800 - BUSINESS PROCEDURES
800 - BUSINESS PROCEDURESStatement of Guiding Principles
The board recognizes that its primary purpose is to provide the best education possible within the limits of the established curriculum and the financial ability of the district. The board also recognizes its deep responsibility to the citizens of the district for the efficient use of public funds. It shall, therefore, be the duty of the board to determine guidelines for the most effective use of public funds and for reporting to the public.
The financial accounting system shall be that prescribed by the State Department of Education plus any additional accounting procedures requested by the board and/or the superintendent/designee.
Date of Adoption/Revision:
July 1979
August 21,1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
801 - Budget Planning
801 - Budget PlanningBUSINESS PROCEDURES
Series 800
Policy Title: Budget Planning
Code No.: 801
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 operate the school district within the budget.
A budget for the school district is prepared annually for the board's review. The budget will include the following:
- the amount of revenues to be raised by taxation;
- the amount of revenues from sources other than taxation;
- an itemization of the amount to be spent in each fund; and,
- a comparison of the amount spent and revenue received in each fund for like purposes in the two prior fiscal years.
It is the responsibility of the superintendent and director of business affairs 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 county auditor by March 20. A public hearing for the Proposed Property Taxes is then held 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 proposed budget by the board, members of the school district community will have an opportunity to review 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 no later than April 30.
The proposed budget filed by the board with the board secretary and the time and place for the public hearing on the proposed budget is published in a newspaper designated for official publication in the school district. It is the responsibility 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 school district to the county auditor by April 30. It is the responsibility of the board secretary 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 to bring any budget amendments necessary to the attention of the board to allow sufficient time to file the amendment with the county auditor no later than May 31 of each year.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
February 2022
February 2024
802 -
802 -
803 - Transfer of Funds
803 - Transfer of FundsSeries 800
Policy Title: Transfer of Funds
Code No.: 803
When the necessity for a fund has ceased to exist, the balance may be transferred to another fund or account by board resolution. School district monies received without a designated purpose may be transferred in this manner. School district monies received for a specific purpose or upon vote of the people 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 debt service fund.
If all requirements for district use of funds under the Preschool Foundation Aid, Professional Development Supplement, Home School Assistance Program, Teacher Leadership Supplement, or any discontinued 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 statutory requirements of each original source of funds have been met 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 action.
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 Oct. 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.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
October 2021
February 2022
June 2023
February 2024
803 Transfer of Funds 2/23/24 Pg. 2
804 - Governmental Accounting Practices and Regulations
804 - Governmental Accounting Practices and RegulationsSeries 800
Policy Title: Governmental Accounting Practices and Regulations
Code No. 804
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 state 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 board secretary 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.
Fund Balance Reporting
Financial reporting for the balances in the district’s governmental funds is based on Governmental Accounting Standards Board (GASB) Statement 54, Fund Balance Reporting and Governmental Fund Types Definitions. Fund balance refers to the difference between assets and liabilities in the governmental funds balance sheets. GASB 54 established a hierarchy that is based on “the extent to which the government is bound to honor constraints on the specific purpose for which the amounts in those funds can be spent.”
The governmental funds can have up to five fund balance classifications. The classifications are defined below from most to least restrictive.
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 converted to cash, including inventories and prepaid expenses. It may also include other property acquired for resale and the principal of a permanent fund.
Restricted Fund Balance should be reported when constraints 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 balances.”
Committed Fund Balance reflects specific purposes pursuant to constraints imposed by formal action of the board. Such constraints can only be removed or changed by board action.
Assigned Fund Balance reflects amounts that are constrained by the government’s intent to be used for specific purposes but meet neither the restricted nor 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.
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.
It is the responsibility of the superintendent to develop administrative regulations implementing this policy. It is also the responsibility of the superintendent to make recommendations to the board regarding fund balance designations.
Date of Adoption/Review/Revision:
March 2012
August 2013
September 2016
February 2022
February 2024
804 Governmental Accounting Practices 2/23/24 1:30 PM Pg. 2
805 - Local - State - Federal - Miscellaneous Revenue
805 - Local - State - Federal - Miscellaneous RevenueBUSINESS PROCEDURES
Series 800
Policy Title: Local - State - Federal - Miscellaneous Revenue
Code No.: 805
Revenues of the school district are received by the board treasurer or their designee. Other persons receiving revenues on behalf of the school 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 school district. It is the responsibility of the board treasurer to deposit the revenues received by the school district in a timely manner. School district funds from all sources will not be used for private gain or political purposes.
Tuition fees received by the school district are 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 recommendation in compliance with current law. Tuition fees for summer school, driver's education and adult education 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 school district are deposited in the general fund. It is the responsibility of the superintendent to recommend to the board when materials fees will be charged and the amount of the materials fees.
Rental fees received by the school district for the rental of school district equipment or facilities are deposited in the general fund. It is the responsibility of the superintendent to recommend to the board a fee schedule for renting school district property.
Proceeds from the sale of real property are placed in the physical plant and equipment levy (PPEL) fund. 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 school district property are placed in the general fund.
The board may claim exemption from the law prohibiting competition with private enterprise for the following activities:
- Goods and services directly and reasonably related to the educational mission;
- Goods and services offered only to students, employees or guests which cannot be provided by private enterprise at the same or lower cost;
- Use of vehicles for charter trips offered to the public, full- or part-time, or temporary students;
- Goods and services which are not otherwise available in the quantity or quality required by the school district;
- Telecommunications other than radio or television stations;
- Sponsoring or providing facilities for fitness and recreation;
- Food service and sales;
- Sale of books, records, tapes, software, educational equipment, and supplies.
- Items displaying the emblem, mascot, or logo of the district or that otherwise promote the identity of the district and its programs if sold on district property;
- Souvenirs and programs relating to events sponsored by or at the district if sold on district property; and
- Goods, products or professional services, which are produced, created or sold incidental to the district's teaching, research, and extension missions.
It is the responsibility of the superintendent to bring to the board's attention additional sources of revenue for the school district.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
February 2022
August 2024
806 - No Policy Exists
806 - No Policy ExistsNo policy exists for #806.
806 Expenditures for a Public Purpose
806 Expenditures for a Public PurposeBUSINESS PROCEDURES
Series 800
Policy Title: Expenditures for a Public Purpose
Code No.: 806
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
Date of Adoption/Review/Revision:
June 2022
July 2022
806R1 Use of Public Funds Regulation
806R1 Use of Public Funds RegulationBUSINESS PROCEDURES
Series 800
Policy Title: Expenditures for a Public Purpose – Use of Public Funds Regulation
Code No.: 806R1
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 408.1 – Credit Card Use.
- 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, but there may be circumstances that allow food and refreshments using public funds. 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. Meals and refreshments may be allowed for welcome/beginning of year receptions, end of year district/department celebrations, and during parent/teacher conference nights. In all cases, the names and number of employees shall be noted on the receipt. Meals for off-site professional development and conferences for Board members, board officers, and accompanying district staff (i.e., Iowa Association of School Boards Annual Convention) to promote effective and efficient board governance may also be allowed when reasonable.
- Apparel/Personal Items: Apparel and personal items including, but not limited to items such as t-shirts, hats, mugs, etc. generally provide personal benefit to individuals and are a personal expense. These items shall not be purchased or reimbursed with public funds. However, there may be circumstances where a staff t-shirt is provided for certain positions for a uniform such as custodial staff so that they are identifiable as district staff for events, as this aligns with the Board’s mission and vision.
- Gifts: Gift cards or 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.
Date of Adoption/Review/Revision:
June 2022
July 2022
807 - Internal Controls
807 - Internal ControlsBUSINESS PROCEDURES
Series 800
Policy Title: Internal Controls
Code No.: 807
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 or the superintendent. The superintendent 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 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 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.
Date of Adoptions/Review/Revision:
June 2022
July 2022
807R1 Internal Controls Regulation
807R1 Internal Controls RegulationBUSINESS PROCEDURES
Series 800
Policy Title: Internal Controls – Procedures Regulation
Code No.: 807R1
Fraud, financial improprieties, or fiscal irregularities include, but are not limited to:
- Forgery or unauthorized alteration of any document or account belonging to the district.
- Forgery or unauthorized alteration of a check, bank draft, or any other financial document.
- Misappropriation of funds, securities, supplies, or other assets.
- Impropriety in the handling of money or reporting of financial transactions.
- Profiteering because of “insider” information of district information or activities.
- Disclosing confidential and/or proprietary information to outside parties.
- Accepting or seeking anything of material value, other than items used in the normal course of advertising, from contractors, vendors, or persons providing services to the district.
- Destroying, removing, or inappropriately using district records, furniture, fixtures, or equipment.
- Failing to provide financial records to authorized state or local entities.
- Failure to cooperate fully with any financial auditors, investigators or law enforcement.
- Any other dishonest or fraudulent act involving district monies or resources.
- Acting for purposes of personal financial gain, rather than in the best interest of the district.
- Providing false, inaccurate or misleading financial information to district administrators or the board of directors.
The superintendent and/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 and/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 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.
Date of Adoption/Review/Revision
June 2022
July 2022
808 - Cash in School Buildings
808 - Cash in School Buildings
Series 800
Policy Title: Cash in School Buildings
Code No. 808
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 district office.
A minimal amount of cash is kept in the district 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 director of business affairs to determine the amount of cash necessary for each day's operations and to comply with this policy.
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.
Date of Adoption/Review/Revision:
August 2013
September 2016
February 2022
809 Student Activities Fund
809 Student Activities FundSTUDENT PERSONNEL
Series 500
Policy Title: Student Activities Fund
Code No. 809
Collection of any funds for school activities must have the recommendation of the building principal/designee and approval of the superintendent/designee. All such funds shall be under the financial control of the board.
Records and procedures relating to internal accounts shall be in accordance with those found in Uniform Financial Accounting for Iowa Schools published by the Department of Education.
An audit of these accounts shall be made at the same time as the annual audit of schools funds.
Date of Adoption/Review/Revision:
July 1979
July 2010
August 1994
August 1997
August 2000
July 2003
July 2006
July 2010
September 2012
August 2015
March 2024
810 - Depository of Funds
810 - Depository of Funds
Series 800
Policy Title: Depository of Funds
Code No.: 810
Each year at its annual meeting, the board will designate by resolution, the name and location of the 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 may be kept on deposit in each bank. This amount will be designated the first time a new depository is identified, and will be reviewed at least once every five years 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 school district's funds.
It is the responsibility of the board secretary to include the resolution in the minutes of the meeting.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
August 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
February 2022
February 2024
811 - Investments
811 - InvestmentsBUSINESS PROCEDURES
Series 800
Policy Title: Investments Code No.: 811
District funds in excess of current needs shall be invested in compliance with this policy. The goals of the district’s investment portfolio in order of priority are:
- To provide safety of the principle;
- To maintain the necessary liquidity to match expected liabilities; and
- To obtain a reasonable rate of return.
In making investments, the district shall exercise the care, skill, prudence, and diligence under the prevailing circumstances 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 months of receipt. When investing operating funds, the investments must mature within three hundred and ninety-seven days or less. When investing funds other than operating funds, the investment must mature according to the need for the funds.
The board authorizes the treasurer to invest funds in excess of current needs in the following investments:
- Interest bearing savings, money market, and checking accounts at the district’s authorized depositories;
- Iowa Schools Joint Investment Trust Program (ISJIT);
- Obligations of the United States government, its agencies, and instrumentalities;
- Certificates of deposit and other evidences of deposit at federally insured Iowa depository institutions;
It shall be the responsibility of the treasurer in conjunction with the superintendent to oversee the investment portfolio in compliance with this policy and the law.
It shall be the responsibility of the treasurer in conjunction with the superintendent 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 services to the board for review and approval. The treasurer in conjunction with the superintendent 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 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.
Contracts with outside persons shall not be based on the performance of the investment portfolio.
The treasurer in conjunction with the superintendent shall be responsible for reporting to and reviewing with the board at its regular meetings the investment portfolio’s performance, transaction activity, and current investments including the percent of the investment portfolio by type of investment and by issue and maturities. 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 in conjunction with the superintendent 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 shall be the responsibility of the superintendent/designee to deliver a copy of this policy to the district’s depositories, auditor, and outside persons doing investment business with the district.
It shall also be the responsibility of the superintendent/designee, in conjunction with the treasurer and board secretary, to develop a system of investment practices and internal controls over the investment practices. The investment practices shall be designed to prevent losses, to document the officers and employees responsible for elements of the investment process, and address the capability of the management.
Date of Adoption/Review/Revision:
October 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
February 2022
812 - Emergency Repairs
812 - Emergency RepairsBUSINESS PROCEDURES
Series 800
Policy Title: Emergency Repairs Code No.: 812
In the event of an emergency requiring repairs, in excess of the state limit, to a school district facility where repairs are necessary to correct or control the situation and to prevent the closing of school, the provisions relating to bidding will not apply.
It is the responsibility of the superintendent/designee to obtain certification from the area education agency administrator stating such repairs in excess of the state limit were necessary to prevent the closing of school.
It is the responsibility of the superintendent/designee to notify the board as soon as possible considering the circumstances of the emergency.
Date of Adoption/Review/Revision:
June 2008
July 2010
August 2013
September 2016
February 2022
813 - Purchasing Policy
813 - Purchasing PolicyBUSINESS PROCEDURES
Series 800
Policy Title: Purchasing - Bidding
No.: 813
The board supports economic development in Iowa, particularly in the school district community. As permitted by law, purchasing preference will be given to Iowa goods and services from locally-owned businesses located within the school district or Iowa based companies if the cost and other considerations are relatively equal and meet the required specifications. However, when spending federal Child Nutrition Funds, geographical preference is allowed only for unprocessed agricultural food items as a part of response evaluation. Other statutory purchasing preferences will be applied as provided by law, including goals with regard to procurement from certified targeted small businesses, minority-owned businesses, and female-owned businesses.
The school board and superintendent will encourage targeted small businesses which are not certified with the Department of Inspections and Appeals to become certified targeted small 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:
- The superintendent shall have the authority to authorize purchases without prior board approval and without competitive request for proposals, quotations, or bids for goods and services up to $5,000
- For goods and services costing at least $5,000 and up to $50,000, the superintendent shall receive proposals, quotations, or bids for the goods and services to be purchased prior to board approval. The quotation process may be informal, and include written or unwritten quotations.
- For goods and services exceeding $50,000 the competitive request for proposal (RFP) or competitive bid process shall be used and received prior to board approval. RFPs and bids are formal, written submissions via sealed process.
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 cost of the goods and services being purchased;
- Availability of service and/or repair;
- The targeted small business procurement goal and other statutory purchasing preferences; and
- Other factors deemed relevant by the board.
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 Improvements
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 is 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 awarded to 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 812 to Emergency Repairs.
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.
Date of Adoption/Review/Revision:
July 9, 1981
August 21, 1990
August 1992
August 1995
August 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
January 2020
November 2020
June 2022
813 Suspension and Debarment of Vendors and Contractors Procedure
813 Suspension and Debarment of Vendors and Contractors Procedure mkohorst@carro… Tue, 05/10/2022 - 12:45813 R1 Suspension and Debarment of Vendore and Contractors Procedure
813 R1 Suspension and Debarment of Vendore and Contractors Procedure
BUSINESS PROCEDURES
Series 800
Policy Title: Purchasing - Bidding - Suspension and Debarment of Vendors and Contractors Procedure
Code No.: 813.R1
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:
1. Obtaining a certification of a party’s compliance with the federal suspension and debarment requirements in connection with any application, bid, or proposal;
2. Requiring compliance with the federal suspension and debarment requirements as an express condition of any sub-award, purchase, or contract in question; or
3. Prior to committing to any sub-award, purchase, or contract, check the online Federal System for Award Management at https://sam.gov/portal/SAM/##11 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.
Date of Adoption/Review/Revision:
February 2021
May 2021
June 2022
813R1 6/28/22 Pg. 2
813R2 Using Federal Funds In Procurement Contracts
813R2 Using Federal Funds In Procurement ContractsBUSINESS PROCEDURES
Series 800
Policy Title: Using Federal Funds In Procurement Contracts
Code No.: 813.R2
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.
Date of Adoption/Review/Revision:
May 2021
June 2022
813E1 Fraud Reporting Policy
813E1 Fraud Reporting Policy
BUSINESS PROCEDURES
Series 800
Policy Title: Fraud Reporting Policy
Code No.: 813E1
2 CFR Part 200 Subpart B-General Provisions
200.113 Mandatory Disclosures
In compliance with Uniform Grant Guidance, in Title 2 Code of Federal Regulation (C.F.R.) Grants and Agreements, Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, this policy is adopted.
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.)
If an employee, elected official, board or commission member, volunteer, agent, etc. learns of a violation of Federal criminal law involving fraud, bribery, or gratuity potentially affecting a Federal grant, they will report the violation to:
Designee
The above named is/are responsible for reporting the violation to the relevant federal agency, or pass-through agency in writing, and in a timely manner.
Passed and adopted this day of
Print and Sign Date
Attest Print and Sign Date
814 - Purchase Orders
814 - Purchase OrdersBUSINESS PROCEDURES
Series 800
Policy Title: Purchase Orders Code No.: 814
The procurement of all supplies, equipment, and other materials and services shall be initiated by the issuance of a district purchase order approved by the department supervisor and the director of business affairs/designee, except those materials and services procured by formal contract.
Members of the transportation and maintenance departments may call the business office for verbal purchase authorization when such procurement is for the maintenance of vehicles, buildings or grounds.
All purchases are to be made through the business office. Purchase orders originating in the schools must be approved by the school principal/designee before being approved by the business office.
Opinions and preferences of those individuals who will use the supplies and materials should be taken into consideration in making procurement decisions or selections.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
June 2022
815 - Approval of Payment for Goods and Services
815 - Approval of Payment for Goods and ServicesBUSINESS PROCEDURES
Series 800
Policy Title: Payment for Goods and Services
Code No.: 815
The board authorizes the issuance payment of claims against the school 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.
The board authorizes the board secretary, upon approval of the superintendent, to issue payment for verified bills, for reasonable and necessary expenses, when the board is not in session. The board secretary will examine the claims and verify bills. The board will approve the bills at its next regular meeting.
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 school district. It is the responsibility of the secretary to bring claims to the board.
It is the responsibility of the superintendent to develop the administrative regulations regarding this policy.
Date of Adoption/Review/Revision:
August 11, 1980
August 21, 1990
April 1992
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
June 2022
815.1 - Suspension and Debarment of Vendors and Contractors Procedures
815.1 - Suspension and Debarment of Vendors and Contractors Procedures
BUSINESS PROCEDURES
Series 800
Policy Title: Suspension and Debarment of Vendors and Contractors Procedure
Code No.: 815.1
In connection with transactions subject to federal suspension and debarment requirements, the district is generally 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/portal/SAM/##11 to determine whether the relevant party is subject to any suspension or debarment restrictions.
Date of Adoption/Revision:
February 2021
816 - Disposition of Obsolete Equipment
816 - Disposition of Obsolete EquipmentBUSINESS PROCEDURES
Series 800
Policy Title: Disposition of Obsolete Equipment Code No.: 816
School property, such as equipment, furnishings, or supplies (hereinafter equipment), will be disposed of when it is determined to be of no further use to the school district. It is the objective of the school district in disposing of the equipment to achieve the best available price or most economical disposal.
Obsolete equipment or property other than real property having a value of no more than $25,000 may be sold or disposed of in a manner determined by the board. However, the sale or disposition of equipment, furnishings or supplies disposed of in this manner will be published in a newspaper of general circulation.
A public hearing will be held regarding the disposal of the equipment with a value of $25,000 or more prior to the board's final decision. The board will adopt a resolution announcing the proposed sale or disposition and will publish notice of the time and place of the public hearing and the description of the property will be in the resolution. Notice of the public hearing will be published at least once, but not less than 10 days and not more than 20 days, prior to the hearing date unless otherwise required by law. Upon completion of the public hearing, the board may dispose of the equipment.
It is the responsibility of the superintendent to make a recommendation to the board regarding the method for disposing of equipment of no further use to the school district.
Date of Adoption/Review/Revision:
August 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
October 2021
June 2022
817 - Lease, Sale, or Disposal of School District Buildings and Sites
817 - Lease, Sale, or Disposal of School District Buildings and SitesBUSINESS PROCEDURES
Series 800
Policy Title: Lease, Sale or Disposal of School District Buildings and Sites
Code No.: 817
Decisions regarding the lease, sale, or disposal of school district real property are made by the board. In making its decision the board will consider the needs of the education program and the efficient use of public funds.
Before the board may authorize disposition of real property, by sale, gift or lease for a period of more than one year a public hearing will be held. The board will adopt a resolution announcing the proposed sale, which will contain notice of the time and place of the public hearing and the description of the property or locally known address. Notice of the time and place of the public hearing will be published at least once, but not less than 10 days and not more than 20 days, prior to the hearing date. Upon completion of the public hearing, the board may authorize disposition of the property in accordance with the proposal reviewed during the public hearing.
The board may market and authorize the sale of any student constructed buildings by any procedure recommended by the Superintendent and authorized by the board and the public hearing requirement contained in this policy will not apply to the sale of student constructed buildings. The public hearing requirement in this policy will also not apply to the lease of school district real property for a period of one year or less or to the lease of a portion of an existing school building for any term.
If the real property contains less than two acres, is located outside of a city, is not adjacent to a city and was previously used as a schoolhouse site, the property may revert to the owner of the tract from whom the property was taken following the procedures set forth in IOWA CODE §§ 297.15-.25.
The board will not enter into an agreement to prohibit the sale of real property to other educational institutions as defined in Iowa Code ch 297.24. If the board offers to sell real property that includes a building or structure, and an educational institution offers to purchase the real property for a purchase price that represents the highest bid the board received, the board will sell the real property to the other educational institution for such purchase price.
In the case of the razing of a school district facility, in an amount in excess of the statutory minimum required by law, the board will advertise and take bids or quotes as may be required and defined by Iowa Code chapter 26 for the purpose of awarding the contract for the project.
The superintendent is responsible for coordinating the action necessary for the board to accomplish the lease, sale, or disposal of school district real property. It will also be the responsibility of the superintendent to make a recommendation to the board regarding the use of school district real property not being utilized for the education program.
Date of Adoption/Review/Revision:
August 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
June 2022
August 2024
818 - Unpaid Warrants
818 - Unpaid WarrantsThe board shall only in the case of absolute necessity issue warrants for which there are no funds available for the payment of such warrants. If warrants are issued for which there are no funds available for payment of such warrants, the treasurer shall institute such procedures as stated in the Code of Iowa, Chapter 74, Sections 1-8 for the payment of said warrants.
Date of Adoption/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
819 - Payroll Periods
819 - Payroll PeriodsBUSINESS PROCEDURES
Series 800
Policy Title: Payroll Periods Code No.: 819
The payroll period for the school district is monthly. Employees are paid on the 20th day of each month. If this day is a holiday, recess, or weekend, the payroll is paid on the last working day prior to the holiday, recess or weekend.
It is the responsibility of the board secretary to issue payroll to employees in compliance with this policy.
Date of Adoption/Review/Revision:
July 1979
August 21 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
June 2022
August 2024
820 - Payroll Deductions
820 - Payroll DeductionsBUSINESS PROCEDURES
Series 800
Policy Title: Payroll Deductions Code No.: 820
Ease of administration is the primary consideration for payroll deductions, other than those required by law. Payroll deductions are made for federal income tax withholdings, Iowa income tax withholdings, federal insurance contributions, and the Iowa Public Employees' Retirement System (IPERS). In addition, any employee may elect to have payments withheld for district related and mutually agreed upon group insurance coverage and/or tax-sheltered annuity programs.
Written requests for the purchase of or a change in tax-sheltered annuities shall be on file in the payroll department thirty (30) days prior to the desired effective date. Requests for reductions in gross wages for contributions to tax-shelter annuities shall conform to the standards of Internal Revenue Service, and all other governing and regulatory agencies in effect at the time of the request. Deductions for tax-sheltered annuities may be revoked thirty (30) days after receiving a written request from the employee.
The district may deduct wages as required or allowed by state or federal law or by order of the court of competent jurisdiction.
It is the responsibility of the superintendent or superintendent's designee to determine which additional payroll deductions will be allowed.
Payroll deduction requirements stated in the employee handbook, if any, will be followed.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
August 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
June 2022
August 2024
821 - Presentation and Publication of Financial Information
821 - Presentation and Publication of Financial InformationBUSINESS PROCEDURES
Series 800
Policy Title: Presentation and Publication of Financial Information
Code No.: 821
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 will report to the board each month about the receipts, disbursements and balances of various funds. This report will be in written form and sent to the board with the agenda for the board meeting.
Following board approval, 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 school district will also be published in a newspaper designated as a newspaper for official publication. It is the responsibility of the board secretary to publish these reports in a timely manner.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
July 2022
August 2024
822 -
822 - Jen@iowaschool… Mon, 11/11/2019 - 09:55823 -
823 -
824 - Audits
824 - AuditsBUSINESS PROCEDURES
Series 800
Policy Title: Audits
Code No.: 824
In accordance with state law, to review the funds and accounts of the school district, the board will employ an independent auditor certified in the state of Iowa to perform an annual audit of the financial affairs of the school district. The superintendent or designee will use a request for proposal procedure in selecting an auditor. The administration will cooperate with the auditors. Annual audit reports will be filed with the State Auditor and remain on file as permanent records of the school district.
Date of Adoption/Review/Revision:
August 23, 1982
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
July 2022
August 2024
824.1 Audit Committee
824.1 Audit CommitteeBUSINESS PROCEDURES
Series 800
Policy Title: Audit Committee Code No.: 824.1
The board recognizes that it is charged with raising tax revenues and related expenditures to maintain the educational program for the school district. Public funds are held in trust by the board to be spent appropriately on the educational program. To further ensure funds are spent appropriately, the board establishes an audit committee to assist the board on internal financial matters and with the annual audit.
The audit committee is comprised of two board members, the superintendent and the Director of Business Affairs.
The audit committee may at their discretion select a chair.
The major responsibilities of the audit committee are to:
- Recommend an auditor to the board at least every three years
- Oversee the selection of the independent auditor and the resolution of audit findings including compliance with the mandatory request for proposal process.
- Act as a liaison between the board and the auditor during the audit process.
- Annually report to the board about the annual audit.
- Recommend internal changes that may need to be made to ensure appropriate internal controls are being implemented.
The audit committee will meet as directed by its' chair. The audit committee is subject to the open meetings law.
Date of Adoption/Review/Revision:
August 2024
825 - Care, Maintenance, and Disposal of District Records
825 - Care, Maintenance, and Disposal of District RecordsBUSINESS PROCEDURES
Series 800
Policy Title: Care, Maintenance, and Disposal of District Records Code No.: 825
School district records are housed in the central administration office of the school 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:
|
Permanently |
|
Permanently |
|
Permanently |
|
Permanently |
|
Permanently |
|
Permanently |
|
Permanently |
|
Permanently |
|
20 years |
|
11 years after maturity, cancellation, transfer, redemption, and/or replacement |
|
11 years |
|
5 years 5 years |
|
1 year |
|
As determined by the grant |
|
7 years after leaving district 3 years after leaving the district |
|
2 years |
|
3 years |
|
3 years after submission of the final claim for reimbursement
|
|
7 years |
In the event that any federal or state agency requires a record be retained for a period of time 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 are housed in the central administration office of the school district. The employees' records are 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 is conducted annually under the supervision of the superintendent. This report is filed with the board secretary.
Date of Adoption/Review/Revision:
June 2023
August 2024
826 - Financial Records
826 - Financial RecordsBUSINESS PROCEDURES
Series 800
Policy Title: Financial Records Code No.: 826
Financial records of the school district are maintained in accordance with generally accepted accounting principles (GAAP) as required or modified by law. School district monies are received and expended from the appropriate fund and/or account. The funds and accounts of the school district will include, but not be limited to:
Governmental Fund Type:
General Fund - This fund is the chief operating fund of the district. It is used to account for all financial resources except those accounted for and reported in another fund.
Special Revenue Fund - These funds account for the proceeds of specific revenue sources other than trusts or major capital projects, that are legally restricted or committed to expenditure for specified purposes other than debt service or capital projects.
Management Levy Fund
Public Education and Recreation Levy Fund (PERL)
Student activity Fund
Capital Projects Fund - These funds are used to account for financial resources to acquire or construct major capital facilities or other capital assets (other than those of proprietary funds and trust funds) and to account for revenues from SAVE.
Physical Plant and Equipment Levy Fund (PPEL)
Secure and Advanced Vision for Education (SAVE)
Debt Service Fund – This fund is used to account for the accumulation of resources for, and the payment of, general long-term debt principal and interest.
Proprietary Fund Type – These funds account for operations of the school district operated similar to private business for which a fee is charged to external users for goods or services, or they account for the costs of providing goods and services provided by one department to other departments on a cost reimbursement basis.
Enterprise Fund
School Nutrition Fund
Child Care Fund
Internal Service Fund
Community Education
Preschool (nonvoluntary, state)
Partial Self-Funded Plan Fund
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.
Trust
Expendable Trust Funds
Nonexpendable Trust Funds
Pension Trust Funds
Custodial Funds
Non-Fiduciary Scholarship Fund
Account Groups- The groups are the accounting records for capital assets and long-term debt.
General capital assets account group
General long-term debt account group
The board may establish other funds in accordance with generally 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.
It is the responsibility 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.
Date of Adoption/Review/Revision:
August 2013
September 2016
February 2021
July 2022
February 2024
827 -
827 - Jen@iowaschool… Tue, 11/12/2019 - 19:48828 - Deleted
828 - Deleted Jen@iowaschool… Tue, 11/12/2019 - 19:49829 - Capital Assets Management System
829 - Capital Assets Management SystemBUSINESS PROCEDURES
Series 800
Policy Title: Capital Assets Management System Code No.: 829
The school district will establish and maintain a capital assets management system for reporting capitalized assets owned or under the jurisdiction of the school district in its financial reports in accordance with generally accepted accounting principles (GAAP) as required or modified by law; to improve the school district's oversight of capital assets by assigning and recording them to specific facilities and programs and to provide for proof of loss of capital assets for insurance purposes.
Capital assets, including tangible and intangible assets, are reported in the government-wide financial statements (i.e. governmental activities and business type activities) and the proprietary fund financial statements. Capital assets reported include school district buildings and sites, construction in progress, improvements other than buildings and sites, land and machinery and equipment. Capital assets reported in the financial reports will include individual capital assets with an historical cost equal to or greater than $5,000. The Federal regulations governing school lunch programs require capital assets attributable to the school lunch program with a historical cost of equal to or greater than $500 be capitalized. Additionally, capital assets are depreciated over the useful life of each capital asset.
All intangible assets with a purchase price equal to or greater than $100,000 with useful life of two or more years are included in the intangible asset inventory for capitalization purposes. Such assets are recorded at actual historical cost and amortized over the designated useful lifetime applying a straight-line method of depreciation. If there are no legal, contractual, regulatory, technological or other factors that limit the useful life of the asset, then the intangible asset needs to be considered to have an indefinite useful life and no amortization should be recorded.
This policy applies to all intangible assets. If an intangible asset that meets the threshold criteria is fully amortized, the asset must be reported at the historical cost and the applicable accumulated amortization must also be reported. It is not appropriate to “net” the capital asset and amortization to avoid reporting. For internally generated intangible assets, outlays incurred by the government's personnel, or by a third-party contractor on behalf of the government, and for development of internally generated intangible assets should be capitalized.
The capital assets management system must be updated monthly to account for the addition/acquisition, disposal, relocation/transfer of capital assets. It is the responsibility of the superintendent/designee to count and reconcile the capital assets with capital assets management system on June 30 each year.
It is the responsibility of the superintendent to develop administrative regulations implementing this policy. It will also be the responsibility of the superintendent/designee to educate employees about this policy and its supporting administrative regulations.
Date of Adoption/Review/Revision:
June 2004
July 2007
July 2010
August 2013
September 2016
July 2022
830 - deleted
830 - deleted Jen@iowaschool… Tue, 11/12/2019 - 19:51831 - Insurance Program
831 - Insurance ProgramBUSINESS PROCEDURES
Series 800
Policy Title: Insurance Program Code No.: 831
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 at least once every three years. Insurance will only be purchased through legally licensed Iowa insurance agents.
The school 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 school district.
Insurance of buildings, structures, or property in the open will not generally be purchased to cover loss exposures below $2,500.00 unless such insurance is required by statute or contract.
The board may retain a private organization for capital assets management services.
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/designee. The director of business affairs is responsible for maintaining the capital assets management system, processing claims and maintaining loss records.
Date of Adoption/Review/Revision:
July 1979
August 21, 1990
August 1992
August 1995
June 1998
June 2001
June 2004
July 2007
July 2010
August 2013
September 2016
July 2022
832 - Deleted
832 - Deleted
833 - Debt Management
833 - Debt ManagementBUSINESS PROCEDURES
Series 800
Policy Title: Debt Management Code No.: 833
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:
- General Obligation Bonds
- Obligation Capital Loan Notes
- Bond Anticipation Notes
- Revenue Anticipation Notes
- School Infrastructure Sales, Services and Use Tax Revenue Bonds
- Lease Purchase Agreements, including Certificates of Participation
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 shall 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 required 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.
Date of Adoption/Review/Revision:
October 2013
September 2016
July 2022
833R1 - Post-Issuance Compliance Regulation for Tax-Exempt Obligations
833R1 - Post-Issuance Compliance Regulation for Tax-Exempt Obligations- 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 subleases;
- 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 a 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.
Date of Adoption/Revision:
October 2013
September 2016
July 2022