Maintenance of Effort (§ 261(b)) The JJDPA requires that LEAA devote 19.5% of its 1972 Safe Streets funds to juvenile justice. However, there is no mechanism that contains information nor reveals that this is happening. We propose that the Act be amended to require LEAA to establish a monitoring system to track compliance with this requirement. Match Requirement (§ 222 (d)) The statute presently gives the LEAA Administrator discretion to require cash or in-kind matching funds. Senator Bayh's amendments retain that discretion. However, the Administration's amendments delete the possibility of in-kind match and only permit cash match. We strongly oppose the Administration's proposal. Removing the possibility of in-kind match effectively destroys the ability of many private organizations with funding problems to apply for grants. We know that organizations, even some of the larger private nonprofits, have funding problems under present economic conditions. Further, the proposed changes handicap small agencies and organizations which are developing innovative programs and cannot secure money from financially troubled municipalities and counties. In short, the deletion of the possibility of the use of in-kind-match hampers the private sector in developing and implementing the kinds of programs envisaged by the Act. State Advisory Councils-State Planning Agencies (SPA'8) There have been problems in a number of States in that SPA's have not been giving Advisory Councils sufficient opportunity to "advise and consult" in the formation of State plans. Too often SPA's have submitted State plans to Advisory Councils directly before submitting them to Washington. This is in direct contravention of the purpose of the Act in creating Staff Advisory Councils. Advisory Councils are to provide citizen participation in the planning process. We ask you to consider imposing a reasonable time frame upon the process, or, as has been recommended by other organizations, statutorily requiring submission of Advisory Council comments on State plans along with submission of the plan. We wish to add to this last recommendation a further condition that the SPA's be required to submit in writing its reasons for not accepting specific Advisory Council proposals. Again, we appreciate this opportunity to present our concerns to you. We believe the JJDPA has enormous potential in aiding both States and private organizations to address the problems of juvenile delinquency and its prevention. We hope to see that potential realized. CHILDREN IN ADULT JAILS A Report by the CHILDREN'S DEFENSE FUND of the Washington Research Project, Inc. CopyrightR December 1976 All rights reserved. No part of this publication may be reproduced or transmitted in any For information about the material in this report Children's Defense Fund 1520 New Hampshire Avenue, N.W. Library of Congress Catalog Card Number: 76-55873 Printed in the United States of America First Printing Price: $2.00 |