APPENDIX II.-STATUTORY INSTRUCTIONS OR PROVISIONS REQUIRING DELEGATION OR TRANSFER OF OEO FUNCTIONS TO OTHER FEDERAL AGENCIES

Section 602(d) of the Economic Opportunity Act, as amended (42 U.S.C. 2942 (d)) provides that:

"In addition to the authority conferred upon him by other sections of this chapter, the Director is authorized, in carrying out his functions under this chapter, to

"(d) with the approval of the President, arrange with and reimburse the heads of other Federal agencies for the performance of any of his functions under this chapter and, as necessary or appropriate, delegate any of his powers under this chapter and authorize the redelegation thereof subject to provisions to assure the maximum possible liaison between the Office of Economic Opportunity and such other agencies at all operating levels, which shall include the furnishing of complete operational information by such other agencies to the Office of Economic Opportunity and the furnishing of such information by such office to such other agencies;" (Emphasis added.)

The legislative history of the above-quoted provision discloses that (p. 39, Sen. Rept. 1218, 88th Cong. 2d sess.):

"The Director is authorized, with the approval of the President, to delegate any of his powers under the act and to authorize their redelegation. In this connection, the committee understands that the Director expects to utilize existing Federal agencies in administering certain of the programs authorized by the act. Specifically, the committee understands that the Department of Health, Education, and Welfare will be utilized in the administration of title I, part C, workstudy programs; title II, part B, adult basic education programs; and title V, work experience programs; that the Department of Labor will be utilized for title I, part B, work-training programs; that the Department of Agriculture will be utilized for title III, part A, special programs to combat poverty in rural areas; and that the Small Business Administration will be utilized in the administration of title IV, employment and investment incentives. The committee expects the Director, however, to establish and be responsible for the policies, rules, and regulations which will govern the administration of these delegated programs.

"The Office of Economic Opportunity will administer directly the other programs authorized by the bill-the Job Corps established by title I, part A; the urban and rural community action programs authorized by title II, part A; the program for assistance for migrant agricultural employees and their families authorized by title III, part B; and the VISTA program authorized by title VI."

It is clear from the foregoing that, although section 602 (d) (42 U.S.C. 2942(d)) does not require the Director of OEO to delegate any of his functions, the congressional committee involved understood that he would utilize other Federal agencies, as explained in the committee report.

Section 621 of the Economic Opportunity Act, as amended (42 U.S.C. 2971) provides that:

"Pursuant to section 2942(d) of this title [section 602(d) of the Economic Opportunity Act], the Director shall delegate his functions under section 2809(a) (2) of this title to the Secretary of Health, Education, and Welfare, and such functions shall be carried out through the Office of Education of the Department of Health, Education, and Welfare." (Emphasis added.)

Section 2942(d) (i.e., sec. 222 (a) (2)) of the Economic Opportunity Act mentioned in the above-quoted code provision concerns the "Follow Through" program (42 U.S.C. 2809 (a) (2)). Thus, section 621 of the act, in effect, requires the Director of OEO-pursuant to section 602(d) to delegate his functions under the Follow Through program to the Secretary of HEW.

Also, section 105 of the Higher Education Amendments of 1968 (Public Law 90-575, 82 Stat. 1014, 1019) reads, in part, as follows:

"(b) Effective July 1, 1969, section 222 (a) of the Economic Opportunity Act of 1964 is amended by striking out paragraph (5) and by redesignating paragraphs (6), (7), and (8) (and references thereto) as paragraphs (5), (6), and (7).

(c) (1) On Julv 1, 1969, all functions, powers, and duties of the Director of the Office of Economic Opportunity with respect to Upward Bound programs, are transferred to the Commissioner of Edu

cation. ***

"(2) For purposes of this subsection the term 'Upward Bound program' means a program carried out under section 222 (a) (5) of the Economic Opportunity Act of 1964 (as so designated prior to the amendment made by subsection (b) of this section) or a comparable program carried out under section 221 of such Act." (Emphasis added.)

The last-quoted provision of law transfers the "Upward Bound" program from OEO to HEW, effective on July 1, 1969.

Also, title IV of the Economic Opportunity Act Amendments of 1966 (80 Stat. 794) amended title IV of the Economic Opportunity Act of 1964 (42 U.S.C. 2901-2907) so as to transfer the lending and guaranty functions authorized therein from the Director of OEO to the Administrator of the Small Business Administration.

Administration of part C ("Work-Study programs") of title I of the Economic Opportunity Act of 1964 was transferred from the Director of the Office of Economic Opportunity to the Commissioner of Education by section 441 of the Higher Education Act of 1965 (Public Law 89-329, Nov. 8, 1965, 79 Stat. 1249). Prior to enactment of the Higher Education Act of 1965, powers of the Director of the Office of Economic Opportunity under part C were delegated to the Secretary of Health, Education, and Welfare by a delegation approved by the President on October 24, 1964 (29 F.R. 14764, Oct. 29, 1964). Section 315 of the Adult Education Act of 1966 (80 Stat. 1222)

repealed part B of title II of the Economic Opportunity Act of 1964, which provided for "Adult Basic Education Programs." Statutory provisions similar to those contained in part B are contained in the Adult Education Act of 1966, the administration of which is vested in the Commissioner of Education, HEW.

Although not clearly involving a mandatory delegation of powers or functions, the following provisions of the Economic Opportunity Act, as amended, are pertinent.

Section 222 (a) (4) (B), involving certain health service programs"(B) ***The Director and the Secretary of Health, Education, and Welfare shall achieve effective coordination of programs and projects authorized under this section with other related activities." Section 222 (a) (6)-now section 222 (a) (5)-involving "Emergency Food and Medical Services"

"(6) *** The Director shall arrange to carry out his functions through the Secretary of Agriculture and the Secretary of Health, Education, and Welfare in a manner that will insure the availability of such foodstuffs and services through a community action agency where feasible, or other agencies or organizations if no such agency exists or is able to administer such foodstuffs and services to needy individuals. ***"

Section 222 (a) (7)-now section 222 (a) (6)-involving "family planning" program

"(7)*** The Director and the Secretary of Health, Education, and Welfare shall coordinate, and assure a full exchange of information concerning, family planning projects within their respective jurisdictions in order to assure the maximum availability of services and in order best to meet the varying needs of different communities. The Secretary of Health, Education, and Welfare shall make the services of Public Health Service officers available to the Director in carrying out this program."

Section 222(a) (8)—now section 222 (a) (7)—involving "Senior Opportunities and Services"

"(8) *** In administering this program the Director shall utilize to the maximum extent feasible the services of the Administration of Aging in accordance with agreements with the Secretary of Health, Education, and Welfare."

Note also the following provisions of part A of title V of the Economic Opportunity Act, as amended, which involve work experience and training programs.

"SEC. 502. In order to permit the carrying out of work experience and training programs meeting the criteria set forth in part E of title II of the Manpower Development and Training Act of 1962, the Director is authorized to transfer funds to the Secretary of Health, Education, and Welfare to enable him (1) to make payments under section 1115 of the Social Security Act of experimental, pilot, or demonstration projects which provide pretraining services and basic maintenance, health, family, basic education, day care, counseling, and similar supportive services required for such programs, and (2) to reimburse the Secretary of Labor for carrying out the activities described in such part É of title II of the Manpower Development and Training Act of 1962. Costs of such projects and activities shall, notwithstanding the provisions of the Social Security Act and the Man

power Development and Training Act of 1962, be met entirely from funds appropriated to carry out this part ***" (42 U.S.C. 2922.)

See also section 505 of the Economic Opportunity Act, as amended (42 U.S.C. 2925) concerning administration of the work experience and training programs by the Secretary of Labor and the Secretary of Health, Education, and Welfare. These programs are, in effect, temporary and will expire June 30, 1970 (42 U.S.C. 2924). However, section 204 of the Social Security Act Amendments of 1967 (Public Law 90-248, 81 Stat. 884) provides for a permanent work experience and training program under the Department of Labor, to be called a "Work Incentive Program." Section 204 was enacted with the understanding (of the Senate Finance Committee) that OEO would phase out the work experience and training program authorized by title V of the Economic Opportunity Act. OEO intends to have phased out the title V work experience and training program by June 30, 1969.

APPENDIX III.-EVALUATION PROBLEMS IN THE GAO REVIEW

There are a number of problems to be considered in the process of determining the extent to which the economic opportunity programs achieve their objectives. These problems have a direct bearing on the extent to which these programs are subject to independent evaluation in measurable terms and on the methods used in undertaking such an evaluation.

We found the problems of lack of data suitable for evaluation and lack of agreed-upon criteria for judging program results to be especially pervasive. Other problems were the limited usefulness of past evaluations, the difficulty of separating administrative and program effectiveness, the difficulty of measuring program accomplishments, the effect of external influences on program operations, and the multiplicity of statutory and regulatory changes. The kinds of problems confronting us in our examination were some measure of the kinds of problems confronting OEO in its own evaluation work.

LIMITED USEFULNESS OF PAST EVALUATIONS

OEO sponsored many past studies of individual projects which were devoted mainly to operational aspects rather than to impact on the alleviation of poverty. Large-scale evaluations based on national samples were virtually nonexistent. For these and other reasons, we found most past evaluations of little help in drawing our own conclusions. We were able to profit from lessons learned and mistakes made in past evaluations.

DIFFICULTY OF SEPARATING ADMINISTRATIVE AND PROGRAM

EFFECTIVENESS

We were directed by the Congress to examine the economic opportunity programs with the twofold objective of determining the efficiency of administration and the extent to which the programs are achieving the objectives of the act. These are not mutually exclusive. The quality of performance of many administrative functions has a direct bearing on the extent to which the economic opportunity programs achieve their objectives. Examples of such functions are the determination of individual and community needs; the establishment of participant eligibility; the supervision of participants in training and work assignments, counseling, and job placement; and the adequacy of followup on participant progress after termination.

LACK OF RELIABLE DATA

The economic opportunity programs include a wide variety of services touching millions of disadvantaged people in thousands of locations throughout the country, and the availability of timely and re