Kamis, 17 Maret 2011

The federal role in financing education



In 1930 the federal government provided only .4 percent of the revenue receipts of the public schools, but that share has been increased in each decade since. The federal government provided 1.8 percent of the revenue receipts of the public schools in 1940, 2.9 percent in 1950, 4.4 percent in 1960, 8.0 percent in 1970, and approximately 9 percent in 1980.
The increases in federal aid for the public schools during recent years have usually been accompanied by much controversy. Federal policy with respect to financial support of the public schools is far from being stabilized. A number of educational organizations and experts on school finance have advocated that the federal government provide 30 percent or more of public school revenue. On the other hand, some business organizations and conservative political leaders would like to see all federal financial support of the public schools discontinued. At this writing, the national administration has recommended that present fed­eral support of the public schools be reduced 20 to 25 percent.
What is the basis of the present controversy over federal aid to education? This is not a simple issue. It is an old issue as well as a current issue. The federal-aid issue has long been involved with a number of other important issues. Ed­ucation has become the battleground for testing many important principles of law, theories of government, theories of economics, and philosophical values. Furthermore, there has been much controversy over the purposes of federal aid, methods of distribution, and federal controls associated with it.
It is impossible in a book of this length to give a comprehensive treatment of the, subject of federal aid to education. This chapter will deal with some of the more important national issues involved in federal aid, its present status-the arguments for and against it, and a brief history of federal aid.
NATIONAL ISSUES AFFECTING FEDERAL AID TO EDUCATION
If the policies of federal aid to education could have been isolated from other important national issues, it is probable that the federal government would have been providing a more substantial share of public school revenue than it is now providing. Some of the more important of those issues are discussed below.

Division of Powers among Governments
The Tenth Amendment to the Constitution of the United States provides: "The powers not delegated to United States by the Constitution, nor prohibited by it to the States, are reserved to the states respectively or to the people." Since the Constitution makes no specific reference to education, it has beer, assumed that education is the legal responsibility of the states. The governmen­tal powers of the states are plenary except for the powers that have been dele­gated to the federal government or withheld from the states by some provision. of the Constitution. On the other hand, the federal government is a limited government, with no powers except those specifically conferred upon it by the Constitution or those that can reasonably be implied as necessary to exercise the powers and responsibilities specifically granted.'
The Constitution, in addition to being a broad statement of principles, also provides road specific grants of power to the federal government. Since the federal government has no specific grant of power to finance, regulate, control, or operate schools, colleges, institutions, or educational programs, its authority to do so must be found in its implied powers. It is in the area of implied powers that the controversy centers.
As will be shown later in this chapter, it is an historical fact that the federal government has assisted in financing many types of public educational institu­tions, including the public schools; it has regulated and controlled public edu­cation to some extent, and it has operated practically every type of education institution and numerous special programs. In fact it is still doing so. It is inter­esting that this exercise of implied powers has never been" successfully chal­lenged in the courts. The issue is not whether the federal government has any implied powers with respect to education but the extent to which those powers should be exercised. It is not possible to define neatly by Constitution or statute the limits of the exercise of the implied or discretionary powers of government, or the times when they should be exercised, or the objects for which they should be exercised.

The implied powers of the federal government have caused bitter con­troversy between the states and the federal government itself. It was one of the fundamental issues of the Civil War.  It is a basic issue in the current controversy over desegregation in the public schools and institutions of higher learning and over civil rights. It was a controversial issue of the past and still remains a live issue.
One of the earliest issues causing the formation of political parties arose over differences of opinion concerning the relative roles of the federal and the state governments. The present-day term "'states' rights" (also an old term) means many things to many people. But in general, it emphasizes the powers of the states -and deemphasizes the powers of the federal government. It was inevitable that the issue of federal aid to education should become associated in the minds of many people with these old issues. Therefore, the position that many people take with respect to federal aid to education is not determined by the virtues of the proposals or the reality of the need for federal aid, but by their thinking concerning these old issues.
Controversy over the Effect of Government
Expenditures on the Economy

The enormous increase in the cost of government at all levels during the past 30 years has been accompanied by bitter controversy. .as pointed out in Chapter 2, the per-capita cost of all government federal, state and local increased from $1,588 in 1950 to 53,608 in 1980 in terms of the purchasing power of 1980 dollars. This is a real increase of 127 percent. The per capita GNP increased from $6,462 in 1950 to $11,569 in 1980 in terms of 1980 dollars. This is a real increase of 79 percent. Therefore the cost of government has been increasing faster than the GNP in recent years.
Much political capital has been made in recent years over the increase in the expenditures of the federal government. However, the direct expendi­tures of the federal government have increased at a lesser rate than the direct expenditures of state and local governments. Direct expenditure is defined as total expenditure less the amount transferred to other governments. The direct expenditures of the federal government increased from 14.7 percent of the GNP to 1950 to 19.6 percent in 1980, whereas the direct expenditures of the state and local governments increased from 9.8 percent of the GNP in 1950 to 13.5 percent in 1980. In terms of the percentage of the GNP, the direct ex­penditures of the federal government increased 33 percent between 1950 and 1980, and state and local government expenditures increased 38 percent during that period. At this writing, great political pressure was being brought to reduce government expenditures at all levels, but greater pressure was being brought to reduce government expenditures at the federal level than at state and local government levels, despite the fact that government expenditures had been increasing at a faster rate at the state and local levels.
The point of view of many modern thinkers is that the trend toward increasing government expenditures in this technological civilization is a nec­essary and desirable trend because (1) only government (especially central government) can provide many of the services essential to a modern civilization, and (2) the expenditures of government are necessary for maximizing production and consumption of goods and services and minimizing unemployment. The fiscally conservative view is that government taxing and spending should be limited to providing the minimum of necessary government services, because (1) continued increases in government spending eventually will result in so­cialism and a welfare state, and (2) socialism will destroy the free-enterprise system and eventually result in the loss of other liberties. These two sharply contrasting views are at the heart of much of present-day political controversy.
Those not fearing the effects of government spending generally support increased revenue for education at all levels of government and especially at the state and federal levels. Those fearing the effects of government spending generally oppose increased spending for education at all levels, especially by the federal government. The conservative generally opposes increased spending for public education, not because he or she is opposed to public education, but rather because of his or her opposition to increases in government spending in general.
The goal of the fiscal conservative is to maximize the market economy and to minimize the government economy. In times of inflation, such as that. experienced in 1980, the fiscal conservative advocates the reduction of gov­ernment expenditures and taxes on the basis that government expenditures add to inflation. In times of deflation and depression, this same conservative still advocates the reduction of government expenditures and taxes contending that one more penny of taxes will break the back of the overburdened taxpayer."
Experts on school financing generally insist that expenditures for edu­cation should not be determined by whether they inflate or deflate the economy, but by the educational needs of the children, youth, and adults of the nation. Such a policy tends to stabilize the economy rather than inflating or deflating it. Furthermore, as pointed out in Chapter 3, investment in people, as well as investment in physical capital, in time increases the total volume of goods and services available for consumption.
The General Welfare Clause of the Constitution
Article I, Section 8, of the Constitution deals with the powers granted to Congress. Clause 1 reads as follows: "The Congress shall have Power To lay and collect Taxes, Duties, Imposts and Excises, to pay the Debts and provide for the common Defense and general Welfare of the United States; but all Duties, Imposts and Excises shall be uniform throughout the United States." Although this clause deals with such important matters as levying and collecting taxes, the payment of debts, and' providing for the common defense, it is commonly called the General Welfare Clause because of the great controversies over the meaning of-the words and general Welfare of the United States. At the time the Constitution was adopted, probably only a few people realized the significance of those words.
The eighteenth, and last, clause of Section 8 grants Congress the final power "to make all Laws which shall be necessary and proper for carrying into Execution the foregoing Powers, and all other Powers vested by this Consti­tution in the Government of the United States, or in any Department or Officer thereof." This clause gives to Congress a broad grant of implied powers. The meaning of Clauses 1 and 18 became a matter of bitter controversy very early in our history. James Madison and Alexander Hamilton took the lead in pre­senting the opposing points of view. Madison argued that the words and general Welfare of the United States confer on Congress no additional powers to tax and spend and that the power of Congress to tax and spend therefore is limited to the purposes specifically enumerated by the Constitution. Hamilton held that those words did confer additional power on Congress to tax and spend for purposes other than those specifically enumerated in the Constitution and that Congress had the power to tax and spend for any purpose that it deemed to be for the general welfare.
Hamilton and Madison did not resolve their differences. In fact, contro­versy over this issue still continues, but the details have changed somewhat. The Supreme Court, in some relatively recent decisions, has supported some of Hamilton's contentions. In a ruling on the Agricultural Adjustment Act, the Court held Shat "the power of Congress to authorize expenditures of public moneys for public purposes is not limited by the direct grants of legislative power found in the Constitution:" The Supreme Court, in ruling on the Social Security Act, held that the decision as to whether an expenditure was for the general welfare had to be made by Congress, provided that it was not a display of arbitrary power. The Court also held in this decision: "Nor is the concept of general welfare static. Needs that were narrow or parochial a century ago may be interwoven in our day with the well-being of the nation. What is critical or urgent changes with the times-5The authority of Congress to tax and spend for public education has been
clearly established by these and other opinions by the Court. Actually, the legal
power of Congress to appropriate and spend money for public education has
never been challenged in the Supreme Court. But the rulings of the Court
have not settled the controversy between the "liberal constructionists" and the
"strict constructionists" of the Constitution. The battle still continues, but the
major issue has changed from the legal power of Congress-to tax and spend for
the general welfare to the wisdom of the policy of doing so. What laws are
"necessary and proper" (Clause 18) "to -provide -for the general Welfare of the
United States" (Clause I )? That issue never Al be finally resolved, because
what is necessary and proper for the general welfare "changes with the times."
The General Welfare Clause has been used extensively during the past
forty years to justify the expansion of old federal activities and the addition of



new activities of the federal government. The advocates of extension of service  of the federal government now contend that Congress has not only the power to promote the general welfare but also the duty to do so. This point of view is vigorously opposed by the conservatives, who bitterly fight practically arc extension of federal spending except for national defense. Therefore, the issue of federal aid to education actually is a part of the old Hamilton-?Madison controversy
FEDERAL CONSTITUTIONAL LIMITATIONS
Following is a brief discussion of some constitutional provisions affecting education.
Limitations on Congress
Article I, Section 9, of the Constitution sets forth the powers denied to Congress. Two of its subsections have some relationship to financing education. Subsection 4 reads as follows: "No Capitation or other direct Tax shall be laid, unless in Proportion to the Census or Enumeration herein before directed to be taken, This provision of the Constitution has effectively prevented Congress from levying a property tax. It is obviously impracticable to levy a property in proportion to the census. The last time Congress attempted to levy such a tax was during the Civil War. Had it not been for this provision of the Consti­tution, Congress probably would have levied property taxes very early in our history.
This subsection also prevented Congress from levying income taxes until it was removed by the Sixteenth Amendment, ratified ir. 1913. It reads: "The Congress shall have power to lay and collect taxes on incomes, from whatever sources derived, without apportionment among the several States, and without regard to any census or enumeration" This amendment greatly increased the taxing powers of Congress.
The federal government now obtains more than 80 percent of its tax revenue from income taxes. This broadening of the taxing powers of Congress has made it possible for the federal- government to extend greatly the federal services provided. It also greatly improved the equity of our taxing system.
Subsection 5 prohibits Congress from laying taxes or duties on articles exported from, any state. This provision and the provisions of Subsection 4 as amended by the Sixteenth Admendment are the only specific limitations upon the taxing powers of Congress, except for the provision of Article I, Section 8, Clause 1, requiring that "all Duties,' Imposts and, Excises shall be uniform throughout the United States. 7 Therefore, it is apparent that Congress has very broad taxing powers. The enormous amount of revenue collected annually by the federal government is evidence of that fact.among state and local governments are avoided. The income tax, both personal and corporate, is levied nationwide. A person or corporation cannot escape the federal income tax by moving to another political jurisdiction within the nation. But the income taxes and certain other taxes of state and local governments can be avoided by moving into jurisdictions not levying the tax. Therefore, "tax competition- limits the potential tax revenues of state and local governments.
The federal government does not suffer from this limitation. it might be argued that tb- federal government faces international tax compeition. That probably is true to some extent, but international tax competition does not have nearly so great a restraining influence on taxation as does the tax com­petition among state and local governments.
Limitations on the States
Article I, Section 10, of the Constitution sets forth the powers denied the states. There are only a few provisions of this section that are related to the financing of education. Subsection 1 includes- the provision that no state shall pass any law impairing the obligation of contracts. Subsection 2 provides: "No State shall without the Consent of the Congress, lay any Imposts or Duties on Imports or Exports, except what may be absolutely necessary for executing its inspection Laws; and the net Produce of all Duties and Imposts, laid by any State on Imports or Exports, shall be for the Use of the Treasury of the United States; and all such Laws shall be subject to the Revision and Control of the Congress. " Subsection 3 provides: "No State shall, without consent of Congress, lay any Duty of Tonnage . . . . "These are the only limitations placed upon the taxing powers of the states by the Constitution. They are relatively minor and therefore place no serious restrictions on the states with respect to levying and collecting taxes.
But it should not be assumed that Article I, Section 10, of the Constitution contains the only federal limitations upon the states in the operation of systems of public education. The Constitution as interpreted by the Supreme Court is the supreme law of the land. Any law of any state on any matter, including education, that is in conflict with any provision of the Constitution is null and void if so declared by the United States Supreme Court. People who argue that the federal government should have no control whatsoever over public education seem to have overlooked this fact. It would be impossible to have a federal government of the United States if the states could nullify the Consti­tution. Therefore, some measure of federal control of public education is ines­capable. The issue of federal control of public education is so important that some specific instances are presented in the following paragraphs.
Equal Protection of the Law The Fourteenth Amendment, Section 1, pro- vides in part: "No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws." It "vas this amendment plus subsequent rulings of the Supreme Court that firmly, established the supremacy of the Constitution and all its provisions.
One of the Court's most dramatic rulings was made on May 17, 1954. The Court had before it five cases dealing with segregation in the public schools. Segregation by race in the public schools was declared unconstitutional when the Court stated: "We conclude that in the field of public education the doctrine of separate but equal' has no place. Separate educational facilities are inherently unequal. Therefore, we hold that the plaintiffs and others similarly situated for whom the actions are brought are, by reason of the segregation complained of, deprived of the equal protection of the laws guaranteed by the Fourteenth Amendment."6
It is interesting to note that the 1954 ruling of the Court reversed a ruling it had made in 1896 dealing with the question of racial segregation on public transportation facilities: The Court ruled in that case that separate but equal facilities were constitutional. 7 The 1954 Brown ruling controls not only the policies if the states relating to segregation but also the policies of boards of education wherever situated. This decision overthrew the "states' rights" theory insofar as certain aspects of public education were concerned.
Decisions of the Court dealing with highly controversial matters are not always accepted by the losers as being the supreme law of the land. Segments of the public continue to resist the implementation of the Court's decisions on controversial matters. This is particularly true of the 1954 ruling on segregation. Controversy over the segregation issue does not produce a climate favorable to the financing of education. This observation is not for the purpose of ques­tioning the correctness of the ruling of the Court, but rather to point out its fiscal effect.
The Civil Rights Act of 1964 greatly increased the power of the federal government to enforce the 1954 decision of the Supreme Court. Title VI of this act states: "No person in the United States shall on the ground of race, color or national origin, -be excluded from participation in, be denied the ben­efits of, or be subject to discrimination, under any program or activity receiving federal financial assistance." Under the provisions of this act, any federal agency disbursing federal funds is given the power to withhold such funds if the re­cipient agency or institution violates this act. The federal agencies in recent 'years have frequently used their power to withhold funds to enforce the pro­visions of the Civil Rights Act and the 1954 decision of the Supreme Court. Since federal funds for education are now rather substantial, this is a powerful control designed to force racial integration.
Separation of Church and State. the First Amendment also apply to the states because of the following pro­vision in the Fourteenth Amendment: No State shall make or enforce any laws which shall abridge the privileges or immunities of citizens of the United States. .. . "Therefore any privilege or immunity granted a citizen of the United States by the Constitution cannot be denied by the states. See chapter 6 for a more extensive discussion of this topic.
Impairment of Contracts. As has been pointed out, Article I, Section 10, of the Constitution contains a provision prohibiting a state from passing a law impairing the obligation of contracts. School financing involves many different types of contracts. School boards, for instance, issue bonds that are important financial contracts. The federal prohibition against the impairment of contracts undoubtedly has improved the credit of boards of education as well as the credit of ail state and local governments. This type of federal control seems to be applauded by almost everyone. Actually, it is not generally recognized as a control, but the fact that it is a control makes it a valuable asset in school financing.
One ruling of the Supreme Court has significance in relation to teacher retirement. The Court has held that "a legislative enactment may contain pro­visions which, when accepted as a basis of action of individuals, become con­tracts between them and the state or its subdivision. . . . ", Teacher retirement laws should be so drafted as to make it clear that provisions for retirement constitute a contract between the teacher and state.
HISTORICAL DEVELOPMENT OF FEDERAL AID
Practically every department of the federal government at one time or another has expended some of its appropriations for education, either directly or in­directly. There is no accurate historical record of all the federal funds that have been expended for education. Actually, no office or agency of the federal gov­ernment can give an accurate statement of federal funds being expended directly or indirectly for education. Even objective investigators working independently cannot arrive at the same total of federal funds expended for education during any given fiscal year. Therefore, it would not be possible to present an accurate history of federal aid even if space permitted. However, it is possible to present certain examples of it that throw some light on its development.
Early Land Grants
The national interest in education was revealed even before the adoption of the Constitution. The Ordinance of 1785 included the provision that "there shall be reserved the lot number 16 of every township for the maintenance of public schools in each township.-


The policies enunciated in the Ordinance of 1785 were put into effect in 1787 by a federal contract for the sale of lands to the Ohio Company. The Ordinance of 1787 contained these often-quoted words expressing federal ed­ucational policy at that time: "Religion, morality and knowledge being necessary to good government and the happiness of mankind, schools and the means of education shall be forever encouraged." The ordinance, providing for the CY) 11- tract of sale in 1787, also reserved certain townships to endow a university.
Most of the states admitted to the Union after 1789 were first administered and organized as territories. The federal government administered the terri­tories and consequently actually founded the public school systems of many states. This direct responsibility of the federal government for education in the territories probably contributed to federal interest in education when the ter­ritories became states.
In 1802, Congress adopted the same general policy of giving support to public education that had been adopted by the Congress of the Confederation seventeen wears earlier. When Ohio was admitted to the Union in 1602, Con­gress initiated its policy of -setting aside public lands for public education at the time of the admission of a state to the Union.
The policy of setting aside the sixteenth section of each township for the public schools was followed for states admitted between 1802 and 18 S. When the Oregon Territory was established iii 1848, Congress set aside two sections of each township for the public school. This policy was continued until 189,6, when Utah was granted four sections in every township. Similar grants were made to other western states, admitted after that year.
It was the hope of some in the early days that the income from school lands would be sufficient to pay for most of the cost of the public schools. However, partly because of poor management of these lands, this was a vain hope and would have been so even if the public lands had been well managed in all cases. But the early grants of land had great significance for the public schools. These federal grants stimulated the interest of the states in public schools. When the states-found that the income from federal grants was insuf­ficient to support their schools, they began to provide state grants in aid There­fore, the early federal grants in effect established the precedent for- state aid for-the public schools.
Two characteristics of these early land grants were of great significance. First, the grants were for general public school -purposes. Second, the federal government exercised no control whatsoever over education as a condition for receiving the grants. Authorities on school finance almost unanimously rec­ommended general federal aid for the public schools in preference to aid for specific educational purposes. Despite this fact, practically all federal grants-in-aid to the public schools after 1862 have been special-purpose grants.
The early federal grants demonstrated the fact that the federal government can given federal aid without imposing federal control. But the history of the management of those grants is not proof that absolutely no federal control is a wise policy Perhaps the states would have benefited from some federal re­quirements concerning sound fiscal management of the grants. Such controls would not have interfered with the prerogative of the states to determine educational policy.


The Morrill Act
The first Morrill Act was passed by Congress in 1862. This act provided for a grant of 30,000 acres to each state for each representative and senator then in Congress. This same grant of land was made available to states thereafter admitted to the Union. The act provided for the giving of scrip to the states in which the public lands were insufficient to make up the allotment. It was provided that the land be sold and the proceeds used for the "endowment, maintenance and support of at least one college where the leading object shall be, without excluding other scientific and classical studies and including military tactics, to teach such branches of learning as are related to agriculture and the mechanic arts in such manner as the legislatures of the states may respectively prescribe." Another stated purpose of the act was "to promote the liberal and practical education of the industrial classes in the several pursuits and profes­sions of life."
This original Morrill Act is the first instance of the federal government's providing a grant for specific educational purposes. It will be noted that federal control was limited to specifying that agriculture, mechanic arts, and military tactics must be taught in those institutions. No limitation was placed on the other types of subjects that might be taught. Also, the act specifically placed the determination of the educational policies of the land-grant institutions in, the hands of the respective legislatures.
This act is of great significance because it again demonstrated the national interest in education. It also showed that, when existing educational institutions did not provide adequately for the "general welfare," the federal government could and would take action. At the time the Morrill Act was passed, the institutions of higher learning were largely classical and academic in character. They catered primarily to the select few. The land-grant colleges have been called people's colleges. Their curricula included subjects that were not 'aca­demically respectable" in 1862, but their educational programs grew in pop­ularity. The influence of these land-grant colleges has been so great that they have contributed substantially to liberalizing the educational programs of many non-land-grant colleges. In thirty-two states, a land-grant college is also the principal state university.
The Smith-Lever Act
The Smith-Lever Act was approved by Congress in 1914. It provided for extension services by county agricultural and home demonstration agents, 4-H leaders, and specialists in agriculture and homemaking, and for professional training of teachers in those subjects. This act was far more specific in detailing the purposes for which the grant funds could be spent than was the Morrill Act. Actually, the services provided under the Smith-Lever Act were practically nonexistent prior to its passage. This act is additional evidence that Congress, when it deems it desirable to do so, will provide for, or stimulate provision for, educational services that are not being furnished by the educational organization.
The extension services provided under the Smith-Lever Act are not an integral part of the system of public education. The service at the local level is usually allocated to the control of the county governing body. Boards of education, especially count), boards, have sometimes subsidized the extension service, but they have no authority over it. The state director of the extension service is usually associated with a land-grant college, but this is about the only direct relationship with the system of public education.
The extension services have made a major contribution to the dissemi­nation of the results of the research conducted on agricultural experiment farms. The home demonstrators have also made major contributions to home and family living. The extension services have brought the "people's colleges" to the people. It should be remembered that the extension services were inau­gurated before the days of radio and television. Thus, these workers were the major communicators of new and improved practices in agriculture and homemaking.
The success of the federally subsidized extension services undoubtedly influenced the state and institutions of higher learning to establish additional extension services and adult education programs.
The Smith-Hughes Act
Between 1862 and 1917 the federal government seemed to be concerned primarily with inadequacies in the programs of institutions of higher learning. No new federal act of any major significance to the public schools was passed by Congress during this period. In 1917, Congress passed the Smith-Hughes Act, which provided- funds for vocational education below college level. A continuing appropriation was provided for vocational education in agriculture, trades and industry, and homemaking. Provision was also made for teacher training in 'these fields. The original Smith-Hughes Act required dollar for­ dollar matching by the states and local units. Some states provided all the matching funds required from state revenues. Other states required local units to match the state funds dollar for dollar and thereby 'provide half the matching funds required by the federal government. This retarded the -development of vocational education in some of the least wealthy districts because of their inability to provide the required matching funds. Some other acts that supple­mented and broadened the Smith-Hughes Act were the George-Reed Act of 1929, the George-Ellzey Act of 1935, the George-Deep Act of 1937, the George-Barden Act of 1946, the Vocational Education Act of 1963 as amended in 1968, and subsequent amendments.
The Smith-Hughes Act provided the first special-purpose grants made available to the public schools by Congress. Vocational education was not a new educational idea. A number of school systems had established some type of vocational education programs prior to 1917. For example, some 500 agricultural high schools had been established by 1909. Some schools in forty-four of the forty-seven states in 1911 offered training in homemaking. A number of city systems had developed trade schools or trade courses in regular high schools. However, most high school students did not have access to suitable kinds of vocational programs.
At the beginning of the twentieth century, most lay people and also most educators believed that the high-school program should be largely aca­demic in character. The prevailing belief was that if a high-school student was not interested in college preparatory work, he or she should not go to high school. High schools did not become mass education institutions until after World War I. Following that war, however, there was a remarkable increase in the demand for secondary education. The development of vocational education, which was stimulated by the Smith-Hughes Act, contributed to providing for large numbers of pupils whose needs could not have been served by the high-school programs generally available prior to 1917.
Grants-in-aid for vocational education have been criticized on the grounds that such grants tend to turn the educational programs in the direction of the subsidized purpose. This was no doubt true in the years immediately following 1917. But that was probably one of the purposes of the Smith-Hughes Act. Any special-purpose grant influences the direction of the educational program. Therefore, a special-purpose grant of any kind, state or federal, contains an element of control.





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