This series of the board policy manual is devoted to the goals and objectives for the school district's noninstructional services and business operations that assist in the delivery of the education program. These noninstructional services include, but are not limited to, transportation, the school lunch program and financial services. The board, as it deems necessary, will provide additional noninstructional services to support the education program. To the extent a group of employees has a recognized collective bargaining unit, the provisions of the master contract regarding such topics shall prevail.
It is the goal of the board to provide noninstructional services and to conduct its business operations in an efficient manner.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 6/10/13; 2/11/19 |
Revised: 9/17/07; 10/13/25 |
Each year at its June regular meeting the Board will designate by resolution the name and location of an Iowa located financial depository institution or institutions to serve as the official school district depository or depositories. The Board will also designate the maximum amount which maybe kept on deposit at each bank. This amount will be designated the first time a new depository is identified, and will be reviewed annually or when an increase or additional depository is needed. The amount stated in the resolution must be for all depositories and include all of the District's funds.
It is the responsibility of the Board secretary to include the resolution in the minutes of the meeting.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
When the necessity for a fund has ceased to exist, the balance may be transferred to another fund or account by Board resolution. District monies received without a designated purpose may be transferred in this manner. District monies received for a specific purpose or upon public vote may only be transferred by Board resolution when the purpose for which the monies were received has been completed. Voter approval is required to transfer monies to the general fund from the capital projects fund and the debt service fund.
If all requirements for district use of funds under the Preschool Foundation Aid, Professional Development Supplement, Home School Asssitance Program, Teacher Leadership Supplement or any discontinued teacher fund have been met and funds remain unexpended and unobligated at the end of the fiscal year, the district may transfer all or a portion of remaining funds by passage of a board resolution into the district's flexibility account in accordance with law. Before the expenditure of amounts in the flexibility account, the district shall publish notice of the time, date, and place of a public hearing on the proposed resolution approving said expenditures. The Board must find and certify that the statutoary requirements of each original source of funds have been meet before adopting the resolution approving the expenditures. The district will present a copy of the signed board resolution to the Department of Education.
The District may transfer by board resolution from the general fund to the student activity fund an amount needed to purchase or refurbish protective and safety equipment required for any extracurricular interscholastic athletic contest or competition sponsored or administered by the Iowa High School Athletic Association or Iowa Girls High School Athletic Union.
If the before and after school program exceeds the amount necessary to operate the program, the excess amount may, following a public hearing, be transferred by resolution of the board of directors of the school corporation for deposit in the general fund of the school corporation to be used for school district general fund purposes. The district will present a copy of the signed board resolution to the Department of Education.
Beginning in FY 2024, unexpended and unobligated dollars that remain at the end of a fiscal year in addition to ongoing revenues may be transferred to the Teacher Salary Supplement (TSS) program from Professional Development Supplement (PDS), Talented and Gifted (TAG), and Teacher Leadership Supplement (TLS) without board aciton.
The district may choose to request approval from the School Budget Review Committee to transfer funds to make a program whole, prior to its elimination.
Temporary transfers (loans) of funds are permitted between funds but must be repaid to the originating fund, with interest, by October 1 following the end of the fiscal year.
It is the responsibility of the Board secretary to make recommendations to the Board regarding transfers and to provide the documentation justifying the transfer.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
Financial records of the District shall be maintained in accordance with generally accepted accounting principles (GAAP) as required or modified by law. District monies shall be received and expended from the appropriate fund and/or account. The funds and accounts of the District will include, but not be limited to:
Governmental fund type
Proprietary fund type - this fund is used to account for the accumulation of resources for, and the payment of, general long-term debt principal and interest.
Fiduciary funds - These funds are used to account for monies or assets held by the school district on behalf of, or in trust for, another entity
Non-Fiduciary scholarship fund
Account groups - The groups are the accounting records for capital assets and long-term debt.
The board may establish other funds in accordance with generaly accepted accounting principles and may certify other taxes to be levied for the funds as provided by state law. The status of each fund must be included in the annual report.
The general fund is used primarily for the education program. Special revenue funds are used to account for monies restricted to a specific use by law. Proprietary funds account for operations of the school district operated similarly to private business, and they account for the costs of providing goods and services provided by one department to other departments on a cost reimbursement basis. Fiduciary funds are used to account for monies or assets held by the District on behalf of, or in trust for, another entity. The account groups are the accounting records for fixed assets and long-term debt.
It is the responsbility of the Superintendent in conjunction with the school business official to implement this policy and bring necessary changes in the maintenance of the school district's financial records to the attention of the board.
---------------------------------------------------------------------------------------------------------------
|
Approved: 7/8/13 |
Reviewed: 3/11/19 |
Revised: 10/13/25 |
School district accounting practices will follow state and federal laws and regulations, generally accepted accounting principles (GAAP) and the uniform financial accounting system provided by the Iowa Department of Education. As advised by the school district's auditor, determination of liabilities and assets, prioritization of expenditures of governmental funds and provisions for accounting disclosures shall be made in accordance with governmental accounting standards.
In Governmental Accounting Standards Board (GASB) Statement No. 54, the board identifies the order of spending unrestricted resources applying the highest level of classification of fund balance - restricted, committed, assigned, and unassigned - while honoring constraints on the specific purposes for which amounts in those fund balances can be spent. A formal board action is required to establish, modify and/or rescind a committed fund balance. The resolution will stake the exact dollar amount. In the event the board chooses to make changes or rescind the committed fund balance, formal board action is required.
The Board authorizes the Superintendent or board treasurer to assign amounts to a specific purpose in compliance with GASB 54. An "assigned fund balance" should also be reported in the order of spending unrestricted resources, but is not restricted or committed.
General
The board strives to maintain adequate fund balances and reserves in order to:
1. Provide sufficient cash flow for daily financial needs;
2. Secure and maintain investment-grade bond ratings;
3. Offset significant economic downturns or revenue shortfalls; and
4. Provide funds for unforeseen expenditures related to emergencies.
Reporting Fund Balances
The board shall engage in accounting and financial reporting procedures in compliance with the Governmental Accounting Standards Board’s Statement No. 54 (“GASB 54”). Fund Balance Reporting and Governmental Fund Types Definitions. Fund balance refers to the difference between assets and liabilities in the government funds balance sheets. GASB 54 established a hierachy that is based on "the extent to which the government is bound to honor constraints on the specific purpose for which amounts in those funds can be spent."
Pursuant to GASB 54, governmental fund balances shall be identified for purposes of reporting as one of the following types of funds, and are defined from most to least restrictive:
|
1. |
Nonspendable fund balance- includes amounts that cannot be spent because they are either not in spendable form, or legally or contractually required to be maintained intact. This includes items not expected to be convereted to cash, including inventorise and prepaid expenses. It may aslo include other property acquired for resale and the principal of a permanent fund. |
|
2. |
Restricted fund balance- should be reported when contraints placed on the use of resources are either externally imposed by creditors, grantors, contributors, or law or regulations of other governments; or imposed by law through constitutional provisions or enabling legislation. This includes "categorical balance". |
|
3. |
Committed fund balance - reflects specific purposes pursuant to contraints imposed by formal action of the board. Such constraints can only be removed or changed by board action. |
|
4. |
Assigned fund balance - reflects amounts that are constrained by the government's intent to be used for specific purposes but meet neither the restricted or committed forms of constraint. Unless the amount is negative, the assigned fund balance is the residual classification for the governmental funds other than the general fund. If the amount is negative, then the residual amount is shown as unassigned. |
|
5. |
Unassigned fund balance- is the residual classification for the general fund only. As noted above, if a negative residual amount exists in other governmental funds then the amount is reported as unassigned. |
---------------------------------------------------------------------------------------------------------------
|
Approved: 7/8/13 |
Reviewed: 3/11/19 |
Revised: 10/13/25 |
The Board recognizes its fiduciary responsibility to oversee the management of school district funds in keeping with the school district vision, mission and goals. To achieve this purpose, the board may engage in learning about the financial needs, operations and requirements of the district as appropriate for the board’s understanding of the district’s financial position. The Board also commits to engaging in annual financial goal setting for the district based upon measurable data and projections for the district.
After the fiscal year has closed, the Superintendent or their designee will provide to the Board concise, timely, well organized financial data. The Board will exercise its oversight responsibilities by reviewing relevant PK-12 public education sector indicators to understand the financial trends of the district.
The board will establish and review financial goals annually. The District will measure whether these goals were obtained as of June 30, but only after completion of the Certified Annual Report due September 15th each year.
Providing the best possible educational experience for all students and meeting federal, state, and local academic goals for each student requires maximizing General Fund resources for use in the instructional program. The board may request from the School Budget Review Committee (SBRC) additional modified spending authority (MSA) where it may be available for items such as:
Any award of modified supplement amount will be levied as a cash reserve based on the recommendation of the superintendent/designee and approved by the Board of Education in keeping with the fiscal management performance measures provided for in district policy.
Approved: 10/13/25 Reviewed: Revised:
The amount of cash that may be kept in the school building for any one day is sufficient for that day's operations. Funds raised by students are kept in the central administrative office.
A minimal amount of cash is kept in the central administration office at the close of the day. Excess cash is deposited in the authorized depository of the school district.
It is the responsibility of the Superintendent or the Superintendent's designee to develop administrative regulations to determine the amount of cash necessary for each day's operations, to establish any necessary petty cash accounts, to determine how often deposits must be made and to comply with this policy.
Approved: 10/13/25 Reviewed: Revised:
Prior to certification of the budget, the board will review the projected revenues and expenditures for the school district and make adjustments where necessary to carry out the education program within the revenues projected. The budget of the school district is the authority for the expenditures of the school district for the fiscal year for which the budget was adopted and certified. It is the responsibility of the Superintendent to manage the operations of the district within the budget.
A budget for the District shall be prepared annually for the Board's review. The budget will include the following:
It is the responsibility of the Superintendent and the Board secretary and/or treasurer to prepare the budget for review by the Board prior to the April 30 deadline each year. The District will provide all of the information necessary for the Proposed Property Tax Statement to the Department of Management by March 15.
Mailing of Proposed Property Tax Hearing Statements is completed by the country auditor by March 20. A public hearing notice for the Proposed Property Taxes shall be published not less than 10 days and not more than 20 days prior to the date of hearing. The hearing notice is published in a newspaper designated for official publication in the school district. The hearing notice must also be posted on the district website and district social media accounts on the same day it is published in the newspaper. The hearing on the Proposed Property Tax must be a unique and separate meeting and be the only item on the agenda.
Prior to the adoption of the proposed budget by the board, the public is apprised of the proposed budget for the school district. Prior to the adoption of the propose budget by the board, members of the school district community will have an opportunity to reivew and comment on the proposed budget. A public hearing for the proposed budget of the board is held each year in sufficient time to file the adopted budget not later than April 30.
The proposed budget filed by the board with the board secretary and the time and place of the public hearing on the proposed budget is published in a newspaper designated for official publication in the school district. It is the responsiblity of the board secretary to publish the proposed budget and public hearing information at least 10 but no more than 20 days prior to the public hearing.
The Board will adopt and certify a budget for the operation of the District to the county auditor by April 30. It is the responsibility of the Board secretary and/or treasurer to file the adopted and certified budget with the county auditor and the Iowa Department of Management.
The Board may amend the budget for the fiscal year in the event of unforeseen circumstances. The amendment procedures will follow the procedures for public review and adoption of the original budget by the board outlined in these policies.
It is the responsibility of the superintendent and the Board secretary and/or treasurer to bring any budget amendments necessary to the attention of the Board as soon as possible in order to allow sufficient time to file the amendment with the county auditor no later than May 31 of each year.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: |
Revised: 5/14/12; 7/8/13; 3/11/19; 10/13/25
|
Revenues of the District shall be received by the Board treasurer or their designee. Other persons receiving revenues on behalf of the District will promptly turn them over to the Board treasurer or their designee.
Revenue, from whatever source, is accounted for and classified under the official accounting system of the District. It is the responsibility of the Board treasurer to deposit the revenues received by the District in a timely manner. District funds from any and all sources will not be used for private gain or political purposes.
Tuition fees received by the District shall be deposited in the general fund. The tuition fees for kindergarten through twelfth grade during the regular academic school year are set by the board based upon the Superintendent's recommendation in compliance with current law. Tuition fees for summer school, driver's education, and adult education, as applicable, are set by the Board prior to the offering of the programs.
The Board may charge materials fees for the use or purchase of educational materials. Educational materials fees received by the District shall be deposited in the general fund. It is the responsibility of the Superintendent to recommend to the Board when educational materials fees will be charged and the amount of the materials fees.
Rental fees received by the District for the rental of District equipment or facilities shall be deposited in the general fund.
Proceeds from the sale of real property shall be placed in the physical plant and equipment levy (PPEL) fund, except as otherwise appropriate. The proceeds from the sale of other District property are placed in the general fund, except as otherwise appropriate. However, following a properly noticed public hearing, the board of directors may elect to deposit proceeds from the sale of real property or buildings into any fund under the control of the school corporation. Notice for the public hearing must be published in a newspaper of general circulation within the district not less than ten and no more than twenty days prior to the proposed public hearing. Notice of the public hearing must include the date, time and location of the public hearing, and a description of the proposed action. The proceeds from the sale of other District property are placed in the general fund, except as otherwise appropriate.
The board may claim exemption from the law prohibiting competition with private enterprise for the following activities:
It is the responsibility of the Superintendent to bring to the board's attention additional sources of revenue for the school district.
---------------------------------------------------------------------------------------------------------------
Approved: 11/14/67 Reviewed: Revised: 5/14/12; 7/8/13; 3/11/19; 10/13/25
DEBT LIMITS
Credit Ratings
The school district seeks to maintain the highest possible credit ratings for all categories of short- and long-term debt that can be achieved without compromising the delivery of services and the achievement of adopted objectives. The school district recognizes that external economic, natural, or other events may from time to time affect the creditworthiness of its debt. Nevertheless, the school district is committed to ensuring that actions within their control are prudent.
Debt Limits
For general obligation debt, the school district’s outstanding debt limit shall be no more than five percent (5%) of the actual value of property within the school district’s boundaries, as prescribed the Iowa constitution and statutory restrictions.
For revenue debt, the school district’s goal is to provide adequate debt service coverage of at least 1.20 times the annual debt service costs.
In accordance with Iowa law, the school district may not act as a conduit issuer or issue municipal securities to raise capital for revenue-generating projects where the funds generated are used by a third party (“conduit borrower”) to make payments to investors.
PURPOSES AND USES OF DEBT
Capital Planning
To enhance creditworthiness and prudent financial management, the school district is committed to systematic capital planning, intergovernmental cooperation and coordination and long-term financial planning.
Capital Financing
The school district may issue long-term debt for capital projects as authorized by Iowa law, which include, but are not limited to, the costs of planning, design, land acquisition, buildings, permanent structures, attached fixtures or equipment, and movable pieces of equipment. Capitalized interest may be included in sizing any capital project debt issue. The types of debt instruments to be used by the school district include:
Working Capital Financing
The school district may issue debt for working capital for operations after cash flow analysis has determined that there is a mismatch between available cash and cash outflows. The school district shall strive to repay working capital debt by the end of the fiscal year in which the debt was incurred. A Working Capital Reserve may be included in sizing any working capital debt issue.
Refundings
Periodic reviews of all outstanding debt will be undertaken to determine if refunding opportunities exist. Refunding will be considered (within federal tax law restraints) if and when there is a net economic benefit of the refunding or if the refunding is otherwise in the best interests of the school district, such as to release restrictive bond covenants which affect the operations and management of the school district.
In general, advance refundings for economic savings will be undertaken when a net present value savings exceeds three percent of the refunded debt can be achieved. Current refundings, which produce a new present value savings of less than three percent will be considered on a case by case basis taking into consideration bond covenants and general conditions. Refundings with negative savings will not be considered unless there is a compelling public policy objective for doing so.
DEBT STANDARDS AND STRUCTURE
Length of Debt
Debt will be structured for the shortest period consistent with a fair allocation of costs to current and future beneficiaries or users. Long-term debt will not be issued for periods exceeding the useful life or average useful lives of the project or projects to be financed. All debt issued will adhere to state and federal law regarding the length of time the debt may be outstanding.
Debt Structure
Debt will be structured to achieve the lowest possible net cost to the school district given market conditions, the urgency of the capital project, the type of debt being issued, and the nature and type of repayment source. To the extent possible, the school district will design the repayment of its overall debt to rapidly recapture its credit capacity for future use.
Generally, the school district will only issue fixed-rate debt. In very limited circumstances, the school district may issue variable rate debt, consistent with the limitations of Iowa law and upon a finding of the board that the use of fixed rate debt is not in the best interest of the school district and a statement of the reasons for the use of variable rate debt.
All debt may be structured using discount, par or premium coupons, and as serial or term bonds or notes, or any combination thereof, consistent with Iowa law. The school district should utilize the coupon structure that produces the lowest True Interest Cost (TIC) taking into consideration the call option value of any callable maturities.
The school district will strive to structure their debt in sinking fund installments for each debt issue that achieves, as nearly as practicable, level debt service within an issue or overall debt service within a particular classification of debt.
Derivatives (including, but not limited to, interest rate swaps, caps, collars, corridors, ceiling and floor agreements, forward agreements, float agreements, or other similar financing arrangements), zero-coupon or capital appreciation bonds are not allowed to be issued consistent with State law.
Decision Analysis to Issue Debt
Whenever the school district is contemplating the issuance of debt, information will be developed concerning the following four categories commonly used by rating agencies assessing the school district’s credit worthiness, listed below.
Debt Analysis – Debt capacity analysis; purpose for which debt is proposed to be issued; debt structure; debt burden; debt history and trends; and adequacy of debt and capital planning.
Financial Analysis – Stability, diversity, and growth rates of tax or other revenue sources; trend in assessed valuation and collections; current budget trends; appraisal of past revenue and expenditure trends; history and long-term trends of revenues and expenditures; evidences of financial planning; adherence to GAAP; audit results; fund balance status and trends in operating and debt funds; financial monitoring systems and capabilities; and cash flow projections.
Governmental and Administrative Analysis – Government organization structure; location of financial responsibilities and degree of control; adequacy of basic service provision; intergovernmental cooperation/conflict and extent of duplication; and overall planning efforts.
Economic Analysis – Geographic and location advantages; population and demographic characteristics; wealth indicators; types of employment, industry and occupation; housing characteristics; new construction; evidences of industrial decline; and trend of the economy.
DEBT ISSUANCE
Credit Enhancement
Credit enhancements (.i.e., bond insurance, etc.) may be used but only when the net debt service on the debt is reduced by more than the costs of the credit enhancement.
Costs and Fees
All costs and fees related to issuing the debt will be paid out of debt proceeds and allocated across all projects receiving proceeds of the debt issue.
Method of Sale
Generally, all school district debt will be sold through a competitive bidding process. Bids will be awarded on a TIC basis providing other bidding requirements are satisfied.
The school district may sell debt using a negotiated process in extraordinary circumstances when the complexity of the issue requires specialized expertise, when the negotiated sale would result in substantial savings in time or money, or when market conditions of school district credit are unusually volatile or uncertain.
Professional Service Providers
The school district will retain external bond counsel for all debt issues. All debt issued by the school district will include a written opinion by bond counsel affirming that the school district is authorized to issue the debt, stating that the school district has met all Iowa constitutional and statutory requirements necessary for issuance and determining the debt’s federal income tax status. The bond counsel retained must have comprehensive municipal debt experience and a thorough understanding of Iowa law as it relates to the issuance of the particular debt.
The school district will retain an independent financial advisor. The financial advisor will be responsible for structuring and preparing all offering documents for each debt issue. The financial advisor retained will have comprehensive municipal debt experience, experience with diverse financial structuring and pricing of municipal securities.
The treasurer shall have the authority to periodically select other service providers (e.g., escrow agents, verification agents, trustees, arbitrage consultants, rebate specialist, etc.) as necessary to meet legal requirements and minimize net debt costs. These services can include debt restructuring services and security or escrow purchases.
Compensation for bond counsel, financial advisor and other service providers will be as economical as possible and consistent with industry standards for the desired qualification levels.
DEBT MANAGEMENT
Investment of Debt Proceeds
The school district shall invest all proceeds received from the issuance of debt separate from the school district’s consolidated cash pool unless otherwise specified by the authorizing bond resolution or trust indenture. Investments will be consistent with those authorized by Iowa law and the school district’s Investment Policy to maintain safety of principal and liquidity of the funds.
Arbitrage and Record Keeping Compliance
The treasurer shall maintain a system of record-keeping, reporting and compliance procedures with respect to all federal tax requirements which are currently, or may become applicable through the lifetime of all tax-exempt or tax credit bonds.
Federal tax compliance, record-keeping, reporting and compliance procedures shall include but not be limited to:
post-issuance compliance procedures (including proper use of proceeds, timely expenditure of proceeds, proper use of bond financed property, yield restriction and rebate, and timely return filing);
proper maintenance of records to support federal tax compliance;
investments and arbitrage compliance;
expenditures and assets;
private business use; and
designation of primary responsibilities for federal tax compliance of all bond financings.
Financial Disclosure
The school district is committed to full and complete financial disclosure, and to cooperating fully with rating agencies, institutional and individual investors, other levels of government, and the general public to share comprehensible and accurate financial information. The school district is dedicated to meeting secondary disclosure requirements on a timely and comprehensive basis, as promulgated by the Securities and Exchange Commission.
The Official Statements accompanying debt issues, Annual Audits, and Continuing Disclosure statements will meet the standards articulated by the Municipal Securities Rulemaking Board (MSRB), the Government Accounting Standards Board (GASB), the Securities and Exchange Commission (SEC), Generally Accepted Accounting Principles (GAAP) and the Internal Revenue Service (IRS). The treasurer shall be responsible for ongoing debt disclosure as required by any Continuing Disclosure Certificate for any debt issue and for maintaining compliance with disclosure standards promulgated by state and federal regulatory bodies.
Approved: 10/13/25 Reviewed: Revised:
---------------------------------------------------------------------------------------------------------------
Approved: 11/14/67 Reviewed: 3/11/19 Revised: 5/14/12; 7/8/13
Role of Compliance Coordinator/Board Treasurer
The board treasurer shall:
Be responsible for monitoring post-issuance compliance;
Maintain a copy of the transcript of proceedings or minutes in connection with the issuance of any tax-exempt obligations and obtain records that are necessary to meet the requirements of this regulation;
Consult with bond counsel, a rebate consultant, financial advisor, IRS publications and such other resources as are necessary to understand and meet the requirements of this regulation;
Seek out training and education to be implemented upon the occurrence of new developments in the area and upon the hiring of new personnel to implement this regulation.
Financing Transcripts’ Filing and Retention
The board treasurer shall confirm the proper filing of an IRS 8038 Series return and maintain a transcript of proceedings and minutes for all tax-exempt obligations issued by the school district including, but not limited to, all tax-exempt bonds, notes and lease-purchase contracts. Each transcript shall be maintained until 11 years after the tax-exempt obligation documents have been retired. The transcript shall include, at a minimum:
Form 8038;
Minutes, resolutions and certificates;
Certifications of issue price from the underwriter;
Formal elections required by the IRS;
Trustee statements;
Records of refunded bonds, if applicable;
Correspondence relating to bond financings; and
Reports of any IRS examinations for bond financings.
Proper Use of Proceeds
The board treasurer shall review the resolution authorizing issuance for each tax-exempt obligation issued by the school district and the school district shall:
Obtain a computation of the yield on such issue from the school district's financial advisor;
Create a separate Project Fund (with as many sub-funds as shall be necessary to allocate proceeds among the projects being funded by the issue) into which the proceeds of issue shall be deposited;
Review all requisitions, draw schedules, draw requests, invoices and bills requesting payment from the Project Fund;
Determine whether payment from the Project Fund is appropriate and, if so, make payment from the Project Fund (and appropriate sub-fund, if applicable);
Maintain records of the payment requests and corresponding records showing payment;
Maintain records showing the earnings on, and investment of, the Project Fund;
Ensure that all investments acquired with proceeds are purchased at fair market value;
Identify bond proceeds or applicable debt service allocations that must be invested with a yield-restriction and monitor the investments of any yield-restricted funds to ensure that the yield on such investments do not exceed the yield to which such investments are restricted;
Maintain records related to any investment contracts, credit enhancement transactions and the bidding of financial products related to the proceeds.
Timely Expenditure and Arbitrage/Rebate Compliance
The board treasurer shall review the Tax-Exemption Certificate (or equivalent) for each tax-exempt obligation issued by the school district and the expenditure records provided in Section 2 of this regulation, above and shall:
Monitor and ensure that proceeds of each such issue are spent within the temporary period set forth in such certificate;
Monitor and ensure that the proceeds are spent in accordance with one or more of the applicable exceptions to rebate as set forth in such certificate if the school district does not meet the "small issuer" exception for said obligation;
Not less than 60 days prior to a required expenditure date, confer with bond counsel and a rebate consultant, if the school district will fail to meet the applicable temporary period or rebate exception expenditure requirements of the Tax-Exemption Certificate. In the event the school district fails to meet a temporary period or rebate exception:
Procure a timely computation of any rebate liability and, if rebate is due, file a Form 8038-T and arrange for payment of such rebate liability;
Arrange for timely computation and payment of yield reduction payments (as such term is defined in the Code and Treasury Regulations), if applicable.
Proper Use of Bond Financed Assets
The board treasurer shall:
Maintain appropriate records and a list of all bond financed assets. Such records shall include the actual amount of proceeds (including investment earnings) spent on each of the bond financed assets;
Monitor and confer with bond counsel with respect to all proposed bond financed assets;
management contracts;
service agreements;
research contracts;
naming rights contracts;
leases or sub-leases;
joint venture, limited liability or partnership arrangements;
sale of property; or
any other change in use of such asset.
Maintain a copy of the proposed agreement, contract, lease or arrangement, together with the response by bond counsel with respect to said proposal for at least three years after retirement of all tax-exempt obligations issued to fund all or any portion of bond financed assets; and
Contact bond counsel and ensure timely remedial action under IRS Regulation Sections 1.141-12 in the event the school district takes an action with respect to a bond financed asset, which causes the private business tests or private loan financing test to be met.
General Project Records
For each project financed with tax-exempt obligations, the board treasurer shall maintain, until three years after retirement of the tax-exempt obligations or obligations issued to refund those obligations, the following:
Appraisals, demand surveys or feasibility studies;
Applications, approvals and other documentation of grants;
Depreciation schedules;
Contracts respecting the project.
Advance Refundings
The board treasurer shall be responsible for the following current, post issuance and record retention procedures with respect to advance refunding bonds. The board treasurer shall:
Identify and select bonds to be advance refunded with advice from internal financial personnel and a financial advisor;
Identify, with advice from the financial advisor and bond counsel, any possible federal tax compliance issues prior to structuring any advance refunding;
Review the structure with the input of the financial advisor and bond counsel, of advance refunding issues prior to the issuance to ensure;
that the proposed refunding is permitted pursuant to applicable federal tax requirements if there has been a prior refunding of the original bond issue;
that the proposed issuance complies with federal income tax requirements which might impose restrictions on the redemption date of the refunded bonds;
that the proposed issuance complies with federal income tax requirements which allow for the proceeds and replacement proceeds of an issue to be invested temporarily in higher yielding investments without causing the advance refunding bonds to become "arbitrage bonds"; and
that the proposed issuance will not result in the issuer's exploitation of the difference between tax exempt and taxable interest rates to obtain an financial advantage nor overburden the tax exempt market in a way that might be considered an abusive transaction for federal tax purposes;
Collect and review data related to arbitrage yield restriction and rebate requirements for advance refunding bonds. To ensure such compliance, the board treasurer shall engage a rebate consultant to prepare a verification report in connection with the advance refunding issuance. Said report shall ensure said requirements are satisfied;
Whenever possible, purchase State and Local Government Series (SLGS) to size each advance refunding escrow. The financial advisor shall be included in the process of subscribing SLGS. To the extent SLGS are not available for purchase, the Board treasurer shall, in consultation with bond counsel and the financial advisor, comply with IRS regulations;
Ensure, after input from bond counsel, compliance with any bidding requirements set forth by the IRS regulations to the extent as issuer elects to the purchase of a guaranteed investment contract;
In determining the issue price for any advance refunding issuance, obtain and retain issue price certification by the purchasing underwriter at closing;
After the issuance of an advance refunding issue, ensure timely identification of violations of any federal tax requirements and engage bond counsel in attempt to remediate same in accordance with IRS regulations.
Continuing Disclosure
The board treasurer shall assure compliance with each continuing disclosure certificate and annually, per continuing disclosure agreements, file audited annual financial statements and other information required by each continuing disclosure agreement. The board treasurer will monitor material events as described in each continuing disclosure agreement and assure compliance with material event disclosure. Events to be reported shall be reported promptly, but in no event not later than 10 business days after the day of the occurrence of the event. Currently, such notice shall be given in the event of:
Principal and interest payment delinquencies;
Non-payment related defaults, if material;
Unscheduled draws on debt service reserves reflecting financial difficulties;
Unscheduled draws on credit enhancements relating to the bonds reflecting financial difficulties;
Substitution of credit or liquidity providers, or their failure to perform;
Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB), or other material notices, or determinations with respect to the tax-exempt status of the bonds, or material events affecting the tax-exempt status of the bonds;
Modifications to rights of Holders of the Bonds, if material;
Bond calls (excluding sinking fund mandatory redemptions), if material and tender offers;
Defeasances of the bonds;
Release, substitution, or sale of property securing repayment of the bonds, if material;
Rating changes on the bonds;
Bankruptcy, insolvency, receivership or similar event of the Issuer;
The consummation of a merger, consolidation, or acquisition involving the Issuer or the sale of all or substantially all of the assets of the Issuer, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material; and
Appointment of a successor or additional trustee or the change of name of a trustee, if material.
---------------------------------------------------------------------------------------------------------------
Approved: 7/8/13 Reviewed: 3/11/19 Revised: 10/13/25
District funds in excess of current needs are invested in compliance with this policy. The goals of the District's investment portfolio in order of priority are:
· To provide safety of the principal funds;
· To maintain the necessary liquidity to match expected liabilities; and
· To obtain a reasonable rate of return.
In making investments, the District will exercise the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use to meet the goals of the investment program.
District funds are monies of the District, including operating funds. "Operating funds" of the District are funds which are reasonably expected to be used during a current budget year or within fifteen (15) months of receipt. When investing operating funds, the investments must mature within three hundred and ninety-seven (397) days or less. If, during the current budget year an amount of public funds will exceed operating funds by at least thirty-three percent, the amount of public funds that exceed operation funds by greater than thirty-three percent may be invested in certificates of deposit at federally insured depository institutions which mature within sixty-three months or less, in accordance with state and federal laws. When investing funds other than operating funds, the investments must mature according to the need for the funds.
The Board authorizes the Board treasurer to invest funds in excess of current needs in the following investments.
It is the responsibility of the Board treasurer to oversee the investment portfolio in compliance with this policy and the law.
If the Board requests it, it shall be the responsibility of the Board treasurer to bring a contract with an outside person to invest District funds, to advise on investments, to direct investments, to act in a fiduciary capacity or to perform other investment services to the Board for review and approval. The Board treasurer shall also provide the Board with information about and verification of the outside person's fiduciary bond. Contracts with outside persons shall include a clause requiring the outside person to notify the District within thirty (30) days of any material weakness in internal structure or regulatory orders or sanctions against the outside person regarding the services being provided to the District and to provide the documents necessary for the performance of the investment portion of the District audit. The compensation of the outside persons shall not be based upon the performance of the investment portfolio.
It is the responsibility of the Board treasurer to report to and review the investment portfolio's performance, transaction activity and current investments including the percent of the investment portfolio by type of investment and by issuer and maturities with the Board at its regular meetings. The report shall also include trend lines by month over the last year and year-to-year trend lines regarding the performance of the investment portfolio. It shall also be the responsibility of the treasurer to obtain the information necessary to ensure that the investments and the outside persons doing business with the District meet the requirements outlined in this policy.
It is the responsibility of the superintendent to deliver a copy of this policy to the District's depositories, auditor and/or other outside persons doing investment business with the school district.
It will also be the responsibility of the Superintendent, in conjunction with the Board treasurer, to develop a system of investment practices and internal controls over the investment practices. The investment practices are designed to prevent losses, to document the officers' and employees' responsibility for elements of the investment process and address the capability of the management.
---------------------------------------------------------------------------------------------------------------
|
Approved: 8/10/92 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
The Board believes gifts, grants, and bequests to the District may be accepted when they will further the interests of the District. The Board shall have sole authority to determine whether the gift furthers the interests of the District.
Gifts, grants, and bequests shall be approved by the Board. Once it has been approved by the Board, a Board member or the Superintendent may accept the gift on behalf of the District.
Gifts, grants, and bequests once accepted on behalf of the District become the property of the District. Gifts, grants, and bequests are administered in accordance with terms, if any, agreed to by the Board.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
Revenue raised by students or from student activities shall be deposited and accounted for in the student activities fund. Revenue raised by students or from student activities is the property of and shall be under the financial control of the Board. Students may use this revenue for purposes approved by the Superintendent or their designee.
Whether such revenue is collected from student contributions, club dues or special activities or result from admissions to special events or from other fund-raising activities, all funds will be under the jurisdiction of the Board and under the specific control of the Superintendent or their designee. The funds will be deposited in a designated depository and will be disbursed and accounted for in accordance with instructions issued by the Superintendent or their designee.
It shall be the responsibility of the Superintendent and/or the Board treasurer to keep student activity accounts up-to-date and complete.
Any unencumbered class or activity account balances will automatically revert to the activity fund when a class graduates or an activity is discontinued.
---------------------------------------------------------------------------------------------------------------
|
Approved: 7/8/13 |
Reviewed: |
Revised: 3/11/19; 10/13/25 |
Fundraising can foster a sense of community and pride in the school district through group efforts to accomplish a common goal. The school board believes fundraising campaigns can further the interests of the district. Care must be taken to help ensure fundraising efforts are done properly and safely to benefit the school community. The school board is responsible for approving all district affiliated and student fundraising. Any person or entity acting on behalf of the district and wishing to conduct a fundraising campaign for the benefit of the district shall begin the process by seeking prior approval from the board or its designee. Any fundraising efforts conducted using the district's resources, name, logos, symbols, or imagery will be conducted in accordance with all policies, regulations and rules for fundraising within the district.
District Affiliated Fundraising
There are times when the school board may decide to engage in district-affiliated fundraising efforts to benefit the school district. All district affiliated fundraising efforts will fulfill a public purpose and will not benefit only one single individual or family, except in unique circumstances pre-approved by the school board. The use of district owned resources to conduct fundraising efforts will be in accordance with all applicable laws and regulations and other relevant district policies and procedures.
Money or items raised by any district affiliated fundraising campaign will be the property of the district only upon acceptance by the board and will be used only in accordance with the terms for which they were given, as agreed to by the board.
Student Fundraising
Students may raise funds for school-sponsored events with the permission of the school board. The school board delegates to the Superintendent the authority to approve routine student fundraising as deemed appropriate. Collection boxes for school fund raising must have prior approval from the school board or its designee before being placed on school property. All funds generated from district-sponsored student fundraising will be placed in the district’s student activity fund. The Superintendent will develop necessary regulations to ensure the safety and equity of student fundraising efforts.
Online Fundraising
The use of the district’s name, logos, symbols, or imagery for online fundraising will be subject to the approval of the Superintendent. All online fundraising efforts will fulfill a public purpose, and will not benefit only one single individual or family except in unique circumstances pre-approved by the school board. If approved, the requestor shall be responsible for preparing all materials and information related to the online fundraising campaign and keeping district administration apprised of the status of the campaign.
All items and money generated from online fundraising are subject to the same controls and regulations as other district property and shall be deposited or inventoried accordingly. No money raised or items purchased shall be distributed to individual employees.
Approved: 5/13/85 Reviewed: 6/10/19 Revised: 2/22/10; 6/10/13; 7/14/25; 10/13/25
1. Describe the fund-raising activity.
A. What is the activity?
B. Who will be doing the activity?
C. When will it be held?
D. Where will it be held?
2. What are the specific purposes for which these funds will be used?
3. What alternative to student fund-raising was considered to meet these fund needs?
4. Amount of funds required to meet the needs listed in Item #2?
$________________________
5. How much do you plan to net from this activity?
$________________________
6. Who is the faculty sponsor of this activity? _____________________________________
7. Is this expected to be an annual activity or for one year?
Annual_______ Once_______
____________________________________ ______________ (Signature – Faculty Sponsor) Date
____________________________________ ______________ (Signature – Principal) Date
All district affiliated fundraising will be approved by the school board. Once approved, funds collected related to district affiliated fundraising will be placed in the appropriate fund in accordance with applicable laws and board policies. Prior to approval of district affiliated fundraising efforts, the board will consider:
Student Fundraising
Student fundraising can enhance a student’s educational experience, but it must not be at the expense of the safety and education of the district’s students. The following are additional regulations to assist the administration in developing procedures necessary for successful fundraising efforts:
Approved: 10/13/25 Reviewed: Revised:
The board supports economic development in Iowa. As permitted by law, purchasing preference by the school district will be given to goods and services in Iowa from a locally-owned business located within the school district or from an Iowa-based company which offers these goods or services if the cost and other considerations are relatively equal and they meet the required specifications. However, when spending federal Child Nutrition Funds, geographical preference is allowed only for unprocessed agricultural food items as part of response evaluation. Other statutory purchasing preferences will be applied as provided by law, including goals and reporting with regard to procurement from certified targeted small businesses, minority-owned businesses, and female-owned businesses.
Goods and Services
The board shall enter into goods and services contract(s) as the board deems to be in the best interest of the school district. It shall be the responsibility of the superintendent to approve purchases, except those requiring board approval as described below or as provided by in law. The superintendent may coordinate and combine purchases with other governmental bodies to take advantage of volume price breaks. Joint purchases with other political subdivisions will be considered in the purchase of equipment, accessories, or attachments with an estimated cost of $50,000 or more.
Purchases for goods and services shall conform to the following:
In the event that only one quotation or bid is submitted, the board may proceed if the quotation or bid meets the contract award specifications.
The contract award may be based on several cost considerations including, but not limited to the following:
The board may elect to exempt certain professional services contracts from the thresholds and procedures outlined above.
The thresholds and procedures related to purchases of goods and services do not apply to public improvement projects.
Public Improvement Projects
The board shall enter into public improvement contract(s) as the board deems to be in the best interest of the school district. ‘Public improvement’ means “a building or construction work which is constructed under the control of a governmental entity and for which either of the following applies: (1) has been paid for in whole or in part with funds of the governmental entity; (2) a commitment has been made prior to construction by the governmental entity to pay for the building or construction work in whole or in part with funds of the governmental entity. This includes a building or improvement constructed or operated jointly with any public or private agency.”
The district shall follow all requirements, timelines, and processes detailed in Iowa law related to public improvement projects. The thresholds regarding when competitive bidding or competitive quotations are required will be followed. Competitive bidding is required for public improvement contracts exceeding the minimum threshold stated in law. Competitive quotations are required for public improvement projects that exceed the minimum threshold amount stated in law, but do not exceed the minimum set for competitive bidding. The board shall approve competitive bids and competitive quotes. If the total cost of the public improvement does not warrant either competitive bidding or competitive quotations, the district may nevertheless proceed with either of these processes, if it so chooses.
The award of all contracts for the public improvement shall be made from the lowest responsive, responsible bidder. In the event of an emergency requiring repairs to a school district facility that exceed bidding and quotation thresholds, please refer to policy 802.03 Emergency Repairs.
The board and the superintendent shall have the right to reject any or all bids, or any part thereof, and to re-advertise. The board will enter into such contract or contracts as the board deems in the best interests of the school district. The procurement of all supplies, equipment, and services shall be initiated by the issuance of an official purchase order signed by the superintendent or by an authorized staff member. Only those supplies, equipment, and services procured by formal contract shall be exempt.
The district shall comply with all federal and state laws and regulations required for procurement, including the selection and evaluation of contractors. The superintendent or designee is responsible for developing an administrative process to implement this policy, including, but not limited to, procedures related to suspension and debarment for transactions subject to those requirements.
------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 8/12/19 |
Revised: 5/14/12; 7/8/13; 8/12/13; 2/9/15; 1/9/23; 10/13/25 |
In connection with transactions subject to federal suspension and debarment requirements, the district is prohibited from entering into transactions with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities.
When soliciting bids or otherwise preparing to enter into such a transaction, the superintendent or designee will use at least one of the following verification methods to ensure that any parties to the transaction are not suspended or debarred prior to committing to any sub-award, purchase, or contract:
Obtaining a certification of a party’s compliance with the federal suspension and debarment requirements in connection with any application, bid, or proposal;
Requiring compliance with the federal suspension and debarment requirements as an express condition of any sub-award, purchase, or contract in question; or
Prior to committing to any sub-award, purchase, or contract, check the online Federal System for Award Management at https://sam.gov/reports/awards/standard to determine whether the relevant party is subject to any suspension or debarment restrictions.
2 CFR Part 200 Subpart B-General Provisions
200.113 Mandatory Disclosures
A non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Non-Federal entities that have received a Federal award including the term and condition outlined in Appendix XII—Award Term and Condition for Recipient Integrity and Performance Matters are required to report certain civil, criminal, or administrative proceedings to SAM. Failure to make required disclosures can result in any of the remedies described in §200.338 Remedies for noncompliance, including suspension or debarment. (See also 2 CFR part 180, 31 U.S.C. 3321, and 41 U.S.C. 2313.) It is the responsibility of the Superintendent to timely report to the relevant federal or pass through agency any violations of federal criminal law involving fraud, bribery or gratuity potentially impacting a federal grant.
-----------------------------------------------------------------------------------------------------------------
Approved: 12/11/23 Reviewed: Revised: 10/13/25
In addition to the District’s standard procurement and purchasing procedures, the following procedures for vendors/contractors paid with federal funds are required. When federal, state, and local requirements conflict, the most stringent requirement will be followed.
2 CFR Part 200, Subpart D Subsection §200.318 (c)(1)
No District employee, officer, or agent may participate in the selection, award and administration of contracts supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. District officers, employees, and agents may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. However, for situations where the financial interest is not substantial or the gift is an unsolicited item of nominal value, district employees must abide by all relevant board policies. Violation of this requirement may result in disciplinary action for the District employee, officer, or agent.
2 CFR Part 200, Subpart D Subsection §200.320 (e)(1-4)
Procurement for contracts paid with federal funds may be conducted by noncompetitive (single source) proposals when one or more of the following circumstances apply: (1) the item is only available from a single source; (2) public exigency or emergency will not permit the delay resulting from competitive bids; (3) the Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or (4) after solicitation of a number of sources, competition is inadequate.
2 CFR Part 200, Subpart D Subsection §200.321
The District will take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. Affirmative steps must include: (1) placing such businesses on solicitation lists; (2) soliciting such businesses whenever they are potential sources; (3) when economically feasible, dividing contracts into smaller tasks or quantities to allow participation from such businesses; (4) establishing delivery schedules that encourage participation by such businesses; (5) when appropriate, utilizing the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and (6) requiring the primary contractor to follow steps (1) through (5) when subcontractors are used.
The district will include the following provisions in all procurement contracts or purchase orders include the following provisions when applicable:
2 CFR Part 200 Appendix II
(A) Contracts for more than the simplified acquisition threshold currently set at $150,000, which is the inflation adjusted amount determined by the Civilian Agency Acquisition Council and the Defense Acquisition Regulations Council (Councils) as authorized by 41 U.S.C. 1908, must address administrative, contractual, or legal remedies in instances where contractors violate or breach contract terms, and provide for such sanctions and penalties as appropriate.
(B) All contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity including the manner by which it will be effected and the basis for settlement.
(C) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of “federally assisted construction contract” in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246, “Equal
Employment Opportunity” (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity,” and implementing regulations at 41 CFR part 60, “Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor.”
(D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland “Anti-Kickback” Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, “Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States”). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency.
(E) Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts awarded by the non-Federal entity in excess of $100,000 that involve the employment of mechanics or laborers must include a provision for compliance with 40 U.S.C. 3702 and 3704, as supplemented by Department of Labor regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40 hours. Work in excess of the standard work week is permissible provided that the worker is compensated at a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40 hours in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide that no laborer or mechanic must be required to work in surroundings or under working conditions which are unsanitary, hazardous or dangerous. These requirements do not apply to the purchases of supplies or materials or articles ordinarily available on the open market, or contracts for transportation or transmission of intelligence.
(F) Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of “funding agreement” under 37 CFR §401.2 (a) and the recipient or subrecipient wishes to enter into a contract with a small business firm or nonprofit organization regarding the substitution of parties, assignment or performance of experimental, developmental, or research work under that “funding agreement,” the recipient or subrecipient must comply with the requirements of 37 CFR Part 401, “Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative Agreements,” and any implementing regulations issued by the awarding agency.
(G) Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387), as amended—Contracts and subgrants of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended (33 U.S.C. 1251-1387). Violations must be reported to the Federal awarding agency and the Regional Office of the Environmental Protection Agency (EPA).
(H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.
(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—Contractors that apply or bid for an award exceeding $100,000 must file the required certification. Each tier certifies to the tier above that it will not and has not used Federal appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any Federal contract, grant or any other award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with non-Federal funds that takes place in connection with obtaining any Federal award. Such disclosures are forwarded from tier to tier up to the non-Federal award.
(J) See §200.322 Procurement of recovered materials.
§200.216 Prohibition on certain telecommunications and video surveillance services or equipment
(a) The district is prohibited from obligating or expending loan or grant funds to:
Procure or obtain;
Extend or renew a contract to procure or obtain; or
Enter into a contract (or extend or renew a contract) to procure or obtain equipment, services, or systems that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. As described in Public law 115-232, section 889, covered telecommunications equipment is telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities).
i. For purpose of public safety, security of government facilities, physical security surveillance of critical
infrastructure, and other national security purposes, video surveillance and telecommunication equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).
ii. Telecommunications or video surveillance services provided by such entities or using such equipment.
iii. Telecommunications or video surveillance equipment or services produced or provided by an entity that the
Secretary of Defense, in consultation with the Director of the National Intelligence of the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned by or controlled by, or otherwise connected to, the government of a foreign country.
(b) In implementing the prohibition under Public Law 115-232, section 889, subsection (f), paragraph (l), heads of executive agencies administering loan, grant, or subsidy programs shall prioritize available funding and technical support to assist affected businesses, institutions and organizations as is reasonably necessary for those affected entities to transition from covered communications equipment and services, to procure replacement equipment and services, and to ensure that communications service to users and customers is sustained.
(c) See Public Law 115-232, section 889 for additional information.
(d) See also §200.471.
-----------------------------------------------------------------------------------------------------------------
Employees may use school district credit cards and/or procurement cards (p-cards) for the actual and necessary expenses incurred in the performance of work-related duties. Actual and necessary expenses incurred in the performance of work-related duties include, but are not limited to travel expenses related to professional development or fulfillment of required job duties, fuel for school district transportation vehicles used for transporting students to and from school and for school-sponsored events, payment of claims related to professional development of the board and employees, and other expenses required by employees and the board in the performance of their duties.
Employees and officers using a school district credit or procurement card must submit a detailed, itemized receipt in addition to a credit or procurement card receipt indicating the date, purpose and nature of the expense for each claim item. Failure to provide a proper receipt will make the employee responsible for expenses incurred. Those expenses are reimbursed to the school district no later than ten working days following use of the school district's credit or procurement card. In exceptional circumstances, the superintendent or board may allow a claim without proper receipt. Written documentation explaining the exceptional circumstances is maintained as part of the school district's record of the claim.
The school district may maintain a school district credit or procurement card for actual and necessary expenses incurred by employees and officers in the performance of their duties. The superintendent may maintain a school district credit or procurement card for actual and necessary expenses incurred in the performance of the superintendent's duties. The transportation director may maintain a school district credit or procurement card for fueling school district transportation vehicles in accordance with board policy.
It is the responsibility of the Superintendent to determine whether the school district credit or procurement card use is for appropriate school business. It is the responsibility of the board to determine through the audit and approval process of the board whether the school district credit or procurement card used by the superintendent and the board is for appropriate school business.
The Superintendent is responsible for developing administrative regulations regarding actual and necessary expenses and use of a school district credit or procurement card. The administrative regulations will include the appropriate forms to be filed for obtaining a credit or procurement card.
Approved: 10/13/25 Reviewed: Revised:
The Board authorizes the issuance of payment of claims against the District for goods and services. The Board will allow the payment after the goods and services have been received and accepted in compliance with Board policy.
Claims for payment of freight, athletic officials, express, postage, printing, water, lights, telephone, rents, and payment of salaries pursuant to the terms of a written contract may be paid by the Board secretary and/or treasurer prior to formal audit and approval by the Board. In addition, the secretary, upon approval of the Superintendent or his designee, may issue warrants for approved registrations, claims offering a discount for early payment, approved travel expenses, approved goods and services delivered C.O.D., and other verified bills filed with the secretary when the Board is not in session prior to payment of these claims and prior to audit and approval by the Board. The Board secretary and/or treasurer shall examine the claims and verify bills.
The secretary will determine to the secretary's satisfaction that the claims presented to the Board are in order and are legitimate expenses of the District. It is the responsibility of the secretary to bring claims to the board.!Thereafter, paid claims shall be entered on record in the regular minutes of board meeting by the board secretary.
The Board president and Board secretary and/or treasurer may sign warrants by use of a signature plate or rubber stamp. If the Board president is unavailable to personally sign warrants, the vice president may sign warrants on behalf of the president.
---------------------------------------------------------------------------------------------------------------
Approved: 11/14/67 Reviewed: 3/11/19 Revised: 5/14/12; 7/8/13; 11/18/19; 10/13/25
The Board acknowledges that expenditures and use of District resources may be needed to support the decision-making process in conducting district business, promote more efficient time frames for conducting business, promulgate a productive working climate, improve personnel well-being and morale, and nurture a positive learning environment. To serve these purposes, the Board supports appropriate expenditures and use of District resources for attainment of the District mission and strategic goals for official District activities and business.
The board recognizes that school district funds are public funds, and as such, should be used to further a public purpose and the overall educational mission of the school community. The district is committed to managing and spending public funds in a transparent and responsible manner. Prior to making a purchase with public funds, an individual should be comfortable defending the purchase/reimbursement to the taxpayers in the district. If the individual is uncomfortable doing so, the purchase may not fulfill a public purpose and additional guidance should be sought before the purchase is made.
Individuals who have concerns about the public purpose of a purchase or reimbursement should utilize the district’s Internal Controls policy and regulation as a resource for questioning a purchase. Concerns should be reported to the superintendent and/or the board president.
The Superintendent shall develop a process for approving expenditures of public funds. The board will review expenditures and applicable reports as necessary to ensure proper oversight of the use of public funds. To the extent possible, expenditures shall be pre-approved by the district prior to expending the funds. Purchases of food and refreshment for district staff, even within district, should comply with the district’s Employee Travel Compensation policy, and all other applicable policies. All purchases/reimbursements shall comply with applicable laws, board policies and district accounting requirements.
Additional guidance regarding appropriate expenditures of school funds is provided in the regulation accompanying this policy.
------------------------------------------------------------------------------------------------------------------------------
|
Approved: 12/8/14 |
Reviewed: 3/11/19 |
Revised: 10/13/25 |
The following is a list of examples organized by activity for what is allowable, or not allowable as a purchase/reimbursement using public funds. This regulation is intended as guidance and there may be situations that are not listed here. Any questions regarding the appropriateness of an expenditure should be submitted to administration prior to expending funds.
Reimbursements to an Individual
Use of Credit/Procurement Card: All purchases through a district-owned credit or procurement card shall be pre-approved and comply with the district’s policy 705.02 – Credit and Procurement Cards.
Mileage: Individuals who are required to travel (other than to and from work) as part of fulfilling their job duties to the district shall be reimbursed for mileage costs in accordance with the requirements stated in the district’s Employee Travel Compensation policy.
Travel accommodations: Employees who are required to travel and stay overnight as part of fulfilling their job duties to the district shall be reimbursed for costs in accordance with the requirements stated in the district’s Employee Travel Compensation policy.
Alcohol: Alcohol is a personal expense and is never allowable for purchase or reimbursement using public funds.
Food/Refreshments: Food and refreshments are typically a personal expense. Meetings spanning meal times should be avoided when possible. When a district meeting is required to take place spanning a customary meal time, the superintendent or designee shall determine whether food and/or refreshment will be provided to employees whose presence is required during the meeting. The cost of food and refreshment for employees shall be reasonable, and when possible, a separate itemized receipt for each employee is required. If an itemized receipt is not available, approval is required by the school business official prior to reimbursement. In all cases, the names and number of employees shall be noted on the receipt.
Apparel/Personal Items: Apparel and personal items including, but not limited to items such as t-shirts, hats, mugs, etc. provide personal benefit to individuals and are a personal expense. These items shall not be purchased or reimbursed with public funds.
Gifts: Gifts given to individuals are personal expenses and public funds should not be used (except for recognition/staff retirement, listed below) for these purposes. Voluntary collections from staff would be an acceptable way of purchasing gifts.
Retirement and Recognition Gifts: Recognizing an employee or volunteer’s years of dedication to educating the community and commitment to the district serves a public purpose by honoring individuals with a token gift, or honorarium, in recognition of their service. The same is true for individual awards, mementos, or items purchased in recognition of employee service to the district. These purchases may use public funds, provided the expenditures are modest and approved by the superintendent.
Honoraria: District employees may at times receive an honorarium from an outside source as compensation for the employee’s time devoted to preparing and delivering a presentation within the scope of their professional field. Honorariums may only be accepted by employees when the employee has used their personal time outside of their work for the district to prepare and deliver the presentation. If the employee uses district time or resources to prepare or deliver a presentation, any honorarium shall be given to the district.
Break Room Supplies: The purchase of perishable or disposable supplies for employee break rooms is primarily designed for individual consumption and is a personal expense. This includes items such as coffee, coffee filters, plates, cups, spoons, napkins, etc.
Supplies for Public Areas
Limited refreshments such as water and coffee may be available in public reception areas of the district including, but not limited to the central office, the building administrator’s office, etc. These refreshments may be purchased with the use of public funds, as they provide light refreshment to members of the community.
Staff Parties/Receptions
Parties and receptions to benefit individual staff members are considered a personal expense and should not be purchased or reimbursed with public funds. This includes but is not limited to holiday parties.
Hosting a group reception to honor all employees retiring from the district in a given school year is allowable as a public expense. Hosting a retirement reception provides a direct benefit to the community as an opportunity for the community to attend and honor the retiring employees’ years of dedication and service to the district.
School/ Student Activity Banquets
School/student activity banquets are typically a personal expense and will not be purchased or reimbursed with public funds unless the public purpose is submitted for review and pre-approved by the superintendent.
Memorial Gifts
Memorial flowers to convey sympathy or congratulations are allowable as a public expense if they have been approved by the superintendent. Memorial cards are always appropriate.
Memorial gifts of any sort other than flowers and a card are a personal expense.
Student Incentives
It is within the discretion of the building principal to authorize the purchase of awards holding a nominal value to commemorate the achievements of a student or group of students. These awards should be designed to reward behavior and values that exemplify the educational and community mission of the district. Awards should not be gift cards or other monetary awards.
Flowers and decorations for school dances held as part of the district’s student activity program are an allowable expense paid out of the student activity fund, provided the purchases are approved by the building principal.
Meetings
To the extent possible, meetings which span normal meal times should be avoided.
Meetings of the district’s board of directors and board committees are made up of individuals who volunteer a large amount of their personal time to serve the needs of the school community. These meetings are also scheduled at time most convenient for the public, and often span normal meal hours. Food and refreshment purchased for board members is an acceptable use of public funds. The service of these unpaid volunteers directly benefits the entire school community. The superintendent has discretion to purchase/reimburse reasonable expenses for providing food and refreshment to these unpaid volunteers during these meetings.
Some expenditures will be considered personal expenses regardless of the context. These include purchase or reimbursement of alcohol, and personal items not included as retirement or memorial gifts listed above.
-----------------------------------------------------------------------------------------------------------------
The district provides leaves of absences to allow employees to be absent from work to attend to important matters outside of the workplace. As public employers, school districts are expected to record and monitor the work that employees perform and to conform to principles of public accountability in their compensation practices.
Consistent with principles of public accountability, it is the policy of the district that, when an employee is absent from work for less than one work day and the employee does not use accrued leave for such absence, the employee’s pay will be reduced or the employee will be placed on leave without pay if:
In each case in which an employee is absent from work for part of a work day, a deduction from compensation will be made or the employee will be placed on leave without pay for a period of time which is equal to the employee’s absence from the employee’s regularly scheduled hours of work on that day.
Approved: 10/13/25 Reviewed: Revised:
The district complies with all applicable laws with respect to payment of wages and benefits to employees including laws such as the federal Fair Labor Standards Act and the Iowa Wage Payment Collection Act. The district will not make pay deductions that violate either the federal or state laws.
Any employee who believes that the district has made an inappropriate deduction or has failed to make proper payment regarding wages or benefits is encouraged to immediately consult with the appropriate supervisor. Alternatively, any employee may file a formal written complaint with the Business Manager. Within 15 business days of receiving the complaint, the Business Manager will make a determination as to whether the pay deductions were appropriate and provide the employee with a written response that may include reimbursement for any pay deductions that were not appropriately made.
This complaint procedure is available in addition to any other complaint process that also may be available to employees.
Approved: 10/13/25 Reviewed: Revised:
The district recognizes the importance and value of fulfilling timely reporting requirements. Regularly providing updated financial information assists the board in making informed decisions for the future financial health of the district.
At the annual meeting, the treasurer will give the annual report stating the amount held over, received, paid out, and on hand in the general and all other funds. This report is in written form and sent to the board with the agenda for the board meeting. The treasurer will also furnish the board with a statement from each depository showing the balance then on deposit. It is the responsibility of the treasurer to submit this report to the board annually.
The Board secretary and/or treasurer shall report to the Board each month the receipts, disbursements, and balances of the various funds. This report shall be in written form and sent to the Board with the agenda for the Board meeting.
Each month the schedule of bills allowed by the Board is published in a newspaper designated as a newspaper for official publication. Annually, the total salaries paid to employees regularly employed by the District will also be published in a newspaper designated as a newspaper for official publication.
It is the responsibility of the Board secretary and/or treasurer to publish these reports in a timely manner.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
In accordance with state law, to review the funds and accounts of the District, the Board shall employ an independent auditor, certified in the state of Iowa, to perform an annual audit of the financial affairs of the District. The Superintendent or their designee shall use a request for proposal procedure in selecting an auditor. The administration will cooperate with the auditors. Such annual audit reports will be filed with the State Auditor and shall remain on permanent file in the central office of the District.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
The board expects all board members, employees, volunteers, consultants, vendors, contractors, students and other parties maintaining any relationship with the school district to act with integrity, due diligence, and in accordance with all laws in their duties involving the school district’s resources. The board is entrusted with public dollars and no one connected with the school district should do anything to erode that trust.
Internal controls are used to help ensure the integrity of district financial and accounting information. Adherence to district-established internal control procedures is the responsibility of all employees of the school district. The superintendent, business manager and board secretary shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the school district subject to review and approval by the board. Administrators shall be alert for any indication of fraud, financial impropriety, or irregularity within the administrator’s area of responsibility.
Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor and the superintendent. The superintendent or the board president shall have primary responsibility for any necessary investigations and shall coordinate investigative efforts with the board’s legal counsel, auditing firm, the Auditor of State's office and other internal or external departments and agencies, including law enforcement officials, as the superintendent or the board president may deem appropriate.
Employees bringing forth a legitimate concern about a potential impropriety will not be retaliated against and those who do retaliate against such an employee will be subject to disciplinary action up to, and including, discharge.
In the event the concern or complaint involves the superintendent, the concern shall be brought to the attention of the board president or vice-president, who shall be empowered to contact the board’s legal counsel, Auditor of State's office, insurance agent, auditing firm, and any other agency to investigate the concern or complaint.
The superintendent or board president shall ensure the Auditor of State’s office is notified as required by law of any suspected embezzlement, theft or other financial irregularity pursuant to Iowa law. The superintendent and/or board president in coordination with the Auditor of State’s office, will determine whether to conduct a complete or partial audit. The superintendent is authorized to order a complete forensic audit if, in the superintendent’s judgment, such an audit would be useful and beneficial to the school district. In the event there is an investigation, records will be maintained for use in the investigation. Individuals found to have altered or destroyed records will be subject to disciplinary action, up to and including termination.
________________________________________________________________
Approved: 12/11/23 Reviewed: Revised: 10/13/25
Fraud, financial improprieties, or fiscal irregularities include, but are not limited to:
The Superintendent or board president shall notify the State Auditor's office of any suspected fraud, embezzlement or financial irregularities as required by law. The district will comply with all investigation procedures and scope as directed by the State Auditor's office. All employees involved in the investigation shall be advised to keep information about the investigation confidential. The Superintendent or board president may engage qualified independent auditors to assist in the investigation.
If an investigation substantiates the occurrence of a fraudulent activity, the Superintendent or the board president, or board vice-president if the investigation centers on the Superintendent, shall issue a report to the board and appropriate personnel. The results of the investigation shall not be disclosed to or discussed with anyone other than those individuals with a legitimate right to know until the results are made public.
-----------------------------------------------------------------------------------------------------------------
School district records are housed in the central administration office of the District. It is the responsibility of the superintendent and board secretary to oversee the maintenance and accuracy of the records. The following records are kept and preserved according to the schedule below:
|
Secretary's financial records |
Permanently |
|
Treasurer's financial records |
Permanently |
|
Open meeting minutes of the Board of Directors |
Permanently |
|
Annual audit reports |
Permanently |
|
Annual budget |
Permanently |
|
Permanent record of individual pupil |
Permanently |
|
School election results |
Permanently |
| Real property records (e.g., deeds, abstracts) |
Permanently |
|
Records of payment of judgments against the school district |
20 years |
|
Bonds and bond coupons |
11 years after maturity, cancellation, transfer, redemption, and/or replacement |
|
Written contracts |
11 years |
|
Cancelled warrants, check stubs, bank statements, bills, invoices, and related records |
5 years |
|
Recordings and minutes of closed meetings except if matters are in litigation |
1 year |
|
Program grants |
As determined by the grant |
|
Nonpayroll personnel records |
7 years after leaving the district |
|
Payroll personnel records |
3 years after leaving the district |
|
Employment applications |
2 years |
|
School meal program accounts/records |
3 years after submission of the final claim for reimbursement |
|
Payroll records |
3 years |
In the event that any federal or state agency requires a record be retained for a period longer than that listed above for audit purposes or otherwise, the record shall be retained beyond the listed period as long as is required for the resolution of the issue by the federal or state agency.
Employees' records shall be housed in the central administration office of the school district. Employee records shall be maintained by the Superintendent, the building administrator, the employee's immediate supervisor, and the Board secretary.
An inventory of the furniture, equipment, and other non-consumable items other than real property of the school district shall be conducted annually under the supervision of the Superintendent. This report shall be filed with the Board secretary.
The permanent and cumulative records of students currently enrolled in the District shall be housed in the administration office of the attendance center where the student attends. Permanent records must be housed in a fireproof safe or vault or electronically with a secure backup. The building administrator shall be responsible for keeping these records current. Records of students who have graduated or are no longer enrolled in the school district shall be housed in the High School administration office. These records will be maintained by the high school principal. Special education records shall be maintained in accordance with the law.
The Superintendent or designee may digitize or otherwise electronically store and/or back-up or use any other reliable mass storage method to preserve school district records and may destroy paper copies of the records. An electronic record which accurately reflects the information set forth in the paper record after it was first generated in its final form as an electronic record, and which remains accessible for later reference meets the same legal requirements for retention as the original paper record.
---------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: |
Revised: 5/14/12; 7/8/13; 3/11/19; 12/11/23; 10/13/25 |
The Board will maintain a comprehensive insurance program to provide adequate coverage against major types of risk, loss, or damage, as well as legal liability. The Board will purchase insurance at replacement values, when possible, after reviewing the costs and availability of such insurance. The comprehensive insurance program is reviewed once every three years. Insurance will only be purchased through legally licensed Iowa insurance agents.
The District will assume the risk of property damage, legal liability, and dishonesty in cases in which the exposure is so small or dispersed that a loss does not significantly affect the operation of the education program or financial condition of the District.
Administration of the insurance program, making recommendations for additional insurance coverage, placing the insurance coverage and loss prevention activities is the responsibility of the Superintendent. The Director of Business is responsible for maintaining the fixed assets management system, processing claims and maintaining loss records.
---------------------------------------------------------------------------------------------------------------
|
Approved: 1/9/68 |
Reviewed: 3/11/19 |
Revised: 5/14/12; 7/8/13; 10/13/25 |
The District will operate a school nutrition program in each attendance center. The school nutrition program services will include meals through participation in the National School Lunch Program and supplementary foods for students during the school day. Students may participate in the school lunch program or may bring their lunches from home and purchase milk and other incidental items at the school.
School nutrition program facilities are provided to serve students and employees when school is in session and during school-related activities. They may also be used under the supervision of the Food Service Director or designee for food service to employee groups, parent-teacher meetings, civic organizations meeting for the purpose of better understanding the schools, and senior citizens in accordance with Board policy.
The school nutrition program is operated on a non-profit basis. The revenues of the school nutrition program will be used only for paying the regular operating costs or improvements of the school nutrition program. Supplies of the school nutrition program will only be used for the school nutrition program.
The Board will set, and annually review, the prices for school nutrition programs. It is the responsibility of the superintendent to make a recommendation regarding the prices of school nutrition programs, in accordance with federal and state law.
It is the responsibility of the Food Service Director to administer the program and to cooperate with the Superintendent and appropriate personnel for the proper functioning of the school food program.
The district shall comply with all federal and state laws and regulations required for procurement, including the selection and evaluation of contractors. The Superintendent or designee is responsible for developing an adminsitrative process to implement this policy, including, but not limited to, procedures related to suspension and debarment for transactions subject to those requirements and prohibitions on purchasing food products misbranded as meat or egg products, or cultivated-protein food products in accordance with applicable laws.
---------------------------------------------------------------------------------------------------------------
|
Approved: 5/8/89 |
Reviewed: 11/11/02 |
Revised: 9/17/07; 6/10/13; 2/11/19; 10/13/25 |
Nondiscrimination Statement
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights, regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating inor administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.
Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the State or local Agency that administers the program or contact USDA through the Telecommunications Relay Service at 711(voice and TTY). Additionally, program information may be made available in languages other than English.
To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992.
Submit your completed form or letter to USDA by:
USDA is an equal opportunity provider, employer, and lender.
Iowa Nondiscrimination Statement
It is the policy of this CNP provider not to discriminate on the basis of race, creed, color, sex, sexual orientation, national origin, disability, age, or religion in its programs, activities, or employment practices as required by the Iowa Code section 216.6, 216.7, and 216.9. If you have questions or grievances related to compliance with this policy by this CNP Provider, please contact the Iowa Civil Rights Commission, 6200 Park Avenue, Des Moines, IA 50321-1270; phone number 515-281-4121 or 800-457-4416; website: https://icrc.iowa.gov/.
Approved: 10/13/25 Reviewed: Revised:
Complaint Contact Information:
Name: _________________________________________________________
Street Address, City, State, Zip: ___________________________________________
County: ___________________________ Area Code/Phone: ___________________
Email Address:_________________________________________________
Complaint Information:
Specific name and location of the entity and individual delivering the service or benefit:
Describe the incident or action of the alleged discrimination or give an example of the situation that has a discriminatory effect on the public, potential program participants, or current participants:
On what basis does the complainant feel discrimination exists (race, color, national origin, sex, age, disability, creed, sexual orientation, religion, political party affiliation, actual/potential parental/family/marital status)?
List the names, titles, and business addresses of persons who may have knowledge of the alleged discriminatory action:
List the date(s) during which the alleged discriminatory actions occurred, or if continuing, the duration of such actions:
Date complaint received: _______________________________
Person receiving complaint: ________________________________________
Action(s) taken:
USDA is the cognizant agency for the Child Nutrition Programs listed and therefore is the first contact for the six protected classes of race, color, national origin, sex, age, and disability for complaints received within 180 days. Civil rights complaints must be submitted to the USDA Office of Civil Rights within five calendar days of receipt and no later than 180 days of the discriminatory act. The link for submission of a complaint is: program.intake@usda.gov.
In Iowa, protected classes also include sexual orientation, religion or creed and complaints can be filed up to 300days of occurrence. The address for Iowa complaints is: Iowa Civil Rights Commission, 6200 Park Avenue, Des Moines, IA 50321-1270; phone number 515-281-4121, 800-457-4416; website: https://icrc.iowa.gov/.
This institution is an equal opportunity provider. 12/2021
Approved: 10/13/25 Reviewed: Revised:
USDA Child Nutrition Programs in Iowa
Procedures for Handling a Civil Rights Complaint
Civil rights complaints related to the National School Lunch Program, School Breakfast Program, Afterschool Care Snack Program, Summer Food Service Program, Seamless Summer Option, or Child and Adult Care Food Program are written or verbal allegations of discrimination based on USDA protected classes of race, color, national origin, sex, age, and disability.
Any person claiming discrimination has a right to file a complaint within 180 days of the alleged discrimination. See below for additional Iowa Civil Rights information. A civil rights complaint based on the protected classes listed in #1 above must be forwarded to the address on the nondiscrimination statement.
All complaints, whether written or verbal, must be accepted by the School Food Authority (SFA)/Sponsor/Organization and forwarded to USDA at the address or link on the nondiscrimination statement within 5 calendar days of receipt. An anonymous complaint should be handled the same way as any other. Complaint forms may be developed, but their use cannot be required. If the complainant makes the allegations verbally or in a telephone conversation and is reluctant or refuses to put them in writing, the person who handles the complaint must document the description of the complaint.
There must be enough information to identify the agency or individual toward which the complaint is directed and indicate the possibility of a violation. Every effort should be made to obtain at least the following information:
5. The date(s) when the alleged discriminatory action(s) occurred or, if continuing, the duration of such action(s).USDA is the cognizant agency for the Child Nutrition Programs listed and therefore is the first contact for the six protected classes listed in #1 above, for complaints received within 180 days. Civil rights complaints must be submitted to the USDA Office of Civil Rights within five calendar days of receipt and no later than 180 days of the discriminatory act. The link for submission of a complaint is: program.intake@usda.gov
6. In Iowa, protected classes also include sexual orientation, religion or creed and complaints can be filed up to 300 days of occurrence. The address for Iowa complaints is: Iowa Civil Rights Commission, 6200 Park Avenue, Suite 100, Des Moines, IA 50321-1270; phone number 515-281-4121, 800-457-4416; website: https://icrc.iowa.gov/.
Bureau of Nutrition and Health, IDOE, 12/2021
Approved: 10/13/25 Reviewed: Revised:
Students enrolled and attending school in the District, who are unable to afford the cost or a portion of the cost of the school lunch and/or breakfast are encouraged to apply for free or reduced school fees and school nutrition programs.
Students enrolled and attending school in the school district who meet USDA eligiblity guidelines will be provided the school nutrition program services at no cost or a reduced price. The school district shall make reasonable efforts to prevent the overt identification of students who are eligible for free and reduced price meals. Students who participate in free or reduced price meal programs will not be distinguished in any way from students who pay the regular price; great care shall be taken to protect the anonymity of these students. Their names will not be made known to any person except such staff member or members as needed to make the special arrangements for them.
The district shall at least twice annually notify all families of the availability, eligibility criteria, and application procedures for free or reduced price meals in accordance with state and federal law.
It is the responsibility of the Food Service or Business Director to determine if a student qualifies for free or reduced cost nutritional programs, in accordance with state and federal law. Students, whom the principal believes are improperly nourished, will not be denied the school nutritional program services simply because the paperwork has not been completed. If school personnel have knowledgew of a student who is in need or free or reduced-price meals, school personnel shall contact the Food Services Director or Building Administrator.
Employees, students, and others will be required to pay for meals consumed.
If a student owes moneuy for five or more meals, the Food Services Director may contact the student's parent or guardian to provide information regarding the application for free or reduced price meals. The school is encourage to provide reimbursable meals to students who request reimbursable meals unless the students' parent or guardian has specifically provided written direction to the school to withhold a meal from the student.
---------------------------------------------------------------------------------------------------------------
|
Approved: 10/16/72 |
Reviewed: 11/11/02 |
Revised: 9/17/07; 6/10/13; 2/11/19; 10/13/25 |
Food served or purchased by students during the school day and food served or purchased for other than special circumstances is approved by the Superintendent or designee. Vending machines in the school building are the responsibility of the building principal. Purchases from the vending machines will reflect the guidelines in Wellness Policy 507.09.
It is the responsiblity of the Superintendent and other appointed appropriate personnel designated to develop administrative regulations for the use of vending machines and other sales of food to students.
________________________________________________________________________________________________
Approved: 10/13/25 Reviewed: Revised:
In accordance with state and federal law, the Spirit Lake Community School adopts the following policy to ensure school district employees, families, and students have a shared understanding of expectations regarding meal charges. The policy seeks to allow students to receive the nutrition they need to stay focused during the school day, prevent the overt identification of students with insufficient funds to pay for school meals, and maintain the financial integrity of the nonprofit school nutrition program.
Payment of Meals
Students have use of a meal account. When an account reaches -$50.00, the school district has the option to deny students the ability to charge anything until the negative account balance is paid and additional funds are deposited into the account. In addition, when an account has ANY negative balance, students WILL NOT be allowed to charge seconds, extra milks or a la carte items to their account. These items will need to be paid in cash until the account has a positive balance. (Families may add money to student accounts via electronic payment through Infinite Campus or send payments to the school offices.)
Students who qualify for free meals shall never be denied a reimbursable meal, even if they have accrued a negative balance from previous purchases. Students with outstanding meal charge debt shall be allowed to purchase a meal if the student pays for the meal when it is received. The school district may provide an alternate meal that meets federal and state requirements to students who have charged the maximum allowance to the student account and cannot pay out of pocket for a meal. The district may charge $1.50 for the alternate meal.
Employees may use a charge account for meals, but may charge no more than $20.00 to this account. When an account reaches this limit, an employee shall not be allowed to charge further meals or a la carte items until the negative account balance is paid.
Negative Account Balances
The school district will make reasonable efforts to notify families when meal account balances are low. Additionally, the school district will make reasonable efforts to collect unpaid meal charges classified as delinquent debt. The school district will coordinate communications with families to resolve the matter of unpaid charges. Families will be notified of an outstanding negative balance once the negative balance reaches -$1.00. Families will be notified by an automated email every day when the balance reaches $20. Negative balances of more than $50 will be turned over to the principals or designee for collection. Options may include: collection agencies, small claims court, or any other legal method permitted by law.
Unpaid Student Meals Account
The district will establish an unpaid student meals account in the school nutrition fund. Funds from private sources and funds from the district flexibility account may be deposited into the unpaid school meals account in accordance with the law. Funds deposited into this account shall be used only to pay individual student meal debt.
Communication of the Policy
The policy and supporting information regarding meal charges shall be provided in writing to:
· All households at or before the start of each school year;
· Students and families who transfer into the district, at time of transfer; and
· All staff responsible for enforcing any aspect of the policy.
Records of how and when the policy and supporting information was communicated to households and staff will be retained. The Superintendent or designee may develop an administrative process to implement this policy.
---------------------------------------------------------------------------------------------------------------------
Approved: 6/12/17 Reviewed: 11/13/2017; 2/11/19 Revised: 11/13/17; 10/13/25
Elementary and middle school students living more than two (2) miles from their designated school attendance centers and high school students living more than three (3) miles from their designated attendance centers are entitled to transportation to and from their attendance center at the expense of the District.
Transportation of students who require special education services will generally be provided as for other students, when appropriate. Specialized transportation of a student to and from a special education instructional service is a function of that service and, therefore, an appropriate expenditure of special education instructional funds generated through the weighting plan or IDEA federal funds designated for special education purposes.
Transportation of a student to and from a special education support service is a function of that service, and shall be specified in the individualized education program (IEP) or the individualized family service plan (IFSP). When the IEP or IFSP team determines that unique transportation arrangements are required and the arrangements are specified in the IEP or IFSP, the District will provide one or more of the following transportation arrangements for instructional services and the AEA for support services:
· Transportation from the student's residence to the location of the special education and back to the student's residence, or child care placement for students below the age of six.
· Special assistance or adaptations in getting the student to and from and on and off the vehicle, en route to and from the special education.
· Reimbursement of the actual costs of transportation when by mutual agreement the parents provide transportation for the student to and from the special education.
The District is not required to provide reimbursement to parents who elect to provide transportation in lieu of agency-provided transportation.
A student may be required, at the Board's discretion, to meet a school vehicle without reimbursement up to three-fourths (3/4) of a mile. The Board may require the parent to transport their children up to two (2) miles to connect with school bus vehicles at the expense of the District when conditions deem it advisable. It is within the discretion of the Board to determine such conditions.
Parents of students who live where transportation by bus is impracticable or unavailable may be required to furnish transportation to and from the designated attendance center at the expense of the District. Parents, who transport their children at the expense of the school district, are reimbursed at the rate per mile established by the state.
Transportation arrangements made by agreement with a neighboring District will follow the terms of the agreement. Students, who choose to attend a school in a District other than their resident school district, will provide transportation to and from the school at their own expense.
---------------------------------------------------------------------------------------------------------------
|
Approved: 9/17/72 |
Reviewed: 2/11/19 |
Revised: 9/17/07; 6/10/13; 10/13/25 |
Students utilizing school transportation shall conduct themselves in an orderly manner fitting to their age level and maturity with mutual respect and consideration for the rights of the bus driver and the passengers. Students who fail to behave in an orderly manner will be subject to disciplinary measures.
The school vehicle driver shall have the authority to maintain order on the school vehicle. It shall be the responsibility of the driver to report misconduct to the building administrator. Infractions will result in disciplinary actions taken by the transportation department and/or administration, dependent upon the severity and frequency of the infractions within one calendar year, up to and including the suspension of transportation privileges for up to one year.
The board supports the use of recording devices on school buses used for transportation to and from school, as well as for field trips, curricular or extracurricular events. The recording devices will be used to monitor student behavior and may be used as evidence in a student disciplinary proceeding. The school district will review videotapes when necessary as a result of an incident reported by a bus driver, student/parent and/or employee. Viewing of videotapes is limited to the individuals having a legitimate purpose.
The recordings are student records subject to school district confidentiality, board policy and administrative regulations. It is the responsibility of the superintendent, in conjunction with the building principal and transportation director, to develop administrative regulations regarding student conduct and discipline when utilizing school district transportation.
--------------------------------------------------------------------------------------------------------------
|
Approved: 5/13/13 |
Reviewed: |
Revised: 6/10/19; 10/13/25 |
All persons riding in school district vehicles will adhere to the rules below. The driver, sponsor or chaperones are to follow the school bus discipline procedure for student violations of this policy. Recording devices may be in operation on the school buses.
Bus riders will be at the designated loading point before the bus arrival time.
Bus riders will wait until the bus comes to a complete stop before attempting to enter.
Riders must not extend arms or heads out of the windows at any time.
Aisles must be kept cleared at all times.
All bus riders will load and unload through the right front door. The emergency door is for emergencies only.
A bus rider will depart from the bus at the designated point unless prior permission to get off at a different location is given to the driver.
A rider may be assigned a seat by the driver.
Riders who damage seats or other equipment will reimburse the district for the cost of the repair or replacement.
Riders are not permitted to leave their seats while the vehicle is in motion.
Waste containers are provided on all buses for bus riders' use.
Classroom conduct is to be observed by students.
The driver is in charge of the students and the vehicle.
A bus rider who must cross the roadway to board or depart from the bus will pass in front of the bus (no closer than 10 feet), look in both directions and proceed to cross the road or highway only on signal from the driver.
Students will not throw objects about the vehicle nor out through the windows.
Roughhousing (touching, pushing, wrestling, fighting) in the vehicle is prohibited.
Students will refrain from pushing.
The use or possession of alcohol, tobacco or look-alike substances is prohibited in the vehicle.
-----------------------------------------------------------------------------------------------------------------
Approved: 10/13/25 Reviewed: Revised
The Board in its discretion may provide District transportation for extracurricular activities including, but not limited to, transporting student participants and other students to and from extracurricular events.
Students participating in or attending extracurricular events, other than those held at District facilities, may be transported to the extracurricular event by District transportation vehicles or by another means approved by the Superintendent.
Students, who are provided transportation in District transportation vehicles for extracurricular events, will ride both to and from the event in the school vehicle unless arrangements have been made with the supervising staff member or building principal prior to the event. A student's parent may personally appear and request to transport the student home from a school-sponsored event in which the student traveled to the event on a District transportation vehicle.
It is the responsibility of the Superintendent to make a recommendation to the Board as to whether the District will provide the transportation authorized in this policy. In making the recommendation to the Board, the Superintendent will consider the financial condition of the District, the number of students who would qualify for such transportation, and other factors the Board or Superintendent deem relevant.
--------------------------------------------------------------------------------------------------------------
|
Approved: 3/10/87 |
Reviewed: |
Revised: 9/17/07; 6/10/13; 2/11/19; 10/13/25 |
Transportation to and from the student's attendance center for summer school instructional programs is within the discretion of the Board. It is the responsibility of the superintendent to make a recommendation regarding transportation of students in summer school instructional programs at the expense of the District. In making the recommendation to the Board, the superintendent will consider the financial condition of the District, the number of students involved in summer school programs, and other factors deemed relevant by the Board or the superintendent.
The District may use school vehicles for transportation to and from summer extracurricular activities. The superintendent will make a recommendation to the Board regarding their use.
--------------------------------------------------------------------------------------------------------------
|
Approved: 11/14/67 |
Reviewed: |
Revised: 9/17/07; 6/10/13; 2/11/19; 10/13/25 |
The Board has sole discretion to determine the method to be utilized for transporting non-resident and nonpublic school students. Nonresident students paying tuition may be, and nonresident students attending a nonpublic school accredited by the Iowa Department of Education will be, transported on an established public school vehicle route as long as such transportation does not interfere with resident public students' transportation. Nonresident and nonpublic school students will obtain the permission of the superintendent or designee prior to being transported by the District.
Parents of resident students who provide transportation for their children attending a non-public school accredited by the Iowa Department of Education will be reimbursed at the established state rate. This reimbursement is paid only if the District receives the funds from the state. If less than the amount of funds necessary to fully reimburse parents of the non-public students is received by the school district, the funds will be prorated.
Continued transportation of non-resident students on a public school vehicle route will be subject to resident public school students' transportation needs. The superintendent will make a recommendation to the Board regarding the method to be used. In making a recommendation to the Board, the superintendent will consider the number of students to be transported, the capacity of the school vehicles, the financial condition of the District and other factors deemed relevant by the Board or the superintendent.
Non-resident students are subject to the same conduct regulations as resident public students as prescribed by Board policy, and to other policies, rules, or regulations developed by the District regarding transportation of students by the District.
--------------------------------------------------------------------------------------------------------------
|
Approved: 5/8/89 |
Reviewed: |
Revised: 9/17/07; 6/10/13; 2/11/19; 10/13/25 |
District vehicles may be made available to local non-profit entities which promote cultural. educational, civic, community, or recreational activities for transporting to and from non-school- sponsored activities within the state as long as the transportation does not interfere with or disrupt the education program of the District and does not interfere with or delay the transportation of students. The local non-profit entity must pay the cost of using the District vehicle as per the current fee schedule.
Prior to making the District transportation vehicle available to the local non-profit entity, the school bus signs shall be covered and the flashing warning lamps and the stop arm made inoperable.
Any use of District vehicles by non-school groups shall be subject to the following guidelines:
--------------------------------------------------------------------------------------------------------------
|
Approved: 11/20/90 |
Reviewed: 2/11/19 |
Revised: 9/17/07; 6/10/13; 10/13/25 |
Date of Request: _______________ Date Bus Needed: _______________
Bus Request: _________________________ Time Needed: __________________
Group Requesting: ___________________________________________
The use of the buses of the District shall be in accordance with the following rules and regulations:
(_____ Total Miles Traveled X _____ Cost per Mile) + (_____ Total Hours Traveled X _____ Hourly Cost of Driver) = _____ Total Bus Charge
_____________________________________ _____________________________________________
Superintendent or Designee Group Representative
-------------------------------------------------------------------------------------------------------------- !
|
Approved: 10/16/72 |
Approved: 10/16/72; 2/11/19 |
Revised: 9/17/07; 6/10/13; 12/9/19; 10/13/25 |
The District will conduct school bus safe riding practices instruction and emergency safety drills at least twice during the school year for students who utilize District transportation. Documentation of these safety drills will be maintained by the district for five years and made available upon request.
Each District vehicle will have a regular emergency safety drill as well as a plan for helping those students who require special assistance to safety during an emergency. This will include, but not be limited to, students with disabilities.
Employees are responsible for instructing the proper techniques to be followed during an emergency, as well as safe riding practices.
--------------------------------------------------------------------------------------------------------------
|
Approved: 9/17/07 |
Reviewed: 2/11/19 |
Revised: 6/10/13; 10/13/25 |
District transportation will not operate when weather conditions due to fog, rain, snow or other natural elements make it unsafe to do so. Because weather conditions may vary around the District and may change quickly, the best judgment possible with the information available will be used.
The final judgment as to when conditions are unsafe to operate will be made by the superintendent or the superintendent’s designee. The superintendent or the superintendent’s designee will be assisted by the actual "on location" decisions and reports of the District’s drivers.
When, in the judgment of the bus driver, weather conditions are so poor as to present a hazard when loading or unloading students, the driver will radio the superintendent or the superintendent’s designee for instructions. If radio contact is not possible, the driver will proceed to the next stop which does not present a hazard and make telephone contact personally, with the assistance of a student rider, monitor, or other person.
When school is cancelled because of weather anywhere in the District, all schools will be closed. Commercial radio, television, website and/or automated phone service will be used to notify employees and students when school is cancelled or temporarily delayed.
When weather conditions deteriorate during the day after school has begun, cancellation notices will be announced in a manner as provided above. Students will be returned to their regular drop-off sites, unless weather conditions prevent it. In that case, students will be kept at or returned to school until they are picked up by the parents.
--------------------------------------------------------------------------------------------------------------
|
Approved: 9/15/80 |
Reviewed: 2/11/19 |
Revised: 9/17/07; 6/10/13; 10/13/25 |
It is the goal of Spirit Lake Community School District Transportation Department to provide the safest student transportation possible. The district shall utilize three-point lap-shoulder belts on district school buses as required by law. All three-point lap-shoulder belts available shoudl be used by passengers when the vehicle is in any nonstationary gear.
Students who may require assistance in using seat belts should ask the bus driver for help, so that all students are safely belted in their seat before the bus is in motion. Drivers will announce prior to the bus leaving that each student needs to be in their seat with the seat belt fastened.
Students refusing to use seat belts create a safety concern for themselves and others, and are subject to school district disciplinary actions. Repeated refusal to wear seat belts can result in suspension from bus riding privileges.
----------------------------------------------------------------------------------------------------------------------
Approved: 9/14/20 Reviewed: Revised: 10/13/25
The Spirit Lake Community School District recognizes the increasingly vital role technology plays in society. It is the goal of the district to embrace technology as a resource to further educate our students and better prepare students for the future. It is the intent of the district to support secure data systems in the district, including security for all personally identifiable information (PII) that is stored digitally on district-maintained devices, computers and networks. Technology also has incredible potential to support increased efficiency, communication and growth through collaboration among administration, students, staff, employees and volunteers.
However, with this growth opportunity comes increased potential for valuable sensitive data to become public. The district takes seriously its responsibility to protect private data. The purpose of this policy is to ensure the secure use and handling of all district data, computer systems, devices and technology equipment by district students, employees, and data users.
The district supports the use of third-party vendors to perform necessary education functions for the district. Utilizing third party vendors to outsource functions the district would traditionally perform provides a cost-effective means to deliver high quality educational opportunities to all students. However, it is paramount that third party vendors with access to sensitive data and PII of district students, employees and data users be held to the highest standards of data privacy and security.
The selection of third-party vendors shall be in accordance with appropriate law and policy. Third-party vendors with access to PII shall meet all qualifications to be designated as a School Official under the Family Educational Rights and Privacy Act (FERPA). The board shall ensure that any approved contract with a third-party vendor will require that the vendor comply with all applicable state and federal laws, rules, or regulations, regarding the privacy of PII.
It is the responsibility of the technology director/technology department to develop procedures for the district to enhance the security of data and the learning environment. The procedures shall address, but not be limited to, the following topics:
Access Control –Access control governs who may access what information within the district and the way users may access the information. Increased access to secure networks and data will inevitably increase the risk of security compromise to those networks and data. It is the responsibility of the technology director/technology department to develop procedures for determining which individuals will have access to district networks, devices and data, and to what extent such access will be granted. System and network access will be granted based upon a need-to-have requirement, with the least amount of access to data and programs by the user as possible.
Security Management –Security management addresses protections and security measures used to protect digital data. These include measures related to audits and remediation, as well as security plans for responding to, reporting and remediating security incidents. It is the responsibility of the technology director/technology department to develop procedures to govern the secure creation, storage and transmission of any sensitive data and personally identifiable information (PII). The technology director/technology department shall implement network perimeter controls to regulate data moving between trusted internal resources to external entities.
Technology and Data Use Training –Technology and data use training addresses acceptable use best practices to safeguard data for students, employees and staff. It is the responsibility of the technology director/technology department to develop procedures for creating and administering a training program on proper data and technology use. The training shall address the proper use and security of all district owned or controlled technology, devices, media and data. Training should be administered to district data users as necessary.
In furtherance of this policy, the technology director/technology department shall be responsible for overseeing district-wide data and technology security, to include development of standards and procedures and adherence to the administrative procedures.
Approved: 10/13/25 Reviewed: Revised:
The District must ensure proper safeguards and procedures exist to use third-party vendors as a resource to further educational functions. The following procedures shall be used to investigate and contract only with qualifying third-party vendors for the performance of necessary educational functions of the district and to ensure that third-party vendors meet the required standards to be designated under the Family Educational Rights and Privacy Act (FERPA) as a School Official to handle personally identifiable information (PII) within the district.
Third-party vendors may be designated by the district as a School Official when the vendor:
Performs an institutional service or function for which the school or district would otherwise use its own employees;
Has met the criteria set forth in the district’s annual notification of FERPA rights for being a school official with a legitimate educational interest in the education records;
Is under the direct control of the district regarding the use and maintenance of education records; and
Uses education records only for authorized purposes and may not re-disclose PII from education records to other parties (unless the provider has specific authorization from the district to do so and is otherwise permitted by FERPA).
Third party vendor data use requirements shall include, but not be limited to the following:
The vendor implement and maintain security procedures and practices consistent with current industry standards; and
The vendor be prohibited from collecting and using PII for:
Targeted advertising;
Amassing a profile about a student or students except in furtherance of educational purposes;
Selling or renting PII for any purpose other than those expressly permitted by law; and
Disclosing PII for any purposes other than those expressly permitted by law.
_________________________________________________________________________________________
Approved: 10/13/25 Reviewed: Revised: