The Restricted Access of Minorities and Females to Georgia's Postsecondary Vocational Education Programs

    NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC 
10 Columbus Circle, New York, N.Y. 10019 • (212) 586-839 

806 Fifteenth Street, N.W., Suite 940 
Washington, D.C. 20005 (202) 638-3278 

THE RESTRICTED ACCESS OF MINORITIES 

AND FEMALES TO GEORGIA'S POSTSECONDARY 

VOCATIONAL EDUCATION PROGRAMS 

By: Nancy E. Hart 
Division of Legal Information 

and Community Service 

August 1981 

Contributions are deductible for U.S. incorne tq:c purposes 

The· NAAC? LEGAL DEFENSE & EDUCATIONAL FUND is not part of the National Association for the Advancement of Colored People although it 
was founde~ by it and shares .its commibnent to_ equal rights. LDF has had for over~20 years a separate Board, program, staff, office and budget 



I. Purpose 

From April 1980 through July 1981, the NAACP Legal Defense 

and Educational Fund and the American Civil Liberties Union of 
1/ 

Georgia- ]ointly investigated the admissions policies and prac-

tices of postsecondary vocational technical schools in the state 

of Georgia. The purpose of our investigation was to determine 

if the admissions procedures used by Georgia's postsecondary 

vocational schools operated to exclude black applicants and female 

applicants from full participation in the schools' programs. 

In particular, our investigation focused on the State's 

use of tests as a criterion for admission to programs. We have 

concluded that the tests have serious discriminatory effects. 

Their usage has resulted in the disproportionately high referral 

rate of black students and female students to remedial programs 

and in the tracking of these students into lower-skill programs 

which lead to.lower-paying jobs. 

The reliance on tests is based on administrative con-

venience. The tests allow for the expeditious processing 

of applicants. Yet test scores cannot be justified as 

reliable predictors of a student's ability to participate 

1/ Ginny Looney was the representative from the ACLU of 
Georgia who was involved in this investigation. In addition, 
Ms. Looney has prepared an excellent report on Georgia's post­
secondary vocational schools: The Unfulfilled Promise of 
Vocational Education, a Look at Sex and Race Equity in Georgia. 



in a vocational program. For example, at most schools one test 

is used to determine admission to all programs despite the dif-

ference in skills required for participation in the different 

programs. The misapplication of these tests is also demon-

strated by the fact that the qualifying scores for the same 
2/ 

programs vary from school to school.-

The State's efforts to revise its admissions procedures 

include the selection of a new test and validation studies of 

that test as well as of other tests currently used by the 

schools. These efforts reflect more the commitment to testing 

for its administrative utility as a "quick" screening instru-

ment than a commi.tment to helping students recognize their 

educational needs and pursue their occupational goals. The 

current use of tests does not serve students -- black or white, 

male or female. 

Al though the Georgia Department of E.ducation plans to 

recommend tha.t tests be used as counseling tools and not as 

admissions instruments, the Department is fully aware that the 

admissions personnel at many of the schools are resistant to 

using the tests for that purpose. It is not enough to make 

recommendations; recommendations achieve meaning only if they 

are implemented •. If tests are to be used in the admissions 

~/ For example, Albany Tech established 7 in reading and 7 in 
math as the minimum qualifying scores for admission to its Body 
and Fender Repair program. Athens Tech established qualifying 
scores of 9 in reading and 9 .in math for its Body and Fender 
Repair program. The rationale for the different qualifying 
scores is not explained nor is it self-evident. 

- 2 -



process, then the Department has an obligation to insure that 

the tests are used to help students identify deficiencies and 

acquire skills which are essential to pursuing their career 

objectives. Past experience demonstrates the potential for 

tests to be used to build barriers rather than to create 

opportunities. The adverse consequences to minorities and 

females are too great for the Department to ignore. In 

addition, if the State is concerned about the high unemploy­

ment rate of minorities, then the provision of training to 

acquire marketable skills is a compelling state goal. 

As our national economy becomes increasingly specialized 

and technical, a.concurrent demand of that economy will be the 

need for more specialized and higher-skilled emplo_yees. Greater 

job security and economic reward will predictably accrue to in­

dividuals who have those skills. Such skills may be acquired 

through various means such as vocational.education, on-the-job 

training, and apprenticeship training. The quality and 

availability of each of these options will obviously vary from 

community to community; accordingly the selection of the best 

preparatory route is not one of the subjects of this report. 

The concern of our investigation was to determine if Georgia's 

postsecondary vocational schools fairly offered educational 

opportunity to all students regardless of race or sex. The 

racial and sexual composition of Georgia's postsecondary 

- 3 -



3/ 
vocational programs- suggests that. the educational oppor-

tunities, and concomitantly the job opportunities, of minorities 

and females are restricted. 

It is our hope that the information we have acquired 

during our investigation will be useful to the effort to revise 

the admissions procedures so that minorities and females will 

have full access to the programs offered by Georgia's post-

secondary vocational schools. 

3/ Our analysis of the enrollment statistics for Georgia's 
postsecondary vocational schools revealed a racial and sexual 
pattern in student assignment to programs. The enrollment data 
were obtained from the ~anagement Information System for the 
Division of State Planning and Operations, Office of Vocational 
Education, Georgia Department of Education. The data cover 
minor taxonomies by program type and represent an accumulative 
report as of April 26, 1979 for each postsecondary area voca­
tional school. 

- 4 -



II. Scope of the Investigation 

Our examination included interviewing admissions personnel 
4/ . 

at nine schools,- meeting with students from several schools 

as well as with interested persons in the community, interview-

ing officials from the Georgia Department of Education, and 

analyzing state and local documents and statistics relating 

to Georgia's postsecondary vocational education programs. We 

also went on tours of Macon Tech, Valdosta Tech and Ben Hill-

Irwin Tech in order to observe classes and to see first-hand 

the facilities and equipment. In addition, we reviewed 

the reports, correspondence, and findings of the Office for 

Civil Rights (OCR) with respect to its investigation of three 

schools: Griffin Spalding Vocational Technical School, Augusta 

Area Technical School, and South Georgia Technical and Voca-

tional School. We have also met with OCR officials in the 

Regional Office in Atlanta to learn of their efforts to bring 

these three schools into compliance with Title VI of the Civil 

Rights Act of 1964, Title IX of the Education Amendments of 

1972, and Section 504 of the Rehabilitation Act of 1973. 

4/ we interviewed admissions personnel at Albany Tech, Athens 
Area Tech, Atlanta Area Tech, DeKalb Tech, Ben Hill-Irwin 
Tech, Griffin Spalding Tech, Macon Tech, Savannah Tech, and 
Swainsboro Tech. 

- 5 -



III. Overview 

A. Governance 

Postsecondary vocational programs in Georgia are offered 

by 24 area vocational technical schools, three junior colleges, 
5/ 

and approximately five adult centers.- Two schools, North 

Georgia Technical and Vocational School and South Georgia 

Technical and Vocational School, have residential campuses and 

are directly administered by the State Department of Education. 

There are seven area schools which are administered by area 

boards. Under this arrangement, two or more political sub-

divisions have agreed to form a consortium to enable them to 

pool their resources to provide vocational programs. The seven 

schools which have this form of administration are Ben Hill-

Irwin. Tech, Coosa Valley Tech, Griffin Spalding Tech, Lanier 
6/ 

Tech, Pickens Tech, Upson Tech, and Waycross-Ware Tech.-

The fifteen remaining area schools are administered by county 

or city boards of education. 

11 Be Better Than You Are Through Georgia's Vocational­
Technical Programs, p. 3, also see editor's note. Published 
by Georgia's Post Secondary Vocational-Technical Schools 
and Public Information and Publications Services, Office of 
Administrative Services, Georgia Department of Education, 
January 1979. 

6/ Information provided by Program Development Division, 
Office of Vocational Education, Georgia Department of Educa­
tion. 

- 6 -



The Board of Regents of the University System of Georgia oversees 
7/ 

the vocational programs offered at the three juniqr colleges.-

Although the Georgia Department of Education is directly 

responsible for the administration of only two area schools, 

it nevertheless provides guidance and sets standards for all 

postsecondary vocational schools. Robert Mabry from the State 

Department of Education indicated that the Department estab-

lishes standards in twelve major areas with numerous criteria 

provided under each area. The twelve areas are Philosophy 

_and Purpose; Organization and Administration; Long-Range 

Planning; Education Programs; Staff; Learning Resources Centers; 

Financial Resources; Physical Facilities; Equipment, Supplie·s 

and Instructional Materials; Student Personnel Services; Place-

ment and Follow-up; and Community Relations. Although the 

State Department of Education requires that the schools meet 

these standards, the determination of how that will be accom-

plished is made by each individual school. In other words, 

the schools determine the means for satisfying the Department's 

standards. For example, the following criterion is listed 

under one of the Department's standards: 

7/ There is a cooperative agreement between the Board of 
Regents and the State Department of Education to provide the 
vocational education division within each junior college with 
the funds to operate vocational programs. 

- 7 -



"Are job-related tests or test batteries avail­
able to assist with the selection and placement 
of students in programs for which there is a 
reasonable chance for success?" 

Now in this example, the Department may even choose to recom-

mend a particular test which it believes will serve the purpose 

of selecting students who have "a reasonable chance for success" 

in a vocational program. However, the schools are not bound 

by that recommendation. They can elect to use other tests 

which they believe will accomplish the same result. Mabry 

described the Department's role as providing leadership, 

policy, and guidelines; and accordingly, leaving the actual 

operation of vocational programs and the implementation of 

policies and standards to the schools themselves. 

The Georgia Department of Education evaluates approxi-

mately twelve postsecondary vocational schools annually and 

the schools are measured against the Department's standards. 

The Department informs schools of their deficiencies and re-

quires the schools to take corrective action. The ultimate 

sanction for a school's failure to correct its deficiencies 

would be the loss of federal and state funds. The Depart-

ment has never imposed this sanction. 

- 8 -



B. Profile of Georgia's Postsecondary Vocational 
Enrollment 8/ • 

Substantial numbers of minorities and females attend 

Georgia's postsecondary vocational-technical schools.- During 

the period from September 1980 through March 1981, there were 

31,317 postsecondary students enrolled in full-time, day 

programs in vocational education. Of that total, 16,319 or 52% 

of t"he enrollees were female; and 14, 998 or 48% of the enrollees 

were male. The racial and ethnic composition of the enrollment 

was as follows: 20,835 students or 66.5% were white, 9,773 

students or 31.2% were black, 371 students or 1.2% were Asian, 

224 students or less than 1% were Hispanic, and 114 students or 

less than 1% were American Indian. 

In the evening or part-time programs, there were 60,590 

students. Females represented 54% ( 3.2, 872) of those par­

ticipating in evening programs; males constituted 46% (27,718) 

of the evening enrollment. The racial and ethnic representa-

tion of students enrolled in the evening or part-time programs 

was as follows: 45,568 white enrollees (75.2%), 13,919 black 

enrollees (23%), 511 Asian enrollees (less than 1%), 332 

Hispanic. enrollees (less than 1 % ) , and 260 American Indian 

enrollees (less than 1%). 

8/ Enrollment data provided by the Division of State Planning 
and Operations, Office of Vocational Education, Georgia 
Department of Education. The data represent a cumulative 
count of postsecondary enrollees from September 1980 through 
March 1981. 

- 9 -



9/ 
IV. The Admissions Process-

A. Admissions Criteria 

The admissions criteria used by Georgia's postsecondary 

vocational schools are relatively uniform. This may be indica-

tive of the weight given by the schools to the recommendations 

made by the State Department of Education. 

All applicants must be at least 16 years old. Since 

nurses must be 18 years old to be licensed by the State Board, 

the schools require applicants to the nursing program to 

be 17 when they start the one-year program. The threshold 

requirements are the payment of a five-dollar application fee 

and the submission of an application and high school tran-

scripts or GED scores. Many of the schools actually require a 

high school diploma or its equivalent; some schools adjust the 

requirement depending on the program choice of the applicant. 

For example, Atlanta Area Vocational-Technical School requires 

a high school diploma or its equivalent for admission to 

the following programs: Medical Laboratory Assistant, Account-

ing, Clerical, Secretarial, and Air Conditioning. It recommends 

that students complete high school if they are seeking admission 

9/ The information for section IV, The Admissions Process, 
was obtained from our interviews with admissions personnel at 
the nine schools listed in footnote 3 and from the catalogs and 
admissions materials the schools provided. We also consulted 
with officials from the Office of Vocational Education, Georgia 
Department of Education. In addition, we relied upon the 
Statements of Findings and Investigative Reports issued by OCR 
after its review of Augusta Tech, South Georgia Tech and 
Griffin Spalding Tech. 

- 10 -



to Architectural Drafting, Industrial Drafting, and Carpentry. 

It does not require a high school diploma for admission to 

Civil Technology, Machine Shop, Major Appliance Servicing, 

Bricklaying, Marketing, Commercial Baking, Food Services, and 

Keypunch. 

Applicants also take an admissions test. The test most 

widely used is the Test of Adult Basic Education (TABE). Each 

of the schools has independently established miminum qualifying 

scores on whichever test it uses for each of the vocational 

programs it offers. For example, applicants to the following 

programs at Grif.fin Tech would have to obtain these cutoff · 

scores on the TABE in order to gain admission to the particular 

program: 

Program 

Accounting 
Auto.Mechanics 
Data Processing 
Electronics 
Secretarial 

Reading Score 

10.0 
a.5 
9.0 

10.0 
9.0 

Math Score 

9.0 
8.5 
9.5 

10.0 
9.0 

Applicants to full-time day programs at all of Georgia's 

postsecondary vocational schools must take some type of admis-

sions test. However, several admissions officers indicated 

that their schools did not require applicants to the evening 

programs to take an admissions test. Charles Horton from the 

Division of Program Management of the State Department of 

Education confirmed that many of the schools did not test 

applicants for evening programs. He explained that ·the evening 

programs were largely directed at employed persons to help 

- 11 -



them upgrade their skills or acquire new ones for the 

purpose of advancement. However, he indicated that this was 

changing and that the evening programs were becoming more 

career-oriented. 

Most schools interview prospective students as a part of 

their admissions procedure for day programs. Typically the 

interview occurs after the student's test scores are reported 

so that the admissions officer or counselor can advise the 

applicant as to which programs he has qualified for. ·Several 

of the schools we visited -- Griffin Spalding Tech, Atlanta 

Tech, Ben Hill-Irwin Tech, and Swainsboro Tech -- indicated· 

that they did not interview applicants to their evening 

programs. 

B. The Use of Tests 
10/ 

1. Description and History of Test Usage~ 

When Georgia's vocational technical schools first opened 

in the 1960's, most of the schools used the General Aptitude 

Test Battery (GATB). The GATB had been developed by the U.S. 
-

Department of Labor (DOL) for use by counselors in Employment 

Security Offices throughout the nation. It had been normed 

10/ The information concerning the historical use of tests by 
Georgia's postsecondary vocational schools was obtained through 
interviews with three Georgia Department of Education officials: 
Dr. John Lloyd, Director of Program Development; Ann Lary, 
Student Services Coordinator; and Griffin Brooks, former Student 
Services Coordinator. 

- 12 -



on incumbent workers in various jobs. It purportedly reflected 

the profiles of the persons who successfully performed those 

jobs and therefore was used as a job placement device. The 

GATB was not designed to predict a student's· success in a 

vocational education program. 

The GATB tests for aptitude, general intelligence and 

dexterity. The D.OL made.the GATB available to the Georgia 

Department of Education. The Department of Education served 

as a liaison between the schools and DOL, with the schools 

contracting directly with DOL and also independently deciding 

if the GATB would be included in their admissions procedures. 

Some schools used the GATB as a criterion for entrance into 

certain programs, others used it as a counseling tool. 

Although the GATB was widely used in the 1960's, a Georgia 

Department of Education official informed us that very few 

schools currently use the GATB in their admissions process. 

Of the nine schools which we surveyed, Macon Tech was the 
11/ 

only school which still used the GATB.~ 

The passage of the Vocational Education Amendments of 1968 

precipitated changes in Georgia's admissions procedures. The 

provisions requiring the states to set aside part of their 

federal dollars to be used exclusively to serve handicapped 

l1J Macon Tech also uses the TABE1 however Macon only ad­
ministers the TABE to applicants who have scored low on the 
GATB. The GATB is the primary test used to determine admission 
to programs. 

- 13 -



and disadvantaged students were the underlying reasons for 

these changes. The states needed to show that these funds were 

actually being spent on these special needs students and to 

document the higher costs of providing educational services 

for these students as compared with regular students. 

With the objective of including more handicapped and 

disadvantaged persons in the postsecondary vocational school 

system, Georgia's schools shifted to an open-door admissions 

policy in about 1969. This policy was continued by some of the 

schools until as late as 1975. During this same period, the 

TABE was introduced and the purposes for which it was used by 

the schools gradually changed. It is therefore difficult to 

determine the duration of the open-door admissions policy since 

each of the schools could independently determine how they 

would use the TABE, and their usage changed throughout this 

period. By about 1975, almost all of the schools had abandoned 

the open-door policy. The primary reason given for the discon­

tinuation of the policy was that the curricula and teaching 

techniques had been designed for "group pace" instruction so 

that teachers found it difficult to accommodate persons with 

varying abilities and competencies. 

In response to the Vocational Education Amendments of. 1968, 

Georgia recognized that it needed to develop special materials 

for handicapped and disadvantaged students and that it also 

needed a procedure for identifying these students. Of course, 

- 14 -



these needs were tied to the state's desire to receive federal 

vocational education funds. To accommodate handicapped and 

disadvantaged students, the Georgia Department of Education 

played a-major role in the implementation of the Individual. 

Prescribed Instruction program (IPI) throughout the postsecon­

dary vocational system. The IPI program provides remedial 

instruction in math, English, and vocabulary. Some schools 

started IPI programs in 1968: by 1974 all of Georgia's post­

secondary vocational schools had some type of remedial program. 

The Department recommended that the schools use the TABE 

test to identify persons who should be referred to the IPI and 

also to determine the type and level of instruction they would 

require in the. IPI.. As John Lloyd from the Department of 

Education described it, "the IPI program was built around the 

TABE." 

After the TABE had been introduced by the Georgia Department 

of Education, the schools gradually extended its use to the 

program admissions process. The schools independently be~an to 

establish minimum cutoff scores for their various vocational 

programs which students would need to obtain in order to gain 

admission to the programs. According to John Lloyd, the 

Department never supported this use of the TABE -- it was to be 

used only as a placement tool for the !PI program. However, the 

role of the Department in the expanded application of the TABE 

can hardly be viewed as neutral. In 1971, the Department brought 

in experts from.the University of Georgia to establish minimum 

- 15 -



reading levels for the tex.tbooks used in the different voca­

tional programs and also to advise the schools on how to 

predict which students would successfully complete the various 

programs. As discussed earlier, the TABE purportedly shows 

the math level and reading level at which the person is func­

tioning. John Lloyd explained that t,he Georgia Department of 

Education did not establish the minimum reading and math levels 

because the curricula of the different schools varied so much; 

the schools would have to determine for themselves what levels 

were required for their programs. In· 1976, the Department 

conducted workshops for the school directors and counselors 

or Student Personnel Services (SPS) to advise them on how 

to determine which cutoff scores on the TABE would be appro­

priate for their programs. Although the Department did not 

initially select the TABE as a program admissions instrument, 

it clearly contributed to the evolutionary use of the TABE 

for that purpose. 

The TABE consists of achievement tests in reading, mathe­

matics, and language. It is basically a repackaging of the 

California Achievement Tests (CAT) which were designed for 

elementary school children "to measure many of the most uni­

versal subject-matter objectives of the curriculum." The 

TABE was derived directly from the CAT with minor language 

changes made to adopt it to adult usage. It still contains 

entire subtests of the CAT. It uses the same content, for-

- 16 -



mat, and organization as the CAT. The interpretation of test 

scores on the TABE is based on the norms established on elemen-

tary school children who took the CAT. Concerning the TABE, 

The Eighth Mental Measurements Yearbook warned that this 

"direct adaptation of a.test which was originally designed for 

children raises questions concerning its content validity, its 

reliability, and the appropriateness of norms when used with 

adults." The Yearbook also found the TABE's practice of 

using grade equivalents to interpret the scores of adults as 

"extremely undesirable." To· elaborate, the Yearbook reported 

that "[g]rade equivalents have such serious limitations when 

used with children that.concerted efforts have been made to 

abolish them. When used with adults, the limitations are com-

pounded to a point where misinterpretation is almost un-
12/ 

avoidable ... -

As previously discussed, the GATB test was widely used 

from the 1960s until about the mid-1970s when the TABE re-

placed it as the major testing instrument. In addition to 

these two tests, there are several other tes.ts which ·are ' 

used by some of Georgia's postsecondary vocational schools. 

These other tests include the TASK (Test of Adult Skills) which 

is the upper end of the Stanford Achievement Test series; the 

12/ Buros, The Eighth Mental Measurements Yearbook, Volume 
I, (1978), pp. 108-111~ Buros, The Seventh Mental Measurements 
Yearbook, Volume I, (1972), pp. 60-62. 

- 17 -



Armed Services Vocational Aptitude Battery (ASVAB); the Wide 

Range Achievement Test (WRAT); the Comparative Guidance and 

Placement Test (CGP); and·the Scholastic Aptitude Test (SAT). 

Some schools also use auxiliary tests for a limited number of 

their programs. For example, Atlanta Tech requires all appli­

cants to daytime programs to take the TABE and then depen~ing 

on their program choice, applicants may also be required to 

take the CGP or the SAT. In addition to these tests, appli­

cants to the Electronics program and the Computer program are 

given a test on their knowledge of algebra. Applicants for the 

Keypunch program are given a typing test. 

The TASK was designed for students in grades 8 through 13. 

Its purpose is to determine the student's grade-level competency 

in reading, English, and math. A State Department of Education 

official reported that the TASK was never used extensively 

and that only a few schools currently use it. Of the nine 

schools which we visited, Albany Tech and Athens Tech were the 

only schools which administered the TASK. 

The Armed Services Vocational Aptitude Battery (ASVAB) 

consists of twelve tests which claim to measure academic 

ability, and aptitude in five career areas. The twelve tests 

are General Information, Numerical Operations, Attention to 

Detail, Word Knowledge, Arithmetic Reasoning, Space Perception, 

Mathematic Knowledge, Electronics Information, Mechanical Compre­

hension, General Science, Shop Information and Automative Infor­

mation. The scores from these twelve tests are summarized as six 

- 18 -



composite scores: Academic Ability; Verbal; Analytic/Quantita­

tive; Clerical; Mechanical; and Trade Technical. The ASVAB was 

normed on miJ.itary personnel who occupied jobs in different 

vocational areas while serving in one of the branches of the 

Armed Services. With the underlying interest of recruiting 

students, the Armed Services made the ASVAB available to the 

schools at no charge beginning in about 1971. From 1971 

through 1975, the ASVAB was used fairly extensively by Georgia's 

postsecondary vocational schools. The Georgia Department of 

Education reported that the ASVAB is rarely used today. 

DeKalb Area Tech was the only school which used the ASVAB of 

the ·nine schools we visited. If SAT or ACT scores are not 

.available, then DeKalb Tech accepts ASVAB scores. 

Th~Wide Range Achievement Test (WRAT) provides scores for 

reading, math, and spelling. It only takes a few minutes to 

administer and grade. The Georgia Department of Education 

indicated that very few schools use the WRAT and that Lanier 

Area Tech was the only school known to be using the WRAT as 

an admissions test. 

Atlanta Tech stopped administering the Comparative Guidance 

and Placement Test (CGP) in about 1976; however it still accepts 

CGP scores. The CGP provides achievement scores in math and 

reading and also includes a vocational interest component. 

- 19 -



The Scholastic Aptitude Test (SAT) is the admissions 

test most commonly used by universi.ties and colleges. The 

SAT's usage in Georgia's postsecondary vocational schools 

appears to be limited. Of the nine schools we surveyed, 

SAT. scores were considered only at Macon Tech and DeKalb 

Tech. Macon Tech required SAT scores for only one of its 

programs -- the Certified Lab Assistant program. DeKalb 

Tech gave students the option of providing scores from one 

of three tests: the SAT, the ACT, or the ASVAB. 

2. Is There a Relationship Between Georgia's 
Use of Tests and the Racial and Sexual 
Composition of its Vocational Programs? 

a. The Disproportionate Representation 
of Blacks and Females in Remedial 
Programs 

In its investigation of three of Georgia's postsecondary 

vocational schools, OCR determined that there was a relation-

ship between the use of tests, specifically the TABE, and the 

racial and sexual composition of the schools' vocational 

programs. OCR found that the TABE had operated adversely to 

affect the educational opportunities of black ·students at all 

three schools, and of female students at two of the three 

schools. Griffin Spalding Vocational Technical School, Augusta 

Area Technical School, and South Georgia Technical School. were 

- 20 -



13/ 
the three schools investigated by OCR.~ 

Since one purpose of the TABE was to determine which 

students would be referred for remediation, OCR inferred from 

the racial composition of the remedial programs at all three 

schools, that the TABE had a discriminatory effect on black 

students. 

From July 1979 through July 1980, Griffin Spalding's 

remedial program was 67% black although the black represen­

tation in the school was only 26%. Furthermore, 142 or 71% 

13/ In November 1979, OCR issued Statements of Findings 
determining that Augusta and South Georgia were in violation of 
Title VI of the Civil Rights Act of 1964, Title IX of the 
Education Amendments of 1972 and Section 504 of the Rehabilita­
tion Act of 1973. Both Augusta and South Georgia had been 
selected for pilot reviews by OCR; the reviews were conducted 
irt 1973. OCR's investigation of Griffin Spalding had been 
prompted by a complaint alleging Title VI violations which had 
been filed by the.NAACP, Griffin Branch, on January 31, 1979. 
In February 1980, the NAACP Legal Defense Fund joined with the 
NAACP to request OCR to reinstate the complaint against Griffin 
Spalding and to compel OCR to issue a Statement of Findings. 
In·addition to the allegations of Title.VI violations, the 
complaint was amended at that time to include allegations of 
Title IX violations. In October of 1980, OCR informed Griffin 
Spalding that it was in violation of Title VI of the Civil 
Rights Act of ·1964 and Title IX of the Education Amendments of 
1972. For purposes of this report, we have focused on those 
violations which relate to the admissions criteria used by the 
three schools, in particular their use of tests. However, OCR 
also found numerous violations relating to other aspects of 
administration at the three schools, e.g., faculty assignment, 
apprenticeship training, student housing, etc. For persons 
interested in the full scope of OCR's findings, copies of the 
Statements of Findings and the Investigative Reports may be 
obtained via a Freedom of Information Act request to the Office 
for Civil Rights, Region IV, 101 Marietta Tower, Atlanta, 
Georgia 30323. 

- 21 -



of the 200 black students at Griff in Spalding during that 

period had been referred for remediation, whereas only 194 or 

35% of the 556 white students had been referred for remediation. 

At South Georgia Tech, OCR examined the results of the 

admissions process for the period of January through May 1978 

and found that the TABE had a similar impact on black students 

there. Of the 198 black applicant.s who were tested, only 51 

or 26% were approved for admission to regular programs. The 

remaining 147 or 74% of the black applicants were referred for 

r.emedial work or for further evaluation. Of the 117 white 

appl.icants who were tested, 69 or 59% were approved for ad­

mission to regular programs. 

At. Augusta Tech 390 students were referred to the Evalua­

tion Learning Center for remediation during 1977-78. Of that 

.total; 248 or 64% were black. The overrepresentation of black 

students in Augusta·Tech's remedial program was significant 

given the fact that black students comprised only 30% of the 

school's enrollment. 

OCR concluded that at two of the three schools, females 

were adversely affected by the schools' reliance on the 

TABE. At South Georgia Tech, OCR referred to the program 

choices of females rather than to female representation 

in remedial programs although the referral of females to 

remedial programs is implicit in that finding. Of the 

172 females who were given the TABE during the period from 

January to May 1978, only 40 or 23% were permitted to enter 

- 22 -



their chosen programs. Of the 143 males who were tested 

at South Georgia Tech, 65 or 45% were admitted to their 

chosen programs of study. At Augusta Tech, 302 or 77% of the 

students enrolled in the remedial program during the 1977-78 

school year were female. 

The dropout rate of students in the remedial programs 

at all three schools was so significant that the TABE in effect 

was operating to deny blacks and females access to regular 

vocational programs at these schools. The proportion of 

students who did not complete the remedial programs was 

54% at Augusta Tech, 50% at South Georgia Tech, and 43% at 

Griffin Spalding Tech. 

Augusta Tech and South Georgia Tech both admitted that 

for those students who had been referred for remediation 

because of their TABE scores, completion of the remedial 

program was a prerequisite for admission to a regular voca­

tional program. Griffin Spalding Tech stated that its policy 

was that students who scored three or more grade levels below 

the established cutoff scores for their program choice were 

required to participate in the remedial program before entering 

a regular program. However, the school maintained that those 

students who scored two grade levels below the required scores 

could elect to take the remedial program simultaneously with a 

regular program or to by-pass the remedial program entirely. 

After interviewing students at Griffin Tech, OCR concluded that 

students were not aware of these options. Students reported to 

- 23 -



OCR that it was their understanding that they would not be 

admitted to regular programs until they completed the remedial 

program and/or achieved the required test scores. 

At all nine schools which the LDF /ACL.U investigated, 

including Griffin Spalding, students with low test scores were 

required to complete the remedial program and/or be retested 

and achieve the minimum scores before those students would be 
1.il 

permitted to enroll in a regular vocational program. A 

counselor at Atlanta Tech pointed out that students who did not 

achieve the qualifying scores for their first program choice, 

could choose. a program with .lower score requirements provided 

that the student had achieved those scores. (This option 

probably exists for applicants at all of these schools). 

However, the counselor at Atlanta Tech also suggested that this 

option had little significance since the qualifying scores for 

the different programs were so close that if a person didn't make 

a high enough score to qualify for one program, the chances were 

high that the person would· not have the minimum scores for any 

of the school's programs. An examination of the qualifying 

scores for Atlanta Tech and other schools confirms this observa-

tion. 

14/· These nine.schools were unable to provide us with informa­
tion concerning the race and sex of students enrolled in their 
remedial p,rograins. Refer back to footnote 3 for a listing of 
the nine schools we visited. 

- 24 -



Most of the schools we visited were not able to give the 

attrition rates of their remedial programs. Athens Tech 

estimated the attrition rate of its remedial program at 25%. 

Ben Hill-Irwin Tech reported that its remedial students are 

retested at the end of the quarter and that about 20% pass the 

test. Only students who pass the test are permitted to enter 

regular programs. If the purpose of Ben Hill-Irwin's remedial 

program is to improve the students' test scores, then the low 

pass rate of the program's participants clearly shows that the 

program is failing to accomplish that objective. 

The information provided by Albany Tech and Swainsboro 

Tech indicates that the impact of tests on access to vocational 

programs may be even greater than the dropout rates of remedial 

programs alone would suggest. ~n addition to acknowledging the 

high dropout rate of the remedial program, the SPS coordinator 

at Swainsboro reported that the majority of students who fail 

the TABE never even make it to the remedial program. When 

applicants to Swainsboro fail to achieve the entry-level 

scores, they are invited by letter to contact the disadvantaged 

specialist. The SPS_ coordinator stated that most applicants 

decline to make that initial contact. At Albany Tech, the SPS 

coordinator estimated that half the students who fail the 

test and who are referred for remediation never show up for the 

remedial program. 

- 25 -



b. Bias in Student Assignment to Regular 
Vocational Programs 

OCR went beyond the initial barrier posed by the TABE 

the referral of minority and female students to remedial 

programs -- to reach the issue of bias in student assignment 

to regular vocational programs. 

OCR's examination of enrollment data for South Georgia 

Tech revealed that the underrepresentation of black students in 

technical and trade programs increased significantly when the 

TABE was introduced as an instrument to determine admission 

to programs. During the 1975-76 school year, there were two 

programs, Electronic Technology and Electrical Construction 

in which black students were underrepresented. In 1976-77, 

there were four programs. By 1977-78, the number of exclu-
15/ 

sionary programs h.ad increased to nine.- OCR concluded that 

"although in use for only one year, the TABE appears to be per­

petuating the underinclusion of black students in non-tradi-

tional programs of study." Using the same analytical approach, 

OCR reached the same conclusion about the TABE's impact on 

the program assignment of black students at Griffin Spalding 

Tech. The TABE was found to contribute to and perpetuate the 

j2/ OCR did not specify the programs which black students 
were underrepresented in for the 1976-77 and the 1977-78 school 
years. 

- 26 -



.· 

underinclusion of blacks in Griffin's technical and trade 

programs. 

OCR observed that the employment of the TABE at South 

Georgia Tech was having a similar effect on the program assign­

ments of females. During the 1976-77 school year there were 

15 students enrolled in programs which were non-traditional for 

their genderi in 1977-78 the number had decreased to ten 

students. In addition, OCR noted that of the 172 female 

students who were given the TABE during the period from January 

through May 1978, only 40 or 23% were approved for admission to 

the programs they had chosen. By comparison, 65 or 45% of the 

143 males who were tested were admitted to their chosen programs. 

OCR did not find that females at the Griffin Spalding Tech 

were being adversely affected by the TABE. 

Although OCR found that the use of the TABE by Augusta 

Tech resulted in the disproportionate referral of blacks and 

females to remedial programs, OCR neglected to extend that 

finding to include assignments to regula7 vocational programs. 

OCR recognized the adverse impact of the test on minorites and 

females. Yet the issue of the TABE's effect on student assign­

ment to regular programs was never discussed in the Statement 

of Findings for Augusta Tech. It seems likely that OCR focused 

on the initial barrier which the TABE created for women and 

blacks at Augusta Tech and simply failed to consider the TABE's 

impact beyond that point. Since low TABE scores resulted in 

- 27 -



the high referral rate of blacks and females to remedial 

programs, it is reasonable to expect the discriminatory effect 

of the TABE to be carried over to regular program admissions 

since qualifying scores are also established for that purpose. 

Indeed, a review of the enrollment data for Augusta Tech 
16/ 

· shows~_, that there are numerous programs in which blacks 

and females are significantly underrepresented. At Augusta 

Tech black students represent 32.6% of the student population. 

The programs with low black participation are Electronic 

Technology (14.9% black); Electrical Technology (9.1% black); 

Instrumentation (7.7% black); Business Data Processing systems 

(8.6% black); Lab Technician (11.5% black); Dental Assisting 

(11.4% black); and Ornamental Horticulture (0% black). Females 

constitute 50% of the students at Augusta Tech. The programs 

with low female participation are: Welding and Cutting (6% 

female); Machine Shop (12.5% female); Masonry (0% female); 

Electricity (0% female); Auto Mechanics (2.3% female) Body 

and Fender Repair (0% female); Air Conditioning (0% female); 

Mechanical Technology (16.7% female); Instrumentation,(4.6% 

female); Electronic Technology (5.9% female); Electrical 

Technology (6% female); General Merchandise (0%) female); 

16/ Refer back to footnote 2 for a description of the enroll­
ment data used for our review of student assignments at Augusta 
Tech. 

- 28-

•. 



Advertising (19.4% female); and Ornamental Horticulture (25% 

female). 

In reviewing the use of tests to determine assignment to 

programs, it is also instructive to compare the qualifying 

scores established by the different schools. The minimum score 

levels for the same programs often vary from school to school. 

This suggests the arbitrariness of the schools' determinations 

of appropriate grade-level scores for programs. To illustrate, 

the following grade-level scores were established for the 

same program, cosmetology, at these different schools: Griffin 

Tech reading 9, math 8; Ben Hill-Irwin Tech -- reading 7.5, 

math 7; Athens Tech -- reading 9, math 9; Valdosta Tech -­

reading 8, math 8; and Albany Tech -- reading 9 and math 8. 

- 29 -



v. The State's Response to OCR's Findings 

The key regulatory provision which OCR applied in its 

determination that the admissions criteria used by Augusta 

Tech, South Georgia Tech, and Griffin Spalding Tech violated 

Title VI, Title IX and Section 504 reads as follows: 

Recipients may not judge candidates for admission 
to vocational education programs on the basis of 
criteria that have the effect of disproportion­
ately excluding persons of a particular race, 
color, national origin, sex, or handicap. How­
ever, if a recipient can demonstrate that such 
criteria have been validated as essential to 
participation in a given program and that 
alternative equally valid criteria that do not 
have such a disproportionate adverse effect 
are unavailable, the criteria will be judged 
nondiscriminatory. Examples of admissions 
criteria that must meet this test are past 
academic performance, record of disciplinary 
infractions, counselors' approval, teac.hers' 
recommendations, interest inventories, high 
school diploma and standardized tests, such 
as the Test of Adult Basic Education (TABE). 111 

To come into compliance with this provision, Section K of 

the Guidelines, OCR directed the schools to develop and to im-

111 Section IV K, Vocational Education Programs Guidelines 
for Eliminating Discrimination and Denial of Services on the 
Basis of Race, Color, National Origin, Sex, and Handicap, 
issued by the Office for Civil Rights, Department of Health 
Education, and Welfare, Federal Register, Vol. 44, No. 56, 
March 21, 1979. Hereinafter, referred to as the Guidelines. 
The Guidelines explain the civil rights responsibilities 
of recipients of federal funds offering or administering 
vocational education programs. They derive from and provide 
guidance supplementary to Title VI of the Civil Rights Act of 
1964 and the implementing departmental regulation (45 CFR Part 
80), Title IX of the Education Amendments of 1972 and the 
implementing departmental regulation (45 CFR Part 86), and 
Section 504 of the Rehabilitation Act of 1973 and the implement­
ing departmental regulation (45 CFR Part 84). The Guidelines 
became effective on March 15, 1979. 

- 30 -



plement admissions criteria and procedures which would not 

discriminate on the basis of race, color, national origin, sex 

or handicap. OCR warned that "such procedures should not use 

testing materials which. are irrelevant to the purpose of the 

school and do not reliably predict a student's potential for 

success in a program of study or class." OCR made clear that 

the TABE had been determined unacceptable as an admissions 

criterion because it had an adverse impact on minorities and 

women, and because it had not been shown to be a valid instru-

ment for predicting "successful participation" in a program. 

By specifically declaring the TABE a discriminatory device 

and conjunctively requiring that admissions tests be validated 

as essential to program participation, OCR' s findings for thes.e 

three schools in fact had implications for all of Georgia's 

postsecondary vocational schools. The majority of the schools 

were using the TABE. Those schools which were using other 

tests surely recognized that they were not immune from scrutiny. 

The standards of racial impact and valid.ation as defined by the 

Guidelines were not the considerations which had guided the 

schools in their original selection of a test. Since the issues 

raised by OCR effectively required every school to reexamine 

its admissions criteria, it was apEropriate and imperative that 

the Georgia Department of Education assist in the effort 
18/ 

to develop new admissions criteria.~ 
' 

18/ The state's response to OCR's findings and the state's 
rationale and objectives in selecting a new admissions system 
were described by John Lloyd and by Ann Lary from the Georgia 
Department of Education during our interview with them on May 
12, 1981, and in subsequent phore conversations. 

- 31 -



An interim Admissions Committee was formed and included 

three officials from. the Georgia Department of Education and 

Student Personnel Services (SPS) coordinators from about six 

schools. The interim Admissions Committee decided that the 
19/ 

selection of a new test and the validation of the TABE~ were 

the initial steps required by OCR's determinations. The Com-

mittee believed OCR's concern was with Georgia's use of "only 

one test, that's the problem; you increase the appropriate-

ness if you have more than one test, a battery of tests if 

appropriately used." 

The Committee arranged for approximately six testing com-

panies to demonstrate their tests. The Career Planning Program 

(CPP) was selected as the test to be presented to the schools 

for approval. American College Testing Services (ACT), the 

publishers of the CPP, demonstrated the test to SPS coordi-

nators from all of Georgia's postsecondary vocational schools 

at. a statewide in-service meeting in August 1980. John Lloyd 

reported,_ "we found a test that was acceptable to every school." 

There were six reasons given by the Committee for choosing the 

CPP: 1) it was nationally-normed and could be state- and 

19/ When the term validation is used with respect to the State's 
examination of the TABE, it refers to one phase of what a state 
official describes as a research project which "will determine 
if correlations exist between the TABE and successful completion; 
the CPP and successful completion and the CPP and the TABE. The 
purpose of this is to develop a more longitudinal data base for 
the CPP for prediction charts information." Letter from John 
Lloyd to Nancy Hart, July 14, 1981. 

- 32 -

·. 



locally-normed; 2) it allowed for group and individual inter-

pretation of scores; 3) it had been validated as nondiscrimi-

natory; 4) it included a battery of tests rather than just 

one test; 5) it covered the occupational areas taught by the 

schools; and 6) it was easy to .administer. As will be ex-

plained later, two of these reasons -- the nondiscriminatory 

validation and the existence of national norms -- were 

incorrect assumptions about the CPP test. 

In August 1980, the Department issued a request for 

proposals to develop a comprehensive admissions system for its 

postsecondary vocational schools. The Department defined the 

objectives of the outcomes as follows: 

1. A nondiscriminatory admissions 
system. 

2. Increased enrollment in non­
traditional programs. 

3. A validated general admissions 
test and admissions criteria. 

4. A unified plan for incorporating 
the CDC [remedial program] in 
the admission testing process. 

5. State norms by instructional 
program for the CPP (Career 
Planning Program) test battery. 

6. Improved completion rates by 
students. · 

7. A methodology to establish~ refine 
and periodically update school 
norms. 

- 33 -



8. Program manuals and materials 
for use by Student Services 
Staff in admissions related 
activities. 20/ 

' 

The contract to develop the comprehensive admissions 

system was awarded to the Associated Educational Consultants, 

Inc. (AEC) of Pittsburgh, Pennsylvania. AEC is the prime 

contractor and is responsible for developing, overseeing, 

and implementing the admissions system. ACT, the developer 

and publisher of the CPP, has also contracted directly with 

the State. Since the CPP test is an integral part of the 

new admissions system, ACT representatives have worked 

closely with the Georgia Department of Education and with the 

schools which are using the CPP. In implementing the new 

procedures, ACT representatives and AEC representatives have 

participated in workshops with SPS coordinators and Depart-

ment officials. 

The Admissions Project Proposal presents the numerous 

objectives which AEC as the prime contractor is ultimately 

responsible for although many of the responsibilities which 

directly involve the CPP test would be either delegated to 

or would involve ACT, the CPP publishers. Some of those 

20/ Request for Proposal (RFP) for a Project to Develop a 
Comprehensive Admissions System for Use by Georgia's Postsecon­
Mary Vocational-Technical Schools, p. 4. Issued by Research 
Coordinating Unit, Division of Program Development, Office of 
Vocational Education, Georgia Department of Education, August 
1980. Hereinafter this document is referred to as the Admis­
sions Project Proposal. 

- 34 -

.• 



objectives include: developing a set of admissions procedures 

and defining the sequence, instruments and materials; pre-

paring an Admissions Handbook for use by admissions personnel; 

preparing a Testing Guidebook for use by SPS and the remedial 

program evaluators; field-testing the CPP and establishing 

cutoff scores by program area; designing a procedure whereby 

the schools can establish and update program norms; develop-

ing recommended test interpretation procedures and a set of 

options available at each decision point; identifying a series 

of supplemental tests for students not meeting the norms of 

the general admissions test; determining the appropriate use of 

the TABE for remedial purposes or recommending an alternative 

test; defining correlations between the CPP test and other 

tests administered such as the TABE, GATB, and ASVAB; and 
w 

developing a student appeals process. 

21/ Admissions Project·Proposal, pp. 8-9. 

- 35 -



VI. The Future of Tests in the Admissions Process 

The objectives of the Admissions Project reflect the 

commitment of the schools to the use of tests in the admis-

sions process. As one ACT representative described it, "many 

SPS people want another TABE ••• a large number of SPS people 

are conditioned to wanting to move people through the admissions 

process quickly instead of helping the student identify his 
22/ 

interests and goals."- The reason for comparing the CPP 

with the TABE is that many SPS personnel i•want to make sure 
23/ 

that the CPP will do for them what the TABE did."- In 

sum, as one Georgia Department of Education official stated, 

"the schools felt -the TABE was working well for them." 

The interest in validating the TABE is largely based on a 

desire to continue using it to identify and refer students to 

remedial programs. Although Georgia is also attempting to 

validate some of the other tests it has used such as the TASK 

and GATB, the interest in validating the TABE is greater since 

it is the most widely used test. 

The validation study of the TABE and other tests will be 
24/ 

conducted at the 13 pilot schools.- AEC will compare the 

22/ Phone Interview with Dr. Anthony Pappas, Assistant Director, 
Career Planning Services, ACT, June 1981. 

23/ Id. 

~ The thirteen pilot schools are Albany Tech, Pickens Tech, 
Upson County Area Voe-Tech, Ben Hill-Irwin Tech, Griffin 
Spalding Tech, Columbus Tech, Augusta Tech, Bainbridge Junior 
College, Atlanta Tech, DeKalb Tech, Athens Tech, Walker Tech, 
and Savannah Tech. 

- 36 -



.· 

entry-level test scores with the first-quarter grades of a group 

of students who attended the schools during the 1978-79 and 1979-

80 school years. The sample size includes 50 students per pro­

gram choice per year with each of the schools providing a pro­

portion of the students for each program. The students were 

selected randomly. AEC will also be collecting information on 
25/ 

the race and sex of the students included in the study.~ 

The study of the CPP test will consider its validity as a 

predictor of success in the various vocational programs and as 

an instrument to identify and refer students for remediation. 

The sample 'technique used to select students was the same as 

the one employed in the TABE study. The students are currently 

being tested and are seeking admission for fall 1981 programs 

at the 13 pilot schools. The CPP test produces both interest 

and ability scores. Tables will be established which correlate 

the first-quarter grades of the students with their ability 

scores on the CPP. Interest scores will not be included in the 

tables since the schools are seeking to compare the CPP with 

the TABE and the TABE includes only ability scores. The in-

troduction of the CPP interest scores would therefore be 

inappropriate since the TABE does not include that dimension. 

It is estimated that approximately 4,600 students will be 

included in the CPP validation st·udy. Data on the race and 

25/ Phone Interview with Dr. John Drugo, ·Director for Research 
and Evaluation, AEC, June 1981. 

- 37 -



26/ 
sex of the students will be collected.~ 

The Career Planning Program or CPP is described as an 

interest and aptitude test. As indicated previously, it 

produces both ability scores and interest scores. The abilities 

it purports to measure are. Mechanical Reasoning i Numerical 

Skillsi Space Relationsi Reading Skillsi Language Usagei and 

Clerical Skills. Interest scores are obtained in the following 

areas: Business (includes Contact with People and Detail)i 

Tradesi Technologyi Sciencei Healthi Creative Artsi and 
27/ 

Social Services.~ 

John Roth, Director of the Career Planning Program (CPP) 

at ACT reported that they had done a national study of the CPP 

test. He explained that the students included in the study 

were not selected randomly in accordance with strict statistical 

procedures and therefore it would not be appropriate for ACT to 

claim that these students are representative of the nation. 

ACT looked at the CPP test performance of 17,000 students from 

100 different two-year technical schools and community colleges 

across the country. The students included in the review were 

not all pursuing the same academic tracki some were enrolled 

in college-transfer programs and others were enrolled in 

vocational technical. programs. 

It would be inappropriate to conclude that the results of 

this national study of the CPP test are probative or even 

26/ Phone Interview with Dr. Anthony Pappas, ACTi and Dr. 
John Drugo, AEC, June 1981. 

27/ Id. 

- 38 -

·. 



predictive of Georgia's experience. The student populations, 

the programs of study, and the statistical procedures and 

methodology used, are not comparable. Still, the results of 

the national study certainly fail to provide reassurance that. 

the test will not have a discriminatory impact on blacks and 

women. John Roth acknowledged that black students as a group 

scored lower on the CPP test than white students as a group 

did. On all six abilities, the average scores of blacks were 

.lower than the average scores of whites. There were also 

differential scores for males and females. Males scored better 

than females on three abilities but females scored better than 

males on the other three abilities. 

The following chart illustrates the differences in the 

average scores of the various, groups: 
~/ 

All Males All Females 
Black Black Black Black 

Ability Measured & White & White Males Females 

Numerical Skills 5.08 4.91 3.30 3.59 
Reading Skills 4.98 5.09 2.87 2.88 
Language Usage 4.68 5.48 3.46 4. 11 
Clerical Skills 4.79 5.18 3.14 2.86 
Space Relations 5.39 4.47 3.45 2.85 
Mechanical Reasoning 5.69 3.79 3.47 2.20 

28/ The information on the national study of the CPP and the 
results presented in the chart above were obtained during a 
phone interview with John Roth, Director of the Career Planning 
Program, ACT •. It should be noted that the columns on the left 
side of the chart include both black and white students by sex 
whereas the columns on the r~ght side include only black 
students by sex. The students were self-identified as black. 
Since the test questionnaire also gave the option of declining 
to indicate race, it is not necessarily true that all black 
students who were tested would be included in the results. 
Roth estimated that the results for approximately 1,500 black 
students are in·cluded in these averages. 

- 39 -



A critical concern is how the tests will be used in the 

admissions process. Dr. Anthony Pappas, Assistant Director of 

Career Planning Pr-0gram Services, ACT, indicated that the CPP 

should be used to help students identify their goals, interests, 

strengths and weaknesses. He expressed concern that many SPS 

personnel want to use the CPP test as a "gate-keeping instrument" 

and that it was not designed for that purpose. He reported 

that ACT had encountered problems with many of the SPS person­

nel because they wanted to use the CPP in the same way that 

they had used the TABE. Many SPS people want a "quick and 

dirty score", something that will allow them to "process 

applicants quickly instead of helping the students to identify 

goals •••• The resistance is at the SPS level, at the schools 

themselves." Pappas further defined the problem as "the mind 

set that we're dealing with ••• we need to change their way of 

thinking of testing for placement to testing for retention and 

the proper fit of the individual for the program." ACT has 

attempted to persuade the SPS people that using the CPP to help 

the students rather than to reject them will increase retention 

rates because students will be in programs which they have 

chosen. Pappas believes that the Georgia Department of Educa­

tion recognizes the problems with SPS personnel and that "the 

Department is trying to get at that.". 

- 40 -

·. 



. · 

Although the Georgia Department of Education is waiting 
29/ 

for the results of the validation studies,~ it hopes to 

recommend the CPP as a counseling tool and either the CPP or 

the TABE as the instrument to identify and refer students for 

remediation •. John Lloyd from the Department believes that the 

inclusion of so many of.the schools in the admissions project 

increases the likelihood that many of the schools will adopt 

the recommendations of the Department. Still, Lloyd admitted 

that, "of course there are no guarantees that the locals will 

accept the Department's recommendations ••• some will and some 

won't." The involvement of the schools is preferable to 

"having the State tell them what to do." Still it should be 

noted that when the remedial programs were first established, 

the Department had recommended to the schools that they allow 

students to participate in regular vocational programs while 

taking the remedial program. Yet of the nine schools which 

the LDF/ACLU surveyed, none of the schools had adopted this 

recommendation. All nine schools required the completion of 

the remedial and/or the attainment of qualifying test scores 

before the student could pursue a regular vocational program • 

29/ The results of the validation studies should be in­
cluded in the final report on the admissions project. AEC 
is expected to submit the report to the Georgia Department 
of Education in mid-March of 1982. 

- 41 -



VII. The Failure of OCR to Follow-Up On Its Findings 

Our interviews with OCR officials indicate that it would 

be injudicious to rely upon OCR to evaluate the new admissions 

procedures or to monitor the remedial action taken by the three 

schools cited for violations. The OCR officials informed 

us that OCR had not done any follow-up work to insure com­

pliance at Griffin Spalding Tech, Augusta Tech, and South 

Georgia Tech since the Statements of Findings were issued. 

These officials maintained that the only way to monitor 

the schools is to do another on-site compliance review of the 

schools or to select a new school for a review. They explained 

that OCR's current Annual Operating Plan (AOP) which expires 

September 30, 1981, does not provide for on-site monitoring. 

The two OCR officials, Raul Gamez and Phillip Lyde, were the 

persons primarily responsible for the inve~tigations of the 

three schools. When asked if the Georgia Department of Educa­

tion and the schools were aware of OCR's weak enforcement 

posture and its passivity with respect to following-up on its 

findings, Lyde acknowledged that Dr. McDaniel, the State 

Superintendent of Schools, "has dealt with this office a long 

time." Lyde wanted it understood that he had not "explicitly 

stated" that this was the State's view of OCR but he agreed 

with the interpretation that he was "strongly implying that." 

Lyde explained, "our office has been one of reaction. Our 

plans are based on reaction. There's clearly a need to have 

time for monitoring built into the AOP." 

- 42 -

·. 



. · 

Lamar Cle~ents, Director of the Elementary and Secondary 

Division of OCR expressed the belief that since the compliance 

issues at these schools concerned admissions procedures, OCR 

could monitor the schools from the office by requesting reports. 

This view is contrary to the opinions expressed by Lyde and 

Gamez, the two officials primarily responsible for the com­

pliance reviews of these schools. When we raised the issue of 

the failure of the AOP to include time for monitoring, Clements 

responded that "OCR would find time." 

With Gamez and Lyde, we also expressed concern that SPS 

personnel might continue to use the test as an admissions 

instrument rather than as a counseling tool as OCR had ordered in 

its interim agreements with the schools. We pointed out that 

since the tests had been used historically for this purpose, it 

might be difficult for the same SPS personnel to change their 

past practices and inclinations. Both officials acknowledged 

that this was a legitimate concern. Nevertheless, Lyde stated 

"the best we're going to get is some written or oral assurance" 

that the tests are only being used to counsel students • 

- 43 -



VIII. Summary of the Problem 

The continued use of tests raises legitimate concer~s 

about their impact on the educational opportunities of minori­

ties and women. The nexus between test scores and minority 

and female placement in programs implicates the tests as 

discriminatory devices. There are several reasons which give 

credence to this assessment. Many of the.SPS personnel we 

interviewed indicated that the test scores were the primary.if 

not the sole determinant of student placement in programs. 

Given that admission, the overrepresentation of blacks and 

females in remedial programs and conversely their underrepre­

sentation in programs which require high test scores, create a 

strong inference that these students are adversely affected by 

the reliance on test scores. 

The selection of the CPP test does little to alleviate the 

concern since a national study alerts us to the possibility 

that minorities may not perform as well on the test as non­

minorities and that males and females may score differently. 

If this same pattern emerges in Georgia, then the representa­

tion of minorites and females in programs traditional for 

their race anp sex could continue. 

Even though the Georgia Department of Education, ACT, and 

AEC are working to persuade the schools that the CPP test 

should be used only as a counseling instrument, it has been 

admitted that there is resistance to using the CPP test for 

- 44 -

• 

·. 



.· 

that purpose. As Dr. Pappas from ACT revealed, "many of the SPS 

people want to use the CPP test as a gate-keeping instrument to 

determine who should get into programs." And ultimately, the 
' 

decision on how the tests will be used rests with the individual 

schools. 

Even if the CPP test and other tests are used strictly to 

counsel students, this function could still have the effect of 

reinforcing the current enrollment patterns. A black student 

who is seeking admission to a program which has historically 

excluded blacks will hardly feel encouraged if a counselor 

informs him that his chances for successfully completing the 

program are 10%. 

The explanation for the underrepresentation or exclusion 

of black students and female students in certain programs is 

not as simple as one Georgia Department of Education official 

suggested: "some programs don't have certain races or sexes 

that will apply for them." Although student choice may be a 

contributory factor,. it cannot seriously be considered as the 

explanation for the absence or underinclusion of minorities and 

females in the trade and technical programs. We met minority 

and female students who had applied to such programs as Cer-

tified Lab Assistant, X-Ray Technician, Electronics Technology 

and Welding, and who were told that their test scores disquali-

fied them for admission to these programs. In addition, if the 

schools perceive that these students are reluctant to apply to 

- 45 -



the technical and trade programs, the schools have an affirma­

tive obligation to inform the students of the economic benefits 

of pursuing these occupations. An employee of the Department 

of Education confirmed that a follow-up survey of the salaries 

of Georgia's postsecondary vocational school graduates showed 

that those students in the trade and technical programs were 

more likely to find higher-paying jobs. 

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.· 

IX. Recommendations 

The effort to revise the admissions system is an ongoing 

one; the evaluation of that system should also be a continuing 

effort. At this stage, there are steps which can be taken to 

improve program access and to increase the educational oppor­

tunities not only of minorities and females, but of all students 

who are seeking training through Georgia's postsecondary 

vocational schools. The recommendations for achieving these 

objectives are discussed and presented below. 

1. The Role of the Georgia Department of Education -

The Georgia Department of Education exercises administrative 

control and supervision over the postsecondary schools, includ­

ing establishing and reviewing teacher certif.ication, curricu­

lum, hours of instruction and other operations. The Department 

should extend its administrative regulation to include the 

admissions system. 

In addition, the Georgia Department of Education, as a 

recipient of federal vocational education funds, must insure 

that both state and locally operated schools comply with federal 

civil rights laws. To assist state departments of education to 

understand and comply with Title VI of the Civil Rights Act of 

1964, Title IX of the Education Amendments of 1972 and Section 

504 of the Rehabilitation Act of 1973, the Office for Civil 

Rights of the Department of Education has issued Vocational 

Education Guidelines for Eliminating Discrimination and Denial 

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of Services on the Basis of Race, Color, National Origin, Sex 

and Handicap. Section II of the Guidelines requires state 

agencies to adopt a compliance program in order to insure non­

discrimination by sub-recipients. The Compliance program must 

include 1) conduct of periodic compliance reviews, 2) making 

findings of unlawful discrimination, 3) notifying sub­

recipients of steps to be t.aken to attain compliance and 

4) attempting to secure voluntary compliance. 

The Georgia Department of Education has the necesary 

authority to regulate the admissions process in a nondiscrimina­

tory manner. Specifically, the Department should require that 

tests, such as the CPP or TABE, be used only for counseling or 

diagnostic purposes. The Department should withhold state 

money from any school that fails to comply with this requirement. 

2. Monitoring the Schools' Admissions Practices - The 

Department should have at least one full-time employee to moni­

tor the schools' admiss.ions practices and to provide technical 

assistance. It is important for the employee to talk not only 

with school officials but also with students to learn of their 

experiences in the admissions/counseling process. 

3. Remedial Programs - Students who need remediation 

should be allowed to participate in a regular vocational 

education program while taking the remedial program. In 

the past tpe Georgia Department of Education presented this 

as a recommendation to the schools and most of the schools 

·ignored that recommendation. The Department should require 

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·. 



.· 

that the schools adopt this policy. The attrition rates of 

the remedial programs suggest that these students are dis-

couraged by the requirement to complete the remedial program 

before entering a regular program. The need to provide re-

mediation for students who are deficient in basic skills is 

recognized: the problem is how to help the student and still 

keep him in the system. If permitted to enroll in a remedial 

and a regular program simultaneously, the student could see 

that he was making progress toward his occupational goal. 

There may be other factors contributing to the high dropout 

rates of the remedial programs. The Department should con-

sider hiring special tutors to work with students who are 

severely deficient. Additionally, the interest in these 

students should go beyond the program referral point. 

Counselors should maintain their interest in these students 

and assist them and follow them through the remedial process. 

Georgia is not fully utilizing its resources to help these 

special needs students. The Vocational Educational Amendments 

of 1976 provide funds which were specifically to be used to 

meet the excess costs of disadvantaged and handicapped persons 

who required special services and assistance in order to 

enable them to succeed in vocational educational programs. 

Yet as of September 30, 1979, Georgia had not spent $664,136 
30/ 

of its funds for the period FY77 through FY79.~ 

30/ Review of Costs Claimed by the State of Georgia for the 
Fiscal Year 1977 Vocational Education Program and the State's 
Program Evaluations, prepared by Office of Inspector General, 
Audit Agency, Region IV, Audit Control No. 04-00103. 

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4. Staff Development - The Department of Education 

should provide in-service training for SPS 'personnel on imple­

menting the new admissions procedures. This training should 

be mandatory for all SPS personnel. 

5. Appeals Procedure - An appeals procedure for students 

who are not admitted to the program of their choice should be 

developed.by the Department and the schools' directors. This 

procedure should provide for timely review of the application 

by a school official other than the person who made the decision, 

and if the applicant chooses, for final review by the Department 

of Education employee described in recommendation number 2. 

6. Publication of New Admissions Proced.ures - The Depart­

ment of Education should require all schools to publish the 

new admissions procedures in local papers and to publish bro­

chures providing the same information to be distributed to 

the local high schools and in general to the community. This 

information should be posted in all of the schools and should 

be also. included in any materials sent to applicants. 

7. Waiting List Procedure - For programs which are over­

subscribed, a waiting list procedure should be established 

which admits students in the order in which they completed 

their applications. The waiting lists for these programs 

should be posted by all of the schools in a location where 

students or applicants can easily view them. 

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