NATIONAL AERONAUTICS AND SPACE ADMINISTRATION, Washington, D.C., October 7, 1969. Chairman, Subcommittee on Intergovernmental Relations, Committee on Government Operations, U.S. Senate, Washington, D.C. Hon. EDMUND S. MUSKIE, DEAR MR. CHAIRMAN: This is in further response to your recent letter in which you request the views of the National Aeronautics and Space Administration with respect to the bill S. 2479, "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." S. 2479 would amend the Intergovernmental Cooperation Act of 1967 in several respects, including the addition of new Titles VII through IX, which, respectively, concern the simplification and standarization of financial management of Federal assistance programs; the consolidation of such programs; and the authorization and facilitation of joint projects drawing upon resources available from more than one such program. The new Title VIII to be added by the bill would also amend the rules of both Houses of the Congress by providing rules for the consideration of consolidation plans. Finally, the bill would amend Title VI of the prior Act to provide for congressional and executive oversight of Federal assistance programs and for reports to the Congress by the President and the individual agencies with respect thereto. At the present time NASA does not administer and Federal assistance programs of the types contemplated by the proposed legislation. NASA should, therefore, take no position on S. 2479. In analyzing the measure, a typographical error on page 3, line 1 has been noted. The title sought to be added to the prior Act, per page 2 lines 21 and 22 should be "Title VII," not "Title VIII." The Bureau of the Budget has advised that, from the standpoint of the Administration's program, there is no objection to the submission of this report to the Congress. Sincerely yours, ROBERT F. Allnutt, Assistant Administrator for Legislative Affairs. OFFICE OF ECONOMIC OPPORTUNITY, Washington, D.C., October 29, 1969. Hon. JOHN L. MCCLELLAN, Chairman, Committee on Government Operations, DEAR MR. CHAIRMAN: Thank you for requesting the views of the Office of Economic Opportunity on S. 2035, the "Grant Consolidation Act of 1969." Our views have also been requested by your Committee's Subcommittee on Intergovernmental Relations on S. 2479, the “Intergovernmental Cooperation Act of 1969", and since both bills deal with the subject of grant consolidation, we are commenting on them in the same report. In his message to the Congress of April 30 on "Improving Administration of Federal Programs", the President called attention to the compelling need to improve the delivery systems employed in the administration of Federal programs. He asserted that the problems of delivery have become more acute as grant-in-aid programs have proliferated, and he observed that "States, cities and other recipients [of intended services] find themselves increasingly faced with a welter o' overlapping programs, often involving multiple agencies and diverse criteria.'f The President urged the enactment of legislation under which he would be given authority (subject to veto by either House of Congress within 60 days) to initiate the consolidation of closely related Federal assistance programs, and to place the consolidated programs under the jurisdiction of a single agency. The exercise of this authority, however, would be subject to stringent safeguards to prevent abuse. S. 2035 is designed to carry out the President's recommendations. On September 9, Mr. Dwight Ink, Assistant Director of the Bureau of the Budget, appeared before your Committee's Subcommittee on Intergovernmental Relations and presented the statement of Mr. Robert P. Mayo, Director of the Bureau, setting forth the agency's views on the bills which are the subject of this report. In a prepared statement which was presented to the Subcommittee, Mr. Mayo urged the enactment of S. 2035, subject to the incorporation of two technical amendments. We fully concur with the views expressed in Mr. Mayo's testimony regarding this measure, and we join in his recommendation that the bill be enacted with the technical changes he has suggested. In his testimony, Mr. Mayo expressed general agreement with the objectives of S. 2479, the proposed "Intergovernmental Cooperation Act of 1969." However, he stated that his agency had certain questions and reservations about the details of that measure. As to the grant consolidation provisions of S. 2479, Mr. Mayo noted that those provisions to a large extent parallel the provisions of S. 2035, many of the differences between the two proposals being merely matters of style and format. However, he expressed the view that S. 2035 contains more appropriate and complete provisions as to what the President's consolidation authority would be and as to the specific limits which would be applicable to that authority. He also expressed a preference for S. 2035's provision allowing 60 days for disapproval by either House of Congress of a consolidation plan, since the 90-day period provided for in S. 2479 would reduce by a month the period during a congressional session in which the President may transmit consolidation plans. We concur with the views of the Bureau of the Budget on the relative merits of the grant consolidation provisions contained in these proposals. We favor the provisions of S. 2479 relating to joint funding simplification and believe their enactment would be desirable, provided they are amended, as suggested in Mr. Mayo's testimony, to (1) eliminate the limitations on the number of interdepartmental joint funding arrangements which may be utilized under this legislation, and (2) to make it possible for applicants other than States and local governments to apply for joint funding projects. The Bureau of the Budget advises that there is no objection to the presentation of this report to the Congress and that the enactment of S. 2035 would be in accord with the President's program. Sincerely, DONALD RUMSFELD, Director. EXECUTIVE OFFICE OF THE PRESIDENT, Hon. EDMUND S. MUSKIE, Chairman, Subcommittee on Intergovernmental Relations, Committee on Government Operations, U.S. Senate, Washington, D.C. DEAR SENATOR MUSKIE: This is in reply to your request for an expression of the views of this Agency concerning S. 2479, 91st Congress, a bill entitled: "Intergovernmental Cooperation Act of 1969." The Office of Emergency Preparedness is in accord with the basic purposes and objectives of the subject legislation. However, with respect to the specific provisions of this bill, we defer to comments made by the Director of the Bureau of the Budget in testimony dated September 9, 1969, before your subcommittee. From the Standpoint of the Administration's program, the Bureau of the Budget advises that it has no objection to the submission of this report. Sincerely, G. A. LINCOLN, Director. THE POSTMASTER GENERAL, Washington, D.C., August 22, 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 response to your request for a report on S. 2479, a bill to amend the Intergovernmental Cooperation Act of 1968, Public Law 90-577. The purpose of the Intergovernmental Cooperation Act of 1968 is to strengthen State and local government and improve the relations between those governments and the Federal Government through closer cooperation and coordination of policies and activities, particularly in the administration of Federal grant and loan programs for development assistance. The present measure would amend this Act to strengthen further the management of Federal assistance programs (1) by improving their accounting, auditing and fiscal reporting procedures, (2) by providing a means for consolidating Federal assistance programs when necessary or desirable, (3) by adapting Federal assistance programs more readily to the needs of the States through the wider use of joint projects drawing upon resources available from more than one Federal program, and (4) by strengthening oversight of Federal assistance programs by the Congress and Federal agencies. The Post Office Department does not administer any assistance programs. Accordingly, we make no recommendation concerning enactment of this bill. In advising with respect to H.R. 7366, a substantially identical bill, the Bureau of the Budget has advised that there was no objection to the submission of that report to the Committee from the standpoint of the Administration's program. Sincerely, Hon. EDMUND S. MUSKIE, WINTON M. BLOUNT. TENNESSEE VALLEY AUTHORITY, Chairman, Subcommittee on Intergovernmental Relations, DEAR SENATOR MUSKIE: This is in response to your letter of July 11 requesting our views with respect to S. 2479 amending the Intergovernmental Cooperation Act of 1968. TVA in conducting its program of regional resource development from time to time makes cooperative agreements with state and local agencies under which TVA may provide funds or technical advice in carrying out the particular project. Such agreements and TVA's contributions are made pursuant to the provisions of the TVA Act. TVA does not administer any grants-in-aid program or any other federal assistance program as such. Consequently, the provisions of S. 2479, which are concerned largely with the latter types of programs, would seem to have little effect on TVA's operations. We agree with the purpose of the legislation, however, of simplifying the administration of federal assistance programs. The Bureau of the Budget advises that it has no objection to the presentation of this report from the standpoint of the Administration's program. Sincerely yours, AUBREY J. WAGNER, Chairman. OFFICE OF THE SECRETARY OF TRANSPORTATION, 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 response 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 inter-governmental cooperation. Proposed title VII, erroneously reflected as title VIII on page 3 of the bill, would contribute significantly to the establishment of this Department's financial management policies in the areas of financial reporting by States and the audit of State financial records. This Department would utilize cross servicing arrangements to the maximum extent in the audit of State financial records. We understand that the Bureau of the Budget is recommending some technical changes to this title, which the Department endorses. Title VIII, section 802 of S. 2479 contains provisions that govern the terms for Presidential consolidation plans. This as written may not provide sufficient flexibility to accommodate more than a single set of matching ratios and apportionPent formulae. For example, the combination of two related programs might be desirable but practicable only as some difference is retained in matching ratios or apportionment. It is not clear that the bill gives the President sufficient authority to provide more than a single set of conditions falling someplace between the bounds set by the constituent programs being consolidated. This is not a fatal flaw but simply something that might limit the future usefulness or applicability of the authority. We believe that title IX of the bill will facilitate and encourage the integrated development and execution of Federal assistance programs to achieve a highly desirable result. The principal Federal assistance programs of this Department which would be affected by the proposed authority are: the Federal Airport, the Federal-aid to Highways, Highway Beautification, Highway Safety, and Urban Mass Transportation programs. In administering the Federal Airport Act, airport grant-in-aid projects, in addition to the cooperation currently taking place, might be coordinated with urban renewal projects, mass transportation projects, open-space projects, metropolitan planning grants, and with the Federal highway program. The Highway and UMTA programs could with the assistance of this bill, be coordinated with the grant-in-aid programs of other Departments. We assume that the portion of section 903(d) of the bill which provides that an account be subject to rules and regulations which are not inconsistent with other applicable law is intended to assure that the joint funds operate in full conformity with appropriate statutory provisions and policies. Restraints on expenditures from the Highway Trust Fund may be necessary since use of the fund (financed through highway user taxes) has been specifically limited by Congress to highway purposes. Subject to the above views the Department of Transportation favors enactment of this legislation. The Bureau of the Budget advises that from the standpoint of the Administration's program, there is no objection to the submission of this report for the consideration of the Committee. Sincerely, CHARLES D. BAKER. VETERANS' ADMINISTRATION, Washington, D.C., October 31, 1969. OFFICE OF THE ADMINISTRATOR OF VETERANS' AFFAIRS, Hon. JOHN L. MCCLELLAN, Chairman, Committee on Government Operations, DEAR MR. CHAIRMAN: This is in response to your request for a report by the Veterans' Administration on S. 2479, 91st Congress, 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. S. 2479 would amend the Intergovernmental Cooperation Act of 1968 (Public Law 90-577, 82 Stat. 1098). Title III of the bill would achieve the objectives of S. 2035, 91st Congress, a bill also pending before your Committee and identical to the proposal of the President, transmitted with his message of April 30, 1969. We believe that the provisions of S. 2035 are preferable to those of S. 2479. Specifically, title I of S. 2479 defines the term Federal assistance "consolidation plan" and "joint project." Title II of the bill would add a new title VIII. entitled 'Accounting, Auditing and Reporting of Federal Assistance Funds" for the purpose of encouraging simplification and standardization of financial reporting requirements of Federal assistance programs, to promote Federal agencies to adopt auditing policies that rely on state and local financial management control standards and to authorize the Comptroller General to prescribe rules and regulations for use of auditing of state and political subdivisions. Title III would add a new title, also designated as "title VIII", entitled "Consolidation of Federal Assistance Programs." Generally, this would provide for the President to examine various programs of Federal assistance and determine which consolidations are neceassry or desirable. When the President, after investigation, finds that a consolidation is necessary or desirable, he would prepare a consolidation plan, meeting the requirements set forth in the new section 802 and transmit such plan to the Congress, which plan would become effective on the first day of the month following the end of the first period of the 90 calendar days of continuous session of the Congress after the date which the plan is transmitted, unless between the date of transmittal, and the end of the 90-day period, either House passes a resolution stating, in substance, that the House does not favor the Federal assistance consolidation plan. New section 804 would provide rules for the Congress in considering Federal assistance consolidation plans. Title IV of the bill would add a new title IX, entitled "Joint Funding Simplification," designed to enable joint projects, with joint funding, where two or more Federal assistance programs are available, including interdepartmental joint projects, and title V would provide for congressional and executive oversight of Federal assistance programs, requiring reports by Federal agencies to the President and the Congress at the end of each fiscal year. Insofar as the Veterans Administration is concerned, title III giving the President broad reorganization authority with respect to Federal assistance programs is the most important segment of S. 2479. While the Veterans Administration does not, in general, have responsibility for administering broad programs involving Federal grants, there are some programs which could be affected by this legislation. Among the programs which might be affected are: programs for grants for the exchange of medical information (38 USC 5055); grants for the construction of state nursing homes (38 USC subchapter III, chapter 81); aid to state soldiers homes (38 USC 641). Additionally, it could affect the Veterans Administration loan guaranty programs (38 USC chapter 37) and the grant program for specially adapted housing (38 USC chapter 21), as well as other areas of less importance. The provisions of title III have no mandatory effect on consolidation of programs, vesting broad discretion in the President after investigation to effect such consolidations as he deems necessary or desirable. Titles II and IV of the bill prescribe accounting, auditing and funding procedures to be regulated by the President, the Comptroller General or the Bureau of the Budget. We feel that Veterans Administration financial management is sufficiently flexible to adapt to any procedures which might be prescribed under these titles of the bill. The reports to the Congress and the President required by the provisions of title V of the bill would not place any undue administrative burden on the Veterans Administration. As set forth above, title III of the bill would achieve the objectives sought by the President in his message to the Congress on April 30, 1969, transmitting a proposal for the consolidation of Federal grant-in-aid programs. Accordingly, we view the overall objectives of S. 2479 as desirable. We feel, however, that the provisions of S. 2035 are preferable to the similar purpose provisions of title III of S. 2479 and urge favorable consideration of that bill by your Committee in lieu of that title. We are advised by the Bureau of the Budget that there would be no objection to the submission of this report to your Committee and that the enactment of S. 2035 would be in accord with the program of the President. Sincerely, DONALD E. JOHNSON, Administrator. THE GENERAL COUNSEL OF THE TREASURY, Hon. EDMUND S. MUSKIE, DEAR MR. CHAIRMAN: Reference is made to your request for the views of this Department on S. 2479, "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 only provisions of the proposed legislation of primary interest to this Department are contained in Titles II and IV of the bill which would add new Titles VIII and IX to the Intergovernmental Cooperation Act of 1968. The first new title VIII, which apparently should read "Title VII," would appear to be designed to improve and simplify procedures under Federal assistance programs relating to accounting, auditing, and reporting of Federal assistance funds. Although the Department is not in a position at this time to furnish substantive views on this title, we are in general agreement with the overall objectives of its provisions. 34-851-69-5 |
