered institutions throughout the country. Grants are
allocated on the basis of a formula that considers the average
per pupil expenditure in the State and the number of eligible
children in residence. The table on page 5 provides fiscal
year 1976 program data.




                             4
                                      Number of
                        Nuniber of    children
                      institutions    (note a)       Funding
State institutions:
    Neglected                28         3,635     $ 2,084,369
    Delinquent              324        29,066      18,090,832
    Adult correc-
      tional                240        12,480       7,284,243
    Subtotal                592        45,181      27,459,444
Local institutions:
    Neglected               999        48,706       9,589,198
    Delinquent              402        19,571       3,853,122
    Adult correc-
    tional                   43         1,549         304,965
    Subtotal              1,444        69,826      13,747,285
        Total             2,036       115,007     $41,206,729
a/Represents the number of children used as a basis for allc-
  cating funds.  (See p. 4.) The number of children actually
  served is not reported to E.

     Grants for children in the nearly 1,500 locally adminis-
tered institutions average about $9,500 per institution,
while State institutions received an average grant of about
$46,400. A principal reason for this difference is that
when appropriated funds are less than the am,)unts which local
and State agencies are entitled to receive, the law requires
that grants to local educational agencies be reduced. Con-
sequently, in fiscal year 1976, State institutions received
on the average about $608 per child, while local institutions
received about $197 per child.
SCOPE OF REVIEW

     Our review was made primarily at OE headquarters and in
California, Virginia, Kansas, and Pennsylvania. These four
States were selected to provide a wide geographical distri-
bution. We did detailed work at 17 institutions for neglected
or delinquent children within these States.  In consultation
with OE, we judgmentally selected the institutions and took
into consideration geographical distribution, the type of
children served, wether the institution was State or locally
administered, and the number of children in residence.



                             5
     We also tracked the activities of 170 program participants
for about a 1-year period following their release from the
institutions. The purpose of the tracking was to determine,
among other things, (1) if the children returned to school and
(2) what assistance they received from the institutions and
probation/parole/welfare agencies.

     Finally, we sent a questionnaire nationwide to a sample
(771 of 2,036) of administrators of State and local institu-
tions, including adult correctional institutions; 562 rsponses
were received. The survey was made to obtain national data on
institutions and institutionalized children, and to obtain
views on the importance of educational needs as compared to
the other needs of the tarcet population. Throughout the
report, the questionnaire survey results are projected to
within about plus or minus 8 percent for the entire popula-
tion under study at the 95-percent level of statistical
confidence. The questionnaire, along with details of the
survey method and design. is shown in appendixes II and III.




                             6
                          CHAPTER 2
                   MORE SELECTIVE FUNDING
                     OF PROJECTS NEEDED
     Title I legislation expresses the Congress desire that
youths participating in the program make substantial progress.
However, substantial progress will be difficult to achieve,
considering the educational deficiencies of the target popula-
tion along with the wide range of social, emotional, and be-
havioral problems that many have.

     The effectiveness of the program can be enhanced if
available funds are argeted to those youths who are likely
to receive a continuum of educational services over a longer
period of time. Services under the program are r tricted
to the period of time that the youths are in resience, and
many--particularly delinquents--are in residence a relatively
short period of time.

     Beyond the institution, it appears that the younger a
youth is, tne more likely a continuum of educational services
will be achieved. Our tracking of 170 program participants
after their release from the institutions showed this to be
the result. The younger youths were, the greater the like-
lii od that they would (1) enroll in school after release and
(2) be attending school regularly about 15 months later.   For
the most part, older youths appeared to be more interested in
obtaining employment rather than continuing their schooling.
     Our review also disclosed that institutions and probation/
parole/welfare officers were doing little to assist youths in
obtaining a continuum of appropriate educational services
following their release. In particular, little effort was
made to provide schools that the students would attend after
release (receiving schools) with timely information on
youths' specific strengths and weaknesses; this information
would assist the schools in helping youths successfully
adjust after release.
PROBLEMS FACED BY TARGET POPULATION

     Neglected and delinquent youths generally have signifi-
cant economic, social, and psychological proLublems, as well
as long histories of failure and rejection. Also, under-
achievement in school is   common characteristic.




                              7
     According to OE, the majority of institutionalized youths
are from 3 to 4 years below normal expectations in reading and
mathematics.  To illustrate the ducational deficiency that
most delinquent youths exhibit on entering the inst:Ltutions,
several examoles of availaLle data are presented below.

     -- A county in California found that 78 percent of the
        juveniles institutionalized in its system read below
        grade level.  The county also found that 69 percent of
        male youths were 3 or more grades below expected grade
        level, and 47 percent of those tested for intelligence
        quotient fell within subnormal categories.

     -- A study of juveniles incarcerated in the California
        State institutional system for delinquents found that
        28 percent were regarded as high school dropouts.
        Most were between 16 and 20 years of age.  Seventy
        percent were 3 or more years below grade level in
        reading, and 85 percent were 3 or more years behind
        in math.

     -- A State institution in Pennsylvania found that the
        average age of its delinquent youths was 15, which
        equates to an expected 9th grade achievement level.
        However, the average reading and math levels of the
        youths were grades 6.0 and 5.8, respectively.

     A 1972 OE-funded study, performed by the Western Inter-
state Commission for Higher Education, obtained comments from
381 teachers at 29 correctional institutions in the West.   The
teachers described, among other things, the students' most
significant learning barrier.  One constant theme in their
descriptions was that institutionalized students were over-
whelmingly viewed as being severely disturbed and exhibiting
complicated problems, unique needs, and a variety of special
characteristics.

     Instititionalized neglected youths are often considered
"predelinquents" because they exhibit similar behavior, eco-
nomic, and educational problems as delinquent youths, who
generally are older.  Our tracking sample of 80 neglected
youths, ranging from 7 to 19 years of age, delineates why
they were institutionalized:




                              8
          Uncontrollable behavior               25
          Poor or deprived home environment     17
          Family problems                       15
          Abandonment                            9
          Burglary, robbery, or theft            5
          Abuse                                  4
          Emotional disturbances                 3
          Information not available              2
             Total                              80
     Delinquent youths have, in many cases, had more than one
contact with police and the juvenile court system before being
placed in an institution; some are institutionalized more than
once. Poor economic conditions, broken homes, and a general
low level of parental education are frequent descriptions of
delinquents' backgrounds. Our sample of 90 delinquents,
ranging from 12 to 21 years of age, delineates why they were
instititutionalized:

          Burglary, robbery, theft or
            possession of stolen property       62
          Uncontrollable behavior               10
          Assault and/or battery                 9
          Sale or use of drugs                   7
          Sexual offenses                        1
          Information not available              1
             Total                              90
     Behavioral problems can adversely affect educational
programs. One particularly graphic example is an institu-
tion that experienced a riot the night before our visit which
caused the entire population to be locked up. Thus, partici-
pants could not attend classes that day. One participant at
the same institution had been locked up so ften that the
teacher could not give him a grade. Some tenchers also
commented that much classroom time is spent on discipline.

     Almost half of the children in institutions served by
the program are handicapped according to the results of our
questionnaire sent to institution administrators.  (See
app. II, question 19.) Only those respondents who indicated
that they tested for handicapping conditions were considered.
The results of the survey, by type of institution, are shown
on the next page.




                             9
                             Institutions serving prjiarily
                             Adult
                           offenders   Neglected    Delinquent
                          (under 21)   children      children

                             ---------- (percent)-----------
Physically handicapped        4.1            1.5        1.8
Mentally retarded            12.6            7.4        7.8
Seriously emotionally
  disturbed                  16.9         32.2         32.9
Specific learning
  disabilities               15.1         19.5         25.0
Other handicapped
  conditions                 17 3        10.9          12.8

    Total   (note a)         43.4         46.6         48.9

a/The total does not equal the sum of the parts because some
  children have more than one type of handicap.

     The data shows that the most prevalent type of handicap
is serious emotional disturbance.  Handicaps classified as
"other" indicated a wide range of problems, with the mnost fre-
quent ones cited being related to mental health impairments.

EXPOSURE TO TITLE 1 SERVICES OFTEN LIMITED

     According to OE, there is little or no reliable informa-
tion on the extent of the program's impact on academic
achievement. 1/ Nonetheless, it appears that the target
population, by its very nature, is an extremely difficult
group to teach.
     Despite common problems among youths and the lack of
information on achievement, certain youths have a greater
opportunity to make substantial progress than others, parti-
cularly those that receive services over a longer period of
time. Program services are available to youths only during
the time they reside at an institution, and the period of
time varies significantly. Generally, for those institu-
tions we visited, neglected youths on the average (23 months)
were institutionalized nearly two and one-half times longer
than delinquents (10 months).


1/OE has underway a national impact evaluation for State in-
  stitutions, which is expected to be completed in the spring
  of 1979.  As part of this effort, steps are also being
  taken to strengthen evaluations for State institutions.


                             10
     Our nationwide questionnaire of a sample of institution
administrators substantiated the length of stay determined
by our fieldwork. The average length of stay for institu-
tions serving primarily delinquent youths is only 9.7 months,
as compared to institutions for the neglected, where the
average stay is more than twice as long--22.4 months. For
youths (under 21) residing in adult correctional institutions,
the average length of stay is 14.3 months. Also, for about
10 percent of the respondents--most of whom stated that they
served emotionally disturbed youths--the average length of
stay was 12.4 months. In estimating the average length of
stay, questionnaire respondents were asked not to include
those youths who were institutionalized less than 30 days.
Therefore, the average length of stay is probably somewhat
less than that discussed above.
     Projecting the questionnaire responses nationally shows
that there are about 730 institutions in which the average
length of stay is 1 year or less, and about 310 institutions
in which the average length of stay s 6 months or less. Most
of these are institutions for delinquents.

     An OE-contracted study dated September 1977 indicates
that actual exposure to program services, as opposed to length
of stay, is relatively short for many program participants.
The study, which was based on a survey of State institutions,
showed that about 70 percent of program participants in insti-
tutions for delinquents and in adult correctional facilities
are enrolled in the program for 6 months or less. Conversely,
about 60 percent of program participants in institutions for
the neglected remained in the program for 10 months or more.

UNSUCCESSFUL RETURN TO
SCHOOL AND COMMUNITY

     Our tracking of program participants after their release
from institutions showed that most had an unsuccessful adjust-
ment to school and/or the community. However, the younger the
youths were, the better they appeared to adjust.

      The tracking was undertaken for several reasons. First,
it provides insight into the payoff of rehabilitative/
treatment efforts as a whole. Second, from ar, educational
standpoint, the extent to which schooling continues after
release has an important bearing on the amount of progress
participants will ultimately make. Fnally, many educators
believe that if educational reenforcement is not received
following release, gains realized in institutions may be
lost.


                             11
Participants selection and methodology

      Ten former program participants were selected from each
of the 17 institutions we visited.   Ninety youths were from
institutions for the delinquent, and the remaining 80 were
neglected youths. The participants selected were the last
10 released from each of the institutions prior to March 1,
1975.

      The Mrch date waz siec'te to coincide with the timing
planned for our fieldwork which, f.- +he most part, was ccm-
pleted in April 1976.   Beyond th'i   ere were other con-
siderations. Generally, the poba.     /parole/social
welfare system has knowledge of the participants' whereabouts
and activities for about 1 year after release. An earlier
date, terefore, would probably have caused difficulty in
locating and obtaining information n the participants. A
later date, such as May or June or during schools' summer
recess, would have reduced the likelihood that the partici-
pants would return to school immediately following release--
a critical time in the participant's transition from the in-
stitution. An even later date, such as September or October
1975 would have significantly reduced the period of activity
covered by our tracking.

     In determining the activities of participants after re-
lease, we examined available records and talked with (1) in-
stitution officials, (2) parole/probation/welfare officers.
and (3) officials of the school to which the participants
returned.  If a youth was reinstitutionalized or entered a
mental hospital at any time after release, we did not examine
his or her activities beyond that point.  Furthermore, if a
youth joined the military or left the State, we did no ddi-
tional followup because of logistical consideratiors.

      For the 170 participants in our sample, 67 were 16 years
of age or older at the time of their release; 54 were either
14 or 15; and 49 were 13 or younger. The vast majority were
male.

Tracking results

     Following release from the institution, 116 (68 percent)
of our sample enrolled in school.  Forty-five youths (26 per-
cent) did not enroll.  Information on nine youths was not
available.

     For the youths who did not enroll in school, all but
nine were 16 or older.  The majority of the 45 youths were


                             12
beyond the age for compulsory school attendance. 1/ According
to the officials we interviewed, the most common reason given
for their not enrolling was a lack of interest or outright
refusal, as shown by the following table.

                    Why 45 Youths Did Not
                      Enroll In School

                     Reason                           Number
 No interest in school or refused to enroll             15
 Needed to work or obtain job skill                      9
 Unknown                                                 8
 Reinstitutonalized before next school session           5
 Transferred to mental hospital                          3
 Parents did not support school attendance               2
 School refused enrollment                               2
 Left town for fear of life                              1
    Total                                               45
     Nine of the 45 youths received a high school diploma or
its equivalent during their stay in the institution.  It is
questionable, however, just how well prepared the youths were
to effectively function in society. Test scores were avail-
able for five of the youths; the scores showed that on the
average, the youths were nearly 4 years behind grade level,
with one youth being as far behind as 7 years.  One community
officer commented that one of the youths--who was in prison
at the time of our fieldwork--lacked the most basic educa-
tional skills.

     The following comments about the 45 participants illus-
trate the youths' negative attitudes toward school and give
greater insight into the remote probability of their returning
to school.  The comments are for the most part typical.


l/In most States, the age for compulsory school attendance
  is 16.




                              13
Age at
release                   Comments                       Source

  15      "A real problem is, and has been,            Institution
          school.   I am afraid there will be much       official
          more trouble if an academic career is
          pursued."

  14      "History of beatings by drunken step-        Social
          father.  Attended summer school for a          worker
          couple of weeks then dropped out because
          he could not stand it.  Kicked out of a
          subsequent school for truancy, marijuana,
          and belligerent behavior.  He was put on
          probation by his mother because she could
          not control him."

  14      "No trouble except he did not attend          Social
          school."                                        worker

  18      "Between the ages of 8 and 17, this youth     Institution
          was brought to the juvenile court 25            report
          times.  Arrests included burglaries,
          shopliftings, possession of stolen prop-
          erty, drugs, drunkenness, beyond control
          of parents, run-away, and fire setting.

          "Institution told him that further school-   Probation
          ing was hopeless.  Youth told officer he       officer
          would not attend school even if forced
          to do so.  Later sent to State prison
          for raping and beating a victim."

     As discussed earlier, 116 youths did get enrolled in
school some time after their release froi, the institution.
Our tracking showed, however, that only half (58 of 116) were
enrolled an average of 15 months later.   Furthermore, of the
58 still enrolled, 20 (more than one-third) had poor attend-
ance, which was typically characterized by school officials
as "terrible absenteeism," "serious truancy problem," and
"61 days absent out of 93 school days."   The details of our
tracking results are on the next page.




                              14
                   Analysis of Enrollments and
              Attendance Frequency About 15 Months
                          After Release

                                                         Number/age
                                                         at release
                        Total            Number        1-I6  14- I3 3
                            Per-                Delin- or    or   or
                    Number cent     Neglected quent over 15 under
Enrolled:             58     34         38       20     7   21   30
  Regular
    attendance        38     22         27       11     5    8   25
  Poor
    attendance        20     12         11        9     2   13    5
Not enrolled:         90     53         24       66    49   29   12
    Total   known    !48     87         62       86    56   50   42
    Status
      unknown
      (note a)        22     13         18        4    11    4    7
        Total        170    100         80       90    67   54   49
a/The status of 22 youths was not known because they e her
  left the State (11), qui- school and had not been heard
  from again (6), or no information on their activities was
  obtained (5).

     The above table shows that, for those youths       15 or over,
only 12 percent (7 of 56) were enrolled in school       as com-
pared to 71 percent (30 of 42) of the children 13       or under.
Furthermore, 83 percent (25 of 30) of the younger       children
who were enrolled in school were attending school       on a regular
basis about 15 months after their release.

     Comparing neglected youth with delinquents shows that
61 percent (38 of 62) of the former were enrolled in school
while only 23 percent (20 of 86) of the latt-r were enrolled.
Alsc, 71 percent (27 of 38) of the neglected youths as com-
pared to 55 percent (11 of 20) of the delinquent youths were
attending school regularly about 15 months after release.

     The foregoing discussed the status of 80 youths about
15 months after release--58 enrolled in school and the status
of 22 unknown. The following discusses the status of the re-
maining 90 youths in our sample who were not enrolled in
school about 15 months after release.


                                   15
      In many respects, the status of the remaining 90 youths
parallels .he earlier results of our tracking. Of the 90
youths, 66 were delinquents and 24 were neglected.   More
specifically, 33 delinquents were reinstitutionalized as
opposed to 12 neglected youths; also, 14 delinquents were
idle as compared to only 2 neglected youths. With regard
to age, the incidence of reinstitutionalization and idleness
increased with the age of the youths. Our tracking results,
which are shown below, also give some insight into why ini-
tial school enrollment dropped drastically from 116 to 58.

                      Status of 90 Youths
                Who Were Not Enrollea In School
                 About 15 Months After Release

                                                    Number/age
                    Total                           at release
                     Percent         Number        16   14   13
                     of total               Delin- or   or   or
                No.   sample    Neglected quent over    15 under

Back in an
  institution
  (note a)       45     26           12     33    23   16    6
Idle, not
  working, or
  enrolled in
  school         16      9            2     14    10    5    1
Working
  (note b)      10       6            1      9     8    2    0
Receiving
  vocational
  training        7      4            1      6     6    1    0
In mental
  hospital
  (note a)        6      4            6      0     1    2    3
Missing
  (note c)        5      3            1      4     0    3    2
In military
  (note a)       I       1            1      0     1    0    0

    Total       90      53           24     66    49   29   12

a/Because we did not track these youths after they reached
  this status, it is possii,le that the above status may have
  changed at the time of our fieldwork.

b/Jobs included- gas station attendant, busboy, trash collec-
  tor, and jani.or.

c/These youths wece still under the court's jurisdiction, but
  their whereabouts were not known.

                                16
     The table on the previous page shows that at least 45
youths--about 26 percent of our sample of 170--were reinsti-
tutionalized. This statistic, although accurate, tends to
underestimate the difficulty that youths nad in adjusting to
life outside the institution. Our tracking showed that
98, or 70 percent, of the youths (for which informaticn
was available) experienced a wde range of behaviocial
problems following release, as shown in the table below.

                  Behavioral Problems Experienced
                         Following Release

                                                         16    14    13
                                Delin-                   or    or    or
 Type of problem          Total quent       Neglected   over   15   under
Burglary, robbery,
  or theft                  41      32           9       21    15     5
Truancy or school
  suspension               16           8        8        4     6     6
Assault and/or
  battery                  11           9        2        3     7     1
Running away                   9        1        8       -      2     7
Arrested (crime
  unknown)                     6        5        1        2     4    -
Uncontrollable
  behavior                     4        2        2        2     -    2
Unspecified delin-
  quent activities             3        3       -        1      2    -
Sexual offenses                3        2       1        2      1    -
Sale or    use of drugs        2        1       1        2      -    -
Traffic warrant for
  arrest                       2        2       -        2      -    -
Illegal use of
  alcohol                      1        1       -        -      1    -
    Total with
      problems             98       66         32       39     38   21
    Total no
      problems             42       19         23       16      8   18
    Total known           Io        85         55       55     46   39
    Total unknown
      (note a)             30
          Total           '170
a/The officials we interviewed did not know if the youths were
  having any problems or not.


                                   17
     The data on page 17 shows that 78 percent (66 of 85)
of the delinquent youths experienced problems as compared
with 58 percent (32 of 55) of the neglected children, and
generally, problems of delinquents were more serious. The
age group appearing to have more difficulty was the 14-15 year
olds; 83 percent (38 of 46) experienced some type of be-
havioral problem. The group having the fewest problems was
the youngest--13 or under; 21 of 39, or 54 percent, had some
type of difficulty.

     As previously discussed, older youths in our sample have
been significantly less successful than younger children in
continuing their schooling following release. Although the
reasons they generally do not continue are many and complex,
a major reason, apparently, is that many do not want addi-
tional schooling.

     In our nationwide survey of institution administrators,
we asked the following question to gain broader insight into
the ambition of youths over 15 years of age.

     "17.   What are the interests and aspirations of those
            juveniles over 15 when they leave your insti-
            tution? (Check all thdt apply.)

            1     i      Go back to school
            2    1-7     Obtain vocational training

            3            Obtain gainful employment
            4    17      Join the service of the Armed Forces
            5   /-7      Return to their former street life
                           styles
            6   /_7      Other    (Specify)"


     As expected, most respondents checked more than one of
the above choices. Nevertheless, an analysis shows a very
strong preference for employment and/or vocational training
over goinq back to school. Thirty percent of the respondents
said the youths were interested in obtaining a job and/or
vocational training, but not in going back to school. Only
8 percent said that the youths would choose the option of
going back to school instead of working and 40 percent of
these wanted vocational training along with the education
received in school.


                                 18
     Although older youths have a strong preference for
gaining employment, our tracking showed most had a difficult
time holding a job. Forty-five youths had at least one job
some time after their release, but only 10 were employed at
the tinle of our fieldwork. Most of the jobs were unskilled,
and common reasons for termination were that they (1) quit,
(2) were fired, (3) were layed off, (4) had trouble with the
law, and (5) were underage.
INADEQUATE BACK-TO-SCHOOL TRANSITION SERVICES
     Much more could be done to help youths receive a con-
tinuum of appropriate educational assistance after they leave
the institution. In particular, the timely receipt of infor-
mation on youths' specific academic strengths and weak-
nesses, behavior problems, etc., can reatly assist receiving
schools in implementing effective instructional approaches.
Such approaches in turn can have an important bearing on how
well youths ultimately adjust to and benefit from the
educational process beyond the institution. As stated
earlier, most youths were not even enrolled in school or
attending regularly about 15 months after their release from
the institution.

     For the youths in our tracking sample, the institutions
initiated some type of contact with a potential receiving
school in only 16 percent of the cases. The nature and
extent of the contacts varied greatly, e.g., from mailing a
transcript to taking on an advocacy role by accompanying the
youths to the school and discussing their specific strengths
and weaknesses.

     Comments made to us by various institution officials
illustrate the shortcomings at the institution level. A
teacher told us that he had never been consulted about the
educational needs of youths at release. Some officials said
that plans for educational activities after release are not
their responsibility. And finally, another official said
that probation officers complain that the institution is
encroaching on their responsibilties if attempts are made to
arrange postrelease activities.
     Probation and parole officers were mainly concerned with
community safety and spent a great deal of time on crisis
situations, trying to keep juveniles out of trouble. Social
workers monitoring neglected children usually directed their
efforts   ward solving family problems. We found that--for
those youths who enrolled in school--p:obation, parole, and
welfare officers (continued)


                             19
     -- discussed academic recommendations with the institu-
        tions in 38 percent of the cases,

     --transferred records to the school in 12 percent of
       the cases,

     -- discussed educational recommendations with school
        officials in 34 percent of the cases, and

     --discussed behavioral problems with school officials
       in 30 percent of the cases.

The most common reason cited by these officers for not assist-
ing in school enrollment was that it was not their responsi-
bility.  Some other reasons given were that youths were not
interested in school, planned to seek employment, or ran away.

     Ofc'-ials at the receiving school, in some cases, knew
nothing   nut the youths they were to enroll.  According to
school o..cials, common problems were that:

     -- No advance notice of the enrollment was received.

     -- Records arrived after enrollment.

     -- Additional records were needed.

     -- Records did not specify academic needs.

     School officials told us that institutions should pro-
vide academic information on the child, such as transcripts
and test data, in order to (1) help the school to determine
the best teaching methods, (2) identify the student's strong
and weak points, and (3) tailor the curriculum to meet the
student's needs.  Some officials also wanted additional in-
formation, including psychological, medical, behavioral, and
family background data to help make proper educational place-
ment and provide supportive services to encourage continued
studies.

     A 1973 study made or Los Angeles County, California,
also found many problems with transition services provided
students upon release.  The study recommended that a compre-
hensive transition program be developed to provide assurance
that the students receive appropriate educational placement
in public schools after release.

     The study found that the period between students' re-
lease from the institution and their return to the community


                             20
is critical, and released juveniles often are confronted with
problems that are beyond their ability to resolve.  In a
number of instances, regular schools were not enthusiastic
about receiving a former problem student and devoted little
energy toward integrating the student into the system.   The
study also found that (1) some returning students were
placed in classes without regard to needs and abilities and
(2) a variety of problems during this period could result in
students having an overwhelming sense of frustration and
futility.

     The study disclosed little coordination of institutional
efforts to prepare students for return to their communities
and no coordination between institutions and regular schools.
Probation officers reported difficulties in discussing educa-
tional factors with school administrators.  The officers were
often unable to state in precise educational terms the status,
problems, learning, and study habits of returning juveniles.
Accordingly, the receiving school administrator usually had
only the youth's school transcript for use in selecting a
school program.

CONCLUSIONS

     The target population is an extremely difficult group to
teach.  The complexity of its problems, including its
severe educational deficiencies, raises a question concerning
the extent to which certain institutional programs can pos-
sibly assist youths in making educational progress or the
extent to which certain youths can benefit from the program.

     Many program participants are exposed to title I program
services for a relatively short period of time primarily be-
cause of their short stay at an institution.  Generally,
neglected children have an opportunity to make greater educa-
tional progress than do delinquents because neglected children
are in residence twice as long.  Furthermore, most delinquent
youths only receive program services for 6 months or less
while most neglected youths receiv3 program services for
10 months or more.

     Although some progress for all program participants is
entirely possible, it would nonetheless seem that certain
youths could ultimately realize greater benefits from the
program.  Specifically, those youths who continue schooling
after release from the institution have a greater likelihood
of building on and sustaining the gains achieved from the
program while in the institution, as opposed to those who do
not.


                             2.1
     Our review shows that younger children have a much higher
incidence of returning to school.  Older youths conversely
do not, and in many cases are not interested in school; they
generally appear more inclined towards obtaining a job.
Furthermore, many older youths have a greater tendency to get
into trouble with the law and are often reinstitutionalized.

     Relating the factors of age and length of exposure to
program services shows that the bulk of available program
resources go to those youths and institutions where a con-
tinuum of educational services is least likely to be achieved.
Institutions serving delinquent children receive nearly twice
the funding that institutions for the neglected receive.
Concerning age, the great majority of younger children are
in institutions for the neglected, which receive about
$11.7 million or only 28 percent of all program funding.

     What then can be done to enhance the effectiveness of
the program? For the most pert, it seems that factors dis-
cussed above are beyond the control of educators. The rela-
tively short exposure to program services is determined pri-
marily by the short period of stay in the institution. The
length of stay, in turn, is governed principally b factors
which are extraneous to the educational process,  .g., the
length of sentence, resolution of beha ioral and tImily
problems, location of suitable foster parents, etc.

     In comparison, providing older youths a continuum of
educational services following release would seem to be a
factor that educators could possibly address.  At the same
time, however, their task would be extremely difficult.
How can educators, fr example, deal with a situation where
a youth beyond the compulsory school age simply will not
attend scnool, or how cn an educator address the problems
created by a youth returning to crime or the peer group with
which the youth chooses to associate?

     Legislative changes would be needed to bring about a
more effective use of program funds.  Under the present leg-
islation, funds are allocated for institutions without con-
sidering the extent to which they can possibly meet the
children's educational needs or the extent to which certain
children are likely to benefit from program services. Avail-
able program resources are scarce and should be directed at
the target population on a more selective basis, with priority
consideration given to institutions that provide services over
a longer term and serve younger children.




                             22
     One way to accomplish this is to provide State educational
agencies a lump-sum entitlement on the basis of existing fund-
ing formulas for children in State and local institutions.
This would assure that individual States obtain the same
amount of funding for children in State and locally operated
institutions that they are now receiving. Once State educa-
tional agencies receive their entitlement, individual grants
could then be made on a competitive basis by the State agency
for the special educational needs of children in institutions
who would most likely benefit from the additional services
provided.
     State educational agencies would select successful appli-
cants on the basis of criteria to be established by the Com-
missioner of Education. Such criteria should give priority
to younger children and those children who receive services
over a longer period of time. Also, the criteria should em-
phasize that adequate prerelease and transitional services
be provided. Such services would provide greater assurance
that the children receive a continuum of appropriate educa-
tional services following their release from the institution.

     Presently, grant funds are generally expected to be ex-
ppnded during a 1-year period.  Under the proposed arrangement,
individual grants should be permitted to cover a period
greater than 1 year, in those cases where program partici-
pants are likely to be an residence beyond such a period.
Grants made in this way would (1) eliminate the administra-
tive burden that would be created if successful applicants
had to compete every year and (2) would provide assurance
that institutions would receive sufficient funds to cover the
period that the youths are likely to be in residence.


     To accomplish the foregoing, recommended revisions to
section 123 of title I, along with other necessary technical
amendments, are presented in appendix IV. Also, for com-
parison purposes, section 123 of title I, as it is presently
authorized, is shown in appendix V. It should be noted,
however, that the recommended course of action should be
considered net by itself but also in light of the findings
discussed in chapter 3 of this report.

 IACENCY COMMENTS AND OUR EVALUATION

     HEW did not agree with our proposal that program funds
be distributed on a more selective basis. HEW believes that
neglected children should not be given priority in the provi-
sion of services at the expense of delinquent youths and that
delinquent youths have the greatest educational needs.

                               23
       HEW, in effect, has stated that delinquent
 be given funding priority because they have the youths should
                                                  greatest edu--
 cational needs. The question of who has the greatest
 however; is a very difficult one.                        need,
                                     Delinquent youths are
generally older and, therefore, frequently further
grade level than neglected children; and for this behind in
                                                     reason, an
argument could be made that they should receive
 the provision of services. At the same time, an  priority   in
                                                   equally valid
argument could be made that younger children
priority for the simple reason that they are should    be given
                                               young. In
essence, why should they have to wait until they
and further behind grade level before they receive are older
                                                      priority
attention? It may be better to intervene at an
                                                  earlier age.
      Regardless of which group it is de-cded has the
                                                        greatest
need, the point of the report is that neglected
to have a greater opportunity to make substantial children   tend
than delinquents because the former are exposed     progress
                                                  to program
services over a much longer period of time. Furthermore,
younger children are more likely to continue their
                                                      schooling
after release from an institution.

     The report does not argue for increased assistance
for neglected children at the expense of delinquent       per se
although neglected children generally would tend     youths,
                                                 to receive
a larger share of program funds under our proposal.
short-term institutions for the neglected, and there there are
neglected youths who are older. Our proposal makes are
tinction between neglected or delinquent youths;     no dis-
                                                 the
is that priority should be given to younger children point
longer-term institutions.                             and

      HEW states that the program may be the "last chance"
older youths, and this may be a reason for                  for
                                            not
consideration to younger youths. It would appeargiving  priority
                                                   to us that
the "land of opportunity" is outside the institution
within. For example, other Federal programs exist      and not
                                                    which
provide educational and training opportunities,
                                                 such as adult
education, vocational rehabilitation, and programs
                                                    under the
Comprehensive Employment and Training Act.
     HEW states that the average length of stay for delin-
quents in an institution (10 months) is sufficient
                                                   time to
benefit from the proyLam.  HEW states that:
     "According to the report * * *, an average
    length of stay for delinquent youths is about
    10 months. For a youth confined to an adult
    correctional institution, the average stay


                             24
    is over 14 months.  The two groups tend to be
    the oldest children served by the program and
    represent 72 percent of Title I expenditures.
    GAO recommends that older youth, because they
    generally are institutionalized a shorter period
    of time and thus receive less program exposure
    than younger youth, be given a lower priority
    in receiving services.

    "If one compares the two averages cited above
    with the length of a regular school year, it
    appears that more than an academic year of in-
    structional exposure is available to these older
    students. Considering that the instruction of
    children in regular schools is disrupted annually,
    it seems that the average institutionalized,
    delinquent child (who is also probably older than
    the average neglected child) has enough exposure
    time to benefit from a Title I program.     Again,
    for many of these children,  this  may be the  'last
    chance' to receive this type  of  service."

     The answer to how much time is needed to benefit from the
program is one of definition and degree; presumably, a youth
could "benefit" with as little as 1 week's participation.
Furthermore, the answer as to what "substantial progress" is
(the desired effect on program participants intended by the
Congress) is also one of definition and degree.   We did not
attempt to define either "benefit"  or "substantial progress;"
our position is that the longer the  exposure to program serv-
ices, the more likely the benefits to be derived or the
progress made will be greater.

     HEW's comparison of institutionalized delinquent youths
with children in regular schools is hardly valid.  First of
all, children in regular schools more than likely will return
to school the following year (most title I programs in regular
schools are targeted at children in kindergarten through
grade 6).  Older institutionalized youths more than likely
will not return to school.  Secondly, the two groups are not
comparable considering the wide range of problems that insti-
titutionalized delinquents have.

     Finally, although HEW is correct in citing the average
length of stay for delinquents as 10 months, OE's recently
completed survey of State institutions shows that most
delinquents' actual exposure to program services is 6 months
or less.



                             25
       HEW states that:

       "Presently, grant funds are generally expected to
       be expended during a one year period.  Under the
       proposed arrangement, individual grants should be
       permitte& to cover a period greater than 1 year,
       in those cases where Title I participants are
       likely to be in residence beyond such a period.

                    *     *     *     *     *


      "It seems this suggested multiple-year funding
      would be inconsistent with the Department's view
      that Title    services are to be tailored to the
      individual needs of the children served.   Since
      participants change from year to year and annual
      needs assessments are required (including the
      identification of those most in need in local in-
      stitutions), multi-year projects for all Title I
      grantees would be inappropriate.   Secondly, under
      Section 412(b) of the General Education Provi-
      sion Act, applicant State and local agencies may
      "carry-over" Title I funds from one fiscal year
      to the succeeding year providing in effect a two
      year funding period."

       We agree that participants can change from year to year
or,   for that matter, even more frequently.  Regardless of the
length of the grant period, institutions should be held re-
sponsible for periodically assessing the educational needs
of the children and directing program services accordingly.

      Designing projects to run for longer than 1 year would
-not inhibit an institution's flexibility in providing services
 to children. On the contrary, we believe that multiple-year
 funding, where appropriate, would provide more flexibility to
 the institutions and would relieve them of the administrative
burden of applying for grants every year.

     The carryover provision can provide some flexibility to
State and local agencies in expending program funds appro-
priated for a given fiscal year. However, it does not negate
the desirability, under a competitive arrangement, for funding
beyond a 1-year period, where appropriate.

      HEW states that:

      "We would agree that services that facilitate the
      transition of children from institutions to normal


                              26
     community life, including school, are needed.
     We would point out, however, that such transi-
     tional services even those that are educational,
     involve the efforts of other agencies as well
     as the Title I applicant agencies. Transitional
     services for children leaving institutions and
     returning to some form of placement are being
     provided, although often inadequately, by State
     and local institutions, as well as other State
     or local   gencies such as parole, probation, and
     public wifare offices and juvenile courts. To
     address the need for transitional services in-
     tended to insure the child's continued education
     without attending to his or her needs for other
     types of community based services is unrealistic.
     "In view of the wide variety of agencies
     currently involved in providing services for
     youth upon their release from institutions,
     Title I should not be the vehicle for Federal
     assistance for the purpose of enhancing those
     services."
     The report points out that the children need assistance
to make a successful transition from the institution back to
school and that the social services and probation/parole
systems are generally preoccupied with other matters. Because
of this, we believe that the institutions should provide re-
ceiving schools timely information on a youth's specific
strengths and weaknesses to help the schools design an effec-
tive program of instruction.

     We share HEW's concern about the inadequacies in the
existing systems. However, we do not believe that this is a
good reason for not taking some action to assist the children.
Furthermore, what we have proposed--the forwarding of timely
information to receiving schools--can hardly be viewed as a
significant burden to title I institutions or being outside
the scope of the title I legislation.




                             27
                            CHAPTER 3

         SHOULD ACADEMIC EDUCATIONAL ASSISTANCE FOR

           INSTITUTIONALIZED YOUTH BE THE HIGHEST

                PRIORITY FOR FEDERAL ASSISTANCE?

     Chapter   2 examined the program   in the context in which
it was authorized,   that is, as an educational program.      This
chapter looks at   the program in   the context of broader   social
issues.

      In 1974 legislation was enacted which underscored the
concerns of the Congress and the executive branch that there
be a responsive and coordinated Federal effort to address
the problems of juvenile delinquency, and child abuse and
neglect.   Becausc of these expressc   oncerns, the many  rob-
lems faced by the target population, and the fact that the
program is the only Federal service program for institution-
alized neglected or delinquent children, our review included
a comparison of the importance of academic educational needs
with other needs of the target population.

     Our analysis of responses to our questionnaire sent to a
nationwide sample of institutions that receive program assist-
ance showed that while academic educational needs are impor-
tant, it is questionable as to whether providing services to
meet these needs should be the exclusive service or top prior-
ity of a Federal service program.
1974 LEGISLATION

      Two major pieces of legislation were enacted in 1974
to address the problems of juvenile delinquency, and child
abuse and neglect. The first, enacted on January 31, 1974,
was the Child Abuse Prevention and Treatment Act (42 U.S.C.
5101).   The second, tne Juvenile Justice and Delinquency
Prevention Act of 1974 (42 U.S.C. 560j) was enacted on
September 7, 1974.
Child Abuse Prevention and Treatment Act

     The at became law in response to the need for a
coordinated Federal effort to assist in solving the complex
and nationwide rcolem of child abuse and neglect. Speci-
fically, with regard to coordination, the law states that




                              28
     "The Secretary [HEW] shall promulgate regulations
     and make such arrangements as may be necessary
     or appropriate to ensure that there is effective
     coordination between programs related to child
     abuse and neglect under this Act and other sch
     programs which are assisted by Federal funds."

     To carry out  he   egislation, the act created the
National Center on Child Abuse and Neglect as a focal    oint
for Federal eforts aimed at identifying, treating, and
preventing the problem.   The center was placed uinder HEW's
Office of Child Development.

Juvenile Justice and Delinquency
Prevention Act o- 1974                   --

     According to the Juvenile Justice and Delinquency Pre-
vention Act of 1974, the Congress found that

     "* * * the high incidence of delinquency in the
     United States today results in enormous annual
     cost and immeasurable loss of human life, personal
     security, and wasted human resources and that juv-
     enile delinquency constitutes a growing threat
     to the national welfare requiring immediate and
     comprehensive action by the Federal Government
     to reduce and prevent delinquency."

     To carry out this critical mandate, the Congress estab-
lished the Office of Juvenile Justice and Delinquency Preven-
tion within the Law Enforcement Assistance Administration,
Department of Justice.  The Administration has been given
broad authority to carry out the act, which includes estab-
lishing overall policies and priorities for all Federal
juvenile delinquency programs and activities.

NATIONWIDE SURVEY OF PROBLEMS
OF INSTITUTIONALIZED YOUTH

     During our fieldwork, few local and State officials
told us that educational needs were clearly the highest pri-
ority of instititutionalized children.   The vast majority
felt that other needs exceeded  or were at least as important
as educational needs; those most often cited were social
and emotional needs.  Also, the program is the only Federal
service program of its kind.   Funds are made available
annually for institutions across the country to meet a par-
ticular need of institutionalized, neglected, or delinquent
youths.


                                29
     For these reasons, we sampled the opinions of institution
administrators nationwide as to the highest priority needs
of the target population.  More specifically, our purpose was
to examine the appropriateness of providing Federal assistance
to meet the   ademic educational needs of the target popula-
tion, as opposed to prciding assistance to meet their other
needs.  In brief, our anaiysis of questionnaire responses
shows tat, while academic educational services are important,
it may 'e more appropriate for Federal assistance to be focused
on other rehabilitative/treatment services.

Methodology

     Our   survey questionnaire ws   addressed to the top admin-
istrative official at the institution, e.g., the warden or
director. These officials were selected because we believed
they were in the best position to assess the overall needs
of the children and the capability of the institution to
respond to these needs. Furthermore, we felt that to address
the questionnaire to an individual responsible for providing
a specialized service (such as vocational education) would
run a high risk of introducing bias into our survey results.

     In the questionnaire, institutional administrators were
offered six types of services to consider in addition to aca-
demic educational services. These were

     -- health and developmental services;
     -- mental health services (social, psycholocical, psychi-
        atric, and counseling services);
     --vocational services;

     -- family services;
     -- diagnostic services; and
     --drug/alcohol abuse services.
Ail of the services are common rehabilitative/treatment serv-
ices found in an institutional setting. The services alsc
cover a broad range of activities, but this was considered
necessary, given the broad age range of the target population
and the diversity of its problems.




                               30
     To test the appropriateness of academic educational needs
as the top priority for Federal assistance, we asked institu-
tional administrators six questions.  The questions, our
rationale for asking them, and the survey results, are
discussed below.

     It should be noted that our survey results, with a few
exceptions, were esse.ntially the same, regardless of (])
whether the institution served adult     ffenders, neglected,
or delinquent chiidren;   (2)  what organization  (e.g., State
or local) administered  the   institution; and  (3) the age or
sex of the youths that  the   institutions served.    Consequently,
results displayed in  the  following  section  1o not  give con-
sideration to these  factors.

     A copy of the questionnaire is shown in appendix I.
We also included additional information on our methodology
and the technical aspects of our survey in appendix  II.

Survey results

     Question No. 11

      This question focused on the high priority needs of
institutionalized youth.    The results show that mental health
services and academic educational services were rated by in-
stitutional administrators   as being the highest priority
needs  of institutionalized  youths, with the former being
rated somewhat higher than the latter.    The table on the next
page shows our survey results. The highest possible rating
for each of the services is 5; that is, if all respondents
checked "essential" for a particular service, it would be
rated "5."




                               31
                    Relative Importance of Needs
                      of Insttutinalzed Youth
           Needs               Importance rating     Rating score
 Mental health services:       Essential                  4.8
     social, psychological,
     psychiatric, and
     counseling

 Educational   (academic)     Essential
   services                                               4.7

 Family services              Very important              4.2
 Diagnostic services          Very important              4.0
 Health and develop-          Very important
   mental services                                       4.0

Vocational services           Very important             4.0
Drug/alcohol abuse            Moderately important       2.9
  services

     The above table shows that the relative
                                               importance of
the services falls into three distinct
                                        categories.   Mental
health and educational services, with
                                       ratings of 4.8 and 4.7,
respectively, are in one category and
                                       are the highest prior-
ity needs of the target population.
                                      The next grouping, all
of which are considered "very important"
                                          needs, consist of
family, diagnostic, health and developmental,
                                                and vocational
services.  The rating for all of these services
                                                  is tightly
clustered around a score of 4.0.  And finally, drug/alcohol
abuse services, with a rating score of
                                        2.9, are in an in-
dependent class and are felt to be the
                                        least important.
     Question No.12

      Because our field testing of the questionnaire
                                                      showed
that administrators were often inclined
                                          to rate many services
as essential in question number 11, we
those services in order of importan:e, then asked them to rank
                                        i.e., the most impor-
tant would be ranked "1," the second
                                      most important would be
ranked ',"   etc.  The ranking of mental health and educational
services   hows that the former is clearly felt
                                                 to be the high-
est prior   y need of the target population.   Mental health




                              32
services received a score of 1.3, while educational services
received a score of 2.2

     Question No.13

     Institutions fce many obstacles in attempting to address
the problems of youth.   Some of the more conlmon are a lack of
resources; relatively short periods of incarceration; unde-
veloped state-of-tthe-art for treating and rehabilitating
youth; and underlying causes often being external to the
institution, i.e., the schools, home, community, etc.

     To obtain an idea of how serious each of these obstacles
is in attempting to meet the needs of the youths, we asked the
administrators to rank them.  Our concern was to determine
those needs of youths where the lack of resources or money
is perceived to be the greatest obstacle. Conversely, the
concern was also to identify those needs where money or
resources would tend to have a lesser impact because other
obstacles were felt to be more serious.

     Our survey results, which are presented below, show the
seriousness of lacK of money or resources as an obstacle.  If
money was felt to be the biggest obstacle by all respondents
in meeting a particular need, it would then receive a rating
of 5, which is the highest possible score; 1 is the lowest
possible score.

    Seriousness of money as an obstacle to            Rating

Correcting for lack of basic vocational
  training or job-entry-level skills                     4.7

Providing appropriate diagnostic services                4.7

Correcting mental health problems                        4.6

CorLecting health and development deficiencies           4.5

Correcting deficiencies in basic educational
  skills, i.e., reading and math                         4.0

Resolving home, environmental, and family
  problems                                               3.9

Providing appropriate drug and alcohol services          3.9

     The above table shows that the seriousness of money as
an obstacle falls into basically two distinct categories.


                             33
The first four problem areas listed are those where money
is likely to have the greatest impact.  The last three
problem areas listed, which include academic educational
problems, are the problem areas where money is likely to have
the least beneficial impact because of other obst cles faced
by the institution.

     Question No.14

     In this question, we asked institutional administrators
to rate the adequacy of the services that were being pro-
vided to the youths.  The rationale was to identify those
services which were in need of improvement. The results are
shown below.  The possible ratings range from "very inade-
quate" (4.5 to 5.0) to "more than adequate" (1.00 to 1.49).

                Extent to Which Needs Are Being Met

                                     Rating   Rating definition

  Vocational services                 3.2        marginal

  Family services                     3.1        marginal

  Drug/alcohol abuse services         2.9        marginal

  Diagnostic services                 2.4        adequate

 Mental health services:
     social, psychological,
     psychiatric, and
     counseling services              2.2        adequate

  Educational   (academic)
    services                         2.1         adequate
  Health and developmental
    services                         1.9         adequate
     The above table shows that the adequacy of vocational,
family, and drug/alcohol services are considered by institu-
tional administrators to be "marginal."  The other four serv-
ices, including academic educational services, were considered
to be adequate.

     Question No.15

     In this question, we asked the administrators the extent
to which they could solve youths' problems, if sufficient


                                34
resources were available. The results are shown below. The
ratings range from "little or no extent" (1.00 to 1.49) to
"very great extent" (5.0 to 5.4).
           Extent to Which Problems Could be Solved
            If Sufficient Resources Were Available

        Problem areas               Rating   Rating definition

Health and development
  deficiencies                        3.9      Great extent

Mental health problems:
    psychological, psychiatric,
    social, etc.                      3.9      Great extent

Deficiencies in basic educa-
  tional skills                       3.9      Great extent

Lack of basic vocational
  training or job-entry-
  level skills                        3.7      Great extent

Inadequate diagnostic
  screening                           3.7      Great extent

Home, environmental, and
  family problems                     2.9      Moderate extent

Drug and alcohol problems             2.9      Moderate extent


With the exception of home, environmental, family, and
drug and alcohol problems, administrators felt that they
could accomplish a great deal if sufficient resources were
available.
     Question No.20
      Because all of the institutions in our sample received
program assistance, it could be argued that institutions would
have possibly rated educational services differently had they
not been receiving this assistance. To check this possibil-
ity, we also asked institutional administrators ho- they
would allocate Federal funds among rehabilitative/treatment
services if no strings were attached concerning how the
funds should be used. The results are shown on the next
page.



                               35
                    How Federal Funds Would Be
              Expen-edf    No_Strlngs Were Attached
                        Concerning Threlr   Use


          Expenditure area                            Percent

  Mental health services:                               24.6
      social, psychological, psychiatric,
      and counseling

  Education   (academic) services                       19.0
  Family services                                       15.6

  Vocational services                                  15.2
  Health and developmental services                    10.9

  Diagnostic services                                   7.8
  Drug/alcohol abuse services
                                                        5.0
  Other                                                 1.9

      Total                                           100.0


     The results support our earlier findings.   That is, edu
cational services, with 19.0 percent of the resources, is
second to mental health services, where institution adminis-
trators would allocate 24.6 percer.r of Federal funds.

CONCLUSIONS

     The title I program was authorized in recognition of the
fact that institutionalized neglected or delinquent children
have special educational needs, as well as children attending
classes in school systems i.hroughout the country. The program
was not specifically created as part of an overall strategy to
address the social problems created by juvenile delinquency,
and child abuse and neglect, but nonetheless, today it is a
significant part of Federal efforts to deal with these
social issues, particularly in an institutional setting.
The program is the only Federal service program for insti-
'utionalized neglected or delinquent children.




                               36
     Given the findings of our review and the 1974 legislation
that emphasizes the Congress and executive branch's desire
for a responsive Federal effort to address juvenile delin-
quency, and child abuse and neglect, the services provided
under the program should be eamined in terms of their re-
sponsiveness to these issues.  With the scarcity of resources,
it is important that funds be expended in a manner which will
do the most good, and the type of services provided should be
determined as the result of a conscious examination of the
various options available.

AGENCY COMMENTS AND OUR EVALUATION

     In our draft report, we proposed that the Secretary,
HEW, and the Attorney General examine the appropriateness
and/or exclusiveness of academic educational services as the
top priority of Federal assistance for institutionalized
neglected or delinquent children.  HEW disagreed with our
recommendation (see app. VI), but the Department of Justice
agreed with us.  (See app. VII.)

HEW comments

     "We do not believe that the joint examination as
     recommended by GAO would be productive. The recom-
     mendation is based upon an analysis of the findings
     of a questionnaire which, in our ooinion, was not
     broad enough to obtain an accurate picture of the
     success of the Title I program in institutions.
     We would further point out that there is an on-going
     study being conducted under the auspices of the Office
     of Education. This study is much broader in scope,
     in that it solicits information not only from adminis-
     trators, but from program staff and recipients of
     Title I services, which appears to indicate that the
     priority assigned to educational services by the Office
     of Education, is appropriate."

     We do not agree with HEW's position that the study would
not be productive.  Considering such controversial issues
as juvenile delinquency, and child abuse and neglect, it is
hard to imagine that such a study is not warranted.

     The questionnaire survey was not designed to obtain an
accurate picture of tha success of the program.  The survey
was designed to gage the relative importance of each of a
wide variety of needs of the target population.  (See p. 29.)




                             37
     The ongoing OE study is not broader in scope than the
study we have recommended.  OE's study intends to

    "* * * measure the impact of the title I program
    on the basic reading and mathematics skills of
    the participants and on the self-concept of the
    participants as it relates to gains in achieve-
    men t.

     HEW also points out that neither the legislation nor the
regulations require that services under the program be limited
to basic skills.  HEW states that a wide variety of services
may be provided under the program, provided those services
are shown to be designed to meet the special educational needs
of children in institutions.

     Although we realize that other services may be provided
under the program, the program as authorized and implemented
is basically an education program. Further, as HEW points
out, the wide variety of services" must be shown to be relat-
ed to an educational goal.  The question posed by the report
is essentially--Should the thrust of the program be basically
education or basically something else?

     HEW provided technical comments on our analysis and in-
terpretation of the responses to questions 11, 14, and 20 on
the questionnaire survey.  HEW concludes that we have intro-
duced a bias into the questionnaire survey results.  HEW's
conclusion appears to be based on a belief that the top admin-
istrator may not be the mst unbiased person to report on the
needs of the institutionalized children and the resources
available to the institution.  HEW also bases its conclusion
on its interpretation of the responses to the three questions
mentioned above.

     In our opinion, the top administrator is the single
person in the best position to provide an unbiased broad
perspective related to the needs of the children served by an
institution and the resources available to the institution.
In addition, the responses to questions 11, 14, and 20, in
our opinion, clearly point out that academic needs, although
important, are not the only needs of institutionalized child-
ren and may not be their top priority need.

Department of Justice comments

     The Department was supportive of our recommendation. It
also felt that the Coordinating Council on   .3L'.   i'e Justice
and Delinquency Prevention would be the appropriate forum


                             38
for conducting the study. The Council was established by the
Juvenile Justice and Delinquency Prevention Act of 1974.

     We have no objection that the Council undertake the
study; our principal concern is that it be done.

RECOMMENDATION TO THE CONGRESS

     We recommend that the Congress direct the Secretary, De-
partment of Health, Education, and Welfare, and the Attorney
General to examine and report on the appropriateness and/or
exclusiveness of academic educational services as the top
priority of Federal assistance for institutionalized neglected
or delinquent children. More specifically, the organizations
to participate in such an undertaking should include OE, the
National Center for Child Abuse and Neglect, and the Office
of Juvenile Justice and Delinquency Prevention under the Law
Enforcement Assistance Administration.

      If it is determined that an academic thrust is not appro-
priate as the exclusive or top priority, then the thrust of
the program should be changed accordingly.   Furthermore, if it
is felt that the desired thrust is not within the legal bounds
of title I legislation, the report to the Congress should in-
clude legislative recommendations, if such action is needed to
bring about a more responsive program to assist instit tion-
alized youths.




                             39
APPENDIX I                                                                        APPENDIX I

                               DESCRIPTIVE INFORMATION ON

                             INSTITUTIONS INCLUDED IN REVIEW

                                                   Average     Average
                                      Number of    age of      months'
        Institution                   children    childan       stay         TitleTperogram
        CAMP PAIGE,                       94         15           7      Reading and math
        LaVerne, Calif.                                                  teachers for children
          An institution for                                             achieving below the
          juvenile delinquents                                           5th-grade level;
          operated by thi county                                         educational aftercere
          probation department;                                          counselor who assists
          academic school on
                          on                                             counselor who assists
          grounds, including a                                           former particoiants
                                                                         back into the com-
          special program using                                          munitv.
          audio-visual equipment
          to teach reading and
          math to nontitle I
          students.  Eight liv-
          ing units supervised
          by probation officers.

        YOUTH TRAINING SCHOOL,        1,140          20          IR      Remedial tchers
        Chino, Calif.
          A State-operated insti-                                        in eanq, lanquaq
                                                                            anmath; tyolaniq  la:
          tution for older,   hard                                       bind mnqath;Itynq
          core" delinquents;                                                                  lau-
                                                                         tin and       nstruionl
                                                                                         a
          three residential halls                                        trin and vclai.     na
          (400 wards per hall,riiarot                                                      h. Par-
          each with its own cell);                                       tbelowoant mradsthe
          school on grounds pro-                                         level and/or have a
          vides primarily voca-                                          referral from voca-
          tional education, with                                         tional instructor;
          academic courses avail-                                        psycholoqist,      0
          able.
                                                                         oercent title I
                                                                         funded; supervisor
                                                                         and steloraer .
         SACRAMENTO CHILDREN'S          109          14          18      One resource special-
         HOME, Sacramento,                                               ist who supervises
         Calif.                                                          remedial reading
           A private institution
                                                                         tutors for 10 child-
           for severely emotion-
                                                                         ten (tutors financed
           ally disturbed and/or
                                                                         under a Federal
           neglected children;                                           College-Work-Study
           residential therapy                                           Program) and performs
           programs including                                            vocational testing,
           an nte,.sive treat-                                           and makes vocational
           ment center for the                                           educational placement
           most severe cases and                                         and employment refer-
           group homes in the                                            rals.
           community. Most
           children attend an on-
           grournds chool for the
           edu:cationully handi-
           capped operated by the
           county.   Psychiatric,
           speech therapy, social
           work and other support-
           ing rograms available.

         LEROYS BOYS HOME,               81         13          13       One part-time tutor,
         Laverne, Calif.                                                 3 hours per night,
           Private institution                                           available to any
           for neglected and emo-                                        ward needing help.
           tionally disturbed                                            One full-time school
           boys.   Most children                                         liaison worker who
           attend a local public                                         checks attendance
           school, however, there                                        at local Shools,
           is a county-operated                                          tutors, and adminis-
           ongrounds school for                                          ters a behavioL
           the educationally                                             modification program
           handicapped.   Individ-                                       in which title I
           ual and group therapy;                                        funds buy candy,
           cottage living quarters;                                      toys, and other re-
           and group homes in the                                        wards for academic
           community.                                                    and behaviorial
                                                                         achievements.




                                         40
APPENDIX                                                                             APPENDIX   I

                                                Average      Average
                                  Number of      age of      months
       Institution                children      children      stay        Title I    rogram
      SACRAMENTO COUNTY BOYS          80           16           5      Remedial reading
      RANCH, Sacramento,                                               teacher, 50 Dercent
      Calif.                                                           title I funded,
        An institution for                                             serves 30 ouths who
        juvenile delin-                                                are achieving below
        quents operated by                                             the 6th-qrade level.
        the county proba-                                              Math teacher 30 Der-
        tion department.                                               cent title    funide.
        Pural "worKing ranch"                                          serving youths need-
        setting in which                                               Ing math credit for
           youths perform all                                          high school   radua-
        maintenance as work                                            tion.  Partially
        experience.   Youths                                           funded field trios
        work half-day and                                              for all youths;
        attend half-day aca-                                           testing material.
        demic classes on
        grounds. Medical,
        pyschological, reli-
        gio;s, and other
        speciao services
        available.

      LOYSVILLE YOUTH DE-           100           15           10      Remedial math tacher
      VELOPMENT CENTER,                                                for youths   :t- the
      Loysville, Pa.                                                   lowest test scorts;
        State-operated insti-                                          graphic arts; summer
        tution for juvenJle                                            camping program;   art
        delinquents. Treat-                                            of the salary co;ts
        ment cottages; on-                                             of a secretary and
        grounds school1 opera-                                         retail merchandise
        ted by local school                                            training; driver
        district provides aca-                                         education teacher;
        demic and vocational                                           equipment purchases;
        education; individual,                                         diagnostic and
        group, and family                                              counseling services.
        counseling.

      BETHANY CHILDREN'S            134           15         T.o       Educational coordi-
      HOME, Womelsdorf,                                    diverse     nator serves as
      Pa.                                                              guidance counselor
        A private institu-                                             and in proper school
        tion for neglected                                             program; tutors in
        children.  Residen-                                            basic subjects; art
        tial cottages, social                                          and craft teacher;
        services, psycholo-                                            summer recreation
        gist, and nurse.                                               teacher.
        Youths attend local
        public schools for
        academic and voca-
        tional education.

      ST GABRIEL'S HALL,            170           15            9      Summer half-day
      Phoenixville, Pa.                                                sessions taught in
        A private institu-                                             reading, language,
        tion for juvenile de-                                          math, social science,
        linquents. Group                                               and vocational sub-
        living; vocational                                             jects.  All youth
        guidance; professional                                         participate.
        social services.   On-
        grounds school includ-
        ing academic and voca-
        tional technical
        courses.

      ST. MICHAEL'S SCHOOL          101           14          14       Teacher aides pro-
      FOR BOYS, Hoben Heights,                                         vide reading assist-
      Pa.                                                              ance individually to
        A private institu-                                             all youths for 10 to
        tion for dependent-                                            30 minutes per day.
        neglected, and emotion-
        ally disturbed boys.
        Social services; dormi-
        tory living; ongrounds
        school centered around
        subjects of reading,
        math, and English.




                                           41
APPENDIX I                                                                       APPENDIX   I

                                             Average    Average
                                 Number of    age of    mocnths
      Institution                children    children    stay        Title   Iprogram
     LIFELINE
     HOME,      CHILDREN'S           31          14        12      Provides school oro-
              ansas City,                                         gram or. grounds for
     Kans.
       A private insti-                                           all children who have
                                                                  been expelled or who
         tution for ne-
                                                                  are failing at public
       glected children.                                          school.   The teachers
       Group living; re-
                                                                  provide instruction
       creation; therapy;
       prevocational edu-                                         in all    subjects.
       cation; most child-
       ren attend public
       schools. Consul-
       tant psychological
       services available.

     LAKE AFTON BOY'S               37          15          2     Instruction in basic
     RANCH, Wichita,
                                                                  math and reading
     Kans.
       A delinquent de-                                           skills ae provided
       tention facility                                           to all youths for
                                                                  2 hours ech day.
       operated by the
       county juvenile
       court. County staff
       provides house-keep-
       ing services.   On-
       grounds school pro-
       vided by local school
       district; no social,
       psychological, or
       guidance services
       available.

     WICHITA CHILDREN'S            43           9          3      Evening reading
     HOME, Wichita,
                                                                  classes for all
     Kans.
       A private temporary                                        children, math
       care facility for                                          classes for those
                                                                  below grade level,
       dependent, neglected,
       and abused children.                                       and arts and crafts
                                                                  in the summer.
       Social worPer; counsel-
       ing.  Wards attend
       local public schools.
       No psychological
       services.

     YOUTH CENTER AT               190          lo        14      Provides teachers in
     TOPEKA, Topeka,
                                                                  remedial reading,
     Kans.                                                        math, social studies,
       A State-operated
                                                                  and oral ad written
       institution for                                            communications,
       delinquents;
                                                                  4 teachers' aides,
       11 residen-                                                part-time program
       tial cottages;                                             director.  Program
       social workers,                                            serves those with
       psychiatrist,
                                                                  severe academic de-
       nurses, chaplain;
                                                                  ftcits as determined
       ongrounds                                                  by tests.
       academic school
       operated by the
       local school dis-
       trict; vocational
       education (thru
       Federal vocation-
       al rehabilitation
       program).
    HANOVER LEARNING
                                                                  Physical education,
    CENTER, Va.                                                   music, and behavior
      A State-operated
                                                                  modification
      institution for                                             teachers.
      younger delinquents                                                    Materials
                                                                  to support above
      stressing academic                                          classes. Participa-
      education.  On-                                             tion is by random
      ground school provid-
                                                                  placement.
      ing cademic and pre-
      vocational classes.
      Team approach to
      treatment; medical
      and recreational
      services.


                                          42
APPENDIX I                                                                    APPENDIX I

                                            Average   Average
                               Number of    age of    months
     Institution               children    children    stay        Title-ILpor[avm
     BEAUMONT LEARNING            221           16       6      Teachers for human
     CENTER, Va.                                                growth and develop-
       A State-operated in-                                     ment, math, reading,
       stitution for older                                      physical education,
       delinquents. On-                                         general equivalency
       grounds school pro-                                      diplomi; and arts and
       viding half-day                                          crafts, materials.
       academic and half-
       day vocational edu-
       cation programs; be-
       havior modification;
       cottage living;
       treatment team
       approach.

     VIRGINIA BAPTISTS           117            15      36      Reading and math
     CHILDREN'S HOME                                            tutors available te
     Salem, Va.                                                 all wards for 3 hours
       A private institu-                                       per week during the
       tion for neglected                                       evening.
       children. Children
       attend local public
       schoolu. Cottage
       living ongrounds;
       social workers;
       recreational facil-
       ities.

     PRESBYTERIAN HOME,            56           13      45      4th, 5th, and
     INC., Lynchburg, Va.                                       6th graders perform-
       A private insti-                                         ing below grade level
       tution for neglected                                     are tutored at ublic
       children. Children                                       -:hool one-half hour
       attend local public                                      per day, 5 days a
       schools. Primary                                         week in reading and
       empl.asis on family                                      math by a full-time
       counseling. Recrea-                                      teacher.
       tion; cottage living;
       work program.




                                           43
APPENDIX II                                                                                                                                           APPENDIX II

                                            QUESTIONNAIRE SENT TO TITLE I INSTITUTIONS

                                                 U.    S.   GENERAL ACCOUNTING OFFICE

                                     SIURVEYOF INSTITUTIONS        SERVING CHILDREN b .UVENILES

   INsTfRUCTONS                                                                                                                  FACILITY DA'I..
         lh puIrp,)      Of this survy     is to, find out what
          th pUrPneed
  the priority            of thi,  survy i    to finpriritd
                              instiltulionalized          ofut what               .             What type or population do you principally
                                                   childran     and                             serve?   (check ie)
  i vnile, ale (ildren          and yoith v:rider the legal
  age of 'i)  and which of these nJs          inst!cutionc can
  mo           ,uccciullv
                    it address.      Our ultimate goal is                                         I           /                Delinquent children & juveniles
  to asi   st he U. S. Cngress in deciding how the                                                                             (including status offend rs)
  Federal Government can best help institutions mlet                                            2          /              /    Adult offenders
  the needs of this population
                                                                                                3                         I    Neglected children & juvenile-s
         This questionnaire is designed to be answered                                                                         ( ;,.luding those dopendent and
  by Dire tors, Superintendents, Wardens or their                                                                               abhusu)
  designees who have ;.ll'overall view of the institutions'                                     4     /           0            Other (Specify)
  ┬░in ltions and operations.   It probably will take only
     'or  O minutes to Lomplte.    Most of  h  questions .                   2.                 What type of organization                            administers this
  can .,e answered in less than a minute by ei her checking                                     istitution?                        (check oe)
  boxes or filling in blanks.
                                                                                                I         /               /    State government
           Be assured that your responses will he ireated
 with the strictest      of cofidenc.     Theounty                                                                                       or    local government
 we are asking for respondent and institution Identi-
 tiatlon      is in the event we need further clarificationoundation,                                                                                     charity,   school,
      1 toc delete the InstlLuLoll's name ror        the fllow-up                                                              church,        tc.    (Specify)
 procedure scheduled for these who fail to return the
 questionnaile.       In fact, all namies of institt    Lions
 and rpondents will bC disassociated from this fcHrm
 and all records, as soon as your rsponsc have been
 nnal!ztd.      The respondent's names and the names of                                         institution designed, equipped and                              stafled    to
 their institutions will nut be used in this or sub-                                            serve at any one time?
 sequent reports.
                                                                                                      se ue t re or s(num ber                  of children and juveniles)
         Names are not important t  this study, but what
 youi, as a spokeserson for your instittion,    have to                      4.             Do you serve males,                               females,or    both?
 say is.    So please give us your most frank and honest
 assessments. We are most grateful for your cooperation,                                        1         /7                   Males
 for we can not make a mcaniingful report to the U.S.
 Congress without your assistance and participation.                                            2                 /            Females

        In answering this questionnaire, you certainly                                          3         /           i        Both
 may seek assistance or onsensus from key staff or
 associates o certain questions if you wish.            It is   5.                          How many fll                          time equivalent          staff members
 important that you provide a reasonable answer to                                          do you have?
 every question.    However, we do realize that there
 may be some instances where the information is difficult                                                                       (no. of full time equivalent
 to obtain.   In these cases, please provide us with your                                                                         staff Iembers)
 best estimate, rather than delay or fail to respond.          6.                           What is                       the estimated number of children or
 Please return the completed form in the self-addressed
 envelope withn 10 days after receiving this questionnaire.
                                    -   ----- --------
                                                  - ---                                     one time? (Answer for each appropriate age
                RESPOND)FNT 'NFORMATTON                       I                             group)                   Number of cni'drn
                                                                                                    Age ;'roup         or juveniles

                                                                                                          Under 6 year i of age
 (Name and phone     tIo. of person completing        form)                                  II           Under
                                                                                            2             Floi b6 to under 9
                                                                                            3             Fri;i 9 Lo und-  12
 (Title   if person compietiing     frni)                                                                 Frl,  9 L under 12
                                                                                            4             Fo    12 to under 14
                                                                         __1          _5                  From 14 to under                      16
 (Alldress)
                                                                         I
                                                                         (Adrs)             f             i rli               11, to under 18
                                                                                            7             From I1                to iurlder     21
                                                                         I                  -             Adulto over 21 years
                                                                         I                 44o                        age




                                                                 44
 APPENDIX II                                                                                                                                                  APPENDIX II

                                                                                                       II.     Ihat arc te  priority needs of the childr,-n t,-
 7.            Do you ometimes keep childre, or juceniles                                               juvenile    i  your institution!  Do not consider Whtitl-
               for a short tima  less than 30 days, e.g. for                                           er or    ,.your insitution has the capability or auth-
               observation, diagnostic or referral purposes)?                                          ority to address these needs.      Indicate your answers
                                                                                                       by chitckin. one and only one priority rating coluiami
              I/       /         yes                 2          /     no                                fo r    each row or priority need.)

                   It yes, continue; if                  no,        o to 9.

                                                                                                                                                     Priority                   '
 8.                About how many chilIren or uveniles do you                                                                                        Rating            Y
                   usually keep foe less than 30 days?                                                                                                                      c   0



                                                          no. of children or                                                                                .Z'   '     /           ,s
                                                           jullenes                                                                              /



      What is the average length of stay for child-                                                              PRI(RITY NEEDS
      ren or juveniles in your institution?   Exclude                                                             RI       NEES                               _
      those who stay for less than 30 days.   Please                                                    1.     Health and deve lopmental
      give us vour best estimate for each age                                                                  services
      group if actual figurts are not avallbl.                                                         2.      Mental   ealth servics:
                                                                Average length                                 social, psychological,
                           Age group                           of stay in months                               psychiatric, and counsel-
                                                                                                               ing services
         l.         Under 12            years
                    of age                                                                              3.     Educational (academic)
                                                                                                               services
      2.            From 12            to   under   18                                                 4.      Vocational   services

      3             From 18 to under 21                                                                5.      Family services
                                                                                                       6.      Diagnostic services
                                                                                                        7.     Drug/alcohol    abuse
                                                                                                               services                    I


10.            In general, where are the basic educational                                             i2      onsider only those needs in question 11 bov,
               services provided (Kindergarden thru grade                                                ,hat yu. checked as essential,  Now rank tlest:
               12)?  (check one)                                                                        ssclntial needs by order of deccreasin, impioltanc,.
                                                                                                       Do this by selecting the most important of al I th
               i.      //              On Campus                                                       needs you considered essential.    Rank this    st hy
                                                                                                       circling.    Then do the same for the remaining
               2.          /_          Off Campus                                                      csstntial needs, ranKinig them 2nd, 3rd    tc., ultiL
                                                                                                       you have ranked each of th needs chlcke-d as
               3.      /_              Both on & off Campus                                            essential. (PEMEMBER EACH NEED CAN HAVE ONLY ONE
                                                                                                       UNIQUE RANKING SCORE.  Check for this by making
               4.          //i         Not provided                                                    sure you do not have more than one circle                            in eacb
                                                                                                       row or colun.)
                                                                                                               PRIORITY NEEDS                          RANKING

 Note:             In tihe following section we are seekin                              answers        1. HIealth and develop-         Ist 2nd 3;d 4th 5th 6th 7th
                    to five ajo)o questions:                                                              mental services
                                                                                                       2.      Mental health setv-
               o-What art the priority needs of the children                                                   ices: social, psy-
                 or juveniles in your institt tion?                                                            chological, psychil-
                                                                                                               tric , and counse ling 1s1 2nd 3rd 4th 5th                       th 7th
               o-What are your Ila jul                   problems          in   lmeetinlg these                services
                 needs?                                                                                i.      Educational (aca-      Ist 2rd Jrd 4th 5th                       th 7th

               o-llow well are these tneeds being                               et?                            demic) services
                                                                                                       4,      Vocational services     1st 2nd 3rd 4th 5th 6th 7th
               o-What needs can you most ffectively meet,                                              5       Family srvics            st     rd     th     h 7th
                 given the constraint  of the institutional
                 setting and an interventioti role.                                                    6.      Diagnostic   services   1st 2nd        3rd 4tth 5th              th       th

               o-lIhat services are most                       neded when Lt,                          7.      Dru/aicool as                   2ld    J3d   41t       5ti       tlh 7ttl
                    childrn            leave the     insttulion.




                                                                                                  45
 APPENDIX II                                                                                                                          APPENDIX II
   I i. Rank the fol lowin, baarriers that you ace in                          11.       BARRIERS TO CORRECTIN:
   meeting, each specilti ne*d areas numerated
                                                                                         DEFICIENCiES IN BASIC
   b low.    Rank ach bahrrier       in order of decreasinl
                                                            h                            EDUCATIONAL SKILIS, I.e,I
   seriousness.    Do this by selecting the most serious                                 READING: & MATH                            RANKINC
   barrier and rankin       it first    by circling the num-                          I. Iack of resources
   h-   I.     Contine Iankin; the remain!           !arrie rs
   hy circling the nurb, rs 2nd, 3rd, 4th                                             (money, adequately       rained
                                                     c until                         staff,   quipmntit      ilate-     Ist
  all the barriers in thi particalar nee              ed are
                                                                                                                               2nd     3rd     4th        5th
                                                                                      rials, faci:itis,        tc
   ranked.    For xalpli if you felt that 1 . o                                      2 Relativly brief perod                            rd           h
   rtesources was thip ut       serious barrier to correc tin                                                                                                   h
                                                                                     of stay i institution
  health and development deficiencies you would                                       3, Underlyine causes of th
  circle the number lt i           tnc 1st row under Lh                              problems are external         o
  neil area hetding. fIf       you felt    that t                                     the institution, i.e., the lIst          2nd     3rd     4th        Sth
  "State-of-Knowltdge" was the 2nd most serious                                      home,   orasunity, schools,
  barrier to correcting health and development
  deficiencies you would circle the number 2nd in                                    peer pressure,     stc.          i
                                                                                     4. "The State-of-Knowlcdgct"
  row 4 ol the need area heading.           Complete hy ranking                      in the field of treatin       ;
  all the rmainin, barriers in the need area until                                   for child   eglect and             tst    2nd     3rd     4th        'th
  all  the baricrs    for each need area are ranked.                                 delinquiney is not wll
                                                                                     deve loped.
  I.   BARRIERS TO CORRECTING
                                                                                     5. Other (Specify)
       HEALTHI AND DEVELOPMENT
       DEFIC:ENCIES                             RANKING                                                                 Ist    2nd     3rd     4th        5th
   I. Lack of resources
   (money, adequately trained
   staff, equipment & ate-    lIst              3nd   'rd    4th    5th         IV. BARRIERS TO RESOLVING
   rials, facilities. etc.)                                                           HOME ENVIRONMENTAL AND
   2.                                                                                 FAMILY PROBLEMS                          R&NKING
   2. Relatively
      Relativelyv brief
                    bri    period
                           period       1st     2nd   3rd   4th     5th             1. Lack of resources
   of stay in institution.
                                                                                    (money, adequately trained
  3. Underlying causes of the                                                       staff, equipment & at -        st          2nrd    3rd     4th        5th
  probinms art, external to                                                         rials. facilities, etc.
  the institution, i.e., the                                                        . seatil
    '                                                                                               biefin        1Is          2nd     3rd .th            5th
    ic, conuunity, schools,      Il     nd  Ird  ith  5th                          2
                                                                                   of    e                                     2n d    3
  per pressu r,   etc..                                                            3. Undrlyin      causes of thw
                            ---.    "Th Stato-u-Knowlede"                          proble-ms are external to
                                                                                   the institutior., i.e., the    Ist         2nd
  in the fie Id of treating                                                                                                            3rd     4th        5th
                                                                                  home, conmnunity, schools,
  for chi'd neglect and                  1st    2nd   3rd   4th    5th            peer pressureetc
  delinquency is not well
                                                                                  4. "The State-o-Knowledge"
  developed.
                                                                    _              in thi fi-ld   o(f treating
  5.   Other (Specify)                                                             for cild nglect and            Ist         2nd     3rd      4th        ,th
                                        Ist 2nd       irrd 4th     5til           delinquency is not well
                                                                                  developed.
                                                                                  5. Other (Specify)
11.  BARRIERS TO CORRECTING
                                                                                                                       Ist    2nd     3rd     4th        5th
     MENTAL HALTH,
     SOCIAL,      COUNSELING
     PROBIEMS                                    RANKINCG                      V.      BARRIERS TO CORRECTINt;
   I. Lack of resources                                                                FOR ACK OF BASIC
  (money, adequately trained                                                           VOCATIONAL TRA-NING OR
  staff, equipment & mate-             'st     2nd    3rd   4th    5th                 JOB ENTRY LEVEL SKILLS
   rials, facili4 lcs       etc.)                                                      IF APPROPRIATE.                         RANKING
  2. Relatively brief period
                            y         '1st     2nd    3rd                            1. Lack o resources
 ofstay    ii institution.                                  4th    5th               (money, adequately trained
  of3.
  3. Undstarlyin
       Underlying causes
                       causes of   te
                              of the;                                                staff, equipment &mate-
                                                                                     rials
                                                                                                                       Ist    znd     3rd     4th        5th
                                                                                             facilities,  etc.)
 problems are external to
                                                                                     rias faciities etc.)
  the institution, i.c.,            I
                                 the' tst      2rd    3rd   4th                     of stay in institution.            It     Znd     3rd     4th        5th
 hoe, comniullity, schools,
                                                                                    3. Underlying causes of the
   eer pressure, etc..
                                                                                    problems are external to
 4, "The State-of-KnowledeL" 1the
 in the tield of treating                                                                institution, i.e.,     the    Ist    2nd     3rd     4th        5th
                                                                                    home,   ommunity, schools,
 fo- child neglect and                Ist      2nd    lrd   4th    5th
 dii.Lquniicv is not well                                                           peer pressure, etc..
                                                                                    4. "The State of-Knowledge"
 5.
     ~                                                                              in the field of treating
 5 Oth.       _Sp cif/ )                                                            for child neglct     and           Ist    2nd     3rd     4 th       rs
                                        Ist    2nd    3rd   4th    5th              delinquency i not well
                                                 dIped.                             4.  "Th  tadeveloped.
                                                                                    5. Other (Specify)    _       g

                                                                                                                       lst    2nd     3rd     4th        5th




                                                                          46
APPENDIX II                                                                                                                  APPENDIX II

       13.     CONTINUED:                                                           i.   Considering the above problems and the con-
                                                                                    straints of your institutional setting, in general
                                                                                    to what extent is your institution actually vneeting
                                                                                    the needs of thl children or juveniles you so:vt?
                                                                                    (Indicate your answer by chicking one and only one
V1.        BARRIERS TO PROVIDING                                                    adequacy rating colurn for ach row or priority
           APPROPRIATE DIAGNOSTIC                                                             r             oleed.)
           SERVICE                                   RANKNC
      I  iLack of resources
      (money, adequately trained                                                                                     A                  /   /
      staff, equipment & att-            list       2nd     3rd   4th   5thA
      -ials, facilities, etc.)                                                                                                 t
      2. Relatively brief period         It         2nd     3td   4th   5th
      of stay in institution .                st'   2nd     37d   4th   5th

      3. Underlying causes of the                                                      P
      problems are external to                                                         PRIORITY NEEDS
      the institution, i.c, the          ist        2nd     3rd   4th   5thh                  and deve
      home, community, schools,                                                     1. Health and develop-
      peer pressure, etc..                                                          mental services
      4. "The State-of-Knowledge"                                                   2. Mental health services:
      in the field of treating                                                      social, psychological,
      for child neglect and               ist       2nd     3rd   4th   5th         psychiatric, and
      delinquency i   not well                                                      counseling services
      developed.                                                                    3. Educational (academic)
      5.     Other (Specify)                                                        services
                                         I_____
                                           st 2nd           3rd   4th   5th         4. Vocational   services
                                                                                    5.   Family services
                                                                                    6. Diagnostic services


VI1.       BARRIERS TO PROVIDING                                                    Services
           APPROPRIATE DRUG AND
           ALCOHOL SERVICE       ;                  RANK1NG
      i. Lack of rsources                                                           15.  Assumin;g sufficient resources (oney,    adequate
      (money, adequately trained                                                    staff, etc.), to what extent it at all,    can you
      staff, equipment & mate-            i t       2ld     3rd   4th   5th         correct the following problem areas     Before you
      rials, facilities, etc.)                                                      answer this question, be sure you carefully weight
                                       it                         ~the                  constraints of your institutional setting
      2. Relatively brief priod        lit          2nd     3rd   4th   5th         (except for money) considered in question 13 and
      of stay in institute ion.         |_I         ___2d   3rd   4th   5t          vour role as an institution for intervention. (Mark
          '   Ondcrlyin,:cause*s
       3. Underlying   causis of of they
                                     Lhe;                                           your answer by checking one column box which indicates
      problems are external to                                                      the extent of correction, for each row or problem
      the institution, i.e.,       the    Ist
                                          1         Znd     3rd   4th   5th         area                             EXTENT OF
      home, community, schools,                                                                                      CORRECTION
      peer pressure, etc..              ]
      4. "The State-of-Knowledge"I                                                                                                      +
      in the field of treating
      for child neglect and              1st        2nd     3rd   4th   5th                                                        4/
      delinquency i nut well
                                                                                           PROBLEM AREAS
      5.   Ohcr (Specify)
                                       5.!Ocher (Spetfy)1                           I. Health and development            1                      ;
                                         1st  2nd   3     4tL           5.h         deficiencies
                                                                                    2. ental health problems; psy-
                                                                                    chological, psychiatric, social,
                                                                                    etc.
                                                                                    3. Deficiencies in basic educ-
                                                                                    ational skills
                                                                                    4. Lack of basic vocational
                                                                                    training or job entry level
                                                                                    skills
                                                                                    R. Home, environmental and
                                                                                    family  roblems


                                                                                    7. Drev and alcohol problems




                                                                               47
      APPENDIX II
                                                                                                                                                                             APPENDIX             II

       lb.     Consid r Ih. priority ned o the cllildren o
                                                                                                               I . (onside      th problllm, of t1l handica.pp d
       juvI rli lt , WhIC thlvLy liav your institution.
                                                           As in                                               children o     juveniles.    houbhly, about what percnt
      thi previous qutstion, rank ord r these needs
                                                             in                                                of your ctildr n    or juvIniles havl rhe fllowin
      order of ducreasiln importance.         Iliatia, indicat,
      the hiehF'st prioritv need by circrl in
                                                                                                         .       pecific types of handicaps: physical handicaps,
                                                    the olumni                                                 Iinlltal r-tardation, sriouo Ileotional iisturlaliu,
      ni-bri        It o, th.  elond hlighe-t by  ircling' 2nd                                                 specifLic l arnin, diabiliti    esI

            PRIORITY NEEDS                                                          RA;iI N                              Phys i a lly         halld i app d
     1. Ira th and de   v lop
     mental services                                                                                                     Men l ly r tardd
                                     st                                                                7th               Sriouly   emotionlly distrbed                       _
     2. Mental he althI srvic r s
     sueital, psychlolu     acl,
                              l.  l.t   2nd 3rd ath                                           th      7th            Sprc;fic larlnin     disahilitits
     psychiatrlic, and cousls. 1-                                                                                    (     , disil,       lv.)
      I. Eduational                                                                                                  Ovh, r haridicapp,,d
                                              (academic)           1ctOt                                                  r i iOlappt
                                                                                                                               l        d
     s.    Vocational                  scr L                       Ist 2nd 3rd 4ti 5thIlth            7th
          . rami               screices                                2
                                                                   Ist       rd   3rd 4th          t___hio
                                                                                                      h7t
     (. Diagnostic services                                        Ist 2nd 3rd 4th 5th 6th 7th
     7. DIru,/alcohol abuse                                       Ist 2nd 3r
      s  _rvices                                                                 th th  th 7t
                                                                  l    nd rd ntb    th th 7th                                           tal     '7. lndicapped
                                                                                                              20.    If no striniss were attached to the Federal monie.
     17.    What are the interest and                                                                         youL are now receiving or you expect to receive,
                                         spirations of those                                                                                                     how
                                                                                                              would you allocate these nonies aong the- ollowing
      llillnil'S oVeI 15 whent they leavr your institution?
                                                                                                              areas'    (Indicate your answer by wriLing tile
      ICh,cY all that apply.)                                                                                                                                   of the
                                                                                                              total Federal lunds that you would spend in
                                                                                                                                                              ach area.)

            I                                                                                                     Expenditlre area
                  /             (;     ba k to school                                                                                                                          of      lotal
                                                                                                               1. Health ard dev, luIpmental
                                                                                                              scr ices
     2      /          /          l
                                 lLbain            vocational            traiin,,                             2. Mental health servirce: social,
                                                                                                              psychonloia I, poychia i,, , and
                               /Obtin
                                    ia                  inn:ul    tliplyr-ilt.                                counselin          ser-ices
                                                                                                                             f
                                                                                                              3. EFucational (academiic) services
     4           //             loin          t         service      of tht       Armed Forces                4. VoriLiona  s-rvice,
            i          /i R ctuoi               to th        i     l eorr-        street                     L. Dia
                                                                                                                  .      ti cservices
                               lii,           st,-lr                                                            Drut/a.,cohol alus                  se rvices
                                                                                                             h. Other
      b     /    7             otill              Spc ify)
                                                                                                                                            TOTAL                                   1007

                                                                                                              1.    If     you have           addi tiolal   coillilt   ull   ally Il       tihe
                                                                                                              items within tile ustionnaire or re attll tpics    not
                                                                                                             coverted, please express your views in th
                                                                                                                                                           pace below.
18.  Prior  to or durinxL their stay at your instit-                                                         (Use the hack of this    theet if necessary.)  Your
ution, are  the children or   uveniles sub jected to                                                         answers and commarnts will be greatly appreciated.
a  iagnostic screenin process d i ned to test
for and identify specific types of handicaps
which may be present (i.e., Iarnine disabilities,
mental retardaLion,    tc,)


I/          /Y             s                  2 _/           No              /      /   Not sr


II v ,                conl                ;       ot
                                                  iu,     wis,       .o    to Z0.




                                                                                                         4P
APE'ENDIX III                                            APPENDIX III



                     ADDITIONAL INFORMATION ON

                QUESTIONNAIRE METHODOLOGY AND RESULTS

     The reported results of the questionnaire survey are
based on a statistical, analysis of questionnaire returns.
The returns represent a sample drawn from a universe of
institutions prepared by OE and used -o compute fiscal year
1976 title I fund allocations.   For p  poses of our sample,
the universe was grouped into six strata--State and locally
administered institutions were each classified as institu-
tions serving delinquents, neglected children, or adults.

     For local-adult, and State-neglected institutions, the
entire population was polled because its size was relatively
small.  For the remaining four strata, sample sizes were
determined to obtain comparable error rates among the strata.
The absolute size of the samples was determined by nonresponse
and sampling error considerations.  The nonresponse rate was
anticipated to be 25 percent, and it was not considered prac-
tical to have sampling errors greater than 10 percent at the
95-percent confidence limits.  The initial sample design
yielded sampling errors that ranged from 5 to 8 percent for
nonresponse rates varying between 0 and 30 percent.  The
table below shows our initial sampling plan.

                     INITIAL SAMPLING PLAN

Population           Population        Sample   Percent of population
  strata                size            size           sampled
                                                       size

Local   neglected        999             250              25
Local   delinquent       402             160              40
Local   adult             43              43             100
State   neglected         28              28             100
State   delinquent       324             150              46
State   adult            240             140              58

    Total              2,036             771              38




                                  49
 APPENDIX III                                                              APPENDIX III




     In population surveys the implementation of a sampling
design does not always proceed as exactly as planned because
one does not have complete control of the sample.  For
example, the population or sampling universe may change; the
nonresponse rates may be worse than expected; the response
rates and, hence, the sampling errors among the stratifica-
tions may vary from their predetermined values; and every
respondent may not answer every question.

      For our survey, the universe changed between the time
the sampling elements were identified and the time our sample
was taken. This change did not come as a great surprise be-
cause the fiscal year 1976 allocation data that we used to
derive the universe was based on fiscal year 1974 attendance
data. Consequently, the universe did not consider that, by
the time our sample was selected, (1) some institutioi   had
closed and (2) opulation changes apparently had taken place.
With regard to .,e latter, adult correctional institutions
indicated that no youths under 21 were in residence at the
time our questionnaires were filled out. Also, a number of
the returned questionnaires noted that the addressee was un-
known. The following table enumerates the invalid sample
units, and shows the sizes of the final samples and the
adjusted universe.


                                  ADJUSTED SAMPLE DESIGN

                                  Invalidsamp.     Elements

                                                    Do not               Adjusted
                                                    serve                universe      Final
  Type of            Initial    Initial             youths    Address   (projected)   sample
institution          universe   samele    closed   under 21   unknown    estimates     size
Local   neglected       999      250         2         -        8           959        240
Local   delinquent      402      160         1         -        5           387        154
Local   adult            43       43         -         4        1            38         38
State   neglected        28       28         2         -        -            26         26
State   delinquent      324      150         1         -        2           317        147
State   adult           240      140         -        41        -           170         99
    Total            2,036       771        .C        45        16        1,897        704




                                            50
APPENDIX    III                                          APPENDIX III




     The deletion of invalid sample elements and the
corresponding adjustments decrease the sample and universe
sizes.  However, the corresponding decrease in the universe
size tends to offset the increase in sampling errorrs that
result when the sample size is reduced.  For example, a sam-
ple of 250 from the local neglected strata had a sampling
error of 5.4 percent, while the adjusted sample and universe
sizes yielded a sampling error of 5.5 percent.

     The overall nonresponse rate to the questionnaire was
about 27 percent, which is about what we anticipated.  This
nonresponse rate increases the sampling error from about
5 percent to near 8 percent; however, this error is still
within the upper tolerance level set at 10 percent.

     The 27 percent consists, in part, of 20 percent that did
not respond either because the questionnaire was (1) returned
substantially incomplete, (2) received after our cut-off date,
or (3) not returned.  The other 7 percent consists of item
or individual-question nonresponses.    -e the nonresponse
rate ranged from 0 to 18 percent.  The most important factor
influencing the item-nonresponse ra*e appeared to be the
irrelevancy of the item to the individual instead of the
complexity, sensitivity, or position of the item.  The re-
sponse rate, by strata, is summarized below.

                  Response Rate For Questionnaires
                    Returned n a Useubie Form

                                          Useable
    Type of              Sample           returned            Response
  institution             size         gquestionnaires          rate

Local   neglected          240              191                  80
Local   delinquent         154              124                  81
Local   adult               38               27                  71
State   neglected           26               19                  73
State   delinquent         147              119                  81
State   adult               99               82                  83

    Total                  704              562                  80




                                  51
 APPENDIX    IV                                      APPENDIX IV



       RECOMMENDED REVISIONS TO SECTION 123 of TITLE I,

        SHOULD IT BE DETERMINED THAT THE PROVISION OF

      ACADEMIC EDUCATIONAL SERVICES IS THE APPROPRIATE

            PROGRAM THRUST FOR INSTITUTIONALIZED YOUTHS

     To provide greater assurance that institutionalized
children receive maximum possible benefit from
                                                title I
program services, the Congress should amend title
                                                   I of the
Elementary and Secondary Education Act of 1965.
                                                  The amend-
ments should combine, into a single program, that
                                                   assistance
presently authorized for institutionalized children
                                                     under
section 103 (local institutions) and section 123
                                                  (State
institutions).

     Authorization for the new program should be
in a revised section 123--Programs for Neglected contained
                                                 or Delinquent
Children.  Suggested language for the new section 123, along
with other necessary technical amendments, is presented
below.  Also, for comparison purposes, the current section
123 is shown in appendix V.

       PROGRAMS FOR NEGLECTED OR DELINQUENT CHILDREN

Sec. 123. (a) - A State education agency, upon
                                               application
to the Commissioner, shall receive an entitlement
                                                   for any
fiscal year under this section to supplement existing
                                                       educa-
tion programs for neglected or delinquent children
                                                    residing
in State or locally administered institutions,
                                               including
adult correctional institutions (but only if such
                                                   entitle-
ments are used only for children in such institutions).

      (b). Except as provided in sections 124 and 125,
                                                       the
entitlement which the State Education Agency (other
                                                    than for
Puerto Rico) shall receive shall be an amou.c equal
                                                    to 40
per centum of the average per pupil expenditure in the
                                                       State
(or (1) in the case where the average per pupil expenditure
in the State is less than 80 per centum of the average
                                                        per
pupil expenditure in the United States, or (2) in the case
where the average per pupil expenditure in the State is
                                                         more
than 120 per centum of the average per pupil expenditure
the United States, 120 per centum of the average per pupilin
expenditure in the United States) multiplied by the aggre-
gate of the number of children in State and local institu-
tions.




                                52
 APPENDIX IV
                                                   APPENDIX IV



            (c).  For State supported or operated schools,
 including schools providing education for children
                                                      under con-
tract or other arrangement for the State, the
                                                number of
children shall be based on average daily attendance
                                                       data, as
determined by the Commissioner, using the most
                                                 recent fiscal
year for which satisfactory data are available;
                                                  for locally
adminstered institutions, the number of children
determined on the basis of caseload data, as       shall be
                                              determined
by the Commissioner, for the month in which
                                             the most recent
reliable data is available to him.   The entitlement which
Puerto Rico shall be eligible to receive under
shall be arrived at by multiplying the number    this section
                                               of children in
Puerto Rico counted as provided in the preceding
                                                   sentence
by 40 per centum of (1) the average per pupil
                                               expenditure
in Puerto Rico or (2) in th3 case where such
                                              average per
pupil expenditure is more than 120 per centum
                                               of the aver-
age per pupil expenditure in the United States,
                                                  120 per
centum of the average per pupil expenditure
                                             in the United
States.

            (d).  To accomplish the purpose of this section,
a State education agency shall make grants directly
                                                      to State
or local institutions, local education agencies,
                                                  or other
public and private nn-profit agencies.    Such grants shall
be made in accordance with criteria set forth
                                               in regulations
established by the Commissioner.   Such criteria shall include
requirements that (1) priority in the use of
                                              funds provided
under thiz   ection shall be given to programs and projects
designed to aid (A) younger children and (B)
                                              those children
who are provided lolg-term institutional care
                                               and (2) adequate
prerelease and transitional services be provided
                                                  to insure
that children, to the extent possible, receive
                                                appropriate
educational placement following their release
                                               from the insti-
tution.

           (e).  Payments under this section shall be used
only for programs and projects (including the acquisition
of equipment and where necessary the construction of
                                                     school
facilities) which are designed to meet the special educational
needs of such children.

            (f). Notwithstanding section 412(b) of the General
Education Provisions Act or any other provision of law, any
funds from appropriations to carry out any programs
                                                    to which
this section is applicable during any fiscal year, which
                                                          are
not obligated and expended by agencies or institutions
                                                        prior
to the beginning of the fiscal year succeeding the fiscal
year of which such funds were appropriated shall remain
available for obligation and expenditure by such agencies
                                                           and


                             53
APPENDIX IV                                      APPENDIX IV




institutions during such succeeding fiscal years as the
Commissioner may determine.



Technical amendments to   title I

     The effect of the technical amendments is to eliminate
the entitlement under section 103 that local education agen-
cies receive for neglected or delinquent youths in locally
administered institutions.  Such entitlements in turn would
be set aside under the new section 123.  The amendments are:

    -- Delete subsection 103(a)(3)(A), and redesignate (3)
       (B) as (3)(A) and (3)(C) as (3)(B).

    --Under subsection 103(c)(1), add the word "and" after
      the phrase "as determined under paragraph (2)(A),"
      and, delete paragraph 103(c)(])(C).

    --Under subsection 103(c)(2)(B), delete the phrase
      "living in institutions for neglected or delinquent
      children, or" from the second sentence.

    -- Under subsection 103(c)(2)(C), delete the sentence
       "For purposes of this section, the Secretary shall
       consider all children who are in correctional
       institutions to be living in institutions for
       delinquent children."




                               54
APPENDIX V                                         APPENDIX V
             SECTION 123 O   TITLE I OF THE ELEMENTARY AND
              SECONDARY EDUCATION ACT OF 1965, AS AMENDED
       PROGRAMS FOR NEGLECTED OR DELINQUENT CHILDREN

         "Sec. 123. (a) A State agency which is directly
    responible for providing free public education for chi_-
    dren in institutions for neglected or delinquent children
    or in adult correctional institutions shall be entitled
    to receive a grant under this section for any fiscal
    year (but only if grants received under this section
    are used only for children in such institutions).

          "(b) Except as provided in sections 124 and 125,
    the grant which such an agency (other than the agency
    for Puerto Rico) shall be eligible to receive shall
    be an amount equal to 40 per centum of the average
    per pupil expenditure in the State (or (1) in the
    case where the average per pupil expenditure in the
    State is less than 80 per centum of the average per
    pupil expenditure in the United States, of 80 per centui;
    of the average per pupil expenditure in the United
    States, or (2) in the case where the average per ppil
    expenditure in the State is more than 120 per centum
    of the average per pupil expenditure in the United
    States, of 120 per centum of the average per pupil
    expenditure in the United States) multiplied by the
    number of such children in average daily attendance,
    as determined by the Commissioner, at schools for
    such children operated or supported by that agency,
    including schools providing education for such children
    under contract or other arrangement with such agency,
    in the most recent fiscal year for which satisfactory
    data dre available. The grant which Puerto Rico shall
    be eligible to receive under this section shall be the
    amount arrived at by multiplying the number of children
    in Puerto Rico counted as provided in the preceding
    sentence by 40 per centum of (1) the average per pupil
    expenditure in Puerto Rico or (2) in the case where
    such average per pupil expenditure is more than 120 per
    centum of the average per pupil expenditure in the United
    States, 120 per centum of the average per pupil expendi-
    ture in the United States.

         "(c) A State agency shall use payments under this
    section only for programs and projects (including the
    acquisition of equipment and where necessa;v the con-
    struction of school facilities) which are designed to
    meet the special educational needs of such children."


                               55
APPENDIX VI                                                          APPENDIX VI



              DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
                            OFFICE OF THE SECRETARY
                              WASHINGTON. D.C.   20201




                                                            AUG 1 1977

Mr. Gregory J. Ahart
Director, Huan Resources
 Division
United States General
 Accounting Office
Washington, D.C. 20548

Dear Mr. Ahart:

The Secretary asked that I respond to your request for our comments on
your draft report entitled, "Educational Assistance for Institutionalized
Neglected or Delinquent Children: Major Changes Needed". The enclosed
comments represent the tentative position of the Department and are
subject to reevaluation when the final version of the report is received.

We appreciate the opportunity to comment on this draft report before its
publication.

                                                 Sincerely yours,



                                                   omas .Morris
                                                 Inspector General


Enclosure




                                    56
APPENDIX VI                                                    APPENDIX VI

Comments of the Department of Health, Education, and Welfare on the
Comptroller General's Report to the Congress Entitled, "Educational
Assistance for Institutionalized Neglected or Delinquent Children:
Major Changes Needed"    [See GAO note 1, p. 63.1
In order to place the specific GAO recommendation and the Department's
response in proper perspective, we wish to comment on some of the
assumptions and conclusions contained.within the body of the report.
These comments are included in an Overview which is followed by our
response to the GAO recommendation   The final part of this response
contains Technical Comments on     ;AO Survey Analysis.

                           OVERVIEW

The following citations are taken from the draft GAO report. The
Department's comments on each are presented as background for the
Department's response to the GAO recommendation:




                    [See GAO note 2,       p.   63.]




2. "GAO believes the effectiveness of title I can be enhanced if
available funds are concentrated on those youths who are
likely to receive a continuum of educational service over a
longer period of time." (p. iii; see also pp. 8, 9, 14, 30-31,
and 37)

Concentrating funds, as GAO suggests, on younger youth (where educational
services are more likely to continue) and on institutions which serve
youth likely to be institutionalized longer would have the effect of
serving primarily neglected youth. As the report points out (pp. 14,
32), neglected youth in general are in residence more than twice as long
as delinquent youth, and the great majority of younger children are in
institutions for the neglected.




                                      57
APPENDIX VI                                                    APPENDIX VI

Na7rowing the scope of the prcg.'am to serve primarily neglected youth at
the expense of .nstitutionalized delinquent children would have the
                                                                The GAO
                         [See     AO note 2,   p.   3.i

                                      Further, the fact that these
students are less likely to return to school upon leaving the institution
may be a rason for providing lather than denying Title I services. A
more concentrated, enriched instructional program at this time may equip
them for bette- and moie lasting employment. As the report indicates,
this may be the "last chance' for the majority of these older, delinquent
youths.

Current regulations, 45 CFR Part 116c, allow State institutions to provide
Title I services to children ho are receiving State-supported nstruction
in vocationally-oriented subjects which may be appropriate for older
children.

3. "Relating the factors of age and length of exposure to program
services shows that the bulk of available resources go to
those youths and institutions in which a continuum of educational
services is least likely to be achieved.   . ..   The relatively
short exposure to program services is determined by the short
period of stay in the institution."   (pp. 31-32)

According to the report (p. 32), an average length of stay for delinquent
youths is about 10 months. For a youth confined to an adult correctional
institution, the average stay is over 14 months. The two groups tend to
be the oldest children served by the program and represent 72 percent of
Title I expenditures. GAO recommends that older youth, because they
generally are institutionalized a shorter period of time and thus receive
less program exposure than younger youth, be given a lowfer priority in
receiving services.

If one compares the two averages cited above with the length of a regular
school year, it appears -hat more than a:. academic year of instructional
exposure is available to hese older students. Considering that the
instruction of children in regular schools is disrupted annually, it
seems that the vc-age institutionalized, elinlquent child (who is also
probably older than the average neglected child) has enough exposure
time to benefit from a Title I program. Again, for many of these
children, this may be the "last chance" co receive this type of service.




                        [See GO    note   ,    . 63.]




                                     58
APPENDIX VI                                                   APPENDIX VI




                       [See GAO note     2, p.   63.]




5. "GAO's survey results show that administrators consider academic
educational needs important, but second to mental health problems.
Responses to other survey questions also raise concerns as to whether
academic educational needs should be the exclusive or top priority of
a Federal service program.:' (p. 29; see also pp. iii, 3, 9, 34, and a/)

The Office of Education has not prohibited grantees from designing
programs which provide supportive services for cildren. Recent
recognition of this intended programmatic flexibility can be found in
the Senate Report of the Committee on Labor and Public Welfare on
S.1539, March 29, 1974, pp. 30-31:

         Title I programs have offered flexible responses to
         local problems facing disadvantaged; local officials are
         charged with developing local solutions to meet specific
         needs. Often the solutions involve remedial educational
         programs in basic skills. But many local officials have
         found that their children's educational progress also
         depends on provision of auxiliary services such as
         guidance and counseling programs or cultural enrichment.
         Title I is not basically a social services program;
         occasionally, however, such social services arc
         necessary if education is to take place.




                                    59
 APPENDIX VI                                                        APPENDIX VI

 Thus, for the purposes of Title I, "special educational needs" are broadly
 conceived and there may be room within the current Title I program to
 provide certain mental health services beyond those provided with State
 and/or local funds. However, it does not appear that the case has been
 made that the current Title I program, which serves children with grave
 educatijonal needs, should be modified to provide mental health services
 alone.

6. "Presently, grant funds are generally expected to be expended during
a one year period. Under the proposed arrangement, individual grants
should be permitted to cover a period greater than 1 year, in those cases
where Title I participants are likely to be in residence beyond such a
period." (p.34)

This multiple-year funding concept in presented as part of a larger
program modification suggested by GAO, and commented upon in other
sections of this response.

It seems this suggested multiple-year funding would be inconsistant with
the Department's view that Title I services are to be tailored to the
individual needs of the children served. Since participants change from
year to year and annual needs assessments are required (including the
indentification of those most in need in local institutions), multi-year
projects fr all Title I grantees would be inappropriate. Secondly,
under Section 412(b) of the General Education Provision Act, applicant
State and local agencies may "carry-over" Title I funds from one fiscal
year to the succeeding year providing in effect a two year funding period.

7.   "GAO believes that . . . provisions Cshould be madejfor addressing    the
need for adequate transitional services to insure that youths, to the extent
possible, receive a continuum of appropriate educational services following
their release from the institutions .     .   "   (pp. ii; see also pp. 25 and 29)

We would agree that services that facilitate the transitior, of children
from i- titutions to normal community life, including school, re p
We would oint out, however, that such transitional services even those that
are educaional, involve the efforts of other agencies as well as the Title I
applicant agencies. Transitional services for children leaving
in3titutions and returning to some form of placement are being provided,
although often inadequately, by State and local institutions, as well as
other State or local agencies such as parole, probation, and public
welfare ffices and juvenile courts. To Ladress the need for transitional
services intended to insure the child's continued education without attending
to his or her needs for other types of community based services is unrealistic.

In view of the wiae variety of agencies currently involved in providing
services for youth pon their release from institutions, Titlp I should
not be the vehicle for Federal assistance for the purpose of ennancing
those services.




                                     60
APPENDIX VI                                                    APPENDIX VI

GAO RECOMMENDATION

We recommend that the S cretary, HEW, jointly with the Attorney General,
Department of Justice, examine the appropriateness and/or the exclusiveness
of academic educational services as t   top priority of Federal assistance
for institutionalized neglected and delinquent children. More specifically,
the organizations to participate in such an undertaking should include
HEW's Office of Education and the National Center for Child Abuse and
Neglect, and the Office of Juvenile Justice and Delinquency Prevention
under the Law Enforcement Assistance Administration.

We do not believe that the joint examination as recommended by GAO would
be productive. The recommendation is based upon an analysis of the
findings of a questionnaire which, in our opinioln, was not broad enough
to obtain an accurate picture of the success of the Title I program in
institutions. We would further point out that there is an on-going
study being conducted under the auspices of the Office of Education.
This study is much broader in scope, in that it solicits information
not only from administrators, but from program staff and recipients of
Title i services, which appears to indicate that the priority assigned
to educational services by the Office of Education, is appropriate.

If it is determined that an academic thrust is not appropriate as the
exclusive or top priority, then the thrust of the program should be
chatiged accordingly. Further, if it is felt that the desired thrust is
not wiLhin the legal bounds of the Title I legislation, the Congress
should be requested to amend Title I, if such action is needed to brin
about a more responsive program tc assist institutionalized youths.

Since we do not concur that a joint examination is required, we do not
see a need at this time to amend legislation accordingly.

Further, neither the current legislation nor the recently published interim
final regulations (45 CFR Part 116c) require the applicant agencies to limit
their programs to instruction in the basic skills. What the regulations do
require is that the needs of institutionalized children as indicated by
their performance in the basic skills be considered in the development of
special assistance under Title I. A wide variety of services may be
provided under Title I, provided those services are shown to be "designed
to meet the special educational needs of children in institutions."

TECHNICAL COMMENTS

GAO's analysis of the survey of inotltutional administrators indicated
the following:

Question   11, pp. 43-44 - Relative Importance of Needs

1.   Mental health and educational services rated essential.

2. Family, diagnostic, health and vocational services rated very
important.



                                     61
APPENDIX V                                                        APPENDIX VI

 3.   Drug/alcohol abuse services rated moderately important.

Question #14,    . 47 - Extent to Which Needs Are Being Met

1.. Diagnostic, mental health, educational and health services rated
as adequate.

2.    Drug/alcohol abuse, family, and vocational services rated marginal.

Question #20, pp. 49-50 - How Federal Funds Would be Expended if No
Strings Were Attached

                               Percent of Total Funds Available
Mental Health                               24.6
Education                                   19.0
Family                                      15.6
Vocational                                  15.2
Health                                      10.9
Diagnostic                                   7.8
Drug/alcohol Abuse                           5.0
Other                                        1.9

Administrators, in response to Question #11, rated all seven areas of
needs as important. Thet is, one of the need areas fell into the two
lower categories of "somewhat important" or "little importance". As
the report also points out, responses tended to cluster at the "essential"
category.   hile a complete analysis cannot be made, it appears that
educational services are viewed as second in priority among the seven
service areas.

An interpretation of the results of Question #14, could be that all seven
areas could stand some improvement but that none were in drastic need
as evidenced by none being rated in the two lower categories. Responses
to Question #20, seem to confirm this interpretation since the
administrators indicated that they would expend any additional funds in
all seven areas.

The relationships between responses to Question #14 (Extent to which
needs are being met) and Question #20 (How Federal funds would be
expended if no strings were attached concerning their use) are
somewhat unclear. for example, administrators elected to expend
62 percent of "no strings attached" Federal money on four service areas
rated as "adequate' in Question #14 and only 36 percent on three service
areas rated as marginally meeting the needs of children. This raises
the question, why would the largest percentage of such funds (24.6) be
expended on mental health services which were rated as adequately
meeting the needs of children, while drug/alcohol abuse services were
rated "marginally" meeting the needs of the children and would receive
the lowest percentage of the funds (5.0)?




                                     62
APPENDIX VI                                                    APPENDIX VI


A final comment concerning the interpretation of the survey results
relates to the validity of the population surveyed. Although the report
indicates (p. 42) that the top administrators were selected to be surveyed
because it was felt they would be the most unbiased persons to report on
the needs of the children and the resources of the institution, the
questions raised above suggest that a bias was introduced into the survey
results. A possible explanation for some of the conflicting responses is
that administrators may have a tendency to cite the most obvious and
possibly the most popular needs rather than those needs that staff members
would identify as critical.




GAO note 1:     Page number references in this appendix may
                not correspond to pages of this report.

GAO note   2:   Deleted comments relate to matters which
                were presented in the draft report but
                were omitted from the final report.




                                    63
APPENDIX VII                                                           APPENDIX VII


                                  NITED STATES DEPARTMENT OF JUSTICE

              .....-..                     ~ASHINGTON, D.(t    20530


     ,ddre.   Hep>       , the                 AUG    8 1377
      Diviioin Indiclred
and Hefrh to Initi.l /ad Number




              Mr. Victor L. Lowe
              Director
              General Government Division
              United States General Accounting Office
              Washington, D.C. 20548

              Dear Mr. Lowe:

                   This letter is in response to your request for comments
              on the draft report entitled "Educational Assistance for
              Institutionalized Neglected or Delinquent Children:  Major
              Changes Needed."

                   Title I of the Elementary and Secondary Education Act
              of 1965 gives administrative control in this program area
              to the Secretary of the Department of Health, Education
              and Welfare (HEW).  However, we generally agree with the
              main conclusion in the report that the Title I program
              needs to be reexamined. This is particularly true in lighr
              of the findings contained in the report and the 1974
              legislative developments in (1) child abuse and neglect, and
              (2) juvenile justice and delinquency prevention.

                   Most individuals who have worked with neglected or
              delinquent children know that educational needs are only
              one of a number of significant variables, such as health
              programs, emotional ills, family crises, etc., which must
              be addressed if the child is to be helped.  Simply focusing
              on education without consideration of the other issues is
              short-sighted and cost ineffective.  If remediation fforts
              such as those under the Title I program are to succeed,
              there is a critical need to develop more effective inter-
              disciplinary methods for assessing and treating individual
              needs.




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APPENDIX VII                                          APPENDIX VII

        The Concentration of Federal Effort provisions of the
  Juv.rlle Justice and Delinquency Prevention (JJDP) Act
  assi ned responsibility to the Law Enforcement Assistance
  Administration (LEAA) for establishing policies and priorities
  for all Federal juvenile delinquency programs.   Section 206
  of the JJDP Act created the Coordinating Council on Juvenile
  Justice and Delinquency Prevention to assist in coordinating
  these programs. The Council is chaired by the Attorney
  General and is composed of the Secretaries of the Departments
  of Health, Education and Welfare, Labor, and Housing and
  Urban Development. We strongly endorse the recommendation
  for HEW and the Department of Justice, through the Office
  of Juvenile Justice and Delinquency Prevention in LEAA, to
  jointly explore the exclusivity of Title I funds for educa-
  tional purposes and believe that the Coordinating Council
  would be the appropriate forum for the recommended inter-
  departmental review and examination of the Title I program.
  Should modifications to the Title I program be required, we
  believe that the annual comprehensive planning requirements
  for all Federal juvenile delinquency programs [JJDP Act,
  Section 204(b)(6)] be identified as the appropriate vehicle
  for formally establishing the necessary interdepartmental
  strategies, roles and responsibilities.

       Formula grants to participating States and territories
  are established under Section 222 of the JJDP Act. Compre-
  hensive plans, which are required to be submitted in order
  to qualify for funding,   st include a detailed study of
  State needs for an effective, comprehensive, coordinated
  approach to juvenile delinquency prevention and treatment
  and the improvement of the juvenile justice system. We
  believe that any procedures which are established to review
  the Title I program must include methods to encourage
  coordination with the juvenile justice and delinquency
  prevention program at the State level.

       A national policy has been established to remove "status
  offenders" -- juveniles charged with or who have committed
  offenses which would not be criminal if committed by an
  adult--from juvenile detention or correctional facilities
  [JJDP Act Section 223(a)(12)].  It appears that this mandate
  would have a significant bearing on the future directions
  of the Title I program. We believe that any subsequent
  review of the Title I program must include a specific




                               65
APPENDIX VII                                             APPENDIX VII

   assessment of the need to coordinate with activities now
   underway in implementation of Section 223(a)(12) of the
   JJDP Act, and the general movement in the field to reduce
   the number of children sent to secure correctional institu-
   tions.

       Finally, we believe it is imperative that all States
   and institutions receiving Federal funds be required to have
   a transition phase from institution to community programs.
   The responsible State agency should be required to track
   children through their respective programs to insure that
   there is a satisfactory link-up between the institution and
   community agencies.

       We appreciate the opportunity given us to comment on
   the draft report.  Should you have any further questions,
   please feel free to contact us.

                                         Sincerely,



                                         Kevin D. Rooney
                                    Assistant Attorney General
                                         for Administration




                               66
APPENDIX VIII                                         APPENDIX VIII




                  PRINCIPAL OFFICIALS OF THE

         DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

                 RESPONSIBLE FOR ACTIVITIES

                  DISCUSSED IN THIS REPORT

                                         Tenure of office
                                         From          To

SECRETARY OF HEALTH, EDUCATION,
  AND WELFARE:
    Joseph A. Califano, Jr.          Jan.      1977     Pzesent
    David Mathews                    Aug.      1975     Jan.  1977
    Caspar W. Weinberger             Feb.      1973     Aug.  1975
    Frank C. Carlucci (acting)       Jan.      1973     Feb.  1973
    Elliot L. Richardson             June      1970     Jan.  1973

ASSISTANT SECRETARY (EDUCATION):
    Mary F. Berry                    Apr.    1977       Present
    Philip E. Austin (acting)        Jan.    1977       Apr.  1977
    Virginia Y. Trotter              June    1974       Jan.  1977
    Charles B. Saunders, Jr.
      (acting)                       Nov.    1973       June   1974
    Sidney P. Marland, Jr.           Nov.    1972       Nov.   1973
COMMISSIONER OF EDUCATION:
    Ernest L. Boyer                  Apr.    1977       Present
    WillIam F. Pierce (acting)       Jan.    1977       Apr.  1977
    Edward Aguirre                   Oct.    1976       Jan.  1977
    William F. Pierce (acting)       July    1976       Oct.  1976
    Terrel H. Bell                   June    1974       July  1976
    John R. Ottina                   Aug.    1973       June  1974
    John R. Ottlna (acting)          Nov.    1972       Aug.  1973
    Sidney P. Marland, Jr.           Dec.    1970       iyov. 1972




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