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is presently what the Administration plans to spend in this

area, the formula provides a dollar amount that is minimally

adequate.

Impact Aid

The reduction of the funds provided as impact aid to localities by eliminating non-military SAFA B is appropriate. This funding covers many families who are employed in high paying jobs by the Federal government, and who do support their local schools through property taxes.

Non-public Schools

The Council has consistently supported the need for Federal financial support to the educational programs of disadvantaged children wherever they attend school. The Council supports the idea that special arrangements be made to deliver remedial services to children eligible for compensatory education, but who attend the non-public schools, as long as two long-standing guarantees are maintained:

1. That services are given to educationally deprived
children who attend non-public schools which can

2.

meet the standards of the Civil Rights Act, and which are not deliberately segregated academies.

That services provided for educationally deprived

children in non-public schools be secular in nature

and specifically designed to raise the educational

attainment of the eligible children.

The Better Schools Act provides for inclusion of nonprofit private school children in the services available under this act. While there is evidence of improvement in most States in the acceptance and implementation of this provision by the public

education agencies legally responsible for administering it, there nevertheless remain many instances in which provisions of State constitutions or administrative policies of State or local agencies effectively or completely prevent equitable participation. In view of the wide disparity among States in this regard, and resulting inequities in opportunity and participation by nonpublic school children, the Council is gratified to see that the Better Schools Act includes a bypass provision to ensure that nonpublic school children receive equitable treatment.

Comparability

The Council supports the concept of comparability which has been a Congressional mandate since April, 1970, and is pleased to note its inclusion in the Better Schools Act. We feel that it is vital to the success of the compensatory education philosophy that Federal funds be used to supplement and not supplant State and local funds providing extra services to educationally deprived children if these children are to have the "something extra" needed to assure them of an equal chance to receive an adequate education.

Forward Funding

The forward funding provision and the specified allocation to poorest schools in poorest districts first are both vital to the effective management of the limited allocation for compensatory education. Forward funding will make it possible for school systems to plan in advance of the year's programs and to have the assurance of funds that will make it possible for them to hire outstanding teachers for compensatory programs.

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In the past the funds for compensatory programs have been so late in coming that school administrations were often forced to hire the teachers that were left over instead of being able to find the most highly qualified to meet the challenge of providing a good education to the educationally disadvantaged child. The concentration of funds in the poorest schools and poorest districts first, given the fact that there are not enough funds to adequately serve all needy children, is wise. Concentration of Federal funds where the need is the greatest avoids a dissolution of funds, the problem of spreading too little money too thinly, and accomplishing little or nothing. Council likes the strict concentration regulations, and is especially pleased to see that any unallocated or returned funds will be reallocated to the States and not returned to the Federal treasury.

Interstate Agreements

The

The provision for interstate agreements is extremely important especially in the area of migrant education, where children are constantly moving during the school year--and often attend schools in two or more States during one academic year. Without interstate cooperation and agreements the provision of coordinated, sequential, adequate education for these children is close to impossible.

Compliance Regulations

The act gives plenty of authority for a willing DHEW to enforce strict and available steps to ensure that localities comply with the intent of this law. And the bill includes provision that all persons' civil rights will be protected and that fair labor standards are to be used in hiring and firing

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practices. All of these items are necessary and appropriate, because, although most localities and administrators do have the right "heart contention" when it comes to compensatory education, there will always be a few who do not. For these few it is necessary that certain rights and privileges are mandated in the legislation to protect the children who are intended as the beneficiaries of this law.

Provision for public information

In light of the philosophy of "New Federalism" we find it especially important that the Better Schools Act has included provision that State Education Agencies shall publish their plan for the distribution of funds available to them and that records be available to the public. If the people at the local level are going to be meaningfully involved in their own government, it is imperative that they know what programs are proposed to be funded, and have adequate public hearing opportunities.

Transfer of funds

The NACEDC supports the obvious emphasis in the Better Schools Act to guarantee high quality and high level services to educationally disadvantaged children by making the funds in the disadvantaged earmark inviolable. The potential for transfering funds to the disadvantaged earmark from other sources in the bill with little red tape is one with which the

NACEDC concurs.

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Recommendations for Improvement of the Better Schools Act

1.

The Better Schools Act omits mandated parent involvement
through mandated parent councils or any other form of
required parent involvement at the local level, and
statutory Presidential councils at the national level.

Parental involvement in his child's academic program and growth is not a new concept. It is a fact of life taken for granted by an overwhelming majority of parents with average income and by the more affluent families in this country.

These parents find it easier than parents of educationally disadvantaged children to be meaningfully involved in the education programs of their children. Low-income parents of educationally disadvantaged children face obstacles when relating to school officials. First, it is frequently a necessity for both parents of a school-aged child to work in less affluent American families. Nonworking mothers have easier access to school teachers and administrators than does a mother who works. Secondly, many parents of educationally disadvantaged children have been underachievers in school. Inadequate verbal skills often render them reluctant or fearful to participate in discussions with school teachers and administrators regarding issues crucial to the academic success of their children. They must be encouraged to do so and the school administrators must act affirmatively and with sincerity.

High School Diploma Attainment of Head of Household, and Preparation for School in the Home Generates Academic Success of Children

Educators are in agreement that there are high correlations between the level of educational attainment of the parent, the