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"There is a potential for the arrangement to grow, possibly to include Title VI [of the Civil Rights Act of 1964] and Title IX [of the Education Amendments of 1972]," he said. These laws prohibit racial discrimination and sex discrimination, respectively.

Mr. Randolph also cautioned that if the program were expanded to include states in other areas of the country, he would "have several questions: Are the states interested in taking on the added responsibility? Do they have the resources [to investigate the complaints]? What kind of commitment do they have to civil-rights enforcement?"

"We may find," he added, "that it's a very viable program in the Northeast, but maybe not in the Southeast or in the West." He acknowledged that the program may be greatly expanded if the Education Department is replaced by a foundation as the Reagan Administration has recommended. "The foundation would put ocr back into a technical-assistance posture," he said.

Reservations also were voiced by Jane A. Razeghi, education coordinator for the American Coalition of Citizens with Disabilities. "If left to the states, there's a possibility that compliance will not happen. States' track records in enforcing Section 504 are not good," she said.

Ms. Razeghi said, however, that the ocr plan to oversee state activity in New England "is not as bad as completely turning enforcement over to the states. It could work, depending on how it's set up," she said.

Lorraine M. Aronson, chief of the office of legal affairs for the State of Connecticut Department of Education, said she expects the deferral agreement to be carried out "to the advantage of [school systems]."

In Connecticut, she said, "we are required to meet the requirements of Section 504 and [the Education for All Handicapped Children Act] and our own state special-education statute, which looks very much like the federal law. In the past several years, we have noticed a proliferation of [three separate] complaint systems at the state level, with the additional overlay of federal complaint systems."

It takes "a lot of paperwork for districts to comply with requests [from both state and federal officials] for information, to make files available for investigations," Ms. Aronson added. "There's a lot of energy and duplication that we can save with this step in the right direction. It only makes sense for our agencies to cooperate because we are engaged in the same mission."

Vol. 01, Issue 22

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