700 PURPOSE OF NONINSTRUCTIONAL AND BUSINESS SERVICES

This series of the board policy manual is devoted to the goals and objectives for the school district's noninstructional services and business operations that assist in the delivery of the education program.  These noninstructional services include, but are not limited to, transportation, the school lunch program and child care.  The board, as it deems necessary, will provide additional noninstructional services to support the education program.

It is the goal of the board to provide noninstructional services and to conduct its business operations in an efficient manner.

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

701 FINANCIAL ACCOUNT SYSTEM

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

 

 

Cross Reference:        

210.1   Annual Meeting

206.4   Treasurer [or 206.3, Secretary-Treasurer]

704.1   Local - State - Federal - Miscellaneous Revenue

 

 

Approved July 2000                           

Reviewed November 2022          

Revised                   

 

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.

If all requirements for district use of funds calculated under the teacher leadership supplement are 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 into the district’s flexibility account in accordance with law.

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 Reference:    701.3    Financial Records
    703    Budget
    704.2    Sale of Bonds

Approved                       Reviewed     November 2022                   Revised         July 2021        

 

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
    • Public education and recreation levy fund
    • Student activity fund
  • Capital Project Fund
    • Physical Plant and Equipment Levy Fund (PPEL)
    • Secure and Advanced Vision for Education (SAVE)
  • 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
    • Pension trust funds
  • Custodial funds

Account groups:

  • General capital assets account group
  • General long-term debt account group

 

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.  A debt service fund is used to account for the accumulation of resources for, and the payment of, general long-term debt principal and interest.  Capital project funds are used to account for financial resources, to acquire or construct major capital facilities (other than those of propriety funds and trust fund) and to account for revenues from SAVE.   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.

The board may establish other funds in accordance with generally accepted accounting principles and may certify other taxes to be levied for the funds as provided by state law. The status of each fund must be included in the annual report.

It is the responsibility of the superintendent 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  July 2000                   

Reviewed November 2022       

Revised October 2018                

701.4 FISCAL YEAR

The school district fiscal year shall begin July 1 and end June 30 each year. The budget shall state the expenditures for the fiscal year, and it shall be the responsibility of the superintendent to operate the education program within the budget.

It shall be the responsibility of the board to ensure the budget is managed effectively.

 

 

 

Legal Reference:         

Iowa Code §§ 24.2 (2013).

 

Cross Reference:        

703      Budget

704      Revenue

705      Expenditures

 

 

Approved  July 2000                    

Reviewed October 2016       

Revised                   

 

 

701.5 CLASSIFICATION OF ACCOUNTS

The money received from the regular and the voter-approved physical plant and equipment levies, the levy for public educational and recreational activities imposed under chapter 300, the proceeds of the sale of bonds authorized by law, and the proceeds of a tax estimated and certified by the board for the purpose of paying interest and principal on lawful bonded indebtedness shall be deposited in the schoolhouse fund and, except when authorized by the electors, shall be used only for the purpose for which originally authorized or certified. The money received from the district management levy shall be deposited in the sub-fund of the general fund of the school district. The treasurer shall keep a separate account for each fund and shall not pay an order that fails to state the fund upon which it is drawn and the specific use for which it is to be applied.

 

 

Legal Reference:         

Iowa Code §§ 11.236; 291.13 (2013).

 

Cross Reference:        

704      Revenue

705      Expenditures

 

 

Approved  July 2000                    

Reviewed November 2022     

Revised                   

 

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.  Funds raised by students are kept in the activity fund.

A minimal amount of cash is kept in the central administration office at the close of the day.  Excess cash is deposited in the authorized depository of the school district.

It is the responsibility of the superintendent or the superintendent's designee to develop administrative regulations to determine the amout of cash necessary for each day's operations, to establish any necessary petty cash accounts, to determine how often deposits must be made and to comply with this policy.

 

 

Legal Reference:         

Iowa Code § 279.8

 

 

Cross Reference:        

701.1   Depository of Funds

704      Revenue

 

 

Approved July 2000                     

Reviewed November 2022       

Revised    July 2021              

 

702.1R1 GATE RECEIPTS

Gate receipts from any given school event have the potential to amount to a substantial sum of cash. In consideration of the board policy to limit cash in the cash drawer in the office and in the safe, at the close of the school day, cash receipts should be removed and deposited on the same day of the event whenever possible.

 

In those instances when same-day deposits are impossible, gate receipts are to be locked in safe until the first business day when a deposit can be made. The board discourages the individual in charge of collection of the gate receipts from personally holding the receipts except in special circumstances approved by the superintendent.

 

The athletic secretary and building secretaries shall be responsible for collections, counting and depositing the gate receipts. The superintendent shall provide administrative regulations to be followed by those chosen to handle the recipts.

703 BUDGET

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 superintendent and 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 April 15.

The proposed budget filed by the board with the board secretary and the time and place for the public hearing on the proposed budget is published in a newspaper designated for official publication in the school district.  It is the responsibility of the board secretary to publish the proposed budget and public hearing information at least 10 but no more than 20 days prior to the public hearing.

The board will adopt and certify a budget for the operation of the school district to the county auditor by April 15.  It is the responsibility of the board secretary 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.

It is the responsibility of the superintendent and the board secretary to bring any budget amendments necessary to the attention of the board to allow sufficient time to file the amendment with the county auditor no later than May 31 of each year.

 

 

Legal Reference:         

Iowa Code §§ 24; 257; 279.8; 297; 298; 618 (2013).

 

Cross Reference:        

214      Public Hearings

703      Budget

704      Revenue

705      Expenditures

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

 

703.2 SPENDING PLAN

The budget of the school district is the authority for the expenditures of the school district for the fiscal year for which the budget was adopted and certified.  It is the responsibility of the superintendent to operate the school district within the budget. 

 

 

Legal Reference:        

Iowa Code § 24.9

 

 

Cross Reference:        

703      Budget

704      Revenue

 

 

Approved July 2000                     

Reviewed November 2022     

Revised                   

703.3 FINANCIAL GOALS

The District’s goal for its undesignated, unreserved general fund balance at June 30 is 5% to 15% of that year’s revenue.  The District will certify annually a cash reserve levy if needed to reach and/or sustain the desired fund balance.  A fund balance of 5% to 15% enables the District to achieve the highest possible credit ratings from rating agencies, such as Moody’s and Standard & Poors.  Higher credit ratings are directly related to lower interest rates on long-term debt issued by the District.  Sufficient fund balances also eliminate short-term borrowings and related interest expense in the general fund and protect the District if the State of Iowa reduces funding mid-year.  A report on meeting this target will be made annually to the Board.
 
The unspent budget authority is the remaining legal spending authority at the end of the fiscal year.  The District’s unspent budget authority at June 30 shall be no less than $1,000 per student.  Maintaining an adequate unspent budget authority provides legal authority to spend the undesignated, unreserved fund balance.  A report on meeting this target will be made annually to the Board.
 
This District shall solicit from the School Budget Review Committee additional allowable growth where it may be available for items such as special education deficit, increasing enrollment, English as a Second Language, and any other lawful purposes.  Any award of allowable growth will be levied as a cash reserve levy, in full, in the next available budget year.  For recurring program deficits that are predictable, the District shall levy in advance for the immediately succeeding year as part of the general cash reserve levy.

 

 

 

 

Approved:  December 2019             Reviewed      November 2022                      Revised

704 REVENUE

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 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.  However, following a properly noticed public hearing, the board of directors may elect to deposit proceeds from the sale of real property or buildings into any fund under the control of the school corporation.  Notice for the public hearing must be published in a newspaper of general circulation within the district not less than ten and no more than twenty days prior to the proposed public hearing.  Notice of the public hearing must include the date, time and location of the public hearing and a description of the proposed action.  The proceeds from the sale of other school distrist 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

 

Cross Reference:        

701.1   Depository of Funds

703      Budget

803      Selling and Leasing

905      Use of School District Facilities & Equipment

 

 

Approved July 2000                           

Reviewed November 2022           

Revised    July 2021              

704.2 DEBT MANAGEMENT

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.

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.Code No. 704.2

Financial Analysis – Stability, diversity, and growth rates of tax or other revenue sources; trend in assessed valuation and collections; current budget trends; appraisal of past revenue and expenditure trends; history and long-term trends of revenues and expenditures; evidences of financial planning; adherence to GAAP; audit results; fund balance status and trends in operating and debt funds; financial monitoring systems and capabilities; and cash flow projections.

Governmental and Administrative Analysis – Government organization structure; location of financial responsibilities and degree of control; adequacy of basic service provision; intergovernmental cooperation/conflict and extent of duplication; and overall planning efforts.

Economic Analysis – Geographic and location advantages; population and demographic characteristics; wealth indicators; types of employment, industry and occupation; housing characteristics; new construction; evidences of industrial decline; and trend of the economy.

DEBT ISSUANCE
Credit Enhancement
Credit enhancements (.i.e., bond insurance, etc.) may be used but only when the net debt service on the debt is reduced by more than the costs of the credit enhancement.

Costs and Fees
All costs and fees related to issuing the debt will be paid out of debt proceeds and allocated across all projects receiving proceeds of the debt issue.

Method of Sale
Generally, all school district debt will be sold through a competitive bidding process.  Bids will be awarded on a TIC basis providing other bidding requirements are satisfied.

The school district may sell debt using a negotiated process in extraordinary circumstances when the complexity of the issue requires specialized expertise, when the negotiated sale would result in substantial savings in time or money, or when market conditions of school district credit are unusually volatile or uncertain.

Professional Service Providers
The school district will retain external bond counsel for all debt issues.  All debt issued by the school district will include a written opinion by bond counsel affirming that the school district is authorized to issue the debt, stating that the school district has met all Iowa constitutional and statutory requirements necessary for issuance and determining the debt’s federal income tax status.  The bond counsel retained must have comprehensive municipal debt experience and a thorough understanding of Iowa law as it relates to the issuance of the particular debt.

The school district will retain an independent financial advisor.  The financial advisor will be responsible for structuring and preparing all offering documents for each debt issue.  The financial advisor retained will have comprehensive municipal debt experience, experience with diverse financial structuring and pricing of municipal securities.

The treasurer shall have the authority to periodically select other service providers (e.g., escrow agents, verification agents, trustees, arbitrage consultants, rebate specialist, etc.) as necessary to meet legal requirements and minimize net debt costs.  These services can include debt restructuring services and security or escrow purchases.Code No. 704.2

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 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 July 2000                     

Reviewed November 2022       

Revised                   

704.02-R(1): DEBT MANAGEMENT - POST ISSUANCE REGULATION FOR TAX-EMEPT OBLIGATIONS

  1. Role of Compliance Coordinator/Board Treasurer

    The board treasurer shall:  
     

    1. Be responsible for monitoring post-issuance compliance;
    2. Maintain a copy of the transcript of proceedings or minutes in connection with the issuance of any tax-exempt obligations and obtain records that are necessary to meet the requirements of this regulation;
    3. Consult with bond counsel, a rebate consultant, financial advisor, IRS publications and such other resources as are necessary to understand and meet the requirements of this regulation;
    4. Seek out training and education to be implemented upon the occurrence of new developments in the area and upon the hiring of new personnel to implement this regulation.
       
  2. Financing Transcripts’ Filing and Retention 

    ​​​​​​​The board treasurer shall confirm the proper filing of an IRS 8038 Series return and maintain a transcript of proceedings and minutes for all tax-exempt obligations issued by the school district including, but not limited to, all tax-exempt bonds, notes and lease-purchase contracts. Each transcript shall be maintained until 11 years after the tax-exempt obligation documents have been retired. The transcript shall include, at a minimum:
    ​​​​​​​

    1. Form 8038;
    2. Minutes, resolutions and certificates;
    3. Certifications of issue price from the underwriter;
    4. Formal elections required by the IRS;
    5. Trustee statements;
    6. Records of refunded bonds, if applicable;
    7. Correspondence relating to bond financings; and
    8. Reports of any IRS examinations for bond financings.
      ​​​​​​​
  3. 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:
    ​​​​​​​

    1. Obtain a computation of the yield on such issue from the school district's financial advisor;
    2. Create a separate Project Fund (with as many sub-funds as shall be necessary to allocate proceeds among the projects being funded by the issue) into which the proceeds of issue shall be deposited;
    3. Review all requisitions, draw schedules, draw requests, invoices and bills requesting payment from the Project Fund;
    4. Determine whether payment from the Project Fund is appropriate and, if so, make payment from the Project Fund (and appropriate sub-fund, if applicable);
    5. Maintain records of the payment requests and corresponding records showing payment;
    6. Maintain records showing the earnings on, and investment of, the Project Fund;
    7. Ensure that all investments acquired with proceeds are purchased at fair market value; 
    8. Identify bond proceeds or applicable debt service allocations that must be invested with a yield-restriction and monitor the investments of any yield-restricted funds to ensure that the yield on such investments do not exceed the yield to which such investments are restricted;
    9. Maintain records related to any investment contracts, credit enhancement transactions and the bidding of financial products related to the proceeds.
      ​​​​​​​
  4. 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:
    ​​​​​​​

    1. Monitor and ensure that proceeds of each such issue are spent within the temporary period set forth in such certificate;
    2. Monitor and ensure that the proceeds are spent in accordance with one or more of the applicable exceptions to rebate as set forth in such certificate if the school district does not meet the "small  issuer" exception for said obligation;
    3. Not less than 60 days prior to a required expenditure date, confer with bond counsel and a rebate consultant, if the school district will fail to meet the applicable temporary period or rebate exception expenditure requirements of the Tax-Exemption Certificate.  In the event the school district fails to meet a temporary period or rebate exception:
      1. Procure a timely computation of any rebate liability and, if rebate is due, file a Form 8038-T and arrange for payment of such rebate liability;
      2. Arrange for timely computation and payment of yield reduction payments (as such term is defined in the Code and Treasury Regulations), if applicable.
        ​​​​​​​
  5. Proper Use of Bond Financed Assets

    The board treasurer shall:
    ​​​​​​​

    1. Maintain appropriate records and a list of all bond financed assets.  Such records shall include the actual amount of proceeds (including investment earnings) spent on each of the bond financed assets;
    2. Monitor and confer with bond counsel with respect to all proposed bond financed assets;
      1. management contracts;
      2. service agreements;
      3. research contracts;
      4. naming rights contracts;
      5. leases or sub-leases;
      6. joint venture, limited liability or partnership arrangements; 
      7. sale of property; or
      8. any other change in use of such asset.
    3. Maintain a copy of the proposed agreement, contract, lease or arrangement, together with the response by bond counsel with respect to said proposal for at least three years after retirement of all tax-exempt obligations issued to fund all or any portion of bond financed assets; and
    4. Contact bond counsel and ensure timely remedial action under IRS Regulation Sections 1.141-12 in the event the school district takes an action with respect to a bond financed asset, which causes the private business tests or private loan financing test to be met.
      ​​​​​​​
  6. 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:
    ​​​​​​​

    1. Appraisals, demand surveys or feasibility studies;
    2. Applications, approvals and other documentation of grants;
    3. Depreciation schedules;
    4. Contracts respecting the project.
      ​​​​​​​
  7. 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:
    ​​​​​​​

    1. Identify and select bonds to be advance refunded with advice from internal financial personnel and a financial advisor;
    2. Identify, with advice from the financial advisor and bond counsel, any possible federal tax compliance issues prior to structuring any advance refunding;
    3. Review the structure with the input of the financial advisor and bond counsel, of advance refunding issues prior to the issuance to ensure;
      1. that the proposed refunding is permitted pursuant to applicable federal tax requirements if there has been a prior refunding of the original bond issue;
      2. that the proposed issuance complies with federal income tax requirements which might impose restrictions on the redemption date of the refunded bonds; 
      3. that the proposed issuance complies with federal income tax requirements which allow for the proceeds and replacement proceeds of an issue to be invested temporarily in higher yielding investments without causing the advance refunding bonds to become "arbitrage bonds"; and 
      4. that the proposed issuance will not result in the issuer's exploitation of the difference between tax exempt and taxable interest rates to obtain an financial advantage nor overburden the tax exempt market in a way that might be considered an abusive transaction for federal tax purposes;
    4. Collect and review data related to arbitrage yield restriction and rebate requirements for advance refunding bonds. To ensure such compliance, the board treasurer shall engage a rebate consultant to prepare a verification report in connection with the advance refunding issuance. Said report shall ensure said requirements are satisfied;
    5. Whenever possible, purchase State and Local Government Series (SLGS) to size each advance refunding escrow. The financial advisor shall be included in the process of subscribing SLGS. To the extent SLGS are not available for purchase, the Board treasurer shall, in consultation with bond counsel and the financial advisor, comply with IRS regulations;
    6. Ensure, after input from bond counsel, compliance with any bidding requirements set forth by the IRS regulations to the extent as issuer elects to the purchase of a guaranteed investment contract;
    7. In determining the issue price for any advance refunding issuance, obtain and retain issue price certification by the purchasing underwriter at closing;
    8. After the issuance of an advance refunding issue, ensure timely identification of violations of any federal tax requirements and engage bond counsel in attempt to remediate same in accordance with IRS regulations.
      ​​​​​​​
  8. 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:
    ​​​​​​​

    1. Principal and interest payment delinquencies;
    2. Non-payment related defaults, if material;
    3. Unscheduled draws on debt service reserves reflecting financial difficulties;
    4. Unscheduled draws on credit enhancements relating to the bonds reflecting financial difficulties;
    5. Substitution of credit or liquidity providers, or their failure to perform;
    6. Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB), or other material notices, or determinations with respect to the tax-exempt status of the bonds, or material events affecting the tax-exempt status of the bonds;
    7. Modifications to rights of Holders of the Bonds, if material; 
    8. Bond calls (excluding sinking fund mandatory redemptions), if material and tender offers;
    9. Defeasances of the bonds;
    10. Release, substitution, or sale of property securing repayment of the bonds, if material;
    11. Rating changes on the bonds;
    12. Bankruptcy, insolvency, receivership or similar event of the Issuer;
    13. The consummation of a merger, consolidation, or acquisition involving the Issuer or the sale of all or substantially all of the assets of the Issuer, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material; and
    14. Appointment of a successor or additional trustee or the change of name of a trustee, if material.

​​​​​​​


I.C. Iowa Code Description
Iowa Code § 278.1 Power of Electors
Iowa Code § 298 School Taxes and Bonds
Iowa Code § 298A School District Fund Structure
Iowa Code § 74 Public Obligation Warrants
Iowa Code § 75 Sale of Public Bonds
Iowa Code § 76 Public Bonds and Debt Obligations
Cross References
Code Description
701.02 Transfer of Funds

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.  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); and,
  • Certificates of deposit and other evidences of deposit at federally insured Iowa depository institutions.

It is the responsibility of the treasurer to oversee the investment portfolio in compliance with this policy and the law.

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. 

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.

 

 

Legal Reference:         

Iowa Code §§ 11.2, .6; 12.62; 12B.10; 12C; 22.1, .14; 28E.2; 257; 279.29; 283A; 285; 502.701; 633.123 (2013).

 

Cross Reference:        

206.4   Treasurer

704      Revenue

 

 

Approved July 2000   

Reviewed November 2022

Revised                   

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 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.

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 July 2000                     

Reviewed November 2022      

Revised                   

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 activities director.

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 activities director.  They will be deposited in a designated depository and will be disbursed and accounted for in accordance with instructions issued by the superintendent.

It is the responsibility of the board secretary to keep student activity accounts up-to-date and complete.

Any unencumbered class or activity account balances will automatically revert to the activity fund when a class graduates or an activity is discontinued.

 

 

 

 

Legal Reference:         

Iowa Code §§ 11.23; 279.8

 

 

Cross Reference:        

504      Student Activities

701      Financial Accounting System

 

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

704.6 BOND DISCLOSURE POLICY

Article I - Key Participants and Responsibilities

Section 1.01  Disclosure Coordinator.  By adoption of this Policy, the District hereby appoints the Board Treasurer to act as the Disclosure Coordinator hereunder.

Section 1.02:  Responsibilities.  The Disclosure Coordinator is responsible for the following tasks:

(A) reviewing and approving all preliminary and final official statements relating to the District's Securities, together with any supplements, for which a Disclosure Agreement is required (each, an "Official Statement"), before such documents are released, in accordance with Article III below;

(B) moderating Board of Directors' approval of all Financial Obligations triggering a Listed Event Notice under any new Disclosure Agreement entered into after February 27, 2019;

(C) reviewing the District's status and compliance with Disclosure Agreements, including filings of disclosure documents thereunder ad in compliance with this Policy, in accordance with Articles IV and V below;

(D) serving as a 'point person' for personnel to communicate issues or information that should be or may need to be included in any disclosure document.

(E) recommending changes to this Policy to the Board of Directors as necessary or appropriate;

(F) communicating with third parties, including coordination with outside consultants assisting the District, in the preparation and dissemination of disclosure documents to make sure that assigned tasks have been completed on a timely basis and make sure that the filings are made on a timely basis and are accurate;

(G) in anticipation of preparing disclosure documents, soliciting 'material' information (as defined for purposes of federal securities law) from Employees identified as having knowledge of or likely to have inforation of Listed Events under Article IV or relevant to Disclosure Agreements;

(H) maintaining records documenting the District's compliance with this Policy; and

(I) ensuring compliance with training procedures as described below.

The responsibility of the Disclosure Coordinator to make certain filings with the MSRB udner Article III (Annual Report Filings) and IV (Listed Event Filings) may be delegated by contract to a dissemination agent, under terms approved by the Board of Directors.

The Disclosure Coordinator shall instruct Employees of the obligation to commuicate with the Disclosure Coordinator on any information relating to financial obligations or amendments to existing financial obligation promptly following occurrence.

 

Article II - Official Statements

Section 2.01 Review and Approval of Official Statements.  Whenever the District issues Securities, an Official Statement may be prepared.  Each of these Official Statements contains information relating to the District's finances.  The Disclosure Coordintor (with advice from Bond Counsel, any retained Disclosure Counsel, and/or Financial Advisor) shall have primary responsibility for ensuring that all such information is accurate and not misleading in any material aspect.  The Official Statement may also include a certification that the information contained in the Official Statement regarding the District, as of the date of each Official Statement, does not contain any untrue statement of materials fact or omit to state any material fact necessary to make the information contained in the Official Statement, in light of the circumstances under which it was provided, not misleading.  When undertaking review of a final or preliminary Official Statement, the Disclosure Coordinator shall:

(A) review the Official Statement to ensure: (i) that there are no material misstatements or omissions of material information in any sections, (ii) that the information relating to the District that is included in the Official Statement is accurate, and (iii) that when necessary the information relating to the District has been reviewed by a knowledgeable Employee or other appropriate person; 

(B) draft, or cause to be drafted, for the Official Statement descriptions of (i) any material current, pending or threatened litigation, (ii) any material settlements or court orders and (iii) any other legal issues that are material information for purposes of the Official Statement; and

(C) report any significant disclosure issues and concerns to the Board of Directors (with advice, as necessary, from Bond Counsel, retained Disclosure Counsel, if any, and/or Financial Advisor).

Section 2.02.  Submission of Official Statements to Board of Directors for Approval.  The Disclosure Coordinator shall submit all Official Statements to the Board of Directors for review and approval.  The Board of Directors shall undertake such review it deems necessary.  This may include consultation with the Disclosure Coordinator, Bond Counsel, retained Disclosure Counsel, if any, and/or the Financial Advisor to fulfill the District's responsibilities under applicable federal and state securities laws.

Article III - Annual Report Filings

Section 3.01.  Overview.  Under the Disclosure Agreements the District has entered into in connection with certain of its Securities, the District is required each year to file Annual Reports with the EMMA system.  Such Annual Reports are generally required to include: (1) certain updated financial and operating information as outlined in each Disclosure Agreement, and (2) the District’s audited financial statements.  The documents, reports and notices required to be submitted to the MSRB pursuant to this Policy shall be submitted through EMMA in one or more electronic document format files as required by the Rule at the time of filing, and shall be accompanied by identifying information, in the manner prescribed by the MSRB, or in such other manner as is consistent with the Rule.  To facilitate the District’s Disclosure Agreements the Disclosure Coordinator shall:

(A)      maintain a record of all Disclosure Agreements of the District using a chart which shall identify and docket all deadlines;

(B)      schedule email reminders on the EMMA website for each issue of Securities to help ensure timely filing of financial disclosures;

(C)      ensure that preparation of the Annual Reports commences as required under each specific Disclosure Agreement; and

(D)      comply with the District’s obligation to file Annual Reports by submitting or causing the required (i) annual financial information and operating data and (ii) audited financial statements to be submitted to the MSRB through EMMA.

  1. In the event audited financial statements are not available by the filing deadline imposed by the Disclosure Agreement, the Disclosure Coordinator shall instead timely submit or cause to be submitted unaudited financial statements, with a notice to the effect that the unaudited financial statements are being provided pending the completion of audited financial statements and that the audited financial statements will be submitted to EMMA when they have been prepared.  In the event neither audited nor unaudited financial statements are timely posted, the District shall cause to be filed a "failure to file notice" in accordance with the Rule.  The failure to file notice for audited financial statements shall include information describing the nature and/or cause of the failure to meet the contractual deadline and, if available, an approximate timeframe for when the completed audited financial statement is expected to be submitted. Audited financial statements shall be filed as soon as available. If updated financial and operating information is not posted by the filing deadline, the Disclosure Coordinator shall cause a "failure to file notice" to be posted to EMMA in accordance with the Rule. 
  2. All documents submitted to the MSRB through EMMA that are identified by specific reference to documents already available to the public on the MSRB's Internet website or filed with the SEC shall be clearly identified by cross reference.

Article IV - Listed Event Filings

Section 4.01.  Disclosure of Listed Events.  The District is obligated to disclose to the MSRB notice of certain specified events with respect to the Securities (a "Listed Event").  Employees shall be instructed to notify the Disclosure Coordinator upon becoming aware of any of the Listed Events in the District’s Disclosure Agreements.  The Disclosure Coordinator may consult with Bond Counsel, retained Disclosure Counsel, if any, or the Financial Advisor, to determine if an occurrence is a Listed Event, and whether a filing is required or is otherwise desirable.  If such a filing is deemed necessary, the Disclosure Coordinator shall cause a notice of the Listed Event (a "Listed Event Notice") that complies with the Rule to be prepared, and the Disclosure Coordinator shall cause to be filed the Listed Event Notice as required by the Rule as follows:

  1. Prior to issuance of new Securities after February 27, 2019, a complete list of current Financial Obligations shall be compiled and submitted to the Disclosure Coordinator for continuous monitoring regarding compliance with all Disclosure Agreements entered on or after February 27, 2019. 
  2. The Disclosure Coordinator shall:
  3. monitor and periodically review the Listed Events identified on Exhibit A, in connection with the Disclosure Agreements identified on the chart in Exhibit B to determine whether any event has occurred that may require a filing with EMMA. To the extent Disclosure Coordinator determines notice for an event is not required based on the event not achieving a level of materiality, Disclosure Coordinator shall document the basis for the determination. 
  4. In a timely manner, not in excess of ten (10) business days after the occurrence of the Listed Event, file a Listed Event Notice for Securities to which the Listed Event applies.
  5. For Securities to which the Listed Event or Events are applicable, the Listed Event Notice shall be filed in a timely manner not in excess of ten (10) business days after the occurrence of the Listed Event.
  6. The Disclosure Coordinator shall monitor Securities data on EMMA regarding rating agency reports for rated Securities and may subscribe to any available ratings agency alert service regarding the ratings of any Securities.

Article V = Miscellaneous

Section 5.01.  Documents to be Retained.  The Disclosure Coordinator shall be responsible for retaining records demonstrating compliance with this Policy.  The Disclosure Coordinator shall retain an electronic or paper file ("Transcript") for each Annual Report the District completes.  Each Transcript shall include final versions of documents submitted to the MSRB through EMMA, and any documentation related to determinations of materiality (or immateriality) of Listed Events.  The Transcript shall be maintained for the period that the applicable Securities are outstanding, and for a minimum of five [5] years after the date the final Annual Report for an issue of Securities is posted on EMMA.

Section 5.02.  Education and Training.  The District shall conduct periodic training to assist the Disclosure Coordinator, Employees and the Supervisors, as necessary and appropriate, in understanding and performing their responsibilities under this Policy.  Such training sessions may include a review of this Policy, the disclosure obligations under the Disclosure Agreement(s), applicable federal and state securities laws, including the Listed Events in Exhibit A, and the disclosure responsibilities and potential liabilities of members of District staff and members of the Board of Directors.  Training sessions may include meetings with Bond Counsel, retained Disclosure Counsel, if any, Dissemination Agent, if any, or Financial Advisor, and teleconferences, attendance at seminars or conferences where disclosure responsibilities are discussed, and/or recorded presentations. Disclosure Coordinator shall maintain a record of training activities in furtherance of this Policy.

Section 5.03.  Public Statements Regarding Financial Information.  Whenever the District makes statements or releases information relating to its finances to the public that is reasonably expected to reach investors and the trading markets (including, without limitation, all Listed Event Notices, statements in the annual financial reports, and other financial reports and statements of the District), the District is obligated to ensure that such statements and information are accurate and complete in all material aspects.  The Disclosure Coordinator shall assist the Board of Directors, the Superintendent, and District’s Attorneys in ensuring that such statements and information are accurate and not misleading in any material aspect.  Employees shall, to the extent possible, coordinate statements or releases as outlined above with the Disclosure Coordinator.  Investment information published on the District’s website shall include a cautionary statement referring investors to EMMA as the official repository for the District’s Securities-related data.

EXHIBIT A

LISTED EVENTS

The following events automatically trigger a requirement to file on EMMA within ten (10) business days of their occurrence (listed events are subject to change by the SEC):

(1) Principal and interest payment delinquencies;

(2) Non-payment related defaults, if material;

(3) Unscheduled draws on debt service reserves reflecting financial difficulties

(4) Unscheduled draws on credit enhancements reflecting financial difficulties;

(5) Substitution of credit or liquidity providers, or their failure to perform;

(6) Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax status of the security, or other material events affecting the tax status of the security;

(7) Modifications to rights of security holders, if material;

(8) Bond calls, if material, and tender offers;

(9) Defeasances;

(10) Release, substitution, or sale of property securing repayment of the securities, if material;

(11) Rating changes;

(12) Bankruptcy, insolvency, receivership or similar event of the obligated person[1];

Note to paragraph (b)(5)(i)(C)(12):

For the purposes of the event identified in paragraph (b)(5)(i)(C)(12) of this section, the event is considered to occur when any of the following occur: The appointment of a receiver, fiscal agent or similar officer for an obligated person in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the obligated person, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the obligated person.

(13) The consummation of a merger, consolidation, or acquisition involving an obligated person or the sale of all or substantially all of the assets of the obligated person, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material;

(14) Appointment of a successor or additional trustee or the change of name of a trustee, if material;

Additionally, the following events apply to Disclosure Agreements entered by the District on or after February 27, 2019:

(15) Incurrence of a Financial Obligation of the obligated person, if material[2], or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of the obligated person, any of which affect security holders, if material*; and

(16) Default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a Financial Obligation of the obligated person, any of which reflect financial difficulties.

 

01978111-1\21086-015

Name of Issue/Principal Amount

Date of Issue

Final Maturity Date

CUSIP for Final Maturity

Date by which Annual Reports Must be Filed (or "exemption" under the Rule)

Annual Reports Information to be Filed

Source of Information

Date Information was Filed

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

[1] The term "obligated person" for purposes of the Rule shall mean the party, if other than the District, responsible for the Securities, e.g. in a conduit issue sold through the District, the conduit party would be the "obligated person" under the Disclosure Agreement.

[2] Materiality is determined upon the incurrence of each distinct Financial Obligation, taking into account all relevant facts and circumstances.  A Financial Obligation is considered to be incurred when it is enforceable against the District.  Listed Event Notices for Financial Obligations (e.g. under 15 and 16 above) should generally include a description of the material terms of the Financial Obligation, including: (i) date of the incurrence, (ii) principal amount, (iii) maturity and amortization; (iv) interest rate(s), if fixed, or method of computation, if variable, (v) other appropriate terms, based on the circumstances.  In addition to a summary of material terms, the District may alternatively, or in addition, submit related materials, such as transaction documents (which may require some redaction), terms sheets prepared in connection with the Financial Obligation, or continuing covenant agreements or financial covenant reports.

 

Approved:  December 20, 2021

Reviewed:  November 2022

704.6 (R) POST-ISSUANCE COMPLAINCE REGULATION FOR TAX-EXEMPT OBLIGATIONS

1.   Role of Compliance Coordinator/Board Treasurer

      The Board Treasurer shall:

a)      Be responsible for monitoring post-issuance compliance;

b)      Maintain a copy of the transcript of proceedings or minutes in connection with the issuance of any tax-exempt obligations and obtain records that are necessary to meet the requirements of this regulation;

c)      Consult with bond counsel, a rebate consultant, financial advisor, IRS publications and such other resources as are necessary to understand and meet the requirements of this regulation;

d)      Seek out training and education to be implemented upon the occurrence of new developments in the area and upon the hiring of new personnel to implement this regulation.

2.  Financing Transcripts’ Filing and Retention

      The Board Treasurer shall confirm the proper filing of an IRS 8038 Series return and maintain a transcript of proceedings and minutes for all tax-exempt obligations issued by the school district including, but not limited to, all tax-exempt bonds, notes and lease-purchase contracts. Each transcript shall be maintained until 11 years after the tax-exempt obligation documents have been retired. The transcript shall include, at a minimum:

a)      Form 8038;

b)      Minutes, resolutions and certificates;

c)      Certifications of issue price from the underwriter;

d)      Formal elections required by the IRS;

e)      Trustee statements;

f)      Records of refunded bonds, if applicable;

g)      Correspondence relating to bond financings; and

h)      Reports of any IRS examinations for bond financings.

3.  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:

a)      Obtain a computation of the yield on such issue from the school district's financial advisor;

b)      Create a separate Project Fund (with as many sub-funds as shall be necessary to allocate proceeds among the projects being funded by the issue) into which the proceeds of issue shall be deposited;

c)      Review all requisitions, draw schedules, draw requests, invoices and bills requesting payment

         from the Project Fund;

d)      Determine whether payment from the Project Fund is appropriate and, if so, make payment from the Project Fund (and appropriate sub-fund, if applicable);

            e)      Maintain records of the payment requests and corresponding records showing payment;

f)      Maintain records showing the earnings on, and investment of, the Project Fund;

g)      Ensure that all investments acquired with proceeds are purchased at fair market value;

h)      Identify bond proceeds or applicable debt service allocations that must be invested with a yield-restriction and monitor the investments of any yield-restricted funds to ensure that the yield on such investments do not exceed the yield to which such investments are restricted;

            i)       Maintain records related to any investment contracts, credit enhancement transactions and the bidding of financial products related to the proceeds.

4.  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:

a)      Monitor and ensure that proceeds of each such issue are spent within the temporary period set forth in such certificate;

b)      Monitor and ensure that the proceeds are spent in accordance with one or more of the applicable exceptions to rebate as set forth in such certificate if the school district does not meet the "small  issuer" exception for said obligation;

c)      Not less than 60 days prior to a required expenditure date, confer with bond counsel and a rebate consultant, if the school district will fail to meet the applicable temporary period or rebate exception expenditure requirements of the Tax-Exemption Certificate.  In the event the school district fails to meet a temporary period or rebate exception:

1.   Procure a timely computation of any rebate liability and, if rebate is due, file a Form 8038-T and arrange for payment of such rebate liability;

2.   Arrange for timely computation and payment of yield reduction payments (as such term is defined in the Code and Treasury Regulations), if applicable.

5.  Proper Use of Bond Financed Assets

      The Board Treasurer shall:

a)      Maintain appropriate records and a list of all bond financed assets.  Such records shall include the actual amount of proceeds (including investment earnings) spent on each of the bond financed assets;

b)      Monitor and confer with bond counsel with respect to all proposed bond financed assets;

1.   management contracts;

2.   service agreements;

3.   research contracts;

4.   naming rights contracts;

5.   leases or sub-leases;

6.  joint venture, limited liability or partnership arrangements;

7.   sale of property; or

8.   any other change in use of such asset.

c)      Maintain a copy of the proposed agreement, contract, lease or arrangement, together with the response by bond counsel with respect to said proposal for at least three years after retirement of all tax-exempt obligations issued to fund all or any portion of bond financed assets; and

d)      Contact bond counsel and ensure timely remedial action under IRS Regulation Sections 1.141-12 in the event the school district takes an action with respect to a bond financed asset, which causes the private business tests or private loan financing test to be met.

6.  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:

a)      Appraisals, demand surveys or feasibility studies;

b)      Applications, approvals and other documentation of grants;

c)      Depreciation schedules;

d)      Contracts respecting the project.

 

Approved:  December 20, 2021

704.7 ONLINE FUNDRAISING CAMPAIGNS - CROWDFUNDING

The Cardinal 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.  Any fundraising efforts conducted using the district's name, symbols, or imagery, will be conducted in accordance with all policies, regulations, and rules for fundraising within the district. 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.
 

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:  October 2016

Reviewed:  November 2022

Revised: July 2021

 

705 EXPENDITURES

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 with regard to procurement from certified targeted small businesses, minority-owned businesses, and female-owned businesses.

Prior to August 15 of each year and after analyzing the school district's anticipated procurement level for the current fiscal year, the school board will set a goal of ten percent of the anticipated procurement level to be purchased from certified targeted small businesses. In determining the procurement level, the cost of utilities (heat, electricity, telephone and natural gas) and employees' costs will not be included.  After the goal has been established, the superintendent will file the required Targeted Small Business Procurement form with the Department of Education by August 15.

By July 31 of each year, the superintendent will file a report with the Department of Education outlining purchases of goods and services from targeted small businesses for the previous fiscal year.

The school board and superintendent will encourage targeted small businesses which are not certified with the Department of Inspections and Appeals to become certified targeted small businesses.

Goods and Services
The board shall enter into goods and services contract(s) as the board deems to be in the best interest of the school district. It shall be the responsibility of the superintendent to approve purchases, except those requiring board approval as described belowor as provided by in law. The superintendent may coordinate and combine purchases with other governmental bodies to take advantage of volume price breaks. Joint purchases with other political subdivisions will be considered in the purchase of equipment, accessories, or attachments with an estimated cost of $50,000 or more.

Purchases for goods and services shall conform to the following:
•    The superintendent shall have the authority to authorize purchases without prior board approval and without competitive request for proposals, quotations, or bids for goods and services up to $5,000.
•    For goods and services costing at least $5,000 and up to $25,000], 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, $25,000the competitive request for proposal (RFP) or competitive bid process shall be used and received prior to board approval. RFPs and bids are formal, written submissions via sealed process.

In the event that only one quotation or bid is submitted, the board may proceed if the quotation or bid meets the contract award specifications.
The contract award may be based on several cost considerations including, but not limited to the following:

•    The cost of the goods and services being purchased;
•    Availability of service and/or repair;
•    The targeted small business procurement goal and other statutory purchasing preferences; and
•    Other factors deemed relevant by the board.

The board may elect to exempt certain professional services contracts from the thresholds and procedures outlined above.

The thresholds and procedures related to purchases of goods and services do not apply to public improvement projects.

Public Improvements
The board shall enter into public improvement contract(s) as the board deems to be in the best interest of the school district. ‘Public improvement’ means “a building or construction work which is constructed under the control of a governmental entity and for which either of the following applies: (1) has been paid for in whole or in part with funds of the governmental entity; (2) a commitment has been made prior to construction by the governmental entity to pay for the building or construction work in whole or in part with funds of the governmental entity. This includes a building or improvement constructed or operated jointly with any public or private agency.”

The district shall follow all requirements, timelines, and processes detailed in Iowa law related to public improvement projects. The thresholds regarding when competitive bidding or competitive quotations is required will be followed. Competitive bidding is required for public improvement contracts exceeding the minimum threshold stated in law. Competitive quotations are required for public improvement projects that exceed the minimum threshold amount stated in law, but do not exceed the minimum set for competitive bidding. The board shall approve competitive bids and competitive quotes. If the total cost of the public improvement does not warrant either competitive bidding or competitive quotations, the district may nevertheless proceed with either of these processes, if it so chooses.

The award of all contracts for the public improvement shall be awarded to the lowest responsive, responsible bidder. In the event of an emergency requiring repairs to a school district facility that exceed bidding and quotation thresholds, please refer to IASB sample 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.

 

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    Expenditures
            801.4    Site Acquisition
            802    Maintenance, Operation and Management
            802.3    Emergency Repairs
            803    Selling and Leasing

 

 

Approved July 2000                           

Reviewed November 2022           

Revised     November 2020 

705.01 - R(1): PURCHASING-BIDDING-SUSPENSION AND DEBARRMENT 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:

  1. Obtaining a certification of a party’s compliance with the federal suspension and debarment requirements in connection with any application, bid, or proposal;
  2. Requiring compliance with the federal suspension and debarment requirements as an express condition of any sub-award, purchase, or contract in question; or
  3. Prior to committing to any sub-award, purchase, or contract, check the online Federal System for Award Management at https://sam.gov/portal/SAM/##11 to determine whether the relevant party is subject to any suspension or debarment restrictions.  

 

2 CFR Part 200 Subpart B-General Provisions
200.113 Mandatory Disclosures

A non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Non-Federal entities that have received a Federal award including the term and condition outlined in Appendix XII—Award Term and Condition for Recipient Integrity and Performance Matters are required to report certain civil, criminal, or administrative proceedings to SAM. Failure to make required disclosures can result in any of the remedies described in §200.338 Remedies for noncompliance, including suspension or debarment. (See also 2 CFR part 180, 31 U.S.C. 3321, and 41 U.S.C. 2313.)  It is the responsibility of the Superintendent to timely report to the relevant federal or pass through agency any violations of federal criminal law involving fraud, bribery or gratuity potentially impacting a federal grant.

 

 


I.C. Iowa Code Description
Iowa Code § 26 Bidding
Iowa Code § 285 Transportation Aid
Iowa Code § 28E Joint Exercise of Government Power
Iowa Code § 297 School Houses/Sites
Iowa Code § 301 Textbooks
Iowa Code § 73A Public Contracts and Bonds
Iowa Code § 73 Preferences
Iowa Code §72.3 Divulging Contents of Sealed Bids
I.A.C. Iowa Administrative Code Description
261 I.A.C. 54 Economical Development - Iowa TSB Program
281 I.A.C. 43.25 Transportation - Purchasing

Regulation 705.01-R(1): Purchasing – Bidding - Suspension and Debarment of Vendors and Contractors Procedure

Status: ADOPTED
Original Adopted Date: 03/10/2022 | Last Reviewed Date: 03/10/2022  

705.01-R(2) PURCHASING-BIDDING-USING FEDERAL FUNDS IN PROCUREMENT

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.

 

Legal Reference: 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

 


I.C. Iowa Code Description
Iowa Code § 26 Bidding
Iowa Code § 285 Transportation Aid
Iowa Code § 28E Joint Exercise of Government Power
Iowa Code § 297 School Houses/Sites
Iowa Code § 301 Textbooks
Iowa Code § 73A Public Contracts and Bonds
Iowa Code § 73 Preferences
Iowa Code §72.3 Divulging Contents of Sealed Bids
I.A.C. Iowa Administrative Code Description
261 I.A.C. 54 Economical Development - Iowa TSB Program
281 I.A.C. 43.25 Transportation - Purchasing

Regulation 705.01-R(2): Purchasing – Bidding - Using Federal Funds in Procurement Contracts

Status: ADOPTED
Original Adopted Date: 03/10/2022 | Last Reviewed Date: 03/10/2022  

705.2 PURCHASING ON BEHALF OF EMPLOYEES

Generally, the school district will not purchase items on behalf of employees.  The school district may in unusual and unique circumstances do so.  It is within the discretion of the board to determine when unique and unusual circumstances exist.

No purchase is made unless the employee has paid the school district prior to the order being placed and the employee has agreed to be responsible for any taxes or other expenses due.

 

 

 

Legal Reference:         

Iowa Code § 279.8 (2013).

 

 

Cross Reference:        

703      Budget

 

 

Approved July 2000   

Reviewed November 2022 

Revised                   

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.

Claims for payment of freight, drayage, express, postage, printing, water, lights, telephone, rents, and payment of salaries pursuant to the terms of a written contract may be paid by the board secretary prior to formal audit and approval by the board. In addition the secretary, upon approval of the board president, may issue warrants for approved registrations, claims offering a discount for early payment, approved travel expenses, approved goods and services delivered C.O.D. and other verified bills filed with the secretary when the board is not in session prior to payment of these claims and prior to audit and approval by the board.

The board 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.] or [The board will approve payment for the bills at the board’s regular board 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.

 

Legal Reference:         

Love v. City of Des Moines, 210 Iowa 90, 230 N.W. 373 (1930).

Iowa Code §§ 279.8, .29, .30, .36; 291.12; 721.2(5) (2013).

281 I.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 July 2000                           

Reviewed November 2022          

Revised  April 2011

705.4 EXPENDITURES FOR A PUBLIC PURPOSE

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.

 

NOTE:  All use of public funds should directly serve a public purpose in a clear and transparent manner.  Districts should consider what purchasing and reimbursement flexibility is needed for their district and apply all restrictions equally. 

Legal References: 

Iowa Constitution Art. III, sec. 31;

Iowa Code §§ 68A.505; 279.8; 721.2.

281 I.A.C. 98.70

1979 Op. Atty. Gen., No. 79-4-26

Cross References:

401.7 Employee Travel Compensation

704.1  Local-State-Federal-Miscellaneous Revenue

704.5 Student Activities Fund

705.1 Purchasing-Bidding

705.2 Purchasing on Behalf of Employees

705.3 Payment for Goods and Services

707.5  Internal Controls

905.1 Community Use of School District Facilities & Equipment

 

Approved       September 2019           

Reviewed     November 2022             

Revised                   

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 401.10 – 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. 

705.5 RECEIVING GOODS AND SERVICES

To assure goods and services procured by the school district are properly accounted for and are of the quality and type ordered, goods will be received by the building secretary. Goods and services which do not meet the requirements specified in the purchase order or contract will not be paid for or accepted.

If goods must be delivered to and received by someone other than the board secretary, it shall be the responsibility of that person to inform the board secretary, to assure the goods and services are properly accounted for, and to ensure they are of the quality and type ordered.

 

 

 

 

Legal Reference:         

Iowa Code § 279.8 (2013).

 

 

Cross Reference:        

705      Expenditures

 

 

 

Approved July 2000                     

Reviewed November 2022     

Revised                   

705.6 UNPAID WARRANTS

Generally, the board shall authorize claims to be paid only when sufficient revenue is available for such claims. The board may authorize the payment of claims for which insufficient funds are available.

When the board deems it necessary to authorize warr4ants without sufficient funds available, stamped warrants or anticipatory warrants may be authorized.

It shall be the responsibility of the board secretary to issue anticipatory warrants when needed.

 

 

Legal Reference:         

Iowa Code chs. 74; 74A

 

 

Cross Reference:        

705      Expenditures

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

705.8 WRITTEN CODE OF STANDARDS OF CONDUCT (Food Service Department)

The Cardinal Community School District seeks to conduct all procurement procedures in compliance with stated regulations; and to prohibit conflicts of interest and actions of employees engaged in the selection, award and administration of contracts. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal, State, or local funds 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 employes 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. The officers, employees, and agents of the non-Federal entity may neither solicit nor accept guidelines, favors, or anything of monetary value from contractors or parties to subcontract. However, organizations may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value.  

413 Classified Employee Termination of Employment

Approved December/January 2018   

Reviewed   November 2022                

  

 

 

 

 

 

705.9 REQUISITIONS AND PURCHASE ORDERS

Supplies, equipment, and services may only be approved for purchase by the superintendent. Requisition for supplies, equipment, and services shall be made by employees to their immediate supervisor. Only those purchases approved by the superintendent shall be processed by the school district.

The superintendent may authorize a procedure for the purchase of small, emergency items, usually at a cost of $5,000 or less.

 

 

 

Legal Reference:         

Iowa Code § 279.8

 

 

Cross Reference:        

705      Expenditures

 

 

Approved July 2000                     

Reviewed November 2022                  

Revised    September 2019              

 

706 PAYROLL PROCEDURES

706.1 PAYROLL PERIODS

The payroll period for the school district is bi-monthly.  Employees are paid on the 5th and 20th day of each month.  If this day is a holiday, recess, or weekend, the payroll is paid on the last working day prior to the holiday, recess or weekend.

It is the responsibility of the board secretary to issue payroll to employees in compliance with this policy.

 

 

Legal Reference:         

Iowa Code §§ 20.9; 91A.2(4), .3

 

Cross Reference:        

706.2   Payroll Deductions

 

Approved July 2000                     

Reviewed November 2022       

Revised   October 2018               

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.

Cross Reference:    406.6    Licensed Employee Tax Shelter Programs
    412.4    Classified Employee Tax Shelter Programs
    706.1    Payroll Periods

Approved                       Reviewed      November 2022                  Revised    July 2021             

 

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.

 

 

 

Legal Reference:             

29 U.S.C. Sec. 2 13(a) (2012)

29 C.F.R. Part 541 (2012)

 

Cross References:           

409.8   Licensed Employee Unpaid Leave

414.8      Classified Employee Unpaid Leave

 

Approved             July 2000       

Reviewed: :  November 2022

Revised                        

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 board secretary.   Within 15 business days of receiving the complaint, the board secretary 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 March/April 2011                 

Reviewed                                         

Revised                        

707 FISCAL REPORTS

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

 

 

Cross Reference:        

206.3   Secretary

210.1   Annual Meeting

707      Fiscal Reports

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

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 all other funds.  This report is in written form and sent to the board with the agenda for the board meeting.  The treasurer will also furnish the board with a 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

 

 

Cross Reference:        

206.4   Treasurer [or 206.3, Secretary-Treasurer]

210.1   Annual Meeting

707      Fiscal Reports

 

 

Approved July 2000                     

Reviewed November 2022     

Revised    July 2021              

 

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

1952 Op. Att'y Gen. 133.

 

 

Cross Reference:        

206.3   Secretary

 

 

Approved July 2000   

Reviewed November 2022

Revised                   

707.4 AUDIT

In accordance with state law, 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. Annual audit reorts shall remain on file as permanent records of the school district.

 

 

 

Legal Reference:         

Iowa Code § 11.6

 

 

Cross Reference:        

701      Financial Accounting System

707      Fiscal Reports

 

 

Approved July 2000                     

Reviewed November 2022               

Revised   July 2021               

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 controls are used to help ensure the integrity of district financial and accounting information. Adherance to district-established internal control procedures is the responsibility of all employees of the school district. The superintendent, business manager and board secretary shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the school district subject to review and approval by the board.  Administrators shall be alert for any indication of fraud, financial impropriety, or irregularity within the administrator’s area of responsibility.

Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor or the superintendent.  The superintendent  shall have primary responsibility for any necessary investigations and shall coordinate investigative efforts with the board’s legal counsel, auditing firm, and other internal or external departments and agencies, including law enforcement officials, as the superintendent  may deem appropriate.

Employees bringing forth a legitimate concern about a potential impropriety will not be retaliated against and those who do retaliate against such an employee will be subject to disciplinary action up to, and including, discharge.

In the event the concern or complaint involves the superintendent, the concern shall be brought to the attention of the board president or vice-president, who shall be empowered to contact the board’s legal counsel, auditor of state's office, insurance agent, auditing firm, and any other agency to investigate the concern or complaint.

The superintendent or board president shall ensure the Auditor of State's office is notified as required by law of any suspected embezzlement, theft or other financial irregularity pursuant to Iowa law.  The superintendent and/or board president in coordination with the Auditor of State's office, will determine whether to conduct a complete or partial audit.  The superintendent is authorized to order a complete forensic audit if, in the superintendent's judgment, such an audit would be useful and beneficial to the school district.  In the event there is an investigation, records will be maintained for use in the investigation.  Individuals found to have altered or destroyed records will be subject to disciplinary action, up to and including termination.

 

Legal References:      

American Competitiveness and Corporate Accountability Act of 2002, Pub. L. No. 107-204.

Iowa Code ch. 11, 279.8

 

Cross References:       

 

Approved April 2011                         

Revised November 2022                  

Reviewed __________

707.5R1 INTERNAL CONTROLS PROCEDURES

Fraud, financial improprieties, or fiscal irregularities include, but are not limited to:

 

  • Forgery or unauthorized alteration of any document or account belonging to the district.
  • Forgery or unauthorized alteration of a check, bank draft, or any other financial document.
  • Misappropriation of funds, securities, supplies, or other assets.
  • Impropriety in the handling of money or reporting of financial transactions.
  • Profiteering because of “insider” information of district information or activities.
  • Disclosing confidential and/or proprietary information to outside parties.
  • Accepting or seeking anything of material value, other than items used in the normal course of advertising, from contractors, vendors, or persons providing services to the district.
  • Destroying, removing, or inappropriately using district records, furniture, fixtures, or equipment.
  • Failing to provide financial records to authorized state or local entities.
  • Failure to cooperate fully with any financial auditors, investigators or law enforcement.
  • Any other dishonest or fraudulent act involving district monies or resources.
  • Acting for purpose of personal financial gain, rather than in the best interest of the district.
  • Providing false, inaccurate, or misleading financial informtion to district administrators or the board of directors.

The superintendent, and/or board president, 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.  The superintendent may engage qualified independent auditors to assist in the investigation.

If an investigation substantiates the occurrence of a fraudulent activity, the superintendent, and/or board president or board vice-president if the investigation centers on the superintendent, shall issue a report to the board and appropriate personnel.  The 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.

708 CARE, MAINTENANCE AND DISPOSAL OF SCHOOL DISTRICT RECORDS

School district records are housed in the central administration office of the school district. It is the responsibility of the superintendent and board secretary to oversee the maintenance and accuracy of the records. The following records are kept and preserved according to the schedule below:

    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                                                                10 years
    Cancelled warrants, check stubs, bank
    statements, bills, invoices, and related record               5 years
    Recordings and minutes of closed meetings                 1 year
    Program grants                                                              As determined by the grant
    Nonpayroll personnel records                                       10 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 above for audit purposes or otherwise, the record shall be retained beyond the listed period as long as is required for the resolution of the issue by the federal or state agency.

Employees' records are housed in the central administration office of the school district. The employees' records are maintained by the superintendent, the building administrator, the employee's immediate supervisor, and the board secretary.

An inventory of the furniture, equipment, and other nonconsumable items other than real property of the school district is conducted annually under the supervision of the superintendent. This report is filed with the board secretary.

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 shall 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 in the [insert location] 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.

 

 

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).
    City of Dubuque v. Telegraph Herald, Inc., 297 N.W.2d 523 (Iowa 1980).

 

Cross Reference:    

206.3    Secretary
215    Board of Directors' Records
401.5    Employee Records
506    Student Records
901    Public Examination of School District Records

 

Approved July 2000                           

Reviewed November 2022           

Revised  July 2021

709 INSURANCE PROGRAM

709.1 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.

Insurance of buildings, structures, or property in the open will not generally be purchased to cover loss exposures below $1000 unless such insurance is required by statute or contract.

The board may retain a private organization for fixed 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.  The superintendent 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

1974 Op. Att'y Gen. 171.

1972 Op. Att'y Gen. 676.

 

 

Cross Reference:        

205      Board Member Liability

804      Safety Program

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

709.2 INSURANCE REPORT

At the annual meeting each year, the board shall receive a written report indicating the types, amounts of and cost of the insurance for the school district. This report shall include bonds purchased for employees and board officers. It shall be in written form and sent to the board with the agenda for the board meeting.

 

 

Legal Reference:         

Iowa Code §§ 279.8 (2013).

                                   

 

Cross Reference:        

709.1   Insurance Program

                                   

 

 

Approved July 2000                     

Reviewed November 2022      

Revised                   

 

710 SCHOOL NUTRITION PROGRAM

710.01 SCHOOL NUTRITION PROGRAM

The school district will operate a school nutrition program in each attendance center.  The school nutrition program will include hot meals through participation in the National School Lunch Program.  Students may bring their lunches from home and purchase milk or juice and other incidental items.

School nutrition program facilities are provided to serve students and employees when school is in session and during school-related activities.  They may also be used under the supervision of the head cook 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 nutition program is operated on a nonprofit basis.  The revenues of the school nutrition program will be used only operations or improvement of such program.  Supplies of the school nutrition program will only be used for the school nutrition program.

The board will set, and annually review, the prices for school nutrition programs.  It is the responsibility of the superintendent to make a recommendation regarding the prices of the school nutrition programs, in accordance with federal and state law.

It is the responsibility of the food service director to administer the program and to cooperate with the superintendent and appropriate personnel for the proper functioning of the school nutrition 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.

 

 

 

Legal Reference:         

42 U.S.C. §§ 1751 et seq. (2012).

7 C.F.R. Pt. 210 et seq. (2012).

Iowa Code ch. 283A (2013).

281 I.A.C. 58.

 

 

Cross Reference:        

710      School Food Services

905      Use of School District Facilities and Equipment

 

 

Approved July 2000                     

Reviewed November 2022      

Revised      August 2022         

 

710.01 SCHOOL NUTRITION PROGRAM R(1)

USDA Child Nutrition Programs in Iowa

Procedures for Handling a Civil Rights Complaint

  1. 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.
     
  2. 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.
     
  3. 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.
     
  4. 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).
      ​​​​​​​
  5. USDA is the cognizant agency for the Child Nutrition Programs listed and therefore is the first contact for the six protected classes listed in #1 above, for complaints received within 180 days. Civil rights complaints must be submitted to the USDA Office of Civil Rights within five calendar days of receipt and no later than 180 days of the discriminatory act. The link for submission of a complaint is: program.intake@usda.gov
     
  6. In Iowa, protected classes also include sexual orientation, 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/.

710.01E1 SCHOOL NUTRITION PROGRAM 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:
1.
Mail: U.S. Department of Agriculture
Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington, D.C. 20250-9410
2.
Fax: 202-690-7442
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/.
Code No.710.1E1

710.01E2 CHILD NUTRITION PROBGRAM COMPLAINT FORM

 
 
 
 
CHILD NUTRITION PROGRAMS CIVIL RIGHTS COMPLAINT FORM

Complaint Contact Information:
Name:
Street Address, City, State, Zip:
County: Area Code/Phone:
Email Address:
Complaint Information:
1. Specific name and location of the entity and individual delivering the service or benefit:
2. 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:
3. 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)?
4. List the names, titles, and business addresses of persons who may have knowledge of the alleged
discriminatory action:
5. List the date(s) during which the alleged discriminatory actions occurred, or if continuing, the duration of such
actions:
6. Date complaint received:
7. Person receiving complaint:
8. 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. 12/2021

 
 

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 will make every effort to eliminate any social stigma attached to, and prevent the overt identification of, students who are eligible for free and reduced price meals.

The district shall annually notify all families of the availability, eligibility criteria, and application procedures for free or reduced price meals in accordance with state and federal law.  

It is the responsibility of the Food Service Director 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 Food Service Director.

Employees, students not qualified for free meals and others will be required to pay for meals consumed.

It is the responsibility of the superintendent to develop administrative regulations for implementing this policy.

NOTE: There are two places in the policy where the board must identify the positions that will be responsible for determining free or reduced cost meal eligibility for the school nutrition programs. The board should ensure that the positions identified are authorized by applicable law to process information as designated in the National School Lunch program annual application.

 

 

 

 

 

 

Legal Reference:    42 U.S.C. §§ 1751 et seq..
    7 C.F.R. §§ 210 et seq..
    Iowa Code § 283A.
    281 I.A.C. 58.

Cross Reference:    710.1    School Nutrition Program
    710.3    Vending Machines
    710.4    Meal Charge Policy

 

Approved                       Reviewed        November 2022                Revised        September 2019        

 

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 building principal.  Purchases from the vending machines will reflect the guidelines in the Wellness Policy 507.9.

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. (2012).

7 C.F.R. Pt. 210 et seq. (2012).

Iowa Code ch. 283A (2013).

281 I.A.C. 58.

 

 

Cross Reference:        

504.5   Student Fund Raising

710      School Food Services

 

 

Approved July 2000                     

Reviewed November 2022      

Revised April 2011

 

710.4 MEAL CHARGES

In accordance with state and federal law, the [insert district name] 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.

The Child Nurtition Program operates as a separate entity and a stand-alone non-profit business supporting the total education of each child through the provision of nutritional meals. The program goal is to serve nutritious meals and food to all clients at a minimum cost.                                                      

Students who are required to pay for meals are expected to provide payment in a timely fashion. However, the school board recognizes that on occasion students may need to charge a meal. Therefore, each student is allowed $10.00 meal charges. Students may not charge a la carte items. In addition, students may not purchase a la carte items if there are outstanding charges. Daily emails will be provided to allow parents/guardians to know their lunch balances. Parents/guardians can also call Heather Smith at 641-652-7531 ext 3257 to inquire about lunch balances.

Once a $10.00 negative balance has been noted, an alternate meal consisting of a cheese sandwich, fruit or vegetable and a carton of milk will be provided. Students and school staff may prepay in the cafeteria or pay at the time of purchase. School staff may charge up to $6.00. Staff members must also pay for any extra food purchases to comply with Federal Nutrition guidelines. Visitors are not allowed to charge. Parents/guardians can also prepay on our school website under food service.

The district is committed to helping families in time of crisis and in assisting with filing free/reduced lunch documentation. Information can be foudn on our website and also by contacting Heather Smith at 641-652-7531 ext 3257. Families that have unique circumstances should contact the superinendent to discuss the concern. It is the discretion of the superintendent to adjust the policy above in a case-by-case situation.

Communication of the Policy

The policy and supporting information regarding meal charges shall be provided in writing to:
•    All households at or before the start of each school year;
•    Students and families who transfer into the district, at time of transfer; and
•    All staff responsible for enforcing any aspect of the policy.  

Records of how and when the policy and supporting information was communicated to households and staff will be retained.

The superintendent may develop an administrative process to implement this policy.

 

 

Legal Reference:     42 U.S.C. §§ 1751 et seq.
            7 C.F.R. §§ 210 et seq.
U.S. Dep’t of Agric., SP 46-2016, Unpaid Meal Charges: Local Meal Charge Policies (2016).
U.S. Dep’t of Agric., SP 47-2016, Unpaid Meal Charges: Clarification on Collection of Delinquent Meal Payments (2016).
U.S. Dep’t of Agric., SP 57-2016, Unpaid Meal Charges: Guidance and Q&A (2016).
            Iowa Code 283A.
            281 I.A.C. 58.
            
Cross Reference:     710.1    School Food Program
            710.2    Free or Reduced Cost Meals Eligibility
            710.3    Vending Machine

 

Approved                       Reviewed       November 2022                 Revised  March 19, 2018               

 

710.7 SEVERE FOOD ALLERGIES

The incidence of severe food allergies in the general population is increasing.  Anaphylactic shock can be caused when an allergic person is exposed to even a small amount of the allergen.  Exposure can occur by swallowing, touching, and/or inhaling airborne particles or absorbing residues from other surfaces.  Peanuts/nuts are the most common cause of fatal food reactions.  In order to minimize the incidence of life threatening allergic reactions, the Cardinal Community School District will maintain a system-wide emergency plan for addressing life threatening allergic reactions.  Training and education for Cardinal School employees, as well as building based student education, will occur to raise the level of awareness.  Further, the District will utilize proactive procedures to minimize the chance of a child experiencing a life threatening allergic reaction.

1.      At the Elementary, school staff and parents in classrooms where one or more students with a life threatening allergy will be notified of the health threat and be provided with a list of foods and materials to avoid.

2.      The district requests that parents and students avoid including peanuts/nuts and peanut/nut products in lunches and snacks in grades PreK-12th.  Elementary students who bring cold lunch will be required to eat lunch at a separate table.

3.      NO HOMEMADE TREATS OR FOOD ITEMS, for students, will be brought into our schools either by parents or staff.  All treats must be commercially prepared and packaged for distribution with intact ingredient labels.  Classrooms with students who have life threatening allergies may have more specific guidelines.

4.      Food preparation will not be allowed in the academic curriculum at the elementary level.  An exception may be made for food preparation as related to the IEP of individual student’s goals served in special education.

5.      At the Elementary - NO TYPE OF FOOD OR CANDY ITEM may be used as a part of a craft project or any elementary school project related to the curriculum whether made at home or school.

School Nurse Responsibilities:

1.      To work with parents, health care providers, and school staff to develop the student’s Individualized Health Plan (IHP) and Emergency Health Plan (EHP) and to update these plans yearly and more often as needed.

2.      To instruct staff, who interact with the student on a regular basis, in the dynamics of the student’s food allergy, to recognize symptoms of a reaction and to know what to do in an emergency.

3.      To train designated staff in the EHP.  This could include training in giving emergency medications and/or administering the epinephrine auto-injector.

4.      To make educational information available to staff, students, and the community when requested.

5.      To reinforce self-management of students in dealing with their food allergies.

Student Responsibilities:

1.      Never trade food or share utensils with other students.

2.      Be aware of the signs and symptoms of a reaction to known allergens.

3.      Notify an adult immediately if he/she has eaten something that may contain the known allergen.

4.      Participate in the development of his/her IHP and EHP, including signing and complying with the epinephrine auto injector contract, if indicated.

       

 

Legal Reference:         

 

 

 

 

 

Cross Reference:        

 

 

 

Approved   Dec. 14, 2009            

Reviewed November 2022    

Revised                   

710.9 BEFORE AND AFTER SCHOOL DAYCARE PAYMENT POLICY

The before and after school program operates and a separate entity and as stand-alone non-profit business supporting parents that need additional childcare before and after school.

Parents are expected to provide payment in a timely fashion. Childcare bills will be generated and handed out to parents/guardians on Monday for the charges of the week before. Payments are due every Wednesday. Services will not be offered if payments are not made in a timely fashion. Parents will be notified if childcare services will be ended due to non-payment of charges. The district will use an electronic billing system to be more efficient. Each child will have a password for checking in and out.

The district is committed to helping families in time of crisis. Families that have unique circumstances should contact the superintendent to discuss the concern. It is the discretion of the superintendent to adjust the policy above in a case-by-case situation.

 

 

Approved October 2016                 

Reviewed      November 2022                                     

Revised                                    

711 TRANSPORTATION

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.

 

 

 

Legal Reference:         

20 U.S.C. §§ 1401, 1701 et seq. (2012).

34 C.F.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 July 2000                           

Reviewed November 2022             

Revised                   

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 recording devices are student records subject to school district confidentiality, board policy and administrative regulations.

After 3 warnings for bad conduct, the building principal will have the authority to suspend transportation privileges of the student or impose other appropriate discipline. Unless behavior is serious and the superintendent may suspend on first offense.

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; 32

 

 

Cross Reference:        

503      Student Discipline

506      Student Records

 

 

Approved July 2000   

Reviewed November 2022

Revised     July 2021             

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.  Video cameras may be in operation on the school buses.

 

1.      Bus riders will be at the designated loading point before the bus arrival time.

2.      Bus riders will wait until the bus comes to a complete stop before attempting to enter.

3.      Riders must not extend arms or heads out of the windows at any time.

4.      Aisles must be kept cleared at all times.

5.      All bus riders will load and unload through the right front door.  The emergency door is for emergencies only.

6.      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.

7.      A rider may be assigned a seat by the driver.

8.      Riders who damage seats or other equipment will reimburse the district for the cost of the repair or replacement.

9.      Riders are not permitted to leave their seats while the vehicle is in motion.

10.  Waste containers are provided on all buses for bus riders' use.

11.  Permission to open windows must be obtained from the driver.

12.  Classroom conduct is to be observed by students while riding the bus except for ordinary conversation.

13.  The driver is in charge of the students and the vehicle, and the driver is to be obeyed promptly and cheerfully.

14.  Students will assist in looking after the safety and comfort of younger students.

15.  A bus rider who must cross the roadway to board or depart from the bus will pass in front of the bus (no closer than 10 feet), look in both directions and proceed to cross the road or highway only on signal from the driver.

16.  Students will not throw objects about the vehicle nor out through the windows.

17.  Shooting paper wads, squirt guns or other material in the vehicle is not permitted.

18.  Students will keep feet off the seats.

19.  Roughhousing in the vehicle is prohibited.

20.  Students will refrain from crowding or pushing.

21.  The use or possession of alcohol, tobacco or look-alike substances is prohibited in the vehicle.

22.  The Good Conduct Rule is in effect.

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 videotapes may be used as evidence in a student disciplinary proceeding.

 

Student Records

The content of the videotapes 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 videotape 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 videotape 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 Cardinal 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 videotapes may be used in a student disciplinary proceeding.  The content of the videotapes are confidential student records and will be retained with other student records.  Videotapes 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 videotapes of their child if the videotapes 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 Videotapes

The school district will review videotapes randomly.  The videotapes may be re-circulated for erasure after 7 days.

Viewing of videotapes is limited to the individuals having a legitimate educational purpose.  A written log will be kept of those individuals viewing the videotapes stating the time, name of individual viewing and the date the videotape was viewed.

 

Video Monitoring System

Video cameras will be used on all school district 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.

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 (2013).

 281 I.A.C. 41.412.

 

 

Cross Reference:        

504      Student Activities

  711      Transportation

 

 

Approved July 2000                           

Reviewed  November 2022           

Revised                   

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, 412

 

 

Cross Reference:        

603.2   Summer School Instruction

711      Transportation

 

 

Approved July 2000                           

Reviewed November 2022           

Revised                   

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

 

 

Cross Reference:        

711      Transportation

 

 

 

Approved July 2000                     

Reviewed:  November 2022     

Revised                   

 

711.6 TRANSPORTATION OF NONSCHOOL GROUPS

Only in unusual circumstances will the board make school district transportation vehicles available to local nonprofit entities which promote cultural, educational, civic, community, or recreational activities for transporting to and from nonschool-sponsored activities in the state.

In the event school district transportation vehicles are made available to local nonprofit entities, it is the responsibility of the superintendent to develop administrative regulations for application for, use of, and payment for using the school district transportation vehicles.

 

 

 

Legal Reference:         

Iowa Code §§ 285.1(21), .10(9), (10)

281 I.A.C. 41.412; 43.10.

 

 

Cross Reference:        

711      Transportation

900      Principles and Objectives for Community Relations

 

 

Approved July 2000                           

Reviewed November 2022       

Revised                   

 

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

281 I.A.C. 41.412; 43.40.

 

 

Cross Reference:        

503      Student Discipline

 507      Student Health and Well-Being

804.2   Warning Systems and Emergency Plans

 

 

Approved July 2000   

Reviewed November 2022

Revised    July 2020           

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.  The superintendent will be assisted by the actual "on location" decisions and reports of the drivers.

Several drivers each year will be specially designated to report weather and road conditions by bus radio when requested to do so.  Other employees and students will be notified by commercial radio and the call em all notification system when school is cancelled or temporarily delayed.  When school is cancelled because of weather anywhere in the school district, all schools will be closed.

When weather conditions deteriorate during the day after school has begun, cancellation notices will be announced by commercial radio and the call em all notification system.  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.

 

 

 

Legal Reference:         

Iowa Code § 279.8 (2013).

 

 

Cross Reference:        

601.2   School Day

 

 

Approved July 2000                     

Reviewed November 2022       

Revised  April 2011

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

 

 

Cross References:       

403      Employee Health and Well-Being

 507      Student Health and Well-Being

711      Transportation

 

 

 

Approved July 2000                           

Reviewed November 2022            

Revised                   

 

711.09 ANTI-IDLING PROCEDURE AND POLICY

Cardinal Community School District is strongly committed to:

  1. Reducing environmental pollutants that are emitted by the district’s buses while unnecessarily idling. The unnecessary idling of vehicles emits pollutants that may impact students and others  respiratory health.
  2. Reducing fuel costs by eliminating unnecessary idling that wastes fuel.

To help reduce environmental pollution and reduce wasted fuel the Cardinal CSD has established the following administrative policy, procedures and guidelines for idling buses:

Warm-Up Idling time for Cardinal CSD buses will be determined by the temperature that appears on the thermometer that is on each bus. Idling time for buses will be determined by using the following temperature scale:

                                    Temperature                                        Maximum Idling Time

                                    33 degrees & above                             3-5 minutes

                                    20 to 32 degrees                                  5-7 minutes

                                    8 to 19 degrees                                    8-10 minutes

                                    7 degrees & below                               12 minutes

After idling warm-up time, the bus driver will depart slowly from their parking area and continue to increase speed slowly to allow the bus to warm-up further.

Idling time may be adjusted under certain circumstances by permission of the Cardinal Transportation Director and/or Cardinal Superintendent.

School Loading Idling buses while loading students after school will not be allowed. When bus drivers pull the bus they are driving into the bus line-up for picking up students at both the elementary and secondary building, they will turn off the bus engine. Buses will not be restarted until all students are on the buses and the buses are ready to depart. By turning bus engines off while waiting for students to load will prevent Cardinal bus drivers from breathing harmful emitted pollutants from buses surrounding them and will eliminate the breathing of harmful pollutants by students while boarding Cardinal buses.

Disciplinary Action A bus driver not following the Anti-Idling policy and procedures of the Cardinal CSD will be reprimanded in writhing. If the bus driver again fails to follow the Anti-Idling Policy and procedure the bus driver will be suspended from driving without pay for three days.

 

Approved March 2008                       

Reviewed November 2022            

Revised                   

711.10 TRANSPORTATION EQUIPMENT

The school district shall purchase transportation vehicles which meet the requirements of the board and the Iowa Department of Education. The purchase of such vehicles shall be in compliance with board policy.

The district shall utilize three-point-lap-shoulder belts on district school buses as required by state law.

School district student transportation vehicles shall be inspected by the Iowa Department of Education. It shall be the responsibility of the superintendent to arrange for the inspection of the school district transportation vehicles requiring inspection and to develop a program for routine maintenance of school district vehicles.

 

 

 

Legal References:       

Iowa Code §285.10(3) (2013).

28I I.A.C. 43.30-.31, .41

 

Cross References:       

705.5   Purchasing-Bidding

 711      Transportation

 

Approved July 2000                           

Reviewed October 2016             

Revised     November 2022             

711.11 SCHOOL VEHICLE ROUTES

The board shall annually approve and review the school district bus routes. It shall be the responsibility of the superintendent to develop the school bus routes keeping in mind the safety of the students, the size of the school buses, the length of the route, the cost to the school district, and other factors deemed relevant by the superintendent. The superintendent shall also develop emergency school bus routes that may be necessary due to weather or other conditions.

The Cardinal Community School developed an emergency hard surface route plan. The purpose of this plan is to provide a bus transportation system on days when it is not possible to run the buses on gravel roads. In situations such as drifted or icy country gravel roads, or soft surface gravel roads, this plan will be implemented. You will also find a copy of this plan on our website www.cardinalcomet.com

Announcement concerning implementation of the Emergency Hard Surface Route plan will be made on the radio and television stations listed below. The decision for implementing this plan will normally be made no later than 6:30 a.m. In addition to the Call Em All notification system.

Albia KLBA - FM 96.7

KCCI - TV

Fairfield KMCD -KICK 96 - AM 1570

Ottumwa KBIZ - AM 1240

KLEE - AM 1480

KTVO - TV Channel 3

KRKN-KISS - 101.5

KOTM - 97.7

 

Approved:

Revised:   October 2016

Reviewed:  November 2022

711.12 DISCRETIONARY STOPS BY SCHOOL VEHICLES

The school district is required to provide a certain level of transportation service to its resident students. The board has complete discretion to provide additional transportation service to its resident and nonresident students. School district transportation vehicles may, at the discretion of the board, make special stops on the bus route as a courtesy to the passengers. Changes in the bus route for discretionary stops must be reviewed by the board.

It shall be the responsibility of the superintendent to recommend to the board whether a school vehicle will make a discretionary stop. In making this recommendation, the superintendent shall consider the safety of the students, the size of the school buses, the length of the route, the cost to the school district,  and other factors deemed relevant by the board or superintendent.

 

 

Legal References:       

Iowa Code §285.10 (2013).

28I I.A.C. 43.30

 

Cross References:       

711      Transportation

 

Approved July 2000                           

Reviewed  November 2022          

Revised                   

 

712 TECHNOLOGY AND DATA SECURITY

The Cardinal CSD recognizes the increasingly vital role technology plays in society.  It is the goal of the district to embrace technology as a resource to further educate our students, and better prepare students for the future.  It is the intent of the district to support secure data systems in the district, including security for all personally identifiable information (PII) that is stored digitally on district-maintained devices, computers and networks.  Technology also has incredible potential to support increased efficiency, communication and growth through collaboration among administration, students, staff, employees and volunteers. 

However, with this growth opportunity comes increased potential for valuable sensitive data to become public.  The district takes seriously its responsibility to protect private data. The purpose of this policy is to ensure the secure use and handling of all district data, computer systems, devices and technology equipment by district students, employees, and data users. 

The district supports the use of third-party vendors to perform necessary education functions for the district.  Utilizing third party vendors to outsource functions the district would traditionally perform provides a cost-effective means to deliver high quality educational opportunities to all students.  However, it is paramount that third party vendors with access to sensitive data and PII of district students, employees and data users be held to the highest standards of data privacy and security.

The selection of third-party vendors shall be in accordance with appropriate law and policy.  Third-party vendors with access to PII shall meet all qualifications to be designated as a School Official under the Family Educational Rights and Privacy Act (FERPA). The board shall ensure that any approved contract with a third-party vendor will require that the vendor comply with all applicable state and federal laws, rules, or regulations, regarding the privacy of PII. 

It is the responsibility of the superintendent to develop procedures for the district to enhance the security of data and the learning environment.  The procedures shall address, but not be limited to, the following topics: 

Access Control –Access control governs who may access what information within the district and the way users may access the information. Increased access to secure networks and data will inevitably increase the risk of security compromise to those networks and data.  It is the responsibility of the superintendent to develop procedures for determining which individuals will have access to district networks, devices and data; and to what extent such access will be granted.  System and network access will be granted based upon a need-to-have requirement, with the least amount of access to data and programs by the user as possible. 

Security Management –Security management addresses protections and security measures used to protect digital data.  These include measures related to audits and remediation, as well as security plans for responding to, reporting and remediating security incidents.  It is the responsibility of the superintendent to develop procedures to govern the secure creation, storage and transmission of any sensitive data and personally identifiable information (PII).  The superintendent or designee shall implement network perimeter controls to regulate data moving between trusted internal resources to external entities.

Technology and Data Use Training –Technology and data use training addresses acceptable use best practices to safeguard data for students, employees and staff.  It is the responsibility of the superintendent to develop procedures for creating and administering a training program on proper data and technology use. The training shall address the proper use and security of all district owned or controlled technology, devices, media and data.  Training should be administered to all district data users.  The training program should be updated and presented to the school board for approval on an annual basis. 

In furtherance of this policy, the superintendent or designee shall be responsible for overseeing district-wide data and technology security, to include development of standards and procedures and adherence to the administrative procedures defined in this document.

Legal References: 

20 U.S.C. §1232g; 34 C.F.R. Part 99

47 U.S.C. §254

20 U.S.C. §6777

Iowa Code §§ 279.70; 715C

Cross References: 

401.13  Staff Technology Use/Social Networking

506.1  Student Records

605.4  Technology in the Classroom

Approved   September 2019  Reviewed   November 2022  Revised