700 Series: Non Instructional and Business Operations
Policy Manual
Grinnell-Newburg School District
Code No. 700
PURPOSE OF NON-INSTRUCTIONAL AND BUSINESS SERVICES
This series of the board policy manual is devoted to the goals and objectives for the school district's non-instructional services and business operations that assist in the delivery of the education program. These non-instructional services include, but are not limited to, transportation and the school food program. The board, as it deems necessary, will provide additional non-instructional services to support the education program. To the extent a group of employees has a recognized collective bargaining unit, the provisions of the master contract regarding such topics shall prevail.
It is the goal of the board to provide non-instructional services and to conduct its business operations in an efficient manner.
Grinnell-Newburg School District, Grinnell, IA
Code No. 701
FINANCIAL ACCOUNTING SYSTEM
The Grinnell-Newburg Community School District's Board of Directors adopts financial accounting guidelines as described in the Uniform Financial Accounting Manual for Iowa LEA's. The manual is published and distributed by the Iowa Department of Education and conforms to generally accepted accounting principles set forth in the Governmental Accounting and Financial Reporting Principles, Statement I of the National Council on Governmental Accounting.
Legal Reference: Iowa Code Chapter 257
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 701.1
DEPOSITORY OF FUNDS
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 maximum deposit amount to be kept in the depository will be stated in the resolution. 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.
Legal Reference: Iowa Code§§ 279.33 (2013).
Cross Reference: 210.1 Annual Meeting
206.4 Treasurer
704.1 Local - State - Federal - Miscellaneous Revenue
Approved: , Reviewed: 913/23, Revised:
Grinnell-Newburg School District, Grinnell, I
Code No. 701.2
TRANSFER OF FUNDS
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.
It is the responsibility of the board secretary to make recommendations to the board regarding transfers and to provide the documentation justifying the transfer.
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 teacher 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 of 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.
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.
Legal Reference: |
Iowa Code §§ 24.21-.22; 257.10, 279.8; 279.42; 298A. 289 I.A.C. 6 |
Cross References:
701.3 Financial Records
704.02 Debt Management
704.2R1 Debt Management - Post-Issuance Compliance Regulation for Tax-Exempt Obligations
Approved: , Reviewed: 1/24/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 701.3
FINANCIAL RECORDS
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
Special revenue fund
Management levy fund
Physical plant and equipment levy fund
Student activity fund
Capital projects fund
Debt service fund
Proprietary fund type:
Enterprise fund
School nutrition fund
Child care fund
Internal service fund
Fiduciary funds:
Trust or agency funds
Expendable trust funds
Nonexpendable trust funds
Agency funds
Pension trust funds
Account groups:
General fixed assets account group
General long-term debt account group
As necessary the board may, by board resolution, create additional funds within the governmental, proprietary and fiduciary fund types. The resolution shall state the type of fund, name of the fund and purpose of the funds
FINANCIAL RECORDS
The general fund is used primarily for the education program. Special revenue funds are used to account for monies restricted to a specific use by law. Proprietary funds account for operations of the school district operated similar to private business, and they account for the costs of providing goods and services provided by one department to other departments on a cost reimbursement basis. Fiduciary funds are used to account for monies or assets held by the school district on behalf of, or in trust for, another entity.
The account groups are the accounting records for fixed assets and long-term debt.
It is the responsibility of the superintendent or designee to implement this policy and bring necessary changes in the maintenance of the school district's financial records to the attention of the board.
Legal Reference: Iowa Code§§ 11.23; 298A (2013).
Cross Reference: 704 Revenue
705 Expenditures
Approved: , Reviewed: 1/24/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, I
Code No. 701.4
GOVERNMENTAL ACCOUNTING PRACTICES AND REGULATIONS
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 superintendent or designee 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.
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.
Legal Reference: Iowa Code§§ 257.31(4); 279.8; 297.22-.25; 298A (2013).
Cross Reference: 701.3 Financial Records
703 Budget
704 Revenue
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 701.5
FISCAL MANAGEMENT
The Board recognizes its fiduciary responsibility to oversee the management of school district funds in keeping with the school district vision, mission and goals. To achieve this purpose, the board may engage in learning about the financial needs, operations and requirements of the district as appropriate for the board’s understanding of the district’s financial position. The Board also commits to engaging in annual financial goal setting for the district based upon measurable data and projections for the district.
After the fiscal year has closed, the Superintendent or their designee will provide to the Board concise, timely, well organized financial data. The Board will exercise its oversight responsibilities by reviewing relevant PK-12 public education sector indicators to understand the financial trends of the district.
The board will establish and review financial goals annually. The District will measure whether these goals were obtained as of June 30, but only after completion of the Certified Annual Report due September 15th each year.
Providing the best possible educational experience for all students and meeting federal, state, and local academic goals for each student requires maximizing General Fund resources for use in the instructional program. The board may request from the School Budget Review Committee (SBRC) additional modified spending authority (MSA) where it may be available for items such as:
Special education deficit balances
Advances to support increasing student enrollment
Supports for students identified as English Learners
At risk / dropout prevention programming
Initial staffing associated with opening new buildings or programs
Any other lawful purpose
Any award of modified supplement amount will be levied as a cash reserve based on the recommendation of the superintendent/designee and approved by the Board of Education in keeping with the fiscal management performance measures provided for in district policy.
Legal Reference: Iowa Code §§ 257.7, 31; 279.8 257.7
Approved: 9/13/23, Reviewed: , Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 701.5R1
FISCAL MANAGEMENT - FINANCIAL METRICS
The following relevant PK-12 public sector indicators will be provided to the Board annually to better understand the financial trends of the district. These indicators will be an accurate depiction as of June 30th of the preceding fiscal year and will depict at a minimum of 2 years of data.
Total revenues and expenditures by fund and major sources;
Financial Solvency Ratio - assigned plus unassigned fund balances divided by total revenue minus AEA flow through;
Unspent Authorized Budget Ratio - amount of maximum spending authority left at year end after deducting the general fund expenditures incurred during the year;
Unspent Authorized Balance Ratio Net of Restricted Fund Balances (Categorical Fund Balances) - amount of maximum spending authority left at year end after deducting both the general fund expenditures incurred during the year and the total restricted fund balances (categorical fund balances) at year end;
Enrollment Trend - funding follows the student so it is important to understand district enrollment numbers;
Staff costs as a percent of total general fund.
Financial Projections
The general fund is the operating fund of the district where the majority of salaries and benefits are funded. Projections will help the board determine sustainability of the annual operating budget and help make future budgetary decisions.
The District is committed to utilizing the following financial metrics in determining district financial goals:
Unspent Authorized Budget Ratio: Maintain unspent authorized budget ratio not less than 8.0% of that year’s annual expenditures. The current year’s projected balance will be discussed with the Board before staffing and other spending decisions are finalized for the succeeding year.
Unspent Authorized Budget Net of Restricted Fund Balances (Categorical Balances): Maintain unspent authorized budget ratio net of restricted fund balances (categorical balances) within the 10-20% target range. The district will attempt to spend the restricted (categorical) annual allocation in the year received to the extent possible.
Solvency Ratio: Maintain an unrestricted, uncommitted general fund balance within the 10-15% target range with 8.0% being a minimum goal. The current year’s projected balance will be discussed with the Board before establishing the succeeding year’s cash reserve levy and before staffing and other spending decisions are finalized.
The District will take reasonable steps to achieve a total general fund balance at least equal to its unspent authority. This enables the District to cash flow its legal spending limit.
Approved: 9/13/23, Reviewed: , Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 702
CASH IN SCHOOL BUILDINGS
The amount of cash that may be kept in the school building for any one day is sufficient for that day's operations. Excess cash is deposited in the authorized depository of the school district on a daily basis.
A minimal amount of cash is kept in the central administration office at the close of the day. Excess cash is deposited in the authorized depository of the school district on a daily basis.
It is the responsibility of the superintendent or designee to determine the amount of cash necessary for each day's operations and to comply with this policy.
Legal Reference: Iowa Code§§ 279.8 (2013).
Cross Reference: 701.1 Depository of Funds
704 Revenue
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 703.1
BUDGET PLANNING
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.
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 Business Manager to prepare the budget for review by the board prior to the April 15 deadline each year.
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 April15.
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 or designee 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 15. It is the responsibility of the board secretary or designee to file the adopted and certified budget with the county auditor and other proper authorities.
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.
BUDGET PLANNING
It is the responsibility of the superintendent or designee 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.
Legal Reference: Iowa Code§§ 24; 257; 279.8; 297; 298; 618 (2013).
Cross Reference: 214 Public Hearings
703 Budget
704 Revenue
705 Expenditures
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 703.2
SPENDING PLAN
The certified budget of the school district is the authority for the expenditure 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 authority limits.
The district’s actual spending plan is controlled through a working line-item budget. A complete line-item budget shall be prepared by the Business Manager and Superintendent and presented to the Board of Directors at a regular board meeting in the Fall of each year. Periodic changes to the working budget shall be made when significant funding cuts, additions or changes occur throughout the year.
Legal Reference: Iowa Code§§ 24.9 (2013).
Cross Reference: 703 Budget
704 Revenue
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.1
LOCAL- STATE- FEDERAL- MISCELLANEOUS REVENUE
Revenues of the school district are received by the board treasurer. Other persons receiving revenues on behalf of the school district will promptly turn them over to the board treasurer.
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 pre-kindergarten through twelfth grade during the regular academic school year are set by the board based upon the superintendent's recommendation in compliance with current law. Tuition fees for summer school, driver's education and adult education 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. 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. 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; and,
• Sale of books, records, tapes, software, educational equipment, and supplies.
It is the responsibility of the superintendent to bring to the board's attention additional sources of revenue for the school district.
Legal Reference: Iowa Code§§ 12C; 23A; 257.2; 279.8; 282.2, .6, .24; 291.12,
297.9-.12, .22; 301.1 (2013).
Cross Reference: 701.1 Depository of Funds
703 Budget
803 Selling and Leasing
905 Use of School District Facilities & Equipment
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.2
DEBT MANAGEMENT POLICY
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
General 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.
DEBT MANAGEMENT POLICY
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 not be limited to:
1) 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);
2) proper maintenance of records to support federal tax compliance;
3) investments and arbitrage compliance;
4) expenditures and assets;
5) private business use; and
6) 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
DEBT MANAGEMENT POLICY
school district is dedicated to meeting secondary disclosure requirements on a timely and comprehensive basis, as promulgated by the Securities and Exchange Commission.
The Official Statements accompanying debt issues, Annual Audits, and Continuing Disclosure statements will meet the standards articulated by the Municipal Securities Rulemaking Board (MSRB), the Government Accounting Standards Board (GASB), the Securities and Exchange Commission (SEC), Generally Accepted Accounting Principles (GAAP) and the Internal Revenue Service (IRS). The treasurer shall be responsible for ongoing debt disclosure as required by any Continuing Disclosure Certificate for any debt issue and for maintain compliance with disclosure standards promulgated by state and federal regulatory bodies
Legal Reference: Iowa Code§§ 74-76; 278.1; 298; 298A (2013).
Cross Reference: 701 Financial Accounting System
704 Revenue
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.2R1
POST-ISSUANCE COMPLIANCE REGULATION FOR TAX-EXEMPT OBLIGATIONS
Role of Compliance Coordinator/Board Treasurer
The board treasurer shall:
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:
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:
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:
Proper Use of Bond Financed Assets
The board treasurer shall:
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:
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:
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:
Legal Reference:
Iowa Code §§ 257.31(4); 279.8; 297.22-.25; 298A (2013).
http://www.irs.gov/taxexemptbond/article/0,,id=243503,00.html
Cross Reference:
704 Revenue
707 Fiscal Reports
Approved 5/25/16, Reviewed: , Revised 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.3
INVESTMENTS
School district funds in excess of current needs are invested in compliance with this policy. The goals of the school district's investment portfolio in order of priority are:
To provide safety of the principal;
To maintain the necessary liquidity to match expected liabilities; and
To obtain a reasonable rate of return.
In making investments, the school district will exercise the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use to meet the goals of the investment program.
School district funds are monies of the school district, including operating funds. "Operating funds" of the school 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. If, during the current budget year an amount of public funds will exceed operating funds by at least thirty-three percent, the amount of public funds that exceed operating funds by greater than thirty-three percent may be invested in certificates of deposit at federally insured depository institutions which mature within sixty-three months or less, in accordance with state and federal laws. When investing funds other than operating funds, the investments must mature according to the need for the funds.
The board authorizes the treasurer to invest funds in excess of current needs in the following investments.
Interest bearing savings, money market, and checking accounts at the school 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;
Repurchase agreements in which underlying collateral consists of investments in government securities. The school district must take delivery of the collateral either directly or through an authorized custodian. Repurchase agreements do not include reverse repurchase agreements;
Prime bankers' acceptances that mature within two hundred seventy days and that are eligible for purchase by a federal reserve bank. At the time of purchase no more than ten percent of the investment portfolio can be in these investments and no more than five percent of the investment portfolio can be invested in the securities of a single issuer;
Commercial paper or other short-term corporate debt that matures within two hundred seventy days and that is rated within the two highest classifications, as established by at least one of the standard rating services, with no more than five percent at the time of purchase placed in the second highest classification. At the time of purchase no more than ten percent of the investment portfolio can be in these investments and no more than five percent of the investment portfolio can be invested in the securities of a single issuer; and,
An open-end management investment company registered with the federal securities exchange commission and commonly referred to as a money market mutual fund. The money market mutual fund will use only the investments individually authorized by law for school districts.
It is the responsibility of the treasurer to oversee the investment portfolio in compliance with this policy and the law.
It is the responsibility of the treasurer to bring a contract with an outside person to invest school 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 will also provide the board with information about and verification of the outside person's fiduciary bond. Contracts with outside persons will include a clause requiring the outside person to notify the school 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 school district and to provide the documents necessary for the performance of the investment portion of school district audit. Contracts with outside persons will not be based on the performance of the investment portfolio.
The treasurer is 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 issuer and maturities. The report will also include trend lines by month over the last year and year-to-year trend lines regarding the performance of the investment portfolio. It will also be the responsibility of the treasurer to obtain the information necessary to ensure that the investments and the outside persons doing business with the school district meet the requirements outlined in this policy.
It is the responsibility of the superintendent to deliver a copy of this policy to the school district's depositories, auditor and outside persons doing investment business with the school district.
It will also be the responsibility of the superintendent, in conjunction with the treasurer, to develop a system of investment practices and internal controls over the investment practices. The investment practices are designed to prevent losses, to document the officers' and employees' responsibility for elements of the investment process and address the capability of the management.
NOTE: This is a mandatory policy.
Legal Reference: |
Iowa Code §§ 11.2, .6; 12.62; 12B.10; 10A; 12C; 22.1, .14; 28E.2; 257; 279.29; 283A; 285; 502.701; 633.123. |
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.4
GIFTS - GRANTS -BEQUESTS
The board believes gifts, grants, and bequests to the school district may be accepted when they will further the interests of the school district. The board will have sole authority to determine whether the gift furthers the interests of the school district.
Gifts, grants, and bequests valued at $10,000 and above are approved by the board. Once it has been approved by the board, a board member or the superintendent may accept the gift on behalf of the school district. The administration will approve and accept gifts, grants, and bequests valued up to $10,000.
Gifts, grants, and bequests once accepted on behalf of the school district become the property of the school district. Gifts, grants, and bequests are administered in accordance with terms, if any, agreed to by the board.
Legal Reference: Iowa Code§§ 279.42; 565.6 (2013).
Cross Reference: 217 Gifts to Board of Directors
402.4 Gifts to Employees
508.1 Class or Student Group Gifts
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.5
STUDENT ACTIVITIES FUND
Revenue raised by students or from student activities is deposited and accounted for in the student activities fund. This revenue is the property of and is under the financial control of the board. Students may use this revenue for purposes approved by the superintendent or designee.
Whether such revenue is collected from student contributions, club dues, and special activities or result from admissions to special events or from other fund-raising activities, all funds will be under the jurisdiction of the board and under the specific control of the superintendent or designee. They will be deposited in a designation depository and will be disbursed and accounted for in accordance with instructions issued by the superintendent or designee.
It is the responsibility of the board treasurer to keep student activity accounts up-to-date and complete.
Any unencumbered class or activity balances will automatically revert to the activity fund when a class graduates or an activity is discontinued.
Legal Reference: Iowa Code§§ 11.23; 279.8 (2013).
Cross Reference: 504 Student Activities
701 Financial Accounting System
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 704.6
ONLINE FUNDRAISING CAMPAIGNS - CROWDFUNDING
The Grinnell-Newburg Community School District Board of Education believes online fundraising campaigns, including crowdfunding campaigns, may further the interests of the district. Any person or entity acting on behalf of the district and wishing to conduct an online fundraising campaign for the benefit of the district shall begin the process by seeking prior approval from the Superintendent. Money or items raised by an online fundraising campaign will be the property of the district only upon acceptance by the board, and will be used only in accordance with the terms for which they were given, as agreed to by the board.
Approval of requests shall depend on factors including, but not limited to:
Compatibility with the district’s educational program, mission, vision, core values, and beliefs;
Congruence with the district and school goals that positively impact student performance;
The district’s instructional priorities;
The manner in which donations are collected and distributed by the crowdfunding platform;
Equity in funding; and
Other factors deemed relevant or appropriate by the district.
If approved, the requestor shall be responsible for preparing all materials and information related to the online fundraising campaign and keeping district administration apprised of the status of the campaign.
The requestor is responsible for compliance with all state and federal laws and other relevant district policies and procedures. All items and money generated are subject to the same controls and regulations as other district property and shall be deposited or inventoried accordingly. No money raised or items purchased shall be distributed to individual employees.
NOTE: This is an optional policy.
Online fundraising campaigns have become an increasingly popular mechanism for individual educators to raise money. “Crowdfunding” can be defined as, the use of small amounts of capital from a large number of individuals to finance a project, business venture, or to fundraise for a specific cause or charity. For examples of organizations dedicated to crowdfunding for education please visit:
DonorsChoose.org, an organization with a mission to empower “public school teachers from across the country to request much-needed materials and experiences for their students."
AdoptAClassroom.org, an organization with a mission to give “teachers a hand by providing needed classroom materials so that students can succeed.”
As districts determine the appropriate approval process, consider other issues that may need to be approved in addition to the project itself.
Legal Reference: Iowa Code§§ 279.8; 279.42; 565.6
Cross Reference: 508.1 Class or Student Group Gifts
504.5 Student Fundraising
704.4 Gifts - Grants - Bequests
904.2 Advertising and Promotion
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 705.1
PURCHASING-BIDDING
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 and reporting with regard to procurement from certified targeted small businesses, minority-owned businesses, and female-owned businesses.
Goods and Services
The board shall enter into goods and services contract(s) as the board deems to be in the best interest of the school district. It shall be the responsibility of the superintendent to approve purchases, except those requiring board approval as described below or as provided by in law. The superintendent may coordinate and combine purchases with other governmental bodies to take advantage of volume price breaks. Joint purchases with other political subdivisions will be considered in the purchase of equipment, accessories, or attachments with an estimated cost of $50,000 or more.
Purchases for goods and services shall conform to the following:
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 not to exceed $10,000.
For goods and services costing at least $10,000 and up to $100,000, 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 $100,000, 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 a 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 are required will be followed. Competitive bidding is required for public improvement contracts exceeding the minimum threshold stated in law. Competitive quotations are required for public improvement projects that exceed the minimum threshold amount stated in law, but do not exceed the minimum set for competitive bidding. The board shall approve competitive bids and competitive quotes. If the total cost of the public improvement does not warrant either competitive bidding or competitive quotations, the district may nevertheless proceed with either of these processes, if it so chooses.
The award of all contracts for the public improvement shall be 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 802.3 - 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.
NOTE: While Iowa law dictates threshold amounts for quotes and bids for public improvement projects, there is no such requirement for goods and services. The district has discretion in this area to set the amounts required for the purchasing process.
NOTE: Districts should compare the discretionary purchasing limits in the section regarding goods and services with purchasing limits set in other policies (e.g., expenditures) to ensure consistency.
Legal Reference: |
Iowa Code §§ 26; 28E; 72.3; 73; 73A; 285; 297; 301. 261 I.A.C. 54. 281 I.A.C. 43.25. |
Cross Reference: 705.4 Expenditures for a Public Purpose
705.4R1 Expenditures for a Public Purpose-Use of Public Funds Regulation
801.4 Site Acquisition
802.3 Emergency Repairs
803.1 Disposition of Obsolete Equipment
803.2 Lease, Sale or Disposal of School District Buildings & Sites
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 705.1R1
PURCHASING - BIDDING - SUSPENSION AND DEBARMENT OF VENDORS AND CONTRACTORS PROCEDURE
In connection with transactions subject to federal suspension and debarment requirements, the district is prohibited from entering into transactions with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. When soliciting bids or otherwise preparing to enter into such a transaction, the superintendent or designee will use at least one of the following verification methods to ensure that any parties to the transaction are not suspended or debarred prior to committing to any sub-award, purchase, or contract:
Obtaining a certification of a party’s compliance with the federal suspension and debarment requirements in connection with any application, bid, or proposal;
Requiring compliance with the federal suspension and debarment requirements as an express condition of any sub-award, purchase, or contract in question; or
Prior to committing to any sub-award, purchase, or contract, check the online Federal System for Award Management at https://sam.gov/reports/awards/standard to determine whether the relevant party is subject to any suspension or debarment restrictions.
2 CFR Part 200 Subpart B-General Provisions
200.113 Mandatory Disclosures
A non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Non-Federal entities that have received a Federal award including the term and condition outlined in Appendix XII—Award Term and Condition for Recipient Integrity and Performance Matters are required to report certain civil, criminal, or administrative proceedings to SAM. Failure to make required disclosures can result in any of the remedies described in §200.338 Remedies for noncompliance, including suspension or debarment. (See also 2 CFR part 180, 31 U.S.C. 3321, and 41 U.S.C. 2313.) It is the responsibility of the Superintendent to timely report to the relevant federal or pass through agency any violations of federal criminal law involving fraud, bribery or gratuity potentially impacting a federal grant.
Cross References: 705.4 Expenditures for a Public Purpose
705.4R1 Expenditures for a Public Purpose - Use of Public Funds Regulations
801.4 Site Ac quisition
802.3 Emergency Repairs
803.1 Disposition of Obsolete Equipment
803.2 Lease, Sale or Disposal of School District Buildings & Sites
Approved: 9/13/23, Reviewed:, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 705.1R2
PURCHASING - BIDDING - USING FEDERAL FUNDS IN PROCUREMENT CONTRACTS
In addition to the District’s standard procurement and purchasing procedures, the following procedures for vendors/contractors paid with federal funds are required. When federal, state, and local requirements conflict, the most stringent requirement will be followed.
2 CFR Part 200, Subpart D Subsection §200.318 (c)(1)
No District employee, officer, or agent may participate in the selection, award and administration of contracts supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. District officers, employees, and agents may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. However, for situations where the financial interest is not substantial or the gift is an unsolicited item of nominal value, district employees must abide by all relevant board policies. Violation of this requirement may result in disciplinary action for the District employee, officer, or agent.
2 CFR Part 200, Subpart D Subsection §200.320 (e)(1-4)
Procurement for contracts paid with federal funds may be conducted by noncompetitive (single source) proposals when one or more of the following circumstances apply: (1) the item is only available from a single source; (2) public exigency or emergency will not permit the delay resulting from competitive bids; (3) the Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or (4) after solicitation of a number of sources, competition is inadequate.
2 CFR Part 200, Subpart D Subsection §200.321
The District will take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. Affirmative steps must include: (1) placing such businesses on solicitation lists; (2) soliciting such businesses whenever they are potential sources; (3) when economically feasible, dividing contracts into smaller tasks or quantities to allow participation from such businesses; (4) establishing delivery schedules that encourage participation by such businesses; (5) when appropriate, utilizing the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and (6) requiring the primary contractor to follow steps (1) through (5) when subcontractors are used.
The district will include the following provisions in all procurement contracts or purchase orders include the following provisions when applicable:
2 CFR Part 200 Appendix II
(A) Contracts for more than the simplified acquisition threshold currently set at $150,000, which is the inflation adjusted amount determined by the Civilian Agency Acquisition Council and the Defense Acquisition Regulations Council (Councils) as authorized by 41 U.S.C. 1908, must address administrative, contractual, or legal remedies in instances where contractors violate or breach contract terms, and provide for such sanctions and penalties as appropriate.
(B) All contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity including the manner by which it will be effected and the basis for settlement.
(C) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of “federally assisted construction contract” in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246, “Equal
Employment Opportunity” (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity,” and implementing regulations at 41 CFR part 60, “Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor.”
(D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland “Anti-Kickback” Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, “Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States”). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency.
(E) Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts awarded by the non-Federal entity in excess of $100,000 that involve the employment of mechanics or laborers must include a provision for compliance with 40 U.S.C. 3702 and 3704, as supplemented by Department of Labor regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40 hours. Work in excess of the standard work week is permissible provided that the worker is compensated at a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40 hours in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide that no laborer or mechanic must be required to work in surroundings or under working conditions which are unsanitary, hazardous or dangerous. These requirements do not apply to the purchases of supplies or materials or articles ordinarily available on the open market, or contracts for transportation or transmission of intelligence.
(F) Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of “funding agreement” under 37 CFR §401.2 (a) and the recipient or subrecipient wishes to enter into a contract with a small business firm or nonprofit organization regarding the substitution of parties, assignment or performance of experimental, developmental, or research work under that “funding agreement,” the recipient or subrecipient must comply with the requirements of 37 CFR Part 401, “Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative Agreements,” and any implementing regulations issued by the awarding agency.
(G) Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387), as amended—Contracts and subgrants of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended (33 U.S.C. 1251-1387). Violations must be reported to the Federal awarding agency and the Regional Office of the Environmental Protection Agency (EPA).
(H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive
Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.
(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—Contractors that apply or bid for an award exceeding $100,000 must file the required certification. Each tier certifies to the tier above that it will not and has not used Federal appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any Federal contract, grant or any other award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with non-Federal funds that takes place in connection with obtaining any Federal award. Such disclosures are forwarded from tier to tier up to the non-Federal award.
(J) See §200.322 Procurement of recovered materials.
§200.216 Prohibition on certain telecommunications and video surveillance services or equipment
(a) The district is prohibited from obligating or expending loan or grant funds to:
Procure or obtain;
Extend or renew a contract to procure or obtain; or
Enter into a contract (or extend or renew a contract) to procure or obtain equipment, services, or systems that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. As described in Public law 115-232, section 889, covered telecommunications equipment is telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities).
i. For purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunication equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).
ii. Telecommunications or video surveillance services provided by such entities or using such equipment.
iii. Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of the National Intelligence of the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned by or controlled by, or otherwise connected to, the government of a foreign country.
(b) In implementing the prohibition under Public Law 115-232, section 889, subsection (f), paragraph (l), heads of executive agencies administering loan, grant, or subsidy programs shall prioritize available funding and technical support to assist affected businesses, institutions and organizations as is reasonably necessary for those affected entities to transition from covered communications equipment and services, to procure replacement equipment and services, and to ensure that communications service to users and customers is sustained.
(c) See Public Law 115-232, section 889 for additional information.
(d) See also §200.471.
Cross References: 705.4 Expenditures for a Public Purpose
705.4R1 Expenditures for a Public Purpose - Use of Public Funds Regulation
801.4 Site Acquisition
802.3 Emergency Repairs
803.1 Dispositions of Obsolete Equipment
803.2 Lease, Sale or Disposal of School District Buildings & Sites
Approved: 9/13/23, Reviewed: , Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 705.2
Code No. 705.2
CREDIT AND PROCUREMENT CARDS
Employees may use school district credit cards and/or procurement cards (p-cards) for the actual and necessary expenses incurred in the performance of work-related duties. Actual and necessary expenses incurred in the performance of work-related duties include, but are not limited to travel expenses related to professional development or fulfillment of required job duties, fuel for school district transportation vehicles used for transporting students to and from school and for school-sponsored events, payment of claims related to professional development of the board and employees, and other expenses required by employees and the board in the performance of their duties.
Employees and officers using a school district credit or procurement card must submit a detailed, itemized receipt in addition to a credit or procurement card receipt indicating the date, purpose and nature of the expense for each claim item. Failure to provide a proper receipt will make the employee responsible for expenses incurred. Those expenses are reimbursed to the school district no later than ten working days following use of the school district's credit or procurement card. In exceptional circumstances, the superintendent or board may allow a claim without proper receipt. Written documentation explaining the exceptional circumstances is maintained as part of the school district's record of the claim.
The school district may maintain a school district credit or procurement card for actual and necessary expenses incurred by employees and officers in the performance of their duties. The superintendent may maintain a school district credit or procurement card for actual and necessary expenses incurred in the performance of the superintendent's duties. The transportation director may maintain a school district credit or procurement card for fueling school district transportation vehicles in accordance with board policy.
It is the responsibility of the superintendent to determine whether the school district credit or procurement card use is for appropriate school business. It is the responsibility of the board to determine through the audit and approval process of the board whether the school district credit or procurement card used by the superintendent and the board is for appropriate school business.
The superintendent is responsible for developing administrative regulations regarding actual and necessary expenses and use of a school district credit or procurement card. The administrative regulations will include the appropriate forms to be filed for obtaining a credit or procurement card.
NOTE: This is a mandatory policy.
Legal Reference: |
Iowa Constitution, Art. III, § 31. Iowa Code §§ 279.8, .29, .30. 281 I.A.C. 12.3(1). |
Cross References: 216.03 Board of Directors’ Member Compensation and Expenses (I, II)
401.07 Employee Travel Compensation
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 705.3
PAYMENT FOR GOODS AND SERVICES
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.
The board president and board secretary may sign warrants by use of a signature plate or rubber stamp. If the board president is unavailable to personally sign warrants, the vice president may sign warrants on behalf of the president.
It is the responsibility of the superintendent to develop the administrative regulations regarding this policy.
Note: The board may delegate payment of verified bills to the board secretary who can then pay upon approval of the superintendent. Should the board delegate this responsibility the board must still approve the payment at the board’s next regular board meeting. Or, the board can maintain the responsibility for reviewing the bills before payment.
Legal Reference: Love v. Citv of Des Moines, 210 Iowa 90,230 N.W. 373 (1930).
Iowa Code§§ 279.8, .29, .30, .36; 291.12; 721.2(5) (2013).
2811.A.C. 12.3(1).
1980 Op. Att'y Gen. 102, 160, 720.
1976 Op. Att'y Gen. 69.
1972 Op. Att'y Gen. 130, 180, 392, 456,651.
1936 Op. Att'y Gen. 375.
Cross Reference: 705 Expenditures
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 705.4
PURCHASE ORDERS
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
The procurement of all equipment, supplies, and services shall be initiated by the issuance of an official purchase order signed by the superintendent and/or authorized staff member. Purchases of $249 and below require approval and signature of immediate supervisor. Purchases of $250 and above require approval and signatures of immediate supervisor and/or business manager. Purchases $2,500 and above require approval and signature of the above and the superintendent.
Failure to follow appropriate purchasing procedures may force the district to hold staff personally responsible for incurred expenses.
Legal Reference: |
Iowa Constitution Art. III, sec. 31; Iowa Code §§ 68A.505; 279.8; 721.2. 281 I.A.C. 98.70 |
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code: 705.4R1
USE OF PUBLIC FUNDS REGULATION
The following is a list of examples organized by activity for what is allowable, or not allowable as a purchase/reimbursement using public funds. This regulation is intended as guidance and there may be situations that are not listed here. Any questions regarding the appropriateness of an expenditure should be submitted to administration prior to expending funds.
Reimbursements to an Individual
Use of Credit/Procurement Card: All purchases through a district-owned credit or procurement card shall be pre-approved and comply with the district’s policy 705.02 – Credit and Procurement Cards.
Mileage: Individuals who are required to travel (other than to and from work) as part of fulfilling their job duties to the district shall be reimbursed for mileage costs in accordance with the requirements stated in the district’s Employee Travel Compensation policy.
Travel accommodations: Employees who are required to travel and stay overnight as part of fulfilling their job duties to the district shall be reimbursed for costs in accordance with the requirements stated in the district’s Employee Travel Compensation policy.
Alcohol: Alcohol is a personal expense and is never allowable for purchase or reimbursement using public funds.
Food/Refreshments: Food and refreshments are typically a personal expense. Meetings spanning meal times should be avoided when possible. When a district meeting is required to take place spanning a customary meal time, the superintendent or designee shall determine whether food and/or refreshment will be provided to employees whose presence is required during the meeting. The cost of food and refreshment for employees shall be reasonable, and when possible, a separate itemized receipt for each employee is required. If an itemized receipt is not available, approval is required by the school business official prior to reimbursement. In all cases, the names and number of employees shall be noted on the receipt.
Apparel/Personal Items: Apparel and personal items including, but not limited to items such as t-shirts, hats, mugs, etc. provide personal benefit to individuals and are a personal expense. These items shall not be purchased or reimbursed with public funds.
Gifts: 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.
Legal Reference:
Iowa Code § 279.8
Iowa Code § 68A.505
Iowa Code § 721.2
Iowa Constitution
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 706.1
PAYROLL PERIODS
The payroll period for the school district is monthly. Employees are paid on the last 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.
Legal Reference: |
Iowa Code §§ 91A. |
Grinnell-Newburg School District, Grinnell, IA
Code No. 706.2
PAYROLL DEDUCTIONS
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).
The district may deduct wages as required or allowed by state or federal law or by order of the court of competent jurisdiction. Employees may elect to have amounts withheld from their pay for items authorized by law, subject to agreement of the district. Requests for these deductions will be made in writing to the superintendent.
It is the responsibility of the superintendent or superintendent's designee to determine which additional payroll deductions will be allowed.
Legal Reference: |
Iowa Code §§ 91A.2(4), .3; 294.8-.9, .16. |
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 706.3
PAY DEDUCTIONS
The district provides leaves of absences to allow employees to be absent from work to attend to important matters outside of the workplace. As public employers, school districts are expected to record and monitor the work that employees perform and to conform to principles of public accountability in their compensation practices.
Consistent with principles of public accountability, it is the policy of the district that, when an employee is absent from work for less than one work day and the employee does not use accrued leave for such absence, the employee's pay will be reduced or the employee will be placed on leave without pay if:
the employee has not sought permission to use paid leave for this partial-day absence,
the employee has sought permission to use paid leave for this partial-day absence and permission has been denied,
the employee's accrued paid leave has been exhausted, or,
the employee chooses to use leave without pay.
In each case in which an employee is absent from work for part of a work day, a deduction from compensation will be made or the employee will be placed on leave without pay for a period of time which is equal to the employee's absence from the employee's regularly scheduled hours of work on that day.
Note: This is a mandatory policy
Legal Reference: 29 U.S.C. Sec. 2 13(a) (2012)
29 C.P.R. Part 541 (2012)
Cross References: 409.8 Licensed Employee Unpaid Leave
414.8 Classified Employee Unpaid Leave
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 706.3R1
PAY DEDUCTION REGULATION
The district complies with all applicable laws with respect to payment of wages and benefits to employees including laws such as the federal Fair Labor Standards Act and the Iowa Wage Payment Collection Act. The district will not make pay deductions that violate either the federal or state laws.
Any employee who believes that the district has made an inappropriate deduction or has failed to make proper payment regarding wages or benefits is encouraged to immediately consult with the appropriate supervisor. Alternatively, any employee may file a formal written complaint with the Business Manager. Within 15 business days of receiving the complaint, the Business Manager will make a determination as to whether the pay deductions were appropriate and provide the employee with a written response that may include reimbursement for any pay deductions that were not appropriately made.
This complaint procedure is available in addition to any other complaint process that also may be available to employees.
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 707.1
SECRETARY'S REPORTS
The board secretary will report to the board each month about the receipts, disbursements and balances of the various funds. This report will be in written form and sent to the board with the agenda for the board meeting.
Legal Reference: Iowa Code§§ 279.8; 291.7 (2013).
Cross Reference: 206.3 Secretary
210.1 Annual Meeting
707 Fiscal Reports
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 707.2
TREASURER'S ANNUAL REPORT
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 schoolhouse 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 sworn 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.
Legal Reference: Iowa Code §§279.31, .33 (2013).
Cross Reference: 206.4 Treasurer
210.1 Annual Meeting
707 Fiscal Reports
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 707.3
PUBLICATION OF FINANCIAL REPORTS
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.
Legal Reference: Iowa Code§§ 279.35, .36; 618 (2013).
1952 Op. Att'y Gen. 133.
Cross Reference: 206.3 Secretary
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 707.4
AUDIT
To review the funds and accounts of the school district, the board will employ an auditor to perform an annual audit of the financial affairs of the school district. The superintendent will use a request for proposal procedure in selecting an auditor. The administration will cooperate with the auditors.
Legal Reference: Iowa Code§ 11.6 (2013).
Cross Reference: 701 Financial Accounting System
707 Fiscal Reports
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 707.5
INTERNAL CONTROLS
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 control is the responsibility of all employees of the school district. The superintendent, business manager and building administrators 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, principal, business manager or superintendent. The superintendent shall have primary responsibility for any necessary investigations and shall coordinate investigative efforts with the board's legal counsel, auditing firm, 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 vice-president, or finance committee member. The board shall be empowered to contact the board's legal counsel, insurance agent, auditing firm, and any other agency to investigate the concern or complaint.
Upon approval of the board, the superintendent may contact the State Auditor or elect to employ the school district's auditing firm or State Auditor to conduct a complete or partial forensic/internal control/SAS99 audit annually or otherwise as often as deemed necessary. 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. The superintendent shall ensure the State Auditor is notified of any suspected embezzlement or theft pursuant to Iowa law.
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.
Legal References: American Competitiveness and Corporate Accountability Act of
2002, Pub. L.No. 107-204.
Iowa Code ch. 11, 279.8 (2013).
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 707.5R1
INTERNAL CONTROLS PROCEDURES
Fraud, financial improprieties, or 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, or board vice president if the investigation centers on the superintendent, shall investigate reports of fraudulent activity in a manner that protects the confidentiality of the parties and the facts. All employees involved in the investigation shall be advised to keep information about the investigation confidential.
If an investigation substantiates the occurrence of a fraudulent activity, the superintendent, or board vice-president if the investigation centers on the superintendent, shall issue a report to the board and appropriate personnel. The final disposition of the matter and any decision to file or not file a criminal complaint or to refer the matter to the appropriate law enforcement and/or regulatory agency for independent investigation shall be made in consultation with district legal counsel. 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.
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
707.5R3 Fraud Reporting Procedures
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: Superintendent or Finance Committee Member
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.
_______________________________________________________
Print and Sign Date
________________________________________________________
Attest Print and Sign Date
Approved: 10/14/2020, Reviewed: 9/23/2023, Revised:
Code No. 707.6
AUDIT COMMITTEE
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: the Superintendent, Business Manager, Board
President, and Board Vice-President.
The audit committee chair is selected by the audit committee. The major responsibilities of the audit committee are to:
Recommend an auditor to the board 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.
Legal References: American Competitiveness and Corporate Accountability Act of
2002, Pub. L. No. 107-204.
Iowa Code ch. 11, 279.8 (2013).
Cross References: 208 Ad Hoc Committees
707.5 Internal Controls
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 708
CARE, MAINTENANCE AND DISPOSAL OF SCHOOL DISTRICT RECORDS
School district records are housed in the central administration office of the schooldistrict. It is the responsibility of the superintendent to oversee the maintenance and accuracy of the records. The following records are kept and preserved according to the schedule below:
Secretary's financial records Permanently
Treasurer's financial records Permanently
Open meeting minutes of the Board of Directors Permanently
Annual audit reports Permanently
Annual budget Permanently
Permanent record of individual pupil Permanently
School election results Permanently
Real property records (e.g., deeds, abstracts) Permanently
Records of payment of judgments against the school district 20 years
Bonds and bond coupons 11 years after maturity, cancellation, transfer, redemption, and/or replacement
Written contracts 11 years
Cancelled warrants, check stubs, bank statements, bills, 5 years
invoices, and related records
Recordings of closed meetings 1 year
Program grant As determined by the grant
Non-payroll personnel records 7 years after leaving district
Employment applications 2 years
Payroll records 3 years
School meal programs accounts/records 3 years after submission of the final claim for reimbursement
In the event that any federal or state agency requires a record be retained for a period of time longer than that listed about 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 periodically under the supervision of the superintendent. This report is filed with the board secretary.
The permanent and cumulative records of students currently enrolled in the school district are housed in the central administration office of the attendance center where the student attends. Permanent records must be housed in a fire resistant safe or vault or electronically with a secure backup file. The building administrator is responsible for keeping these records current. Permanent records of students who have graduated or are no longer enrolled in the school district are housed electronically and will be retained permanently. These records will be maintained by the superintendent. Special education records shall be maintained in accordance with law.
The superintendent may digitize or otherwise electronically retain school district records and may destroy paper copies of the records. An electronic record which accurately reflects the information set forth in the paper record after it was first generated in its final form as an electronic record, and which remains accessible for later reference meets the same legal requirements for retention as the original paper record.
Note: Most of the limits listed in this policy are based on legal requirements. Where the law is silent, best practice time limits have been developed. Prior to changing any of the time limits listed, it is recommended that local counsel be contacted.
Legal Reference: |
7 C.F.R. § 210.23(c). Iowa Code §§ 22.3; 22.7; 91A.6; 279.8; 291.6; 554D.114; 554D.119; 614.1(13). 281 I.A.C. 12.3(4); 41.624. City of Sioux City v. Greater Sioux City Press Club, 421 N.W.2d 895 (Iowa 1988). |
Cross References: 206.3 Secretary
215 Board of Directors’ Records
401.5 Employee Records
401.5R1 Employee Records - Regulation
506.1 Education Records Access
506.1R1 Education Records Access - Regulation
506.1E1 Education Records Access - Request of Nonparent for Examination or Copies of Education Records
506.1E2 Education Records Access - Authorization for Release of Education Records
506.1E3 Education Records Access - Request for Hearing on Correction of Education Records
506.1E4 Education Records Access - Request for Examination of Education Records
506.1E5 Education Records Access - Notification of Transfer of Education Records
506.1E6 Education Records Access - Letter to Parent Regarding Receipt of a Subpoena
506.1E7 Education Records Access - Juvenile Justice Agency Information Sharing Agreement
506.1E8 Education Records Access - Annual Notice
901 Public Examination of School District Records
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 709
INSURANCE PROGRAM
The board will maintain a comprehensive insurance program to provide adequate coverage against major types of risk, loss, or damage, as well as legal liability. The board will purchase insurance at replacement values, when possible, after reviewing the costs and availability of such insurance. The comprehensive insurance program is reviewed once every three years. Insurance will only be purchased through legally licensed Iowa insurance agents.
The 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.
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 or designee. The superintendent or designee is responsible for maintaining the fixed assets management system, processing claims and maintaining loss records.
Legal Reference: Iowa Code§§ 20.9; 85.2; 279.12, .28; 285.5(6), .10(6); 296.7;
298A; 517A.1; 670.7 (2013).
1974 Op. Att'y Gen. 171.
1972 Op. Att'y Gen. 676.
Cross Reference: 205 Board Member Liability
804 Safety Program
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.1
SCHOOL FOOD PROGRAM
The school district will operate a school lunch and breakfast program in each attendance center. The school food program services will include hot lunches through participation in the National School Lunch Program and supplementary foods for students during the school day. Students may bring their lunches from home and purchase milk or juice and other incidental items.
School food service facilities are provided to serve students and employees when school is in session and during school-related activities. They may also be used under the supervision of a ServSafe certified staff member for food service to employee groups, parent-teacher meetings, civic organizations meeting for the purpose of better understanding the schools, and senior citizens in accordance with board policy.
The school food program is operated on a nonprofit basis. The revenues of the school food program will be used only for paying the regular operating costs of the school food program. Supplies of the school food program will only be used for the school food program.
The board will set, and periodically review, the prices for school lunches, breakfast and special milk programs. It is the responsibility of the superintendent to make a recommendation regarding the prices of school lunch, breakfast and milk.
It is the responsibility of Food Services Director to administer the program and to cooperate with the superintendent and head cooks for the proper functioning of the school food program.
The district shall comply with all federal and state laws and regulations required for procurement, including the selection and evaluation of contractors. The superintendent or designee is responsible for developing an administrative process to implement this policy, including, but not limited to, procedures related to suspension and debarment for transactions subject to those requirements.
Note: This is a mandatory policy.
Legal Reference: 42 U.S.C. §§ 1751 et seq. (2010).
7 C.P.R. Pt. 210 et seq. (2010).
Iowa Code ch. 283A.
281 I.A.C. 58.
Cross Reference: 710 School Food Services
905 Use of School District Facilities and Equipment
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.1E1
SCHOOL NUTRITION PROGRAM NOTICES OF NONDISCRIMINATION
USDA Nondiscrimination Statement
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity
conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at 800-877-8339. Additionally, program information may be made available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: https://www.usda.gov/oascr/how-to-file-a -program-discrimination-complaint, any USDA office, or write a letter addressed to USDA and provide in the letter all of the
information requested in the form. To request a copy of the complaint form, call 866-632-9992. Submit your completed form or letter to USDA by:
Mail: U.S. Department of Agriculture
Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington. D.C. 20250-9410
Fax: 202-690-7442
Email: program.intake@usda.gov
This institution is an equal opportunity provider.
Iowa Nondiscrimination Statement
It is the policy of this CNP provider not to discriminate on the basis of race, creed, color, sex, sexual orientation, gender identity, national origin, disability, age, or religion in its programs, activities, or employment practices as required by the Iowa Code section 216.6, 216.7, and 216.9. If you have questions or grievances related to compliance with this policy by this CNP Provider, please contact the Iowa Civil Rights Commission, Grimes State Office Building, 400 E 14th St, Des Moines, IA 50319-1004; phone number 515-281-4121 or 800-457-4416; website: https://icrc.iowa.gov/.
Cross References: 710.2 Free or Reduced Cost Meals Eligibility
710.3 Vending Machines
710.4 Meal Charges
Approved: 9/13/23, Reviewed:, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.1E2
CHILD NUTRITION PROGRAMS CIVIL RIGHTS COMPLAINT FORM
Complaint Contact Information:
Name:
Street Address, City, State,
Zip:
County:
Area
Code/Phone:
Email Address:
Complaint Information:
Specific name and location of the entity and individual delivering the service or
benefit:
Describe the incident or action of the alleged discrimination or give an example of the situation that has a discriminatory effect on the public, potential program participants, or current participants:
On what basis does the complainant feel discrimination exists (race, color, national origin, sex, age, disability, creed, sexual orientation, religion, gender identity, political party affiliation, actual/potential parental/family/marital status)?
List the names, titles, and business addresses of persons who may have knowledge of the alleged discriminatory action:
List the date(s) during which the alleged discriminatory actions occurred,or if continuing, the duration of such actions:
Date complaint received:
Person receiving complaint:
Action(s) taken:
USDA is the cognizant agency for the Child Nutrition Programs listed and therefore is the first contact for the six protected classes of race, color, national origin, sex, age, and disability for complaints received within 180 days. Civil rights complaints must be submitted to the USDA Office of Civil Rights within five calendar days of receipt
and no later than 180 days of the discriminatory act. The link for submission of a complaint is: program.intake@usda.gov
In Iowa, protected classes also include sexual orientation, gender identity, religion or creed and complaints can be filed up to 300 days of occurrence.
The address for Iowa complaints is:
Iowa Civil Rights Commission, Grimes
State Office building, 400 E.
14th St. Des Moines, IA 50319-1004; phone number 515-281
-4121, 800-457-4416;
website:https://icrc.iowa.gov/.
This institution is an equal opportunity provider.
Approved: 9/13/23, Reviewed:, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code 710.1R1
SCHOOL NUTRITION PROGRAM CIVIL RIGHTS COMPLAINTS PROCEDURE USDA
Child Nutrition Programs in Iowa
Procedures for Handling a Civil Rights Complaint
Civil rights complaints related to the National School Lunch Program, School Breakfast Program, Afterschool Care Snack Program, Summer Food Service Program, Seamless Summer Option, or Child and Adult Care Food Program are written or verbal allegations of discrimination based on USDA protected classes of race, color, national origin, sex, age, and disability.
Any person claiming discrimination has a right to file a complaint within 180 days of the alleged discrimination. See below for additional Iowa Civil Rights information. A civil rights complaint based on the protected classes listed in #1 above must be forwarded to the address on the nondiscrimination statement.
All complaints, whether written or verbal, must be accepted by the School Food Authority (SFA)/Sponsor/Organization and forwarded to USDA at the address or link on the nondiscrimination statement within 5 calendar days of receipt. An anonymous complaint should be handled the same way as any other. Complaint forms may be developed, but their use cannot be required. If the complainant makes the allegations verbally or in a telephone conversation and is reluctant or refuses to put them in writing, the person who handles the complaint must document the description of the complaint.
There must be enough information to identify the agency or individual toward which the complaint is directed and indicate the possibility of a violation. Every effort should be made to obtain at least the following information:
Name, address and telephone number or other means of contacting the complainant;
The specific location and name of the organization delivering the program service or benefit;
The nature of the incident(s) or action(s) that led the complainant to feel there was discrimination;
The basis on which the complainant feels discrimination occurred (race, color, national origin, sex, age, or disability);
The names, titles, and addresses of people who may have knowledge of the discriminatory action(s); and
The date(s) when the alleged discriminatory action(s) occurred or, if continuing, the duration of such action(s).
USDA is the cognizant agency for the Child Nutrition Programs listed and therefore is the first contact for the six protected classes listed in #1 above, for complaints received within 180 days. Civil rights complaints must be submitted to the USDA Office of Civil Rights within five calendar days of receipt and no later than 180 days of the discriminatory act. The link for submission of a complaint is: program.intake@usda.gov
In Iowa, protected classes also include sexual orientation, gender identity, religion or creed and complaints can be filed up to 300 days of occurrence. The address for Iowa complaints is: Iowa Civil Rights Commission, Grimes State Office building, 400 E. 14th St. Des Moines, IA 50319- 1004; phone number 515-281-4121, 800-457-4416; website: https://icrc.iowa.gov/.
Bureau of Nutrition and Health, IDOE, 12/2021
Approved: 9/13/23, Reviewed:, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.2
FREE OR REDUCED COST MEALS ELIGIBILITY
Students enrolled and attending school in the school district who meet USDA eligibility guidelines will be provided the school nutrition program services at no cost or at a reduced price. The school district shall make reasonable efforts to prevent the overt identification of students who are eligible for free and reduced price meals.
The district shall at least twice annually notify all families of the availability, eligibility criteria, and application procedures for free or reduced price meals in accordance with state and federal law.
It is the responsibility of the Food Services Director or designee to determine the eligibility of students for free or reduced price school nutrition programs, in accordance with criteria established by state and federal law. If school personnel have knowledge of a student who is in need of free or reduced-price meals, school personnel shall contact the Administrative Assistant or Food Service Director.
If a student owes money for five or more meals, the Administrative Assistant or Food Service Director may contact the student’s parent or guardian to provide information regarding the application for free or reduced price meals. The school is encouraged to provide reimbursable meals to students who request reimbursable meals unless the students’ parent or guardian has specifically provided written direction to the school to withhold a meal from the student.
Employees will be required to pay for meals consumed.
It is the responsibility of the superintendent to develop administrative regulations for implementing this policy.
Legal Reference: 42 U.S.C. §§ 1751 et seq.
7 C.F.R. Pt. 210 et seq.
Iowa Code ch. 283A.
281 I.A.C. 58.
Cross Reference: 710.1 School Nutrition Program
710.1R1 School Nutrition Program Civil Rights Complaints Procedure
710.1E1 School Nutrition Program Notices of Nondiscrimination
710.1E2 Child Nutrition Programs Civil Rights Complaint Form
710.3 Vending Machines
710.4 Meal Charge Policy
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.2
FREE OR REDUCED COST MEALS ELIGIBILITY
Students enrolled and attending school in the school district who meet USDA eligibility guidelines will be provided the school nutrition program services at no cost or at a reduced price. The school district shall make reasonable efforts to prevent the overt identification of students who are eligible for free and reduced price meals.
The district shall at least twice annually notify all families of the availability, eligibility criteria, and application procedures for free or reduced price meals in accordance with state and federal law.
It is the responsibility of the Food Services Director or designee to determine the eligibility of students for free or reduced price school nutrition programs, in accordance with criteria established by state and federal law. If school personnel have knowledge of a student who is in need of free or reduced-price meals, school personnel shall contact the Administrative Assistant or Food Service Director.
If a student owes money for five or more meals, the Administrative Assistant or Food Service Director may contact the student’s parent or guardian to provide information regarding the application for free or reduced price meals. The school is encouraged to provide reimbursable meals to students who request reimbursable meals unless the students’ parent or guardian has specifically provided written direction to the school to withhold a meal from the student.
Employees will be required to pay for meals consumed.
It is the responsibility of the superintendent to develop administrative regulations for implementing this policy.
Legal Reference:
42 U.S.C. §§ 1751 et seq.
7 C.F.R. Pt. 210 et seq.
Iowa Code ch. 283A.
281 I.A.C. 58.
Cross Reference:
710.1 School Nutrition Program
710.1R1 School Nutrition Program Civil Rights Complaints Procedure
710.1E1 School Nutrition Program Notices of Nondiscrimination
710.1E2 Child Nutrition Programs Civil Rights Complaint Form
710.3 Vending Machines
710.4 Meal Charge Policy
Approved 1/24/18
Revised 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.3
VENDING MACHINES
Food served or purchased by students during the school day and food served or purchased for other than special circumstances is approved by the superintendent. Vending machines in the school building are the responsibility of the Food Service Director. Purchases from the vending machines will reflect the guidelines in the Wellness policy 507.09.
It is the responsibility of the superintendent to develop administrative regulations for the use of vending machines and other sales of food to students.
Legal Reference: |
42 U.S.C. §§ 1751 et seq. 7 C.F.R. Pt. 210 et seq. Iowa Code ch. 283A 281 I.A.C. 58. |
Cross Reference: 504.5 Student FundRaising
710 School Food Services
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 710.4
NUTRITION FUND FINANCIAL SUPPORT
In accordance with state and federal law, the Community School District adopts the following policy to ensure school district employees, families, and students have a shared understanding of expectations regarding meal charges. The policy seeks to allow students to receive the nutrition they need to stay focused during the school day, prevent the overt identification of students with insufficient funds to pay for school meals, and maintain the financial integrity of the nonprofit school nutrition program.
Payment of Meals
Students have use of a meal account. Families may add money to student accounts Infinite Campus Parent Portal or pay at one of the school offices.
Students who qualify for free meals shall never be denied a reimbursable meal, even if they have accrued a negative balance from previous purchases. Schools are encouraged to provide a reimbursable meal to students with outstanding meal charge debt. If an alternate meal is provided, the meal must be the same meal presented in the same manner to any student requesting an alternate meal.
Employees have a meal account. An employee shall not be allowed to charge meals or a la carte items with a negative account balance.
Negative Account Balances
The school district will make reasonable efforts to notify families when meal account balances are low. Additionally, the school district will make reasonable efforts to collect unpaid meal charges classified as delinquent debt. The school district will coordinate communications with the student’s parent or guardian to resolve the matter of unpaid charges. Parents or guardians will be notified of an outstanding negative balance once the student owes $20.00 or more. Parents or guardians will be notified by one of the following: automated calling system, email, letters sent home. Negative balances of more than $20.00, not paid prior to the end of the school year. will be turned over to the superintendent or superintendent’s designee for collection. Options may include: collection agencies, small claims court, or any other legal method permitted by law.
Unpaid Student Meals Account
The district will establish an unpaid student meals account in a school nutrition fund. Funds from private sources and funds from the district flexibility account may be deposited into the unpaid school meals account in accordance with law. Funds deposited into this account shall be used only to pay individual student meal debt.
Communication of the Policy
The policy and supporting information regarding meal charges shall be provided in writing to:
All households at or before the start of each school year;
Students and families who transfer into the district, at time of transfer; and
All staff responsible for enforcing any aspect of the policy.
Records of how and when the policy and supporting information was communicated to households and staff will be retained.
It is the responsibility of the superintendent to develop an administrative regulation for implementing this policy.
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.1
STUDENT SCHOOL TRANSPORTATION ELIGIBILITY
Elementary and middle school students living more than two miles from their designated school attendance centers and high school students living more than three miles from their designated attendance centers are entitled to transportation to and from their attendance center at the expense of the school district.
Transportation of students who require special education services will generally be provided as for other students, when appropriate. Specialized transportation of a student to and from a special education instructional service is a function of that service and, therefore, an appropriate expenditure of special education instructional funds generated through the weighting plan.
Transportation of a student to and from a special education support service is a function of that service, and is specified in the individualized education program (IEP) or the individualized family service plan (IFSP). When the IEP or IFSP team determines that unique transportation arrangements are required and the arrangements are specified in the IEP or IFSP, the school district will provide one or more of the following transportation arrangements for instructional services and the AEA for support services:
Transportation from the student's residence to the location of the special education and back to the student's residence, or child care placement for students below the age of six.
Special assistance or adaptations in getting the student to and from and on and off the vehicle, en route to and from the special education.
Reimbursement of the actual costs of transportation when by mutual agreement the parents provide transportation for the student to and from the special education.
The school district is not required to provide reimbursement to parents who elect to provide transportation in lieu of agency-provided transportation.
A student may be required, at the board's discretion, to meet a school vehicle without reimbursement up to three-fourths of a mile. The board may require the parent to transport their children up to two miles to connect with school bus vehicles at the expense of the school district when conditions deem it advisable. It is within the discretion of the board to determine such conditions. Parents of students who live where transportation by bus is impracticable or unavailable may be required to furnish transportation to and from the designated attendance center at the expense of the school district. Parents, who transport their children at the expense of the school district, are reimbursed at the rate per mile set by the state.
Transportation arrangements made by agreement with a neighboring school district will follow the terms of the agreement. Students, who choose to attend a school in a school district other than their resident school district, will provide transportation to and from the school at their own expense.
Note: This policy reflects the legal requirements of transportation. Boards may expand transportation eligibility and, if so, the school district’s practice should be reflected in board policy.
Legal Reference: 20 U.S.C. §§ 1401, -1701 et seq. (2012).
34 C.P.R. Pt. 300 et seq. (2012)
Iowa Code§§ 256B.4; 285; 321 (2013).
281 I.A.C. 41.412.
Cross Reference: 501.16 Homeless Children and Youth
507.8 Student Special Health Services
603.3 Special Education
711 Transportation
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.2
STUDENT CONDUCT ON SCHOOL TRANSPORTATION
Students utilizing school transportation will conduct themselves in an orderly manner fitting to their age level and maturity with mutual respect and consideration for the rights of the school vehicle driver and the other passengers. Students who fail to behave in an orderly manner will be subject to disciplinary measures.
The driver will have the authority to maintain order on the school vehicle. It is the responsibility of the driver to report misconduct to the building administrator.
The board supports the use of recording devices on school buses used for transportation to and from school as well as for field trips, curricular or extracurricular events. The recording devices will be used to monitor student behavior and may be used as evidence in a student disciplinary proceeding. The recordings are student records subject to school district confidentiality, board policy and administrative regulations.
After second warnings for bad conduct, the building principal will have the authority to suspend transportation privileges of the student or impose other appropriate discipline.
It is the responsibility of the superintendent, in conjunction with the building principal, to develop administrative regulations regarding student conduct and discipline when utilizing school district transportation.
Legal Reference: Iowa Code§§ 279.8; 285; 321
Cross Reference: 804.06 Use of Recording Devices on School Property
804.06R(1) Use of Recording Devices on School Property-Use OfDistrict Owned Recording Devices Regulation
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.2R1
STUDENT CONDUCT ON SCHOOL TRANSPORTATION REGULATION
All persons riding in school district vehicles will adhere to the following rules. The driver, sponsor or chaperones are to follow the school bus discipline procedure for student violations of this policy. Recording devices may be in operation on the school buses.
Bus riders will be at the designated loading point before the bus arrival time.
Bus riders will wait until the bus comes to a complete stop before attempting to enter.
Riders must not extend arms or heads out of the windows at any time.
Aisles must be kept cleared at all times.
All bus riders will load and unload through the right front door. The emergency door is for emergencies only.
A bus rider will depart from the bus at the designated point unless written permission to get off at a different location is given to the driver.
A rider may be assigned a seat by the driver.
Riders who damage seats or other equipment will reimburse the district for the cost of the repair or replacement.
Riders are not permitted to leave their seats while the vehicle is in motion.
Waste containers are provided on all buses for bus riders' use.
Permission to open windows must be obtained from the driver.
Classroom conduct is to be observed by students while riding the bus except for ordinary conversation.
The driver is in charge of the students and the vehicle, and the driver is to be obeyed promptly and cheerfully.
Students will assist in looking after the safety and comfort of younger students.
A bus rider who must cross the roadway to board or depart from the bus will pass in front of the bus (no closer than 10 feet), look in both directions and proceed to cross the road or highway only on signal from the driv
Students will not throw objects about the vehicle nor out through the windows.
Shooting paper wads, squirt guns or other material in the vehicle is not permitted
Students will keep feet off the seats.
Roughhousing in the vehicle is prohibited.
Students will refrain from crowding or pushing.
The use or possession of alcohol, tobacco or look-alike substances is prohibited in the vehicle.
The Good Conduct Rule is in effect.
Cross Reference: 804.06 Use of Recording Devices on School Property
804.06R(1) Use of Recording Devices on School Property-Use Of District Owned Recording Devices Regulation
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.2R2
USE OF VIDEO CAMERAS ON SCHOOL BUSES REGULATION
The board supports the use of video cameras on school buses as a means to monitor and maintain a safe environment for students and employees. The video cameras may be used on buses used for transportation to and from school, field trips, curricular events and extracurricular events. The contents of the recordings may be used as evidence in a student disciplinary proceeding.
Student Records
The content of the recordings is a student record subject to board policy and administrative regulations regarding confidential student records. Only those persons with a legitimate educational purpose may view the videotapes. In most instances, those individuals with a legitimate educational purpose may be the superintendent, building principal, transportation director, bus driver and special education staffing team. A video recorded during a school-sponsored trip, such as an athletic event, may also be accessible to the sponsor or coach of the activity. If the content of the record becomes the subject of a student disciplinary proceeding, it will be treated like other evidence in the proceeding.
Notice
The school district will annually provide the following notice to students and parents:
The Grinnell-Newburg Community School District Board of Directors has authorized the use of video cameras on school district buses. The video cameras will be used to monitor student behavior to maintain order on the school buses to promote and maintain a safe environment. Students and parents are hereby notified that the content of the recording may be used in a student disciplinary proceeding. The content of the recordings are confidential student records and will be retained with other student records. Recordings will only be retained if necessary for use in a student disciplinary proceeding or other matter as determined necessary by the administration. Parents may request to view recordings of their child if the recordings are used in a disciplinary proceeding involving their child.
The following notice will also be placed on all school buses equipped with a video camera:
This bus is equipped with a video/audio monitoring system.
Review of Recordings
The school district will review recordings when necessary as a result of an incident reported by a bus driver or student. The recordings may be re-circulated for erasure after14 days.
Viewing of recordings is limited to the individuals having a legitimate educational purpose. A written log will be kept of those individuals viewing the recordings stating the time, name of individual viewing, and the date the record was viewed.
Video Monitoring System
Video cameras are on all route buses.
Determination of how video cameras will be used and which school buses will be equipped with video equipment will be made by the superintendent in consultation with the building principals and transportation director.
Student Conduct
Students are prohibited from tampering with the video cameras on the school buses. Students found in violation of this regulation will be disciplined in accordance with the school district discipline policy and Good Conduct Rule and will reimburse the school district for any repairs or replacement necessary as a result of the tampering.
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.3
STUDENT TRANSPORTATION FOR EXTRACURRICULAR ACTIVITIES
The board in its discretion may provide school district transportation for extracurricular activities including, but not limited to, transporting student participants and other students to and from extracurricular events.
Students participating or attending extracurricular events, other than those held at the school district facilities, may be transported to the extracurricular event by school district transportation vehicles or by another means approved by the superintendent.
Students, who are provided transportation in school district transportation vehicles for extracurricular events, will ride both to and from the event in the school vehicle unless arrangements have been made with the building principal prior to the event. A student's parent may personally appear and request to transport the student home from a school-sponsored event in which the student traveled to the event on a school district transportation vehicle.
It is the responsibility of the superintendent to make a recommendation to the board annually as to whether the school district will provide the transportation authorized in this policy. In making the recommendation to the board, the superintendent will consider the financial condition of the school district, the number of students who would qualify for such transportation, and other factors the board or superintendent deem relevant.
Legal Reference: Iowa Code§§ 256B.4; 285.1-.4; 321.
281 I.A.C. 41.412.
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.4
SUMMER SCHOOL PROGRAM TRANSPORTATION SERVICE
The school district may use school vehicles for transportation to and from summer extracurricular activities. The superintendent will make a recommendation to the board annually regarding their use.
Transportation to and from the student's attendance center for summer school instructional programs is within the discretion of the board. It is the responsibility of the superintendent to make a recommendation regarding transportation of students in summer school instructional programs at the expense of the school district. In making the recommendation to the board, the superintendent will consider the financial condition of the school district, the number of students involved in summer school programs, and
other factors deemed relevant by the board or the superintendent.
Legal Reference: Iowa Code§ 285.10 (2013).
281 I.A.C. 43.10,
281 I.A.C. 41.412
Cross Reference: 603.2 Summer School Instruction
711 Transportation
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.5
TRANSPORTATION OF NONRESIDENT AND NONPUBLIC SCHOOL STUDENTS
The board has sole discretion to determine the method to be utilized for transporting nonresident and nonpublic students. Nonresident students paying tuition may be, and resident students attending a nonpublic school accredited by the State Department of Education, will be transported on an established public school vehicle route as long as such transportation does not interfere with resident public students' transportation. Nonresident and nonpublic school students will obtain the permission of the superintendent prior to being transported by the school district.
Parents of resident students who provide transportation for their children attending a nonpublic school accredited by the Iowa Department of Education will be reimbursed at the established state rate. This reimbursement is paid only if the school district receives the funds from the state. If less than the amount of funds necessary to fully reimburse parents of the nonpublic students is received by the school district, the funds will be prorated.
The charge to the nonresident students is determined based on the students' pro rata share of the actual costs for transportation. The parents of these students are billed for the student's share of the actual costs of transportation. The billing is according to the schedule developed by the superintendent. It is the responsibility of the superintendent to determine the amount to be charged and report it to the board secretary for billing.
Continued transportation of nonresident and nonpublic school students on a public school vehicle route will be subject to resident public school students' transportation needs. The superintendent will make a recommendation annually to the board regarding the method to be used. In making a recommendation to the board, the superintendent will consider the number of students to be transported, the capacity of the school vehicles, the financial condition of the school district and other factors deemed relevant by the board or the superintendent.
Nonresident and nonpublic school students are subject to the same conduct regulations as resident public students as prescribed by board policy, and to other policies, rules, or regulations developed by the school district regarding transportation of students by the school district.
Legal Reference: Iowa Code§§ 285.1-.2, .10, .16 (2013).
Cross Reference: 711 Transportation
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.6
TRANSPORTATION OF NON SCHOOL SPONSORED ACTIVITIES
School district buses may be available to local nonprofit entities which promote cultural, educational, civic, community, or recreational activities for transporting to and from non school-sponsored activities within the state as long as the transportation does not interfere with or disrupt the education program of the school district and does not interfere with or delay the transportation of students. Prior to making the school district transportation bus available to the local nonprofit entity, the "school bus" signs will be covered and the flashing warning lamps and the stop arm made inoperable.
Bus fees for transportation related to non school sponsored activities will be based upon a cost per mile rate. Such rate will equal the average district cost per mile traveled as stated in the most current Transportation Annual Report (filed with the Iowa Department of Education), plus a 3% inflationary adjustment.
It is the responsibility of the superintendent to develop administrative regulations for use of school district transportation vehicles to transport students and others to school sponsored events within the state and for application for, use of, and payment for using the school district transportation vehicles by local nonprofit entities for a non school sponsored activity.
School district buses may only be operated by a school district employee properly licensed to operate said bus.
Legal Reference: Iowa Code§§ 285.1(21), .10(9), (10) (2013).
281 I.A.C. 41.412;
281 I.A.C. 43.10
Cross Reference: 711 Transportation
900 Principles and Objectives for Community Relations
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.7
SCHOOL BUS SAFETY INSTRUCTION
The school district will conduct school bus safe riding practices instruction and emergency safety drills at least twice during the school year, once in the fall and once in the spring, for students who utilize school district transportation. Documentation of these safety drills will be maintained by the district for five years and made available upon request.
Each school bus vehicle will have, in addition to the regular emergency safety drill, a plan for helping those students who require special assistance to safety during an emergency. This will include, but not be limited to, students with disabilities.
Employees are responsible for instructing the proper techniques to be followed during an emergency, as well as safe riding practices. It is the responsibility of the superintendent to develop administrative regulations regarding this policy.
Legal Reference: Iowa Code§§ 279.8; 321 (2013).
281 I.A.C. 41.412;
281 I.A.C. 43.40.
Cross Reference: 507.05 Emergency Plans and Drills
711.10 School Bus Passenger Restrains
804.02 District Emergency Operations Plans
Approved: , Reviewed: 1/10/18, Revised: 9/13/23
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.8
TRANSPORTATION IN INCLEMENT WEATHER
School district buses will not operate when weather conditions due to fog, rain, snow or other natural elements make it unsafe to do so. Because weather conditions may vary around the school district and may change quickly, the best judgment possible will be used with the information available.
The final judgment as to when conditions are unsafe to operate will be made by the superintendent.
When weather conditions deteriorate during the day after school has begun, cancellation notices will be announced. Students will be returned to their regular drop-off sites unless weather conditions prevent it. In that case, students will be kept at or returned to school until they are picked up by the parents.
Note: This is a mandatory policy, but the content isn’t. Boards should amend the policy if necessary to reflect their practices.
Legal Reference: Iowa Code§ 279.8 (2013).
Cross Reference: 601.2 School Day
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA
Code No. 711.9
DISTRICT VEHICLE IDLING
The board recognizes that it has a role in reducing environmental pollutants and in assisting students and others be free from pollutants that may impact their respiratory health. Unnecessary vehicle idling emits pollutants and wastes fuel. The board directs the superintendent, in conjunction with the Director of Transportation, to work on administrative regulations to implement this policy and reduce school vehicle idling time.
Legal References: Iowa Code §279.8 (2013).
Cross References: 403 Employee Health and Well-Being
507 Student Health and Well-Being
711 Transportation
Approved: , Reviewed: 9/13/23, Revised:
Grinnell-Newburg School District, Grinnell, IA