the evaluations, and, in cases where improvements had been suggested, there was little followup to monitor their implementation. We found also that OEO's management information system had not provided management with data of the type needed or in a format suitable for use in administering and monitoring project operations, such as expenditures per individual case by litigation category, and that many LSP projects were not adhering to the reporting requirements of the system. We were advised by the Deputy Director, LSP, that the management information system reports were being revised to meet the informational needs of LSP.

We believe that the systematic monitoring of program operations and indepth evaluations provide means for assessing progress in achieving program objectives and for identifying and obtaining correction of management weaknesses. Moreover, the 1967 amendments to the EOA require that OEO provide for continuing evaluation of the programs and their effectiveness in achieving stated goals, their impact on related programs, and their structure and mechanisms for the delivery of services.

In our analysis of the evaluation reports, we found that representatives of the poor in a number of projects were not effectively participating in the development and implementation of the program although required to participate by the EOA, as amended. We found that representatives of the poor were not regularly attending LSP board of directors' meetings or participating in discussions and that this was attributed to the lack of knowledge and training in law or to the fact that the poor were not informed of the nature of the program and their role as representatives and were not encouraged to actively take part in the planning, policymaking, and operation of the program.

Administrative improvements needed in the operations of the LSP, which were reported by a management consulting firm under contract with OEO and which we also noted, included (1) the need for OEO to more adequately define program objectives and to provide national direction and assistance to LSP projects and (2) the need for OEO to provide uniform administrative guidance to local projects through the development and distribution of a project director's administrative management manual.

The Committee of State Officials on Suggested State Legislation of the Council of State Governments receives from BOB and from State and public service organizations proposals for consideration by the State legislatures. Also, FTC, Office of Federal-State Cooperation, has a working arrangement with State officials for exchanging information. on deceptive practices of companies and for assisting in drafting legislation for consideration by State legislatures.

We believe that LSP projects are in a position to make meaningful recommendations through BOB and FTC for changes in State laws that adversely affect the poor. The attorneys of LSP are practicing law in forty-nine of the fifty States and from this widespread practice should be able to obtain much information that would afford a basis for needed legislative recommendations to the States.

We found, however, that OEO had not established a means by which LSP attorneys could submit recommended legislative changes in State laws to BOB for submission to the Council of State Governments or submit compilations of recurring consumer problems of the poor to FTC for consideration by State officials or by State legislatures.

In our field review of the two LSP projects, we were limited in our attempt to evaluate the extent and effectiveness of the services rendered to clients by LSP projects, since information which would afford a basis for such evaluations was contained in records not available to us because access to these files would disclose legal details and the clients' identity and thus would violate the confidentiality of the attorney-client relationship.

Arrangements were being made between OEO, the American Bar Association, and the National Legal Aid and Defender Association to determine the type of information that may be considered as nonconfidential and to devise uniform intake and disposition forms which can be used in the program and made available for review purposes. We found that the two projects reviewed had provided legal assistance to a significant number of persons to whom such services may not otherwise have been available but that the projects' activities had been quite limited in the field of law reform. At the time of our review, officials of the projects were taking action to increase their efforts in this area.

Other areas requiring management attention at one or both locations included the need to (1) more adequately staff fewer offices by reducing the number of field or area offices with light caseloads, in order to increase the number of needy persons served by LSP attorneys, (2) involve the poor in the selection of the agency's representatives to the CAA board of directors and establish advisory councils to assist in directing the program, (3) provide for training of attorneys and other staff members in dealing with the problems of the poor, (4) improve the administration of funds, and (5) develop acceptable plans for self-evaluation of the program.

VOLUNTEERS IN SERVICE TO AMERICA (VISTA) PROGRAM

The VISTA program offers adults 18 years of age and over the opportunity to participate in a personal way in the "war on poverty" by living and working among the poor of all ages and in all areas. VISTA volunteers serve in rural areas and urban communities, on Indian reservations, among migrant workers, in institutions for the mentally ill and mentally retarded, and Job Corps centers.

From the inception of the VISTA program through December 31, 1968, about $90.4 million was obligated to fund the program, $29.2 million of which was applicable to fiscal year 1968. At June 30, 1968, there were 3,204 full-time VISTA volunteers, 1,565 VISTA associates (short-term volunteers), about 40,000 in the Citizens Corps (parttime volunteers), and 1,828 prospective full-time VISTA volunteers in training. We reviewed selected aspects of the program at VISTA headquarters in Washington, D.C., two OEO regional offices, two VISTA regional training centers, and 14 VISTA projects where VISTA volunteers were assigned. In addition, our contractor reviewed VISTA's evaluation efforts and, in particular, its progress toward assessing the relative impact of various uses of the volunteers. Other information concerning the VISTA program is presented in appendix I beginning on page 182.

CONCLUSIONS

An overall evaluation of the performance of VISTA volunteers who engage in a variety of functions is a complex task. At the local level, evaluations often encompass the entire program rather than just the volunteer services and as a result it is difficult to isolate the impact of a volunteer's activity when he is only one of several individuals performing similar services in the community.

On the basis of our review, however, we have identified weaknesses in certain functions of administration, the correction of which would improve the effectiveness of the program.

1. The VISTA volunteers at some of the projects that we reviewed could have been more effectively utilized in carrying out the VISTA mission if the project sponsors and supervisors had been better informed regarding the role of the assigned volunteer and the degree of supervision to be provided to him.

2. The two VISTA regional training centers at which our review was made generally met contract requirements. However, trainees would be better prepared for VISTA service if, at the beginning of training, a specific project assignment was made for each volunteer and his training was adapted to preparing him for work at that assignment. 3. The regional offices need additional guidance and technical assistance from headquarters if they are to meet their recruiting quotas. In this respect the regional offices would benefit from additional assistance from headquarters in conducting recruiting campaigns, developing new recruiting methods and techniques, and planning and conducting in-service training for the recruiting staffs.

4. To improve the evaluation and selection of applicants for assignment to regional training centers, VISTA needs to improve its selection process. In many cases applicants were accepted without being interviewed. Therefore, greater assurance of the acceptability of applicants could be obtained if each were interviewed and given an aptitude test before being considered eligible for VISTA training.

Since the completion of our fieldwork, VISTA initiated a number of actions to (1) correct supervision shortcomings, (2) structure the training programs to be more responsive to the specific needs of VISTA projects, and (3) provide additional guidance and technical assistance to the OEO regional offices in their recruiting activities.

RECOMMENDATION

We recommend to the Director, OEO, that, to improve the procedures leading to the assignment of selected applicants to the VISTA regional training centers, consideration be given to the feasibility of requiring that the applicants be interviewed and given an aptitude test before they are considered eligible for VISTA training.

PROGRAM RESULTS AND ADMINISTRATION

During fiscal year 1968, VISTA conducted a self-examination of its program which was designed to (1) determine what the volunteers on each project were doing, how many people they were working with and what results had been obtained and (2) measure the potential effectiveness of individual projects, using a single set of criteria for all projects.

VISTA's survey of its activities, made mainly during April and May 1968, covered 371 of the 440 VISTA projects in operation at the time of the survey. On the basis of the data on these 371 projects and statistical information on all projects and volunteers for fiscal year 1968, VISTA determined that, during fiscal year 1968, its full-time volunteers spent 3,360 man-years in carrying out the VISTA mission and served or regularly involved 562,800 members of the target population under nine activity categories-recreation, individual assistance, education, community organization, housing and neighborhood improvement, legal services, health, income improvement, and employment.

An examination of the effectiveness of individual projects began in February 1968 and included projects which had been in operation for at least 9 months. By June 30, 1968, 301 of the total of about 350 such projects had been evaluated.

Of the 301 projects evaluated by the end of June, 225 projects met evaluation requirements. For the remaining 76 projects, VISTA headquarters recommended that regional offices terminate 38 projects and 35 components of an additional 17 projects, and, on their own initiative, the regional offices terminated or scheduled for termination 20 other projects and 2 components of one project. As of October 1968, the regional offices had completed or initiated action on most of the projects for which recommendations had been made by VISTA headquarters.

Although the evaluations gave consideration to the apparent effectiveness of the volunteers, they were primarily measurements of the worth of projects devised by local sponsors. This circumstance points to the inherent difficulty in evaluating the effectiveness of VISTA because, although the program may be of great worth conceptually, its real value is dependent on the quality of the projects devised by the sponsors; therefore, the contribution of the volunteers may represent only a small part of the total project.

A further difficulty in evaluating VISTA was noted by our contractor which found that, even with the available data, comparisons among activities were basically meaningless. For instance, although one category of data solicited is the number of volunteer-hours spent performing an activity, meaningful comparisons cannot be made between the value of the number of hours spent on an education project' on the one hand and of those spent on a mental health project on the other. Further, although an attempt is made to impute results to VISTA activities, it is doubtful if those imputations are unbiased since it is also almost impossible to separate those results which can be attributed directly to VISTA activities from those activities of the sponsoring agency for which the volunteer is working.

In our review of 14 projects we noted that, although the evaluation of the volunteers' activities was not practicable except in the context of the total projects, a number of administrative weaknesses detracted from the effectiveness of the program.

In one or more cases, we found that (1) there was a lack of adequate supervision over the volunteers by the project sponsors and supervisors, (2) volunteers were used in tasks or in positions that could apparently have been performed by neighborhood residents or project individuals in staff positions, (3) project sponsors and supervisors did not receive adequate instructions and information from VISTA as to

how volunteers could be used or what their role in the community was to be, and (4) VISTA did not provide the project sponsors and supervisors with adequate advance information on the skills, qualifications, sex, age, and number of volunteers that were being assigned to the project.

As part of our review, we interviewed 55 volunteers assigned to the 14 projects we reviewed. The responses we obtained also raised questions relating to the VISTA program. For example, although most volunteers considered that the projects to which they were assigned were improving or were moderately successful, seven stated that their projects were getting worse and two stated that their projects were worthless. In addition, 27 volunteers stated that the projects had not been explained to them at the time of their arrival and 18 volunteers stated that they had been used in areas for which they had received no training. Also, on the basis of the comments of those interviewed, it appeared that only 29 had received adequate supervision from their project supervisors.

As previously stated, sponsors were not being provided with adequate advance information on the qualifications and other particulars of volunteers being assigned.

In this connection we noted that the training of VISTA volunteers at the regional training centers was not adapted to preparing the individual trainee for work at the particular VISTA project which he would serve as a VISTA volunteer. The contracts awarded for the operation of the regional training centers did not require such specialized training, nor did the training guidelines issued by VISTA. Furthermore, the regional training centers were not provided, at the start of each training cycle, with a list of vacancies at designated VISTA projects that required filling by graduates who had completed that cycle, neither were they furnished with the assignment descriptions for volunteers at each of these VISTA projects, nor were they given information about the characteristics, qualifications, and interests of each individual candidate in advance of his arrival for enrollment in training.

VISTA has recognized that weaknesses exist in the supervision of volunteers and in the training program and has informed us that it has initiated efforts to (1) correct supervision shortcomings by providing for a substantial increase in the number of VISTA-paid supervisors on its projects, (2) conduct special training programs for supervisors of VISTA volunteers, and (3) structure the training programs for its volunteers to be more responsive to the specific needs of VISTA projects by placing greater emphasis on on-the-job training.

We noted also that there were no standard procedures for obtaining feedback information from former trainees as to the adequacy of the training program or for obtaining pertinent comments from the sponsoring organizations to which the volunteers were assigned.

We examined into VISTA recruiting policies and procedures. VISTA headquarters reports of recruitment results in fiscal year 1968 showed that none of the seven OEO regional offices had achieved the total 1968 recruitment quotas assigned to them by headquarters and that only a few of the quarterly quotas had been achieved. The recruitment drives of the seven regional offices resulted in a total of