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Guam

The Governor of Guam may reorganize the internal structure of all executive agencies under the Organic Act of 1950.

1968-The Governor proposed to the legislature the reorganization or creation of Departments of Administration, Labor, Revenue and Taxation, and Resource Development. All proposals were subsequently enacted except that concerning resource development. Also enacted was a reorganization of the Department of Corrections.

1969-Legislation is pending that would reorganize the Department of Parks and Recreations.

Puerto Rico

1968 The Reorganization Committee of the Executive Branch was created by the "Reorganization Act of 1968."

This law also allows the Governor to submit the Committee's recommendations to the Legislative Assembly effective one day after adjournment of the session unless vetoed by %'s vote of the total assembly. These powers expire in January, 1970.

Virgin Islands

The 1954 Revised Organic Act of the Virgin Islands authorized reorganization of the executive into not more than nine departments. The Governor can submit plans to the legislature for approval.

1968-The legislature created the Select Commission on the Reorganization of the Government of the Virgin Islands to make a report not later than December 18, 1968. This was later amended and the report is now expected in November, 1969.

BOARD OF SUPERVISORS,
COUNTY OF LOS ANGELES,
Washington, D.C., November 4, 1969.

Hon. EDMUND S. MUSKIE,
Senate Office Building,

Washington, D.C.

SIR: The Los Angeles County Board of Supervisors has authorized me to inform you of its position in support of S. 2479. The attached letter, adopted by the Board, indicates the Board's reasons for taking this position on this particular legislation.

The Los Angeles County Board of Supervisors serves as the executive and legislative head of the largest and most complex County government in the entire United States. It is charged with the responsibility of representing over seven million people, a population greater than any other county in the nation and exceeded in population by only seven states.

Vital services provided to citizens by Los Angeles County include law enforcement, judicial administration, property assessment, tax collection, public health protection, public social services, flood control, water conservation, fire prevention, disaster and civil defense, air pollution control, animal control, inquests, military and veterans affairs, schools, roads, libraries, parks, beaches, hospitals, botanical gardens and museums.

In addition to providing vital services to its unincorporated areas, the County offers contract services to its seventy-seven incorporated cities.

Because of the size of its population and the vital functions performed by the County of Los Angeles for its citizens, the Board of Supervisors has asked that you take into consideration its position regarding this legislation.

Very truly yours,

Hon. BOARD OF SUPERVISORS,
County of Los Angeles.

[Attachment]

JOSEPH POLLARD,
Legislative Consultant.

COUNTY OF LOS ANGELES,
Los Angeles, Calif., July 28, 1969.

GENTLEMEN: For the past several years, Congress has been making a concerted effort to make grant-in-aid programs more adaptable to the needs of local government. Senator Muskie, who is also a member of the Advisory Commission on Intergovernmental Relations, has introduced Senate Bill S.2479, which is entitled "Intergovernmental Cooperation Act of 1969."

The Act would accomplish the following:

1. Encourage simplification and standardization of financial reporting requirements of Federal assistance programs and promote, among Federal agencies administering such programs, accounting and auditing policies that rely on State and local financial management control systems.

2. Establish the authority and mechanism for the President to provide better coordination among individual assistance programs and to consolidate various grant programs within the same functional areas.

3. Enable states and their political subdivisions to use Federal assistance programs more effectively and efficiently to adapt such programs more readily to their particular needs through the wide use of joint projects drawing upon resources available from more than one Federal program.

4. Strengthen Congressional review of Federal grants-in-aid.

5. Extend and amend the law relating to intergovernmental cooperation. If enacted into law, Senate Bill S.2479 should materially assist future County grant programs.

It is recommended that the board:

1. Go on record as supporting Senate Bill S.2479.

2. Request the U.S. Senate and House of Representatives to support enactment of Senate Bill S.2479.

3. Authorize the Chief Administrative Officer to transmit the Board's indication of support to the California Delegation through Mr. Joseph Pollard, Legislative Consultant.

Very truly yours,

L. S. HOLLINGER, Chief Administrative Officer.

ADDITIONAL AGENCY REPORTS-S. 2479

GENERAL COUNSEL OF THE DEPARTMENT OF COMMERCE,
Washington, D.C., November 5, 1969.

Hon. EDMUND S. MUSKIE,

Chairman, Subcommittee on Intergovernmental Relations,
Committee on Government Operations,

U.S. Senate, Washington, D.C.

DEAR MR. CHAIRMAN: This is in further reply to your request for the views of this Department concerning S. 2479, a bill "To improve the financial management of Federal assistance programs; to facilitate the consolidation of such programs; to provide temporary authority to expedite the processing of project applications drawing upon more than one Federal assistance program; to strengthen further congressional review of Federal grants-in-aid; and to extend and amend the law relating to intergovernmental cooperation," to be cited as the "Intergovernmental Cooperation Act of 1969."

S. 2479 would add three new titles to the Intergovernmental Cooperation Act of 1968 (P.L. 90-577). The additions would be title VII dealing with accounting, auditing, and reporting of Federal assistance funds; title VIII dealing with consolidation of Federal assistance programs; and title IX dealing with joint funding simplification. In addition, the bill would add new provisions to the existing title VI of the 1968 Act dealing with review of Federal grant-in-aid programs.

While this Department supports the objectives of S. 2479, we would defer to the views of the Bureau of the Budget as to whether the bill should be enacted in its present form.

We do, however, have the following comments on the bill:

Proposed new title VIII, dealing with the consolidation of Federal assistance programs, is for the same general purpose as S. 2035, the "Grant Consolidation Act of 1969" which was introduced to implement the President's recommendation for such a proposal contained in his message of April 30. 1969, to the Congress on Improving Administration of Federal Programs. We prefer the provisions contained in S. 2035, the Administration's bill, and recommend it be enacted in lieu of the proposed new title VIII in S. 2479.

The reference to title VIII, in line 1 of page 3 of the bill, should be changed to title VII.

We have been advised by the Bureau of the Budget that there would be no objection to the submission of this report from the standpoint of the Administration's program.

Sincerely,

WILLIAM E. MURANE,
Acting General Counsel.

THE CHAIRMAN OF THE COUNCIL OF ECONOMIC ADVISERS,
Washington, November 7, 1969.

Hon. EDMUND S. MUSKIE,
U.S. Senate,

Washington, D.C.

DEAR SENATOR MUSKIE, The Council agrees in principle with the objectives of your bill S. 2479, the Intergovernmental Cooperation Act of 1969. We would, however, prefer that the provisions of S. 2035, the Administration's bill on grant consolidation, be substituted for Title III of your bill. Among other things, we would prefer the 60-day period for Congressional consideration and limiting the terms under the consolidated grant to the range covered by the preexisting programs.

The Bureau of the Budget has advised that there is no objection to the submission of this report to the Committee.

Sincerely,

PAUL W. MCCRACKEN.

GOVERNMENT OF THE DISTRICT OF COLUMBIA,

EXECUTIVE OFFICE, Washington, D.C., November 5, 1969.

Hon. JOHN L. MCCLELLAN, Chairman, Committee on Government Operations, U.S. Senate, Washington, D.C. DEAR SENATOR MCCLELLAN: The Commissioner of the District of Columbia has for report S. 2479, a bill "To improve the financial management of Federal assistance programs; to facilitate the consolidation of such programs; to provide temporary authority to expedite the processing of project applications drawing upon more than one Federal assistance program; to strengthen further congressional review of Federal grants-in-aid; and to extend and amend the law relating to intergovernmental cooperation."

The basic objective of S. 2479, the "Intergovernmental Cooperation Act of 1969", is to provide for more effective cooperation, consistency, and coordination between the Federal Government and the States (the District of Columbia being included thereunder) and their political subdivisions in the operation of Federal assistance and grant-in-aid programs.

S. 2479 would amend the Intergovernmental Cooperation Act of 1968 (Public Law 90-577) by inserting in title I thereof definitions of "Federal assistance consolidation plan" and "joint project", and by adding thereto three titles discussed in greater detail below. Finally, title V of the bill provides for Congressional and Executive oversight of Federal assistance programs.

Title II of S. 2479 adds to the 1968 Act a title VII requiring Federal agencies administering Federal assistance programs to rely, to the maximum extent feasible, on State and local financial management control systems, including State and local accounting and auditing procedures. In addition, title VII would give the President authority to develop rules and regulations to simplify and unify Federal financial reporting requirements.

Title III adds to the Intergrovernmental Cooperation Act a title VIII which would establish a procedure for consolidation of Federal assistance programs. Under the new procedures, the President would transmit Federal assistance consolidation plans to the Congress and such plans would become effective after a specified period of time unless either or both Houses of Congress passed a resolution disapproving the plan. The Commissioner notes, however, that the Administration has also proposed a bill which deals with procedures for consolidation of Federal assistance programs. The President, in his April 30, 1969, message to the Congress on Consolidation of Federal Assistance Programs, stated that: "As grant-in-aid programs have proliferated, the problems of delivery have grown more acute. States, cities, and other recipients find themselves increasingly faced with a welter of overlapping programs, often involving multiple agencies and diverse criteria. This results in confusion at the local level, in the waste of time, energy and resources, and often in frustration of the intent of Congress." The President urged enactment of a Grant Consolidation Act, and S. 2035, introduced on May 1, 1969, would implement the President's recommendations. The Commissioner, therefore, recommends enactment of S. 2035 rather than title III of S. 2479.

Title IV adds a title IX to the Act which would allow Federal agencies to develop joint Federal assistance projects and joint funding arrangements drawing upon resources available from more than one Federal program, appropriation, or agency. The proposed joint projects would be designed to enable States and localities to use Federal assistance programs more flexibly.

Title V would provide for Congressional review of Federal grant-in-aid programs every three years. In addition, Federal agencies would be required to make annual reports to the President and the Congress on Federal assistance programs, and the President would be required to submit to Congress an annual summary report on Federal assistance activities.

The Commissioner is of the view that the District of Columbia as a recipient of Federal assistance programs would benefit from improved administration of such programs. Therefore, the Commissioner of the District of Columbia supports the objectives of S. 2479. With respect to the specific provisions of the bill, the Commissioner defers to the views of affected Federal agencies.

The Commissioner of the District of Columbia has been advised by the Bureau of the Budget that, from the standpoint of the Administration's program, there is no objection to the submission of this report to the Congress and that enactment of S. 2035 would be in accord with the program of the President.

Sincerely yours,

THOMAS W. FLETCHER,
Assistant to the Commissioner
(For Walter E. Washington,
Commissioner).

THE SECRETARY OF HOUSING AND URBAN DEVELOPMENT,

Hon. JOHN L. MCCLELLAN,

Washington, D.C., November 5, 1969.

Chairman, Committee on Government Operations,
U.S. Senate, Washington, D.C.

DEAR MR. CHAIRMAN: This is in further reply to your request for our views on S. 2035, the Grant Consolidation Act of 1969, and S. 2479, the Intergovernmental Cooperation Act of 1969.

This Department fully supports the enactment of S. 2035, the Grant Consolidation Act of 1969. This legislation would provide new opportunities to bring about the merger of closely related Federal programs in a responsible and practical manner. The benefits of such mergers would occur not only here in Washington, but also in the States and at the regional and local levels. The sheer number of grant-in-aid programs with their differing guides and regulations has caused confusion, administrative waste, and a preoccupation with grantsmanship and paperwork.

This Department is in the process of reviewing its own grant authority to identify some areas of possible simplification. Our objective is to merge separate but similar programs so that grant support may be provided for a broader range of purposes and on common terms under single administrative direction. The achievement of this objective could be facilitated under the authority provided by the proposed Grant Consolidation Act.

This Department also supports the objectives of S. 2479, which addresses itself to other useful approaches, in addition to grant consolidation, for making our Federal aids more effective.

We generally support the provisions of title II of S. 2479 which deal with the accounting, auditing, and reporting of Federal assistance funds, but defer to the Bureau of the Budget for detailed comments on this title. We also generally support the grant consolidation provisions of title III of the bill, but defer to the Bureau of the Budget for detailed comments.

We believe that the approach to joint funding simplification taken in title IV of S. 2479 seems to be both realistic and experimental. It focuses essentially on those joint funding arrangements that are necessary to achieve effective intradepartmental program packaging and places more difficult to achieve interdepartmental joint projects on a more limited demonstration basis. Title IV would help upgrade the management of this Department's assistance activities in respect to many programs by encouraging the development of a more flexible application and funding approach in administering these programs. Joint funding is a necessary compliment to, though not a substitute for, grant consolidation. We believe that title V of S. 2479 would improve congressional and executive

oversight of Federal assistance programs. Periodic reports would serve a useful purpose in identifying areas of program administration and management which require improvements. They would also provide a basis for determining the feasibility of consolidation and simplification.

The Bureau of the Budget has advised that there is no objection to the presentation of this report from the standpoint of the Administration's program. Sincerely,

GEORGE ROMNEY,

Secretary.

OFFICE OF THE DEPUTY ATTORNEY GENERAL,
Washington, D.C., November 5, 1969.

Hon. JOHN L. MCCLELLAN,
Chairman, Government Operations Committee,
U.S. Senate, Washington, D.C.

DEAR SENATOR: This is in response to your request for the views of the Department of Justice on S. 2479, the "Intergovernmental Cooperation Act of 1969." The bill would amend the Intergovernmental Cooperation Act of 1968 (Pub. L. 90-577, 82 Stat. 1098) by the addition of three new titles. These would provide for-new title VII: accounting, auditing and reporting policies calling for reliance by federal agencies on State management control systems where these systems meet established standards, new title VIII: consolidation of federal assistance programs, through transmission to Congress by the President of plans (utilizing the reorganization plan technique) which would place responsibility in a single federal agency for administration of federal assistance programs where a related formula for consolidation proves feasible, and new title IX: development of joint funding simplification through arrangements for intradepartmental actions and interdepartmental joint projects on an experimental and limited demonstration basis. The bill also provides that title VI of the Intergovernmental Cooperation Act of 1968 would be extended by inclusion of provisions for Congressional and executive oversight of federal assistance programs enacted on or after January 3, 1971, which provide for grants in aid over a three-year period. New sections within the title also provide authority for Congressional review specialists, for annual reports on programs by federal agencies and for a report to the Congress by the President on federal assistance activities.

This Department supports generally the principles of S. 2479. It is noted especially that the provision for a consolidation of grants procedure would implement an important objective urged for accomplishment by the President in his message of April 30, 1969, on "Consolidation of Federal Assistance Programs." The Administration bill, S. 2035, embodies the provisions recommended in the President's message. At the same time the Department of Justice urges your Committee's consideration of the questions and reservations respecting S. 2479 which were submitted for the Bureau of the Budget in testimony before the Subcommittee on Intergovernmental Relations on September 9, 1969. These are discussed briefly herein.

Implementation of new title VII (erroneously identified "VIII" in line 1, page 3 of the bill) regarding reliance on State financial systems, would upon enactment await prescription by the Bureau of the Budget of rules and regulations to affect all departments and agencies. This Department offers no comment as to those provisions for financial management control systems. These are concerned with subject matter of a technical nature as to which this Department possesses no expertise.

In its testimony, the Bureau of the Budget noted that the provisions in new title VIII dealing with consolidation of federal assistance programs largely parallel those in S. 2035. The Bureau stated that such differences as exist between the two bills are in most part matters of style and format with perhaps the more appropriate and complete arrangements in S. 2035 for Presidential consolidation authority and for the imposition of specific limitations upon that authority. It is felt that these are differences which the Committee can work out with representatives of the Bureau of the Budget. In addition the Bureau expresses a preference, which we support, for provisions which would permit consolidation plans to become effective after a 60-day rather than a 90-day period unless disapproved by either House. The additional 30 days, we feel, would impose a delay in the effective date of consolidation plans which experience with reorganization plans has not demonstrated to be necessary.

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