700 Non-Instructional Operations and Business Services

The school district's non-instructional services and business operations assist in the delivery of the education program and include, but are not limited to, transportation, the school lunch program, and child care. The board, as it deems necessary, will provide additional non- instructional services to support the school district’s education program. It shall be the goal of the board to provide non-instructional services and to conduct its business operations and use of public funds in an efficient manner.

Expenditure for Public Purpose

The Board of Directors recognizes and supports the principle that District funds are to be expended only for legitimate public purposes and not for private personal gain for which services of comparable value have not been rendered to the District. The Board of Directors believes it is important to designate those expenditures for officers, directors, employees, and volunteers, which are in addition to salaries and benefits authorized and/or specified in Code 400 and legitimate expense reimbursements, which serve a legitimate public purpose.

The Board of Directors authorizes the expenditure of District funds for District officers, directors, employees, and volunteers for the following purposes, as these are commonly-granted benefits for employees and volunteers in public and private organizations which aid in recruitment of personnel, promote improvement of staff morale and cooperation, assist in building a commitment to the District, and improve employee and business efficiency, thus assisting in creating a more productive learning environment:

  • Mementos for employees for recognition of 25 years of service to the District, with the mementos not to exceed $50 each in cost to the District.

  • A retirement appreciation function once per year to recognize retiring employees 

  • A recognition item upon the retirement of an employee, with the recognition item not to exceed $75 in cost to the District.

  • A recognition item upon the end of service by a Board member not to exceed $50 each in cost to the District.

  • Staff welcome and appreciation meal which Board members and employees attend (a limited number of invited community members may be invited also), once per school year, to recognize employee contributions and to promote communication between Board members, administrators, and other staff members, with the cost of the meal to the District not to exceed $10 per attendee.

  • Meals for licensed interviewees (and if the interviewee is an administrative candidate, the interviewee’s spouse) and members of the interview committee accompanying the interviewee at the time of an interview not to exceed $10  per attendee if the interview extends over lunch and/or dinner.

  • Meals on-site during staff development (in-service) meetings, committee meetings, and meetings hosted at Knoxville with the costs of the meals to the District not to exceed $10 per attendee. This is to promote a more efficient day so that staff members and attendees do not leave the premises.

  • A volunteer appreciation function which Board members, employees, and volunteers may attend once a year to recognize the contributions of volunteers with the cost not to exceed $3 per attendee and where tokens of appreciation may be given to volunteers not to exceed $3 per volunteer in cost to the District.

The Board of Directors also authorizes the expenditure of District funds for coffee and soft drinks in the school buildings. Coffee, soft drinks, light refreshments, such as cookies, may also be made available at Board and committee meetings to promote a welcoming environment and as a common courtesy for individuals who travel to the District building for attendance at District meetings and conferences.

No District funds will be used to pay the cost of any alcoholic beverage and no alcoholic beverage will be available on school grounds.

 

Approved:        10/21/2019                   Reviewed:                     Revised:   

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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

701.1 Depository of Funds

Each year at its annual meeting, the board shall designate by resolution the name and location of the Iowa located financial depository institution or institutions to serve as the official school district depository or depositories. The board will also designate the maximum amount which may be kept on deposit in each bank.  This amount will be designated the first time a new depository is identified, and will be reviewed at least once every five years or when an increase or additional depository is needed. The amount stated in the resolution must be for all depositories and include all of the school district's funds.

It is the responsibility of the board secretary to include the resolution in the minutes of the meeting.

 

 

Approved:        10/21/2019                   Reviewed:                     Revised: 02/26/2024

701.2 Transfer of Funds

When the necessity for a fund has ceased to exist, or when the board is given authority to transfer categorical or other funds and has met the conditions of exercising the authority, the balance may be transferred to another fund or account or the expenditures may be directed by board resolution, as required. 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 or when authority to exercise local discretion to expend funds flexibility has been granted. Voter approval is required to transfer monies to the general fund from the capital projects fund and debt service fund unless state authority allows such transfer without a vote.

If all requirements for district use of funds under the Preschool Foundation Aid, Professional Development Supplement, Home School Assistance Program, Teacher Leadership Supplement or any discontinued fund teacher  have been met and funds remain unexpended and unobligated at the end of the fiscal year, the district may transfer all or a portion of remaining funds by passage of a board resolution into the district’s flexibility account in accordance with law.  Before the expenditure of amounts in the flexibility account, the district shall publish notice of the time, date, and place of a public hearing on the proposed resolution approving said expenditures. The board must find and certify that the statutory requirements of each original source of funds have been met before adopting the resolution approving the expenditures. The district will present a copy of the signed board resolution to the Department of Education.

The District may transfer by board resolution from the general fund to the student activity fund an amount needed to purchase or refurbish protective and safety equipment required for any extracurricular interscholastic athletic contest or competition sponsored or administered by the Iowa High School Athletic Association of Iowa Girls High School Athletic Union.

If the before and after school program exceeds the amount necessary to operate the program, the excess amount may, following a public hearing, be transferred by resolution of the board of directors of the school corporation for deposit in the general fund of the school corporation to be used for school district general fund purposes. The district will present a copy of the signed board resolution to the Department of Education.

Beginning in FY 2024, unexpended and unobligated dollars that remain at the end of a fiscal year in addition to ongoing revenues may be transferred to the Teacher Salary Supplement (TSS) program from Professional Development Supplement (PDS), Talented and Gifted (TAG), and Teacher Leadership Supplement (TLS) without board action.

The district may choose to request approval from the School Budget Review Committee to transfer funds to make a program whole, prior to its elimination. 

Temporary transfers (loans) of funds are permitted between funds but must be repaid to the originating fund, with interest, by Oct. 1 following the end of the fiscal year. 

It is the responsibility of the board secretary to make recommendations to the board regarding transfers and to provide the documentation justifying the transfer.
 

 

Approved:        10/21/2019                   Reviewed:                     Revised:  02/26/2024 

701.3 Financial Records

Financial records of the school district shall be maintained in accordance with generally accepted accounting principles (GAAP) as required or modified by law. School district monies shall be received and expended from the appropriate fund and/or account. The funds and accounts of the school district shall include, but not be limited to:

Governmental fund type:

  • General fund - This fund is the chief operating fund of the district. It is used to account for all financial resources except those accounted for and reported in another fund.

  • Special Revenue Fund - These funds account for the proceeds of specific revenue sources other than trusts or major capital projects, that are legally restricted or committed to expenditure for specified purposes other than debt service or capital projects.   

    • Management levy fund

    • Public education and recreation levy fund

    • Student activity fund

  • Capital projects fund - These funds are used to account for financial resources to acquire or construct major capital facilities or other capital assets (other than those of proprietary funds and trust funds) and to account for revenues from SAVE.

    • Physical plant and equipment levy fund

    • Secure and Advanced Vision for Education (SAVE)

  • Debt service fund – This fund is used to account for the accumulation of resources for, and the payment of, general long-term debt principal and interest.  

Proprietary fund type: – These funds account for operations of the school district operated similar to private business for which a fee is charged to external users for goods or services, or they account for the costs of providing goods and services provided by one department to other departments on a cost reimbursement basis.  

  • Enterprise fund

    • School nutrition fund

    • Child care fund

    • Internal Service Fund

    • Community Education

    • Preschool (nonvoluntary, state)

Fiduciary funds: -These funds are used to account for monies or assets held by the school district on behalf of, or in trust for, another entity.  

  • Trust

    • Expendable trust funds

    • Nonexpendable trust funds

    • Pension trust funds

  • Custodial Funds

Non-Fiduciary Scholarship Funds

Account groups: - The groups are the accounting records for capital assets and long-term debt.

  • General fixed assets account group

  • General long-term debt account group

As necessary, the board may, by board resolution, create additional funds within the governmental, proprietary and fiduciary fund types. The resolution shall state the type of fund, name of the fund, and purpose of the fund.

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

It is the responsibility of the superintendent in conjunction with the school business official to implement this policy and bring necessary changes in the maintenance of the school district's financial records to the attention of the board.

Approved:        10/21/2019                   Reviewed:                     Revised: 02/26/2024  

701.4 Governmental Accounting Practices & Regulations

School district accounting practices will follow state and federal laws and regulations, generally accepted accounting principles (GAAP) and the uniform financial accounting system provided by the Iowa Department of Education.  As advised by the school district’s auditor, determination of liabilities and assets, prioritization of expenditures of governmental funds and provisions for accounting disclosures shall be made in accordance with governmental accounting standards.

In Governmental Accounting Standards Board (GASB) Statement No. 54, the board identifies the order of spending unrestricted resources applying the highest level of classification of fund balance - restricted, committed, assigned, and unassigned - while honoring constraints on the specific purposes for which amounts in those fund balances can be spent.  A formal board action is required to establish, modify and or rescind a committed fund balance.  The resolution will state the exact dollar amount.  In the event, the board chooses to make changes or rescind the committed fund balance, formal board action is required.

The Board authorizes the superintendent to assign amounts to a specific purpose in compliance with GASB 54.  An ‘assigned fund balance’ should also be reported in the order of spending unrestricted resources, but is not restricted or committed.  

Fund Balance Reporting

Financial reporting for the balances in the District’s governmental funds is based on Governmental Accounting Standards Board (GASB) Statement 54, Fund Balance Reporting and Governmental Fund Types Definitions.  Fund balance refers to the difference between assets and liabilities in the governmental funds balance sheets.  GASB 54 established a hierarchy that is based on “the extent to which the government is bound to honor constraints on the specific purpose for which the amounts in those funds can be spent.”

The governmental funds can have up to five fund balance classifications.  The classifications are defined below from most to least restrictive.

Nonspendable Fund Balance includes amounts that cannot be spent because they are either not in spendable form, or legally or contractually required to be maintained intact.  This includes items not expected to be converted to cash, including inventories and prepaid expenses.  It may also include other property acquired for resale and the principal of a permanent fund.

Restricted Fund Balance should be reported when constraints placed on the use of resources are either externally imposed by creditors, grantors, contributors, or law or regulations of other governments; or imposed by law through constitutional provisions or enabling legislation.  This includes “categorical balances.”

Committed Fund Balance reflects specific purposes pursuant to constraints imposed by formal action of the board. Such constraints can only be removed or changed by board action.

Assigned Fund Balance reflects amounts that are constrained by the government’s intent to be used for specific purposes but meet neither the restricted nor committed forms of constraint.  Unless the amount is negative, the assigned fund balance is the residual classification for the governmental funds other than the general fund.  If the amount is negative, then the residual amount is shown as unassigned.

Unassigned Fund Balance is the residual classification for the general fund only.  As noted above, if a negative residual amount exists in other governmental funds then the amount is reported as unassigned.

It is the responsibility of the superintendent or designee to develop administrative regulations implementing this policy.  It is also the responsibility of the superintendent or designee to make recommendations to the board regarding fund balance designations.   

Approved:                        Reviewed:                        Revised: 02/26/2024

701.5 - R(1) Fiscal Management - Financial Metrics

The following relevant PK-12 public sector indicators will be provided to the Board annually to better understand the financial trends of the district.  These indicators will be an accurate depiction as of June 30th of the preceding fiscal year and will depict at a minimum of 5 years of data.  

  • Total revenues and expenditures by fund and major sources; 
  • Financial Solvency Ratio - assigned plus unassigned fund balances divided by total revenue minus AEA flow through;
  • Unspent Authorized Budget Ratio - amount of maximum spending authority left at year end after deducting the general fund expenditures incurred during the year;
  • Unspent Authorized Balance Ratio Net of Restricted Fund Balances (Categorical Fund Balances) - amount of maximum spending authority left at year end after deducting both the general fund expenditures incurred during the year and the total restricted fund balances (categorical fund balances) at year end;
  • Enrollment Trend - funding follows the student so it is important to understand district enrollment numbers;
  • Staff costs as a percent of total general fund. 

Financial Projections

Five-year financial projections of the general fund will be prepared and updated annually. The general fund is the operating fund of the district where the majority of salaries and benefits are funded.  Projections will help the board determine sustainability of the annual operating budget and help make future budgetary decisions.

The District is committed to utilizing the following financial metrics in determining district financial goals:

  1. Unspent Authorized Budget Ratio:  Maintain unspent authorized budget ratio within the10-25% target range.  The current year’s projected balance will be discussed with the Board before staffing and other spending decisions are finalized for the succeeding year.
  2. Unspent Authorized Budget Net of Restricted Fund Balances (Categorical Balances): Maintain unspent authorized budget ratio net of restricted fund balances (categorical balances) within the 10-25% target range. The district will attempt to spend the restricted (categorical) annual allocation in the year received to the extent possible.
  3. Solvency Ratio: Maintain an unrestricted, uncommitted general fund balance within the 10-20% target range with 10% being a minimum goal.  The current year’s projected balance will be discussed with the Board before establishing the succeeding year’s cash reserve levy and before staffing and other spending decisions are finalized.

Adopted:  01/23/2023                     Reviewed: 03/20/2023                   Revised 01/08/2024

701.5 Fiscal Management

General Fund Budget

The District shall prepare an annual 5-year general fund budget forecast that includes estimates of unspent authorized budget (spending authority), as well as restricted, assigned and unassigned fund balances available at the end of each fiscal year.  The estimates shall be prepared utilizing scenarios for likely State Supplementary Assistance (SSA) rates and enrollment projections. The projections shall include estimates of property tax rates and income surtax rates, if applicable.

 

Monthly Update

The Treasurer shall report monthly to the Board as to actual revenue and expenditures for the month and year-to-date, as compared to budgeted revenues and expenditures and compared to historical revenues and expenditures (both in dollar amounts and percentages), for each fund maintained by the district.  The Treasurer shall provide context with respect to current year variances between budgeted and historical revenues and expenditures.

 

Budget Amendments

The District shall amend the certified budget, when necessary, at the earliest practical date after receipt of knowledge indicating that the budget must be amended and prior to any statutory deadline.  Monthly budget reports shall include amended amounts at the earliest possible date after the receipt of knowledge indicating that the budgets must be amended.

 

Solvency Ratio

The District’s goal is to maintain an unassigned general fund balance that will allow the solvency ratio to fall within the 10-20% target range.  The current year’s projected balance will be discussed with the Board before establishing the succeeding years cash reserve levy and before staffing and other spending decisions are finalized.

 

Unspent Budget Authority

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 10 percent with target of 20 percent and a maximum of 25 percent of its general fund budget (spending) authority.  The calculation shall divide the Unspent Budget Authority by the Maximum Authorized Budget to determine the percentage. 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.

 

Contingency

The district shall prepare a budget that includes a contingency of at least 0.5 percent of the general fund budgeted expenditures.

 

Modified Supplemental Amount  

The district shall solicit from the School Budget Review Committee additional Modified Supplemental Amount (spending authority) where it may be available for items such as special education deficit, increasing enrollment, budget guarantee, open enrollment not on prior year count, English Language Learner, and any other lawful purposes.  The board shall be provided a resolution to approve the maximum request authorized. Any award of Modified Supplemental Amount may be levied as a cash reserve levy, in full, in the next available budget year. For recurring program deficits that are predictable and estimable, the district shall levy in advance for the immediately succeeding year as part of the general cash reserve levy if the deficit causes the estimated assigned and unassigned to fall below the minimum required. Grants of spending authority not funded by the state or other sources may ultimately be levied against property taxes. 

 

 

Approved:      10/21/2019                   Reviewed:                     Revised:   

701.5 Fiscal Management

The Board recognizes its fiduciary responsibility to oversee the management of school district funds in keeping with the school district vision, mission and goals.  To achieve this purpose, the board may engage in learning about the financial needs, operations and requirements of the district as appropriate for the board’s understanding of the district’s financial position.  The Board also commits to engaging in annual financial goal setting for the district based upon measurable data and projections for the district.

After the fiscal year has closed, the Superintendent or their designee will provide to the Board concise, timely, well organized financial data.  The Board will exercise its oversight responsibilities by reviewing relevant PK-12 public education sector indicators to understand the financial trends of the district.  

The board will establish and review financial goals annually.  The District will measure whether these goals were obtained as of June 30, but only after completion of the Certified Annual Report due September 15th each year.

Providing the best possible educational experience for all students and meeting federal, state, and local academic goals for each student requires maximizing General Fund resources for use in the instructional program. The board may request from the School Budget Review Committee (SBRC) additional modified spending authority (MSA) where it may be available for items such as:

  • Special education deficit balances
  • Advances to support increasing student enrollment
  • Supports for students identified as English Learners
  • At risk / dropout prevention programming
  • Initial staffing associated with opening new buildings or programs
  • Any other lawful purpose

Any award of modified supplement amount will be levied as a cash reserve based on the recommendation of the superintendent/designee and approved by the Board of Education in keeping with the fiscal management performance measures provided for in district policy.

 

Adopted: 01/23/2023    Reviewed:  03/20/2023    Revised:  

702 Cash in School Buildings

The amount of cash that may be kept in the school building for any one day shall be sufficient for that day's operations. Funds raised by students shall be kept in the central office for a maximum of five day and then deposited in the student activity fund.

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

 

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

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

A budget for the school district shall be prepared annually for the board's review. The budget shall include the following:

  • the amount of revenues from sources other than taxation;

  • the amount of revenues to be raised by taxation;

  • an itemization of the amount to be spent in each fund; and,

  • comparison of the amount spent and revenue received in each fund for like purposes in the two prior fiscal years.

It shall be the responsibility of the Superintendent and Business Manager to prepare the budget for review by the board prior to the April 30 Certified Budget deadline each year. The District will provide all of the information necessary for the Proposed Property Tax Statement to the Department of Management by March 15.

Mailing of Proposed Property Tax Hearing Statements is completed by the county auditor by March 20.  A public hearing for the Proposed Property Taxes is then held not less than 10 days and not more than 20 days prior to the date of hearing. The hearing notice is published in a newspaper designated for official publication in the school district.  The hearing notice must also be posted on the district website and district social media accounts on the same day it is published in the newspaper. The hearing on the Proposed Property Tax must be a unique and separate meeting and be the only item on the agenda. 

Prior to the adoption of the proposed budget by the board, the public shall be 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 shall have an opportunity to review and comment on the proposed budget. A public hearing for the proposed budget of the board shall be held each year in sufficient time to file the adopted budget no later than April 30.

The proposed budget filed by the board with the board secretary and the time and place for the public hearing on the proposed budget shall be published in a newspaper designated for official publication in the school district. It shall be the responsibility of the board secretary to publish the proposed budget and public hearing information not less than ten days nor more than 20 days prior to the public hearing.

The board shall adopt and certify a budget for the operation of the school district to the county auditor by April 30. It shall be 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. The amendment procedures shall follow the procedures for public review and adoption of the original budget by the board outlined in these policies.

 

Approved:          10/21/2019                   Reviewed:                     Revised: 02/24/2026  

703.1A Intangible Assets Policy

 

I.         Definition of Intangible Assets

           A.       Intangible Asset:  

 

Intangible assets are assets that are:

           (1)       Identifiable – Either the assets:

(a)       Can be separated or divided from the District and sold, transferred, licensed, rented or exchanged; or

(b)       Arose from some legal right (i.e., a contractual right), regardless of whether those rights are separable or dividable;

           (2)       Lacking physical substance;

           (3)       Non-financial in nature – The assets are not in a monetary form, such as cash or investment securities; and

           (4)       Possessing a useful life that extends beyond a single financial reporting period.[1]

 

Examples of intangible assets include the following:

(1)       Easements or land use rights (i.e., water rights, timber rights and mineral rights);

(2)       Patents, trademarks and copyrights; and

(3)       Computer software or websites that are purchased, licensed or internally generated.

 

Examples of assets that are not intangible assets for purposes of this Policy include only the following:

(1)       Assets acquired or created primarily for purposes of obtaining income or profit, as these are considered investment assets;

(2)       Assets from capital lease transactions reported by lessees, except licensing agreements to lease commercially available computer software; and

(3)       Goodwill established or created between the District and another entity.

 

           B.       Outlays Associated with Internally Generated Intangible Assets

Intangible assets that are generated or created internally likely have outlay expenses associated with the generation or creation.  Intangible assets are considered to be generated or created internally if they are:

(1)       Created by the District;

(2)       Created by a third-party contracted by the District; or

(3)       Acquired by the District from a third-party and require more than minimal incremental effort on the part of the District to begin to achieve the expected level of service capacity.

 

           C.       Outlays Associated with Internally Generated Computer Software

 

Computer software that is generated or created internally likely has outlay expenses associated with the generation or creation.  Computer software is considered to be generated or created internally if it is:

  1. Developed by the District;

  2. Developed by a third-party contracted by the District; or

  3. Commercially available software acquired, purchased or licensed by the District from a third-party that is modified using more than minimal incremental effort before being put into operation.

 

II.        Measuring of Intangible Assets

           A.       Threshold for Capitalization of Intangible Assets

 

The District shall adopt an intangible asset capitalization threshold policy to govern the amount at and above which intangible assets must be reported in the District’s annual reporting statements and audits.  More specifically, the policy shall provide a threshold to be applied to individual intangible assets and shall prohibit the aggregation of items, including intangible assets and outlays, to meet the threshold.[2]  The policy shall be approved by the Board of Education prior to its adoption.

 

[Note: The District’s policy regarding intangible asset capitalization threshold should generally be designed to capture eighty percent (80%) of the total cost of the District’s intangible assets.  Therefore, prior to creating a policy regarding intangible asset capitalization threshold, the District must know the total value of its intangible assets.]

 

           B.       Recognition of Intangible Assets

 

The District shall record individual intangible assets exceeding the threshold amount outlined in the District’s intangible asset capitalization threshold policy as follows:

  1. Intangible assets received in an exchange transaction or purchased shall be recorded at actual historical cost, which includes direct costs, and excludes indirect costs;          

  2. Intangible assets in the form of business activities and enterprise funds received in an exchange transaction or purchased shall be recorded at actual historical cost, which includes direct costs, specifically capitalized interest and ancillary charges, and excludes indirect costs; and

  3. Intangible assets received in a non-exchange transaction or donated shall be recorded at estimated fair market value at the time of acquisition, which requires implementation of a rational method to determine or estimate the value at which the asset could be exchanged between willing parties not involved in a forced sale.

  4. Intangible assets reported retroactively[3] shall be recorded at actual historical cost,[4] regardless of whether the asset is fully amortized prior to June 30, 2009.  If an intangible asset reported retroactively is fully amortized prior to June 30, 2009, the District shall record the value of the intangible asset separately from the value of the amortization.

 

III.       Accounting for Intangible Assets

A.       Intangible Assets

 

Intangible assets exceeding the threshold shall be accounted for as capital assets.  Therefore, all financial requirements concerning capital assets, including, but not limited to, all accounting and reporting requirements, such as those associated with recognition, measurement, presentation and disclosure, shall be followed.

 

           B.       Outlays Associated with Internally Generated Intangible Assets

 

Outlays from internally generated intangible assets exceeding the threshold shall not be accounted for as capital assets until they are identifiable and the “specified conditions criteria” have occurred (see below).  Outlays exceeding the threshold not meeting these requirements and/or incurred prior to these criteria occurring shall be accounted for as an expense when the expense is incurred.

 

Outlays from internally generated intangible assets exceeding the threshold shall be accounted for as capital assets if they occur after such time as:

 

  1. The assets are identifiable – See the definition outlined in Section I of this Policy; and

  2. The “specified conditions criteria” have occurred, as follows:

(a)       Determination of the specific objective of the project and the nature of the service capacity that is expected to be provided by the intangible asset upon completion of the project;

(b)       Demonstration of the technical or technological feasibility for completing the project so that the intangible asset will provide its expected service capacity; and

(c)       Demonstration of the current intention, ability, and presence of effort to complete or, in the case of a multiyear project, continue development of the intangible asset.

 

          C.       Outlays Associated with Internally Generated Computer Software

 

Outlays from internally generated computer software developed by the District or by a third-party contracted by the District exceeding the threshold shall be accounted for as follows:

 

(1)       During the preliminary project stage, all outlays exceeding the threshold shall be accounted for as an expense when the expense is incurred.  The preliminary project stage involves the conceptual formulation and evaluation of alternatives, the determination of the existence of needed technology and the final selection of alternatives for development of the software.

 

(2)       During the application development stage, outlays that occur before the specified conditions criteria have occurred and exceed the threshold shall be accounted for as an expense when the expense is incurred; outlays that occur after the specified conditions criteria have occurred[5] and exceed the threshold[6] shall be accounted for as capital assets; and outlays that occur after the computer software is substantially complete and operational and exceed the threshold shall be accounted for as an expense when the expense is incurred.  The application development stage involves the design of the chosen path, including, but not limited to the purchase of the software or license;[7] the software configuration and the software interfaces; the coding; the installation to hardware; the testing; any minor modifications made to the software before it is placed into operation;[8] and the data conversion, if such was deemed necessary in order to make the software operational.

 

(3)       During the post-implementation and operation stage, all outlays exceeding the threshold shall be accounted for as an expense when the expense is incurred.  The post-implementation and operation stage includes the data conversion, if such was not deemed necessary during the application development stage in order to make the software operational; the application training; and the software maintenance.

 

Outlays from internally generated computer software extensively modified by the District or by a third-party contracted by the District exceeding the threshold shall be accounted for as follows:

 

(1)       All outlays from the modification of computer software exceeding the threshold shall be accounted for as capital assets if one of the following conditions exist:

 

(a)       The modification causes an increase in the functionality of the software (the software is able to perform tasks that it was previously incapable of performing);

 

(b)       The modification causes an increase in the efficiency of the software (the software offers an increased level of service without the need for an increased performance of tasks); or

 

(c)       The modification extends the estimated useful life of the software.

 

(2)       All outlays from the modification of computer software exceeding the threshold shall be accounted for as an expense when the expense is incurred if none of the above conditions exists.

 

 

IV.      Amortization of Intangible Assets

 

In amortizing an intangible asset that is capitalized because it exceeds the threshold and meets the requirements above,[9] the following general rules shall apply:

 

(1)       The useful life of an intangible asset generally shall be estimated.  Therefore, the intangible asset has a determinable useful life, even if it must be estimated, and shall be amortized using the straight-line method.

 

(2)       The useful life of an intangible asset that arises from and is limited by contractual or other legal rights shall not exceed the period of the intangible asset’s service capacity provided under the contract or other legal provision.  Therefore, the intangible asset has a determinable useful life, even if it must be estimated, and shall be amortized using the straight-line method.

 

(3)       The useful life of an intangible asset that is not limited by any legal, contractual, regulatory, technological or other factors shall be indefinite.  Therefore, the intangible asset has no determinable useful life and shall not be amortized.

 

In considering changes in circumstances that affect the amortization of an intangible asset, the following rules shall apply:

 

(1)       An intangible asset that arises from and is limited by contractual or other legal rights shall take into consideration contract renewal periods for purposes of determining its useful life and its amortization schedule only if the following requirements are met:

 

(a)       There is evidence that the District will seek and be able to achieve contract renewal; and

(b)       The anticipated outlay for contract renewal is nominal in relation to the level of service capacity obtained by the contract renewal.

 

(2)       An intangible asset that was once not limited by any legal, contractual, regulatory, technological or other factors, but now is limited by such factors due to changes in conditions, shall be tested for impairment[10] because the expected duration of the useful life of the asset has changed, and then the following rules shall apply:

 

(a)       If an impairment is determined not to exist, the intangible asset has a determinable useful life and shall be amortized using the straight-line method.

(b)       If an impairment is determined to exist, the following must occur:

 

(i)        The loss due to the impairment shall be accounted for as a loss;

(ii)       The intangible asset has a useful life that must be estimated and is determinable; and

(iii)      The carrying value, or the value remaining after accounting for the impairment, shall be amortized using the straight-line method over the remaining estimated useful life.

 

 

V.       Selling or Disposing of Intangible Assets

 

In selling or disposing of intangible assets, the District shall calculate and report a gain or loss on the sale or disposal.  The gain or loss shall be calculated by subtracting the net book value, which consists of the historical cost less any accumulated amortization, from the net amount realized on the sale or disposal.

 

 

VI.      Application of Policy

 

The requirements of this Policy shall apply to all financial statements covering periods beginning after June 30, 2009.  Consequently,

 

The requirements of this Policy shall apply retroactively to intangible assets that were in existence from July 1, 1980, through June 30, 2009.[11]  However, the following intangible assets shall not be retroactively reported as capital assets:

 

(1)       Intangible assets considered to have an indefinite useful life as of June 30, 2009;

(2)       Intangible assets considered to be internally generated as of June 30, 2009;

(3)       Outlays from internally generated computer software incurred in the application development stage on or prior to June 30, 2009;[12]

(4)       Any intangible asset held by a “Phase 3” District, characterized as such for purposes of implementing GASB Statement 34.  [Note: The District needs to include a specific statement regarding whether the District was classified as “Phase 3” for purposes of implementing GASB Statement 34.]

 

[Note: This effectively means that the District, which is on an accrual basis of accounting, will be required to restate its beginning net assets, fund balances, or fund net assets in order to fully report, as of July 1, 2009, the beginning of fiscal year 2010, the appropriate value and amortization of certain intangible assets that were in existence from July 1, 1980 to June 30, 2009.]

____________________________________________________________________________ 

[1] This requirement also applies to an intangible asset in the form of a computer software license purchased or renewed, and the useful life must extend beyond a single reporting period in order for the computer software license to be capitalized.

[2] With intangible assets in the form of computer software licenses purchased or renewed, each individual license must be accounted for separately and all licenses cannot be aggregated for purposes of measuring wither the assets have exceeded the threshold.

[3] Reference Section VI of this Policy for the retroactive reporting of intangible assets.

[4] If actual historical cost cannot be determined for intangible assets acquired prior to June 30, 2009, due to lack of sufficient records, estimated historical cost shall be used.

[5] The specified conditions criteria are considered to be met for internally generated computer software developed by the District or a third-party contracted by the District when the preliminary project stage is complete and the Board authorizes and/or commits to funding the development of new computer software.

[6] In determining whether the outlays exceed the threshold, each outlay shall be accounted for separately and no outlay shall be aggregated with any other outlay for purposes of measuring wither the outlays have exceeded the threshold.  For example, the initial purchase of the computer software or license and the modifications made to the computer software or license should be accounted for separately and should not be aggregated for purposes of measuring wither the outlays have exceeded the threshold.

[7] The purchase of the computer software or license shall be treated as an outlay that shall be capitalized.

[8] Making minor modifications to the computer software or license shall be treated as an outlay that shall be capitalized.

[9] This includes intangible assets that were in existence from July 1, 1980, through June 30, 2009, and must be retroactively reported.

[10] Internally generated intangible assets and computer software commonly experience impairment with development stoppage, including, but not limited to, stoppage of development of computer software due to changes in the priorities of management.

[11] This includes computer software purchased prior to June 30, 2009, that is currently still in use.

[12] Reference Section III, Subsection C of this Policy for the accounting of outlays from internally generated computer software incurred in the application development stage after June 30, 2009.

 

Approved:        10/21/2019                   Reviewed: 02/26/2024                    Revised:   

703A Governmental Fund Balances

General

The board strives to maintain adequate fund balances and reserves in order to:

1.              Provide sufficient cash flow for daily financial needs;

2.              Secure and maintain investment-grade bond ratings;

3.              Offset significant economic downturns or revenue shortfalls; and

4.              Provide funds for unforeseen expenditures related to emergencies.

 

Reporting Fund Balances

The board shall engage in accounting and financial reporting procedures in compliance with the Governmental Accounting Standards Board’s Statement No. 54 (“GASB 54”) or successor.

 

Pursuant to GASB 54, governmental fund balances shall be identified for purposes of reporting as one of the following types of funds:

1.              “Nonspendable”- fund balances that can never be spent because the balances are either not in spendable form because they cannot currently be spent or cannot ever be spent (i.e., supply inventory funds, prepaid items, long-term loans receivables (including from loans to other funds of the District) and non-financial assets held for resale) or the District is legally or contractually required to maintain the balances in-tact (i.e., principal of an endowment fund).

2.              “Restricted”- fund balances that can be used only for the specific purposes permitted in externally enforceable legal restrictions, including, but not limited to, the constitution, enabling legislation or external resource providers (i.e., PPEL funds, Debt Service funds, Capital Project funds, state grant carryover funds, categorical funds including for example, per pupil supplement funds, special education funds, drop-out prevention funds).

3.              “Committed”- fund balances that can be used only for the specific purposes determined by a formal action of the Board.

4.              “Assigned”- fund balances that are constrained by the District’s intent to use the funds for specific purposes determined by the Board and/or designee, but which are neither restricted nor committed (i.e., cash flow fund, funds for book fairs or field trips that are within the general fund).

5.              “Unassigned”- fund balances that have not been restricted, committed or assigned (i.e., residual classification for the general fund or a deficit balance from overspending for specific purposes for which amounts have been restricted, committed or assigned for other funds).

Governmental fund balances shall first be distinguished based upon whether the fund balance is nonspendable, as defined above, and then shall be distinguished based upon whether the fund balance is restricted, classified, assigned or unassigned, all as defined above. 

 

Governmental fund balances shall be identified at the highest category of identification possible, regardless of whether the fund balance also fits into a lower category of identification (i.e., a PPEL fund balance should be reported as “restricted,” even if a separate Board action “committed” a portion of the PPEL fund balance to a specific purpose).

 

Governmental fund balances identified as committed fund balances after the end of the fiscal year, the amount shall be reflected as assigned on the balance sheet for that year.

 

Authority to Commit or Assign Fund Balances

The Board shall have the authority to determine whether a governmental fund balance in the District’s general fund is committed and/or assigned, both as defined above.  The Board delegates to the [superintendent and/or the Board secretary] the authority to assign a fund balance in the District’s general fund to be used for a specific purpose.

 

The Board shall take formal board action prior to committing a fund balance, modifying the commitment of a fund balance or removing the commitment of a fund balance.  The Board shall approve by a majority vote the commitment of a fund balance, the modification of the commitment of a fund balance and the removal of the commitment of a fund balance.  The Board shall take action to commit a fund balance prior to the end of each fiscal year in which the original committed amount is determined. The Board may take action to commit a fund balance without determining the exact amount of the committed fund balance prior to the end of the fiscal year, provided the intended committed purpose is identified prior to the end of the fiscal year and the exact amount of the committed fund balance is determined after the end of the fiscal year.

 

Spending Fund Balances

Pursuant to GASB 54 and absent any other specific direction in place at the District, the District shall spend and/or reduce governmental fund balances in the following order: restricted fund balance, committed fund balance, assigned fund balance and unassigned fund balance.

Approved:        10/21/2019                   Reviewed:                     Revised:   

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 district property are placed in the general fund.

The board may claim exemption from the law prohibiting competition with private enterprise for the following activities:

  • Goods and services directly and reasonably related to the educational mission;
  • Goods and services offered only to students, employees or guests which cannot be provided by private enterprise at the same or lower cost;
  • Use of vehicles for charter trips offered to the public, full- or part-time, or temporary students;
  • Goods and services which are not otherwise available in the quantity or quality required by the school district;
  • Telecommunications other than radio or television stations;
  • Sponsoring or providing facilities for fitness and recreation;
  • Food service and sales; and,
  • Sale of books, records, tapes, software, educational equipment, and supplies.

It is the responsibility of the superintendent to bring to the board's attention additional sources of revenue for the school district.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

704.2 Debt Management Policy

DEBT LIMITS

Credit Ratings

The school district seeks to maintain the highest possible credit ratings for all categories of short- and long-term debt that can be achieved without compromising the delivery of services and the achievement of adopted objectives.  The school district recognizes that external economic, natural, or other events may from time to time affect the creditworthiness of its debt. Nevertheless, the school district is committed to ensuring that actions within their control are prudent.

Debt Limits

For general obligation debt, the school district’s outstanding debt limit shall be no more than five percent (5%) of the actual value of property within the school district’s boundaries, as prescribed in the Iowa constitution and statutory restrictions.

For revenue debt, the school district’s goal is to provide adequate debt service coverage of at least 1.20 times the annual debt service costs.

In accordance with Iowa law, the school district may not act as a conduit issuer or issue municipal securities to raise capital for revenue-generating projects where the funds generated are used by a third party (“conduit borrower”) to make payments to investors.

PURPOSES AND USES OF DEBT 

Capital Planning

To enhance creditworthiness and prudent financial management, the school district is committed to systematic capital planning, intergovernmental cooperation and coordination and long-term financial planning.

Capital Financing

The school district may issue long-term debt for capital projects as authorized by Iowa law, which include, but are not limited to, the costs of planning, design, land acquisition, buildings, permanent structures, attached fixtures or equipment, and movable pieces of equipment. Capitalized interest may be included in sizing any capital project debt issue.  The types of debt instruments to be used by the school district include:

  • General Obligation Bonds

  • General Obligation Capital Loan Notes

  • Bond Anticipation Notes

  • Revenue Anticipation Notes

  • School Infrastructure Sales, Services and Use Tax Revenue Bonds

  • Lease Purchase Agreements, including Certificates of Participation

Working Capital Financing

The school district may issue debt for working capital for operations after cash flow analysis has determined that there is a mismatch between available cash and cash outflows.  The school district shall strive to repay working capital debt by the end of the fiscal year in which the debt was incurred.  A Working Capital Reserve may be included in sizing any working capital debt issue.

Refundings

Periodic reviews of all outstanding debt will be undertaken to determine if refunding opportunities exist. Refunding will be considered (within federal tax law restraints) if and when there is a net economic benefit of the refunding or if the refunding is otherwise in the best interests of the school district, such as to release restrictive bond covenants which affect the operations and management of the school district.

In general, advance refundings for economic savings will be undertaken when a net present value savings exceeds three percent of the refunded debt can be achieved.  Current refundings, which produce a new present value savings of less than three percent will be considered on a case by case basis taking into consideration bond covenants and general conditions.  Refundings with negative savings will not be considered unless there is a compelling public policy objective for doing so.

DEBT STANDARDS AND STRUCTURE

Length of Debt

Debt will be structured for the shortest period consistent with a fair allocation of costs to current and future beneficiaries or users.  Long-term debt will not be issued for periods exceeding the useful life or average useful lives of the project or projects to be financed.  All debt issued will adhere to state and federal law regarding the length of time the debt may be outstanding.

Debt Structure

Debt will be structured to achieve the lowest possible net cost to the school district given market conditions, the urgency of the capital project, the type of debt being issued, and the nature and type of repayment source.  To the extent possible, the school district will design the repayment of its overall debt to rapidly recapture its credit capacity for future use.

Generally, the school district will only issue fixed-rate debt.  In very limited circumstances, the school district may issue variable rate debt, consistent with the limitations of Iowa law and upon a finding of the board that the use of fixed rate debt is not in the best interest of the school district and a statement of the reasons for the use of variable rate debt

All debt may be structured using discount, par or premium coupons, and as serial or term bonds or notes, or any combination thereof, consistent with Iowa law.  The school district should utilize the coupon structure that produces the lowest True Interest Cost (TIC) taking into consideration the call option value of any callable maturities.

The school district will strive to structure their debt in sinking fund installments for each debt issue that achieves, as nearly as practicable, level debt service within an issue or overall debt service within a particular classification of debt.

Derivatives (including, but not limited to, interest rate swaps, caps, collars, corridors, ceiling and floor agreements, forward agreements, float agreements, or other similar financing arrangements), zero-coupon or capital appreciation bonds are not allowed to be issued consistent with State law.

Decision Analysis to Issue Debt

Whenever the school district is contemplating the issuance of debt, information will be developed concerning the following four categories commonly used by rating agencies assessing the school district’s credit worthiness, listed below.

Debt Analysis – Debt capacity analysis; purpose for which debt is proposed to be issued; debt structure; debt burden; debt history and trends; and adequacy of debt and capital planning.

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

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

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

DEBT ISSUANCE 

Credit Enhancement

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

Costs and Fees

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

Method of Sale

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

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

Professional Service Providers

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

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

The treasurer shall have the authority to periodically select other service providers (e.g., escrow agents, verification agents, trustees, arbitrage consultants, rebate specialist, etc.) as necessary to meet legal requirements and minimize net debt costs.  These services can include debt restructuring services and security or escrow purchases.

Compensation for bond counsel, financial advisor and other service providers will be as economical as possible and consistent with industry standards for the desired qualification levels.

DEBT MANAGEMENT

Investment of Debt Proceeds

The school district shall invest all proceeds received from the issuance of debt separate from the school district’s consolidated cash pool unless otherwise specified by the authorizing bond resolution or trust indenture.  Investments will be consistent with those authorized by Iowa law and the school district’s Investment Policy to maintain safety of principal and liquidity of the funds.

Arbitrage and Record Keeping Compliance

The treasurer shall maintain a system of record keeping reporting and compliance procedures with respect to all federal tax requirements which are currently, or may become applicable through the lifetime of all tax-exempt or tax credit bonds.

Federal tax compliance, record-keeping reporting and compliance procedures shall include not shall 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.

 

Approved:      5/11/2020                   Reviewed:                     Revised:   

704.2 - R1 Post-Issuance Compliance Regulations 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;

i.     management  contracts;

ii.   service agreements;

iii.     research contracts;

iv.     naming rights;

v.    contracts;

vi.     leases or sub-leases;

vii. joint venture, limited liability or partnership arrangements; 

vi.     sale of property; or

ix.     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)     Shall 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 (if required);

b)     Applications, approvals and other documentation of grants (where applicable);

c)     Depreciation schedules;

d)     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:

a)     Identify and select bonds to be advance refunded with advice from internal financial personnel, and a financial advisor;

b)     Identify, with advice from the financial advisor and bond counsel, any possible federal tax compliance issues prior to structuring any advance refunding;

c)     Review the structure with the input of the financial advisor and bond counsel, of advance refunding issues prior to the issuance to ensure (i) that the proposed refunding is permitted pursuant to applicable federal tax requirements if there has been a prior refunding of the original bond issue; (ii) that the proposed issuance complies with federal income tax requirements which might impose restrictions on the redemption date of the refunded bonds; (iii) 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 (iv) that the proposed issuance will not result in the issuer's exploitation of the difference between tax exempt and taxable interest rates to obtain a financial advantage nor overburden the tax exempt market in a way that might be considered an abusive transaction for federal tax purposes;

d)     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;

e)     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;

f)     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 a guaranteed investment contract;

g)     In determining the issue price for any advance refunding issuance, obtain and retain issue price certification by the purchasing underwriter at closing;

h)     After the issuance of an advance refunding issue, ensure timely identification of violations of any federal tax requirements and engage bond counsel in an attempt to remediate the same in accordance with IRS regulations.

 

8.     Bond Disclosure Policy

        Section 1.01.  Disclosure Coordinator.  By adoption of this Policy, the District hereby             appoints the 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 and 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 information 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 responsibilities of the Disclosure Coordinator to make certain filings with the MSRB under Articles 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 communicate with the Disclosure Coordinator on any information relating to financial obligations or amendments to existing financial obligations 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 Coordinator (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 material 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.  

(i)        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. 

(ii)       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: 

(A)         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. 

(B)          The Disclosure Coordinator shall:

(i)            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.  

(ii)          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.

 (C)          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.

 (D)         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 Director or the change of name of a Director, 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. 

Suggested Practices in Submitting Annual Financial Information to EMMA*

Annual Financial Information is to be submitted to EMMA as follows:

·       through the EMMA Dataport;

 ·       in one or more electronic word-searchable portable document format files configured to permit documents to be saved, viewed, printed and retransmitted by electronic means (“properly formatted pdf file”); and

·       indexed by the submitter as “Annual Financial Information and Operating Data” – this EMMA indexing category should be used for all submissions consisting of one or both parts of an annual financial information submission. A submission should be indexed in EMMA by the submitter as “Annual Financial Information and Operating Data” if it consists of complete annual financial information (including audited financial statements and/or the CAFR).

If the audited financial statements have not been prepared in time to meet the deadline:

·       file unaudited financial statements with a notice to the effect that the unaudited financial statements are being provided pending completion of audited financial statements and that the audited financial statements will be submitted to EMMA when they have been prepared.

If annual financial information is provided by reference to other submitted documents file:

·       a notice that includes specific reference to a document available on the EMMA website or the SEC (such as, but not limited to, an official statement), to the extent that such document in fact includes the information required to be include in the annual financial information; and

·       the submitter should confirm that such document in fact is available from the EMMA website or the SEC and should include in such notice (A) a textual description of the document that includes the required information, with sufficient detail for a reasonable person to determine the precise document being referenced, and (B) an active hyperlink to the pdf file of such document as then posted on the EMMA website or to the SEC’s EDGAR system; further, if such document includes audited financial statements, the submitter should also index such submission as “Audited Financial Statements or CAFR” in addition to (but not instead of) “Annual Financial Information and Operating Data” unless the submitter submits such audited financial statements separately to EMMA.

Failure to file notices are to be submitted to EMMA as follows:

·       through the EMMA Dataport;

·       as an electronic word-searchable and properly formatted pdf file; and

·       indexed by the submitter as “Failure to Provide Annual Financial Information.”

* Procedures subject to change.

[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.

 

 

        Legal Reference:    Iowa Code §§ 257.31(4); 279.8; 297.22-.25; 298A (2011)                http://www.irs.gov/taxexemptbond/article/0,,id=243503,00.html

 

 

Approved:  5/11/2020        Reviewed:          Revised:  

 

704.3 Investments

 

School district funds in excess of current needs shall be invested in compliance with this policy. This policy applies to all operating funds, bond proceeds, and other funds.

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.

 

The responsibility for conducting investment transactions resides with the treasurer and those authorized by resolution.  It shall be the responsibility of the treasurer to oversee the investment portfolio in compliance with this policy and Iowa Code Chapter 12B.  The investment of bond funds or sinking funds shall comply not only with this policy, but also the applicable bond resolution.

 

In making investments, the school district shall 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, bond proceeds, and other funds. Operating funds are funds which are reasonably expected to be used during the current budget year or within fifteen months of receipt. When investing operating funds, the investments must mature within three hundred and ninety-seven (397) days or less. When investing funds other than operating funds, the investments 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:

  1. Obligations of the United States government, its agencies and instrumentalities; and

  2. Certificates of deposit and other evidences of deposit at federally insured Iowa depository institutions approved pursuant to Iowa Code Chapter 12C and authorized as a depository of the district by resolution;

  3. Prime bankers’ acceptances that mature within two hundred seventy (270) days and that are eligible for purchase by a federal reserve bank, provided that at the time of purchase no more than ten percent (10%) of the investment portfolio shall be in investments authorized by this subparagraph and that at the time of purchase no more than five percent (5%) of the investment portfolio shall be invested in the securities of a single issuer;

  4. Commercial paper or other short-term corporate debt that matures within two hundred seventy (270) days and that is rated within the two highest classifications, as established by at least one of the standard rating services approved by the superintendent of banking by rule adopted pursuant to Iowa Code chapter 17A, provided that at the time of purchase no more than five percent (5%) of all amounts invested in commercial paper and other short-term corporate debt shall be invested in paper and debt rated in the second highest classification, and provided further that at the time of purchase no more than ten percent (10%) of the investment portfolio shall be in investments authorized by this subparagraph and that at the time of purchase no more than five percent (5%) of the investment portfolio shall be invested in the securities of a single issuer;

  5. Repurchase agreements whose underlying collateral consists of the investments set out in (1) if the political subdivision takes delivery of the collateral either directly or through an authorized custodian. Repurchase agreements do not include reverse repurchase agreements;

  6. An open-end management investment company registered with the federal Securities and Exchange Commission under the federal Investment Company Act of 1940, 15 U.S.C. §80a-1, and operated in accordance with 17 C.F.R. §270.2a-7.

  7. A joint investment trust organized pursuant to Iowa Code chapter 28E, provided that the joint investment trust shall be one of the following: (i) Rated within the two highest classifications by at least one of the standard rating services approved by the superintendent of banking by rule adopted pursuant to Iowa Code chapter 17A and operated in accordance with either 17 C.F.R. §270.2a-7, or with the requirements of the governmental accounting standards board for external investment pools. (ii) Registered with the federal securities and exchange commission under the federal Investment Company Act of 1940, and operated in accordance with 17 C.F.R. §270.2a-7.  The manager or investment advisor of the joint investment trust shall be registered with the federal Securities and Exchange Commission under the Investment Advisor Act of 1940;

  8. Warrants or improvement certificates of a levee or drainage district.

 

It shall be the responsibility of the treasurer to bring a contract with an outside person to invest school district funds, to advise on investments, to direct investments, to act in a fiduciary capacity or to perform other services to the board for review and approval. The treasurer shall also provide the board with information about and verification of the outside person's fiduciary bond. Contracts with outside persons shall include a clause requiring the outside person to notify the school district within thirty days of any material weakness in internal structure or regulatory orders or sanctions against the outside person regarding the services being provided to the school district and to provide the documents necessary for the performance of the investment portion of the school district audit. The compensation of the outside persons shall not be based on the performance of the investment portfolio.

 

The treasurer shall be responsible for reporting to and reviewing with the board at its regular meetings the investment portfolio's performance, transaction activity, and current investments including the percent of the investment portfolio by type of investment and by issuer and maturity. The report shall also include trend lines by month over the last year and year-to-year trend lines regarding the performance of the investment portfolio. It shall also be the responsibility of the treasurer to obtain the information necessary to ensure that the investments and the outside persons doing business with the school district meet the requirements outlined in this policy.

 

It shall be the responsibility of the superintendent to deliver a copy of this policy and any future amendments to the school district's depositories, auditor, and outside persons doing investment business with the school district.

 

It shall 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 shall be designed to prevent losses, to document the officers' and employees' responsibility for elements of the investment process, and address the capability of any outside party assisting with the management of the district funds.

 

Approved:          10/21/2019                   Reviewed:                     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 shall have sole authority to determine whether a gift, grant or bequest furthers the interests of the school district.

Gifts, grants, and bequests shall be approved by the board. Once a gift, grant or bequest has been approved by the board, a board member or the superintendent may accept the gift, grant or bequest on behalf of the school district.

Gifts, grants, and bequests once accepted on behalf of the school district shall become the property of the school district. Gifts, grants, and bequests shall be administered in accordance with terms, if any, agreed to by the board.

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

704.5 Student Activities Funds

Revenue raised by students or from student activities shall be deposited and accounted for in the student activities fund. This revenue is the property of and shall be under the financial control of the board. Students may use this revenue for purposes approved by the superintendent and business manager.

Whether such revenue is collected from student contributions, club dues or special activities or result from admissions to special events or from other fund-raising activities, all funds will be under the jurisdiction of the board and under the specific control of the activities director. They will be deposited in a designated depository and will be disbursed and accounted for in accordance with instructions issued by the Iowa Department of Education and State Auditor’s Office.

It shall be the responsibility of the school business official to keep student activity accounts up-to-date and complete.

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

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

704.6 - Online Fundraising Campaigns - Crowdfunding

The Board of Education believes online fundraising campaigns, including crowdfunding campaigns, may further the interests of the district. Online fundraising campaigns have become an increasingly popular mechanism for individual educators to raise money. “Crowdfunding” can be defined as, the use of small amounts of capital from a large number of individuals to finance a project, business venture, or to fundraise for a specific cause or charity. Some examples of organizations dedicated to crowdfunding for education are below:

  • DonorsChoose.org, an organization with a mission to empower “public school teachers from across the country to request much-needed materials and experiences for their students." 
  • AdoptAClassroom.org, an organization with a mission to give “teachers a hand by providing needed classroom materials so that students can succeed.”

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 board or their designee. 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. No funds collected shall be deposited to a staff members personal account. 

 

Approved:          02/27/2023                   Reviewed:                     Revised:   

 

705.1 Purchasing – Bidding

The board supports economic development in Iowa, particularly in the school district community. As permitted by law, purchasing preference will be given to Iowa goods and services from locally-owned businesses located within the school district or Iowa based companies if the cost and other considerations are relatively equal and meet the required specifications. However, when spending federal Child Nutrition Funds, geographical preference is allowed only for unprocessed agricultural food items as a part of response evaluation. Other statutory purchasing preferences will be applied as provided by law, including goals and reporting with regard to procurement from certified targeted small businesses, minority-owned businesses, and female-owned businesses. 

Goods and Services 

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

Purchases for goods and services shall conform to the following: 

  • The superintendent shall have the authority to authorize purchases without prior board approval and without competitive request for proposals, quotations, or bids for goods and services up to $10,000. 
  • For goods and services costing at least $10,000 and up to $139,000, 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, $139,000, the competitive request for proposal (RFP) or competitive bid process shall be used and received prior to board approval. RFPs and bids are formal, written submissions via sealed process. 

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

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

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

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

Public Improvements

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

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

The award of all contracts for the public improvement shall be awarded to the lowest responsive, responsible bidder. In the event of an emergency requiring repairs to a school district facility that exceed bidding and quotation thresholds, please refer to policy 802.03 – 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.

Approved:   2/27/23                    Reviewed:                      Revised: 10/03/23

705.1-R(1) Purchasing - Bidding- Suspension and Debarment of Vendors and Contractors Procedure

In connection with transactions subject to federal suspension and debarment requirements, the district is prohibited from entering into transactions with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. 

When soliciting bids or otherwise preparing to enter into such a transaction, the superintendent or designee will use at least one of the following verification methods to ensure that any parties to the transaction are not suspended or debarred prior to committing to any sub-award, purchase, or contract:

  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.

705.1-R(2) Purchasing - Bidding - Using Federal Funds in Procurement Contracts

In addition to the District’s standard procurement and purchasing procedures, the following procedures for vendors/contractors paid with federal funds are required.  When federal, state, and local requirements conflict, the most stringent requirement will be followed.

2 CFR Part 200, Subpart D Subsection §200.318 (c)(1) 
No District employee, officer, or agent may participate in the selection, award and administration of contracts supported by a Federal award if he or she has a real or apparent conflict of interest.  Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.  District officers, employees, and agents may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.  However, for situations where the financial interest is not substantial or the gift is an unsolicited item of nominal value, district employees must abide by all relevant board policies. Violation of this requirement may result in disciplinary action for the District employee, officer, or agent.

2 CFR Part 200, Subpart D Subsection §200.320 (e)(1-4)
Procurement for contracts paid with federal funds may be conducted by noncompetitive (single source) proposals when one or more of the following circumstances apply: (1) the item is only available from a single source; (2) public exigency or emergency will not permit the delay resulting from competitive bids; (3) the Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or (4) after solicitation of a number of sources, competition is inadequate. 

2 CFR Part 200, Subpart D Subsection §200.321
The District will take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. Affirmative steps must include: (1) placing such businesses on solicitation lists; (2) soliciting such businesses whenever they are potential sources; (3) when economically feasible, dividing contracts into smaller tasks or quantities to allow participation from such businesses; (4) establishing delivery schedules that encourage participation by such businesses; (5) when appropriate, utilizing the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and (6) requiring the primary contractor to follow steps (1) through (5) when subcontractors are used.

The district will include the following provisions in all procurement contracts or purchase orders include the following provisions when applicable:
2 CFR Part 200 Appendix II
(A) Contracts for more than the simplified acquisition threshold currently set at $150,000, which is the inflation adjusted amount determined by the Civilian Agency Acquisition Council and the Defense Acquisition Regulations Council (Councils) as authorized by 41 U.S.C. 1908, must address administrative, contractual, or legal remedies in instances where contractors violate or breach contract terms, and provide for such sanctions and penalties as appropriate. 

(B) All contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity including the manner by which it will be effected and the basis for settlement. 

(C) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of “federally assisted construction contract” in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246, “Equal 

Employment Opportunity” (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity,” and implementing regulations at 41 CFR part 60, “Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor.” 

(D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland “Anti-Kickback” Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, “Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States”). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. 

(E) Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts awarded by the non-Federal entity in excess of $100,000 that involve the employment of mechanics or laborers must include a provision for compliance with 40 U.S.C. 3702 and 3704, as supplemented by Department of Labor regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40 hours. Work in excess of the standard work week is permissible provided that the worker is compensated at a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40 hours in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide that no laborer or mechanic must be required to work in surroundings or under working conditions which are unsanitary, hazardous or dangerous. These requirements do not apply to the purchases of supplies or materials or articles ordinarily available on the open market, or contracts for transportation or transmission of intelligence. 

(F) Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of “funding agreement” under 37 CFR §401.2 (a) and the recipient or subrecipient wishes to enter into a contract with a small business firm or nonprofit organization regarding the substitution of parties, assignment or performance of experimental, developmental, or research work under that “funding agreement,” the recipient or subrecipient must comply with the requirements of 37 CFR Part 401, “Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative Agreements,” and any implementing regulations issued by the awarding agency. 

(G) Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387), as amended—Contracts and subgrants of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended (33 U.S.C. 1251-1387). Violations must be reported to the Federal awarding agency and the Regional Office of the Environmental Protection Agency (EPA). 

(H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. 

(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—Contractors that apply or bid for an award exceeding $100,000 must file the required certification. Each tier certifies to the tier above that it will not and has not used Federal appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any Federal contract, grant or any other award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with non-Federal funds that takes place in connection with obtaining any Federal award. Such disclosures are forwarded from tier to tier up to the non-Federal award. 

(J) See §200.322 Procurement of recovered materials.

§200.216 Prohibition on certain telecommunications and video surveillance services or equipment

(a)    The district is prohibited from obligating or expending loan or grant funds to:

  1. Procure or obtain;
  2. Extend or renew a contract to procure or obtain; or
  3. Enter into a contract (or extend or renew a contract) to procure or obtain equipment, services, or systems that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.  As described in Public law 115-232, section 889, covered telecommunications equipment is telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities). 

           i.    For purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunication equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).
           ii.    Telecommunications or video surveillance services provided by such entities or using such equipment.
          iii.    Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of the National Intelligence of the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned by or controlled by, or otherwise connected to, the government of a foreign country. 
(b)    In implementing the prohibition under Public Law 115-232, section 889, subsection (f), paragraph (l), heads of executive agencies administering loan, grant, or subsidy programs shall prioritize available  funding and technical support to assist affected businesses, institutions and organizations as is reasonably necessary for those affected entities to transition from covered communications equipment and services, to procure replacement equipment and services, and to ensure that communications service to users and customers is sustained.
(c)    See Public Law 115-232, section 889 for additional information.
(d)    See also §200.471.

705.3 Payment for Goods and Services

The board authorizes the issuance of warrants for payment of claims against the school district for goods and services. The board will allow the warrants after the goods and services have been received and accepted in compliance with board policy and the claims audited by the board.

Claims for items pursuant to the terms of a written contract approved by the board, such as payment of freight, athletic officials, postage, printing, water, lights, telephone, rents, and payment of salaries 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 secretary shall examine the claims and verify bills.

The secretary shall 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 shall be the responsibility of the secretary to bring claims to the board for approval.  Hereafter, paid claims shall be entered on record in the regular minutes of the secretary.

All warrants must be processed through the district’s secure financial accounting software system that utilizes electronic signatures.

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

705.4 R(1) Expenditures for a Public Purpose - 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.  
     
  • 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.  

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.  

706.1 Payroll Periods

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

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

 

Approved:  4/10/23                   Reviewed:                     Revised:   

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.

Approved: 11/28/2022.                   Reviewed: 11/28/2022                  Revised: 11/28/2022

Draft - (Safety Grant) 706.3 R(1) Pay Deductions - Regulation

The district complies with all applicable laws with respect to payment of wages and benefits to employees including laws such as the federal Fair Labor Standards Act and the Iowa Wage Payment Collection Act.  The district will not make pay deductions that violate either the federal or state laws.

Any employee who believes that the district has made an inappropriate deduction or has failed to make proper payment regarding wages or benefits is encouraged to immediately consult with the appropriate supervisor. Alternatively, any employee may file a formal written complaint with the Business Manager. Within 15 business days of receiving the complaint, the Business Manager will make a determination as to whether the pay deductions were appropriate and provide the employee with a written response that may include reimbursement for any pay deductions that were not appropriately made.

This complaint procedure is available in addition to any other complaint process that also may be available to employees.

707.1 Financial Reports

The board secretary shall report to the board each month the receipts, disbursements, and balances of the various funds. This report shall be in written form and sent to the board with the agenda for the board meeting.

Each month the schedule of bills allowed by the Board of Directors shall be published in a newspaper designated as a newspaper for official publication by the board secretary. Annually, the total salaries paid to employees regularly employed by the school district shall also be published in a newspaper designated as a newspaper for official publication.

The board shall cause to have published the proceedings of each regular or special meeting after the adjournment of such meetings. The secretary shall furnish a copy of the proceedings within two (2) weeks following the adjournment of the meeting.

 

Approved:          10/21/2019                   Reviewed:                     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 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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   
 

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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

707.4 Audit

To review the funds and accounts of the school district, the board shall employ an auditor to perform an annual audit of the financial affairs of the school district in compliance with Iowa Code Chapter 11.  The results of the annual audit shall be included in the official record of the board. Such annual audit shall be filed with the Auditor of State and the Iowa Department of Education and the federal government, if required, within nine months of the conclusion of the fiscal year.  

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

707.5 & 707.5-R1 Internal Controls and Procedures

The Board expects all board members, employees, volunteers, consultants, vendors, contractors, students, and other parties maintaining any relationship with the school district to act with integrity, due diligence, and in accordance with all laws in their duties involving the school district’s resources.  The Board is entrusted with public dollars and no one connected with the school district should do anything to erode that trust.

Internal control is the responsibility of all employees of the school district.  The superintendent, business manager, and 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 an indication of fraud, financial impropriety, or irregularity within the administrator’s area of responsibility.

Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor, and/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 vice-president, who shall be empowered to contact the Board’s legal counsel, insurance agent, auditing firm, and any other agency to investigate the concern or complaint.

Upon approval of the Board, the superintendent may contact the State Auditor or elect to employ the school district’s auditing firm or State Auditor to conduct a complete or partial forensic/internal control/SAS99 audit annually or otherwise as often as deemed necessary.  The superintendent is authorized to order a complete forensic audit if, in the superintendent’s judgment, such an audit would be useful and beneficial to the school district.  The superintendent shall ensure the State Auditor is notified of any suspected embezzlement or theft pursuant to Iowa law.  In the event there is an investigation, records will be maintained for use in the investigation.  Individuals found to have altered or destroyed records will be subject to disciplinary action up to, and including, termination of employment.

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

  • Forgery or unauthorized alteration of any document or account belonging to the district.

  • Forgery or unauthorized alteration of a check, bank draft, or any other financial document.

  • Misappropriation of funds, securities, supplies, or other assets.

  • Impropriety in the handling of money or reporting of financial transactions.

  • Profiteering because of “insider” information of district information or activities.

  • Disclosing confidential and/or proprietary information to outside parties.

  • Accepting or seeking anything of material value, other than items used in the normal course of advertising, from contractors, vendors, or persons providing services to the district.

  • Destroying, removing, or inappropriately using district records, furniture, fixtures, or equipment.

  • Failing to provide financial records to authorized state or local entities.

  • Failure to cooperate fully with any financial auditors, investigators, or law enforcement.

  • Any other dishonest or fraudulent act involving district monies or resources.

The superintendent shall investigate reports of fraudulent activity in a manner that protects the confidentiality of the parties and the facts.  All employees involved in the investigation shall be advised to keep information abut the investigation confidential.

If an investigation substantiates the occurrence of a fraudulent activity, the superintendent, or board vice-president if the investigation centers on the superintendent, shall issue a report to the Board and appropriate personnel.  The final disposition of the matter and any decision to file or not file a criminal complaint or to refer the matter to the appropriate law enforcement and/or regulatory agency for independent investigation shall be made in consultation with district legal counsel.  The results of the investigation shall not be disclosed to or discussed with anyone other than those individuals with a legitimate right to know until the results are made public.

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

  • Forgery or unauthorized alteration of any document or account belonging to the district.

  • Forgery or unauthorized alteration of a check, bank draft, or any other financial document.

  • Misappropriation of funds, securities, supplies, or other assets.

  • Impropriety in the handling of money or reporting of financial transactions.

  • Profiteering because of “insider” information of district information or activities.

  • Disclosing confidential and/or proprietary information to outside parties.

  • Accepting or seeking anything of material value, other than items used in the normal course of advertising, from contractors, vendors, or persons providing services to the district.

  • Destroying, removing, or inappropriately using district records, furniture, fixtures, or equipment.

  • Failing to provide financial records to authorized state or local entities.

  • Failure to cooperate fully with any financial auditors, investigators or law enforcement.

  • Any other dishonest or fraudulent act involving district monies or resources.

The superintendent, shall investigate reports of fraudulent activity in a manner that protects the confidentiality of the parties and the facts.  All employees involved in the investigation shall be advised to keep information about the investigation confidential.

If an investigation substantiates the occurrence of a fraudulent activity, the superintendent, or board vice-president if the investigation centers on the superintendent, shall issue a report to the board and appropriate personnel.  The final disposition of the matter and any decision to file or not file a criminal complaint or to refer the matter to the appropriate law enforcement and/or regulatory agency for independent investigation shall be made in consultation with district legal counsel.  The results of the investigation shall not be disclosed to or discussed with anyone other than those individuals with a legitimate right to know until the results are made public.

 

Approved:   5/11/2020              Reviewed:           Revised:  

 

707.6 Audit Committee

The board recognizes that it is charged with raising tax revenues and related expenditures to maintain the educational program for the school district.  Public funds are held in trust by the board to be spent appropriately on the educational program.  To further ensure funds are spent appropriately, the board establishes an audit committee to assist the board on internal financial matters and with the annual audit.  

The audit committee is comprised of: 
All members of the school board.

The audit committee chair is the President of the school board.

The major responsibilities of the audit committee are to:

  • Recommend an auditor to the board every three years.
  • Oversee the selection of the independent auditor and the resolution of audit findings including compliance with the mandatory request for proposal process. 
  • Act as a liaison between the board and the auditor during the audit process.
  • Annually report to the board about the annual audit.
  • Recommend internal changes that may need to be made to ensure appropriate internal controls are being implemented.

The audit committee will meet as directed by its chair.  The audit committee is subject to the open meetings law.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

708 Care, Maintenance and Disposal of School District Records

School district records shall be housed in the central administration office of the school district. It shall be the responsibility of the superintendent to oversee the maintenance and accuracy of the records. The following records shall be kept in accordance with Generally Accepted Accounting Principles (GAAP) and other applicable laws, 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. deedes, abstracts): Permanently

  • Records of payment of judgments against the school district: 20 years

  • Bonds and bond coupons: 11 years after maturity, cancellation, transfer, redemtion and/or replacement                        

  • Written contracts: 11 years

  • Cancelled warrants, check stubs, bank statements, bills, invoices, and related records:  5 years

  • Recordings of closed meetings, except if matters are in litigation: 1 year

  • Program grants: Determined by the grant

  • Non-payroll personnel records:  7 years following employee separation from the district

  • Payroll/Personnel records: 3 years after leaving the district

  • Employment applications: 2 years

  • Payroll records: 3 years

  • School meal programs accounts/records: 3 years after submission of the final claim for reimbursement

 

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

An inventory of the furniture, equipment, and other non-consumable items other than real property of the school district shall be conducted annually under the supervision of the superintendent. This report shall be filed with the board secretary.  A perpetual inventory shall be maintained on consumable property of the school district.

The permanent and cumulative records of students currently enrolled in the school district shall be maintained in the administration office of the attendance center where the student attends.

Permanent records must be preserved in a manner safe from destruction by fire or other natural disaster. The building administrator shall be responsible for keeping records current. Records of students who have graduated or are no longer enrolled in the school district shall be preserved by the District Office. These records will be maintained by the high school principal.

The superintendent or designee may electronically store and/or back-up or use any other reliable mass storage method to preserve school district records and may destroy paper copies of the records if they are more than three years old.

Approved:          10/21/2019                   Reviewed:                     Revised:   06/26/2023

709 Insurance Program

The board will maintain a comprehensive insurance program to provide adequate coverage against major types of risk, loss, or damage, as well as legal liability. The board will purchase insurance at replacement values, when possible, after reviewing the costs and availability of such insurance. The comprehensive insurance program shall be reviewed at least once every three years. The board shall periodically use a request for proposal procedure in selecting their insurance provider.  Insurance will only be purchased through legally licensed Iowa insurance agents.

The school district may 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 $ 1000.00 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 shall be the responsibility of the superintendent. The fixed assets manager shall be responsible for maintaining the fixed assets management system, processing claims, and maintaining loss records.

Approved:          10/21/2019                   Reviewed:                     Revised:   

710.1 School Food Program

The school district will operate a school lunch and breakfast program in each attendance center. The school food program services will include hot lunches through participation in the National School Lunch Program and supplementary foods for students during the school day. Students may bring their lunches from home and purchase milk or juice and other incidental items.

School food service facilities are provided to serve students and employees when school is in session and during school-related activities. They may also be used under the supervision of the superintendent for food service to employee groups, parent-teacher meetings, civic organizations meetings for the purpose of better understanding the schools, and senior citizens in accordance with board policy.

The school food service program is operated on a non-profit basis. The revenues of the school food service program will be used only for paying the costs of the school food service program. Supplies of the school food service program shall only be used for the school food service program.

The board will set, and periodically review, the prices for school lunches, breakfasts, and special milk programs. It shall be the responsibility of the superintendent and business manager to make a recommendation regarding the prices of school lunches, breakfasts, and milk. Employees, students and others will be required to pay for meals consumed.

It shall be the responsibility of Food Service Director to administer the program and to coordinate with the superintendent and business manager for the proper functioning of the school food services program.

710.1E1 - School Nutrition Program Notices of Nondiscrimination

710.1E2 - Child Nutrition Programs Civil Rights Complaint Form

710.1R1 - School Nutrition Program Civil Rights Coplaint Procedure

 

 

Approved:          10/21/2019                   Reviewed:                     Revised:   02/27/2023

710.1E1 - School Nutrition Program Notices of Nondiscrimination

Code No. 710.1E1

SCHOOL NUTRITION PROGRAM NOTICES OF NONDISCRIMINATION

USDA Nondiscrimination Statement:

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.

Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at 800-877-8339. Additionally, program information may be made available in languages other than English.

To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: https://www.usda.gov/oascr/how-to-file-a-program-discriminationcomplaint, 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

3. Email: program.intake@usda.gov

This institution is an equal opportunity provider.

Iowa Nondiscrimination Statement It is the policy of this CNP provider not to discriminate on the basis of race, creed, color, sex, sexual orientation, gender identity, national origin, disability, age, or religion in its programs, activities, or employment practices as required by the Iowa Code section 216.6, 216.7, and 216.9. If you have questions or grievances related to compliance with this policy by this CNP Provider, please contact the Iowa Civil Rights Commission, Grimes State Office Building, 400 E 14th St, Des Moines, IA 50319- 1004; phone number 515-281-4121 or 800-457-4416; website: https://icrc.iowa.gov/.

710.1E2 - Child Nutrition Programs Civil Rights Complaint Form

Code No. 710.1E2

CHILD NUTRITION PROGRAMS CIVIL RIGHTS COMPLAINT FORM

Complaint Contact Information

Name:

Street Address:

City:                                                                                  State:                                                     Zip:

County:                                                                             Area Code/Phone:

Email Address:

 

Complaint Information:

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.

710.1R1 - School Nutrition Program Civil Rights Complaints Procedure

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/.

Bureau of Nutrition and Health, IDOE, 12/2021

710.2 Free or Reduced Cost Meals Eligibility

Students enrolled and attending school in the school district, who are unable to afford the special milk program, the cost or a portion of the cost of a school lunch, breakfast, and supplemental foods, will be provided school food program services at no cost or at a reduced cost.

 

It shall be the responsibility of the food service director to determine if a student qualifies for free or reduced cost school food services. Students, whom the food service director believes are in need of proper nourishment will not be denied school food program services simply because the necessary paperwork has not been completed.

 

*It shall be the responsibility of the Superintendent to establish regulations regarding the collection of unpaid meal debt and service of meals for students who are not eligible for free or reduced price lunch for whom sufficient funds are not available in their account for payment for payment.

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

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 and Activities Director.  Purchases from the vending machines, will reflect the guidelines in the Wellness policy 536.

It is the responsibility of the superintendent to develop administrative regulations for the use of vending machines and other sales of food to students.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

710.4 Meal Charges

In accordance with state and federal law, the Knoxville Community School District adopts the following policy to ensure school district employees, families, and students have a shared understanding of expectations regarding meal charges. The policy seeks to allow students to receive the nutrition they need to stay focused during the school day, prevent the overt identification of students with insufficient funds to pay for school meals, and maintain the financial integrity of the nonprofit school nutrition program. 

Payment of Meals

Students have use of a meal account.  Families may add money to student accounts electronically through the student information system or by bringing funds to the school office.

Students who qualify for free meals shall never be denied a reimbursable meal, even if they have accrued a negative balance from previous purchases.  Schools are encouraged to provide a reimbursable meal to students with outstanding meal charge debt.  If an alternate meal is provided, the meal must be the same meal presented in the same manner to any student requesting an alternate meal.  

Employees may use the district student information system to add funds to their lunch account. Employees may not go into the negative on their account. 

Negative Account Balances
The school district will make reasonable efforts to notify families when meal account balances are low. Additionally, the school district will make reasonable efforts to collect unpaid meal charges classified as delinquent debt. The school district will coordinate communications with the student’s parent or guardian to resolve the matter of unpaid charges. Parents or guardians will be notified of an outstanding negative balance of $20 or more via a daily notification from the student information system. Negative balances of more than $40, not paid prior to the end of the school year, will be turned over to the superintendent or superintendent’s designee for collection. Options may include: collection agencies, small claims court, or any other legal method permitted by law. 

Unpaid Student Meals Account
The district will establish an unpaid student meals account in a school nutrition fund.  Funds from private sources and funds from the district flexibility account may be deposited into the unpaid school meals account in accordance with law.  Funds deposited into this account shall be used only to pay individual student meal debt. 

Communication of the Policy 
The policy and supporting information regarding meal charges shall be provided in writing to:

  • All households at or before the start of each school year; 
  • Students and families who transfer into the district, at time of transfer; and
  • All staff responsible for enforcing any aspect of the policy.  

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

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

 

Approved:  4/10/23                   Reviewed:                     Revised:   

711.1 Student School Transportation Eligibility

Elementary and middle school students living more than two miles from their designated school attendance center and high school students living more than three miles from their designated attendance center shall receive transportation to and from their attendance center at the expense of the school district.

 

Transportation of students who require special education services shall 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 weighted funds or IDEA federal funds designated for special education purposes.

 

Transportation of a student to and from a special education support service is a function of that service, and shall be specified in the individualized education program (IEP) or the individualized family service plan (IFSP). When the IEP 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 program 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, enroute to and from the special education location.

Reimbursement of the actual costs of transportation when by mutual agreement the parents provide transportation for the student to and from the special education location.

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 shall be 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, shall be reimbursed at the current federal rate per mile as set by the IRS.

 

Transportation arrangements made with a neighboring school district shall follow the terms of the agreement.  Students who choose to attend a school in a school district other than their resident school district, shall provide transportation to and from the school at their own expense unless they are eligible for reimbursement by the school district of resident.  The district retains the authority to determine the means of transportation, either via district bus to attending district or to a bus stop in the attending district, allowing the attending district to come into the district of residence to pick up the student, or reimbursement to the parent of allowable transportation expenses.

 

Approved:          10/21/2019                   Reviewed:                     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 recordings 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.

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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

711.2-R(1) Student Conduct On School Transportation - Regulation

All persons riding in school district vehicles will adhere to the following rules.  The driver, sponsor or chaperones are to follow the school bus discipline procedure for student violations of this policy.  Recording devices may be in operation on the school buses.

  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. 
     
  14. 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.
     
  15. Students will not throw objects about the vehicle nor out through the windows.
     
  16. Students will keep feet off the seats.
     
  17. Roughhousing in the vehicle is prohibited.
     
  18. Students will refrain from crowding or pushing.
     
  19. The use or possession of alcohol, tobacco or look-alike substances is prohibited in the vehicle.
     
  20. The Good Conduct Rule is in effect.

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 in 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 attending extracurricular events, other than those held at the school district facilities, may be transported to the extracurricular event by school district transportation vehicles.

Students, who are provided transportation in school district transportation vehicles for extracurricular events, shall ride both to and from the event in the school vehicle unless arrangements have been made with the activities director 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 shall be the responsibility of the superintendent to make a recommendation to the board annually as to whether the school district shall provide the transportation authorized in this policy. In making the recommendation to the board, the superintendent shall 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.

Approved:          10/21/2019                   Reviewed:                     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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

711.5 Transportation of Nonresident and Nonpublic School Students

The board has sole discretion to determine the method to be utilized for transporting non- resident and non-public school students. Non-resident students paying tuition may be, and resident students attending a non-public 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. Non-resident and non-public school students shall 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 non- public school accredited by the Iowa Department of Education will be reimbursed at the established state rate. This reimbursement shall be 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 non-public school students is received by the school district, the funds shall be prorated accordingly.

 

The charge to the non-resident students shall be determined based on the students' pro rata share of the actual costs for transportation. The parents of these students shall be billed for the student's share of the actual costs of transportation. The billing shall be according to the schedule developed by the superintendent. It shall be the responsibility of the superintendent to determine the amount to be charged and report it to the board secretary for billing.

Continued transportation of non-resident and non-public school students on a public school vehicle route will be subject to resident public school students' transportation needs. The superintendent shall make a recommendation annually to the board regarding the method to be used. In making a recommendation to the board, the superintendent shall 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.

Non-resident and non-public school students shall be subject to the same conduct regulations as resident public students as prescribed by board policy, and other policies, rules or regulations developed by the school district regarding transportation of students by the school district.

Approved:          10/21/2019                   Reviewed:                     Revised:   

711.6 Transportation of Non-School Groups

School district vehicles may be made available to local non-profit entities which promote cultural. educational, civic, community, or recreational activities for transporting to and from non-school- sponsored activities within the state as long as the transportation does not interfere with or disrupt the education program of the school district and does not interfere with or delay the transportation of students. The local non-profit entity must pay the cost of using the school district vehicle as per the current fee schedule. Prior to making the school district transportation vehicle available to the local non-profit entity, the school bus signs shall be covered and the flashing warning lamps and the stop arm made inoperable.

 

Any use of school district vehicles by non-school groups shall be subject to the following guidelines:

  1. Requests must be made a minimum of one week in advance. If the request interferes or conflicts with school district use of the vehicle, the request will be denied. The final decision of whether a request will be granted is within the discretion of the administration.

  2. Requests must be made by recognized youth organizations and/or groups or organizations sponsoring projects in the interest of the local community, state or national benefit or welfare.

  3. The rental period will be negotiated directly with the administration.

  4. Adult chaperones may be required to accompany the bus driver and riders.

  5. All requests will be charged bus and driver fees.

  6. Alcoholic beverages and nicotine products are prohibited on school district vehicles.

  7. Whenever damage caused by vandalism or carelessness results, the group shall reimburse the school district for cost of repairs and may be denied further use of school district vehicles.

Approved:          10/21/2019                   Reviewed:                     Revised:   

721.1 Agreement for Use of School Buses

Date of Request:     _____________________________________________                                                                                 

 

Date Bus Needed:   _____________________________________________                                                                                 

 

Bus Request:           _____________________________________________                                                                                 

 

Time Needed:          _____________________________________________                                                                                 

 

Group Requesting:  _____________________________________________                                                                                 

                                                                                  

 

The use of the buses of the school district shall be in accordance with the following rules and regulations:

  1. Requests must be made a minimum of one week in advance.

  2. Use of the buses fees shall be assessed based upon the actual state transportation report cost per mile.

  3. Driver fees shall be assessed based upon staff employees necessary and available, and at the actual driver contract cost per hour.

  4. Requests must be made a minimum of one week in advance. If the request interferes or conflicts with school district use of the vehicle, the request will be denied. The final decision of whether a request will be granted is within the discretion of the administration.

  5. Requests must be made by recognized youth organizations and/or groups or organizations sponsoring projects in the interest of the local community, state or national benefit or welfare.

  6. The rental period will be negotiated directly with the administration.

  7. Adult chaperones may be required to accompany the bus driver and riders.

  8. All requests will be charged bus and driver fees.

  9. Alcoholic beverages and nicotine products are prohibited on school district vehicles.

  10. Whenever damage caused by vandalism or carelessness results, the group shall reimburse the school district for cost of repairs and may be denied further use of school district vehicles. 

  11. The person signing this agreement shall be financially responsible for all costs accrued.

 

 

(______Total Miles Traveled X_____ Cost per Mile) + (______ Total Hours Traveled X    Hourly Cost of Driver) = ______Total Bus Charge

 

 

SIGNED BY:

 

 

_____________________________________________     _________________________                                                                      

Superintendent or Designee                                              Group Representative

 

Approved:           10/21/2019                  Reviewed:                     Revised:   

711.7 School Bus Safety Instruction

The school district shall conduct school bus safe riding practices instruction and emergency safety drills once a year for students who utilize school district transportation. Each school bus vehicle shall 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 shall include, but not be limited to, students with disabilities. School district vehicle drivers are required to attend each safety drill. Employees shall be responsible for instructing the proper techniques to be followed during an emergency, as well as safe riding practices.

 

All school personnel and designees must wear seat belts while operating private vehicles for school functions and while operating school vehicles equipped with seat belts. All school personnel must use the tire protective cage when inflating or deflating a tire used on school buses and tractors.

 

Approved:       10/21/2019                   Reviewed:                     Revised:   

711.1 School Bus Seats

It is the goal of the Knoxville Community School District Transportation Department to provide the safest student transportation possible. The District purchased school buses equipped with lap/shoulder seat belts in the 2020-2021 school year. The District requires all students riding a school district bus equipped with lap/shoulder seat belts to wear them while the bus is in motion. 

All students will receive instruction on the proper use of the lap/shoulder seat belts during the twice annual bus safety drill. Drivers are not responsible (i.e. liable) for students wearing the lap/shoulder seat belt while riding. Drivers are responsible for instructing students to put on lap/shoulder seat belts prior to the bus moving. 

Students who may require assistance in using lap/shoulder seat belts should ask the bus driver for help, so all students are safely belted in their seats before the bus is in motion. Drivers will announce prior to the bus moving that each student needs to be in their seat with the lap/shoulder seat belt fastened. 

Students refusing to use the lap/shoulder seat belts create a safety concern for themselves and others, and are subject to school district disciplinary actions. Repeated violations not to wear lap/shoulder seat belts can result in bus suspension. 

All adults accompanying students as bus riders are expected to utilize the lap/shoulder seat belts, too.

711.8 Operation of Buses During Inclement Weather

 

Buses owned and operated by the school district will not operate when weather conditions due to fog, rain, snow, ice or other natural elements make such operation unsafe. Because weather conditions may vary throughout the district and may change quickly, the best judgment will be used that is possible with the information available.

The final judgment as to when conditions are unsafe to operate will be made by the superintendent or the superintendent’s designee.

Commercial radio, television, web site and/or automated phone or notification service will be used to notify employees and students when school is cancelled or temporarily delayed.

When, in the judgment of the bus driver, weather conditions are so poor as to present a hazard when loading or unloading students, the driver will contact the superintendent or the superintendent’s designee for instructions. If contact is not possible, the driver will proceed to the next stop which does not present a hazard and make contact personally, with the assistance of a student rider, monitor or other person.

Approved:          10/21/2019                   Reviewed:                     Revised:   

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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

712 Technology and Data Security

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

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

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

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

It is the responsibility of the superintendent or designee 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 or designee 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 or designee 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 or designee 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.

 

Approved:  4/10/23                   Reviewed:                     Revised:   

712-R(1) Technology and Data Security - Security Requirements of Third-Party Vendors Regulation

The District must ensure proper safeguards and procedures exist to use third-party vendors as a resource to further educational functions.  The following procedures shall be used to investigate and contract only with qualifying third-party vendors for the performance of necessary educational functions of the district; and to ensure that third-party vendors meet the required standards to be designated under the Family Educational Rights and Privacy Act (FERPA) as a School Official to handle personally identifiable information (PII) within the district.  

Third-party vendors may be designated by the district as a School Official when the vendor:  

  1. Performs an institutional service or function for which the school or district would otherwise use its own employees;
  2. Has met the criteria set forth in the district’s annual notification of FERPA rights for being a school official with a legitimate educational interest in the education records; 
  3. Is under the direct control of the district regarding the use and maintenance of education records; and  
  4. Uses education records only for authorized purposes and may not re-disclose PII from education records to other parties (unless the provider has specific authorization from the district to do so and is otherwise permitted by FERPA).  

Third party vendor data use requirements shall include, but not be limited to the following:

  1. The vendor implement and maintain security procedures and practices consistent with current industry standards; and
  2. The vendor be prohibited from collecting and using PII for:
    1. Targeted advertising;
    2. Amassing a profile about a student or students except in furtherance of educational purposes;
    3. Selling or renting PII for any purpose other than those expressly permitted by law; and
    4. Disclosing PII for any purposes other than those expressly permitted by law.  

713 Responsible Technology Use & Social Networking

Computers, electronic devices and other technology are powerful and valuable education and research tools and, as such, are an important part of the instructional program. In addition, the school district depends upon technology as an integral part of administering and managing the schools’ resources, including the compilation of data and recordkeeping for personnel, students, finances, supplies and materials. This policy outlines the board’s expectations in regard to these different aspects of the school district’s technology resources. Students, staff and volunteers must conduct themselves in a manner that does not disrupt the educational process and failure to do so may result in discipline, up to and including student discipline under all relevant district policies and discharge for employees. 

General Provisions

The superintendent is responsible for designating a Technology Director who will oversee the use of school district technology resources. The Technology Director will prepare in-service programs for the training and development of school district staff and relevant volunteers in technology skills, appropriate use of district technology and for the incorporation of technology use in subject areas.

The superintendent, working with appropriate staff, shall establish regulations governing the use and security of the school district’s technology resources. The school district will make every reasonable effort to maintain the security of the district networks and devices. All users of the school district’s technology resources, including students, staff and volunteers, shall comply with this policy and regulation, as well as others impacting the use of school equipment and facilities. Failure to comply may result in disciplinary action, up to and including discharge or expulsion, as well as suspension and/or revocation of technology access privileges.

Usage of the school district’s technology resources is a privilege, not a right, and that use entails responsibility. District-owned technology and district-maintained Internet-based collaboration software social media and e-mail accounts are the property of the school district. Therefore, users of the school district’s network must not expect, nor does the school district guarantee, privacy for use of the school district’s network websites visited. The school district reserves the right to access and view any material stored on school district equipment, within district-owned software or any material used in conjunction with the school district’s network.

The superintendent, working with the appropriate staff, shall establish procedures governing management of technology records in order to exercise appropriate control over technology records, including financial, personnel and student information. The procedures will address at a minimum:  

  • passwords,

  • system administration,

  • separation of duties,

  • remote access, 

  • data back-up (including archiving of email),

  • record retention, and

  • disaster recovery plans.

Social Networking or Other External Web Sites

For purposes of this policy, any website, other than the school district website or school-school district sanctioned websites, are considered external websites. Employees and volunteers shall not post confidential or proprietary information, including photographic images, about the school district, its employees, students, agents or others on any external website without prior written consent of the superintendent or designee. Employees and volunteers shall adhere to all applicable privacy and confidentiality policies adopted by the school district when on external websites. Employees, students and volunteers shall not use the school district logos, images, iconography, etc. on external websites unless authorized in advance by school administration. Employees shall not use school district time or property on external sites that are not in direct relation to the employee’s job duties. Employees, students and volunteers need to realize that the internet is not a closed system and anything posted on an external site may be viewed by others. Employees, students and volunteers who don’t want school administrators to know their personal information, should refrain from sharing it on the internet. Employees and volunteers should not connect with students via external websites without consent of the building level administrator.

Employees and volunteers who wish to connect with students through an Internet-based software application that is not District-approved must first obtain the prior written consent of the building administrator.  At all times, no less than two licensed employees must have access to all accounts and interactions on the software application. Employees and volunteers who would like to start a social media site for school district-sanctioned activities should obtain prior written consent from the superintendent. 

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

Approved:                     Reviewed: 02/26/2024                     Revised:   

 

713.R1 Responsible Technology Use & Social Networking-Regulation

General

The following rules and regulations govern the use of the school district's network systems, employee access to the internet, and management of digital records:

  • Employees will be issued a school district email account. Employees are required to set up 2-factor authentication for security purposes.

  • Each individual in whose name an access account is issued is responsible at all times for its proper use.

  • Employees are expected to review their email regularly and shall reply promptly to inquiries with information that the employee can reasonably be expected to provide.

  • Communications with parents and/or students must be made on a school district computer or platform, unless in the case of an emergency. 

  • Employees may access the internet for education-related and/or work-related activities.

  • Employees shall refrain from using technology resources for personal use, including access to social networking sites.

  • Use of the school district technology and school email address is a public record. Employees cannot have an expectation of privacy in the use of the school district’s  network and technology

  • Use of technology resources in ways that violate the acceptable use and conduct regulation, outlined below, will be subject to discipline, up to and including discharge.

  • Use of the school district’s network is a privilege, not a right. Inappropriate use may result in the suspension or revocation of that privilege.

  • Off-site access to the school district network will be determined by the superintendent in conjunction with appropriate personnel. 

  • All network users are expected to abide by the generally accepted rules of network etiquette. This includes being polite and using only appropriate language. Abusive language, vulgarities and swear words are all inappropriate.

  • Network users identifying a security problem on the school district's network must notify appropriate staff. Any network user identified as a security risk or having a history of violations of school district technology use guidelines may be denied access to the school district's network.

  • Employees are representatives of the district at all times and must model appropriate character, both on and off the worksite.  This applies to material posted with personal devices and on personal websites and/or social media accounts.  Posted messages or pictures which diminish the professionalism or discredit the capacity to maintain respect of students and parents may result in disciplinary action up to and including termination if the content posted is found to be disruptive to the educational environment and adversely impacts the employee’s ability to effectively serve as a role model or perform his/her job duties for the district. The type of material that would affect an employee’s ability to serve as an appropriate role model includes, but is not limited to, text or depictions involving hate speech, nudity, obscenity, vulgarity or sexually explicit content.  Employee communications with students should be limited as appropriate.  If there is any uncertainty, employees should consult their building administrator.

Prohibited Activity and Uses

The following is a list of prohibited activity for all employees concerning use of the school district's network.  Any violation of these prohibitions may result in discipline, up to and including discharge, or other appropriate penalty, including suspension or revocation of a user's access to the network.

  • Using the network for commercial activity, including advertising, or personal gain.

  • Infringing on any copyrights or other intellectual property rights, including copying, installing, receiving, transmitting or making available any copyrighted software on the school district network. See Policy 605.07, Use of Information Resources for more information.

  • Using the network to receive, transmit or make available to others obscene, offensive, or sexually explicit material

  • Using the network to receive, transmit or make available to others messages that are racist, sexist, and abusive or harassing to others.

  • Use of another’s account or password.

  • Attempting to read, delete, copy or modify the electronic mail (e-mail) of other system users.

  • Forging or attempting to forge e-mail messages.

  • Engaging in vandalism. Vandalism is defined as any malicious attempt to harm or destroy school district equipment or materials, data of another user of the school district’s network or of any of the entities or other networks that are connected to the Internet. This includes, but is not limited to, creating and/or placing a virus on the network.

  • Using the network to send anonymous messages or files.

  • Revealing the personal address, telephone number or other personal information of oneself or another person.

  • Intentionally disrupting network traffic or crashing the network and connected systems.

  • Installing personal software or using personal technology on the school district’s technology and/or network without the permission of the Technology Director.

  • Using the network in a fashion inconsistent with directions from teachers and other staff and generally accepted network etiquette.

Other Technology Issues

Employees should contact students and their parents through the school district's technology or phone system unless in the case of an emergency or with prior consent of the principal. Employees should not release their cell phone number, personal email address, etc. to students or their parents.

Approved:                         Reviewed: 02/26/2024                      Revised:

 

727 Capital Assets

The school district will establish and maintain a capital assets management system for reporting capitalized assets owned or under the jurisdiction of the school district in its financial reports in accordance with generally accepted accounting principles (GAAP) as required or modified by law; to improve the school district's oversight of capital assets by assigning and recording them to specific facilities and programs and to provide for proof of loss of capital assets for insurance purposes. 

Capital assets, including tangible and intangible assets, are reported in the government-wide financial statements (i.e. governmental activities and business type activities) and the proprietary fund financial statements.  Capital assets reported include school district buildings and sites, construction in progress, improvements other than buildings and sites, land and machinery and equipment. Capital assets reported in the financial reports will include individual capital assets with an historical cost equal to or greater than $2,000. The Federal regulations governing school lunch programs require capital assets attributable to the school lunch program with a historical cost of equal to or greater than $500 be capitalized.  Additionally, capital assets are depreciated over the useful life of each capital asset.  

All intangible assets with a purchase price equal to or greater than $50,000 with useful life of two or more years, are included in the intangible asset inventory for capitalization purposes. Such assets are recorded at actual historical cost and amortized over the designated useful lifetime applying a straight-line method of depreciation. If there are no legal, contractual, regulatory, technological or other factors that limit the useful life of the asset, then the intangible asset needs to be considered to have an indefinite useful life and no amortization should be recorded.

Phase III districts, as determined under GASB 34, will not retroactively report intangible assets. If actual historical cost cannot be determined for intangible assets due to lack of sufficient records, estimated historical cost will be used.

This policy applies to all intangible assets.  If an intangible asset that meets the threshold criteria is fully amortized, the asset must be reported at the historical cost and the applicable accumulated amortization must also be reported. It is not appropriate to “net” the capital asset and amortization to avoid reporting.  For internally generated intangible assets, outlays incurred by the government's personnel, or by a third-party contractor on behalf of the government, and for development of internally generated intangible assets should be capitalized.

The capital assets management system must be updated monthly to account for the addition/acquisition, disposal, relocation/transfer of capital assets. It is the responsibility of the superintendent to count and reconcile the capital assets with capital assets management system on June 30 each year.

It is the responsibility of the superintendent to develop administrative regulations implementing this policy. It will also be the responsibility of the superintendent to educate employees about this policy and its supporting administrative regulations.   

 

NOTE:  It is suggested the board consider a capitalization threshold consistent with the GASB 34 Committee Recommendations which recommended "districts and AEAs implement capitalization levels that would capture at least 80% of the value of assets.  However, the threshold should not be greater than $5,000."   In addition, Boards may wish to establish guidelines at lower thresholds for keeping track of capital assets for internal control and insurance purposes.

In determining the capital asset capitalization threshold, the size of the school district, the property insurance deductible and the time and effort necessary to account for and track capital assets with a lesser value should be considered.  It is strongly recommended the board consult with the school auditor prior to setting the capitalization threshold.  

An intangible asset should be recognized in the statement of net assets only if it is identifiable which means the asset is either separable or, arose from contractual or other legal rights, regardless of whether those rights are transferable or separable.  The intangible asset must also possess all of the following characteristics/criteria:

  • lack of physical substance;  
  • be of a nonfinancial nature (not in monetary form like cash or investment securities); and,
  • the initial useful life extending beyond a single reporting period.

Examples of intangible assets include easements, land use rights, patents, trademarks and copyrights.  In addition, intangible assets include computer software purchased, licensed or internally generated, including websites, as well as outlays associated with an internally generated modification of computer software. 

Intangible assets can be purchased or licensed, acquired through nonexchange transactions or internally generated.  Intangible assets exclude assets acquired or created primarily for purposes of directly obtaining income, assets from capital lease transactions reported by lessees, and goodwill created through the combination of a government and another entity.

A school district could, and many do, use bar code identification tags to control capital assets, such as VCRs, technology equipment, etc., even though these capital assets have a cost below the capitalization threshold.  In tracking these capital assets only the information necessary to control the location and use of them needs to be maintained.  Some school districts video-tape each classroom/office annually to save time and effort tracking capital assets below the capitalization threshold.  The video tape is also helpful for insurance claims.  Whether a school district chooses to track capital assets with a cost below the capitalization threshold or not, capital assets with a cost below the capitalization threshold should not be included in the capital assets listing for reporting purposes.  

This policy provides for valuing capital assets at historical cost as required by GAAP.  This policy bases the capitalization threshold on the historical/acquisition cost of the individual asset.  The school district can choose to use the historical cost of all the items included in a purchase order as the basis for determining whether to capitalize the capital asset.  The cost of improvements may be added to the historical cost of a capital asset.  Deciding whether to add the costs of an improvement to a capital asset's historical cost is a judgment call which should be made after consulting with the school auditor.

 

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

727.1 Capital Assets - Regulation

A. Capital Assets Management System 

The superintendent, and/or other designated staff, shall:

  1. Conduct the capital assets physical count;

  2. Develop the capital assets listing;

  3. Tag capital assets included in the capital assets management system with a bar code identification number;  

  4. Make a recommendation of a computer software program for managing the capital assets management system;

  5. Enter the necessary data into the capital assets management system and compile the appropriate reports;

  6. Develop forms and procedures for maintaining the integrity of the capital assets management system; and,

  7. Maintain responsibility for an accurate capital assets management system.  

 

B. Determining historical cost

  1. The historical cost of a capital asset is based on the actual costs expended in making the capital assets serviceable.      

  2. Gifts of capital assets are valued at the estimated fair market value at the addition/acquisition date.  

  3. Capital assets purchased under a capital lease are valued at historical cost of their net present value of the minimum lease payments on the addition/acquisition date.    

  4. The historical cost of capital assets must include capitalized interest.

 

C. Annual capital assets listing reconciliation

  1. The superintendent, and/or other designated staff, in conjunction with the capital assets management team, will conduct an annual capital assets physical count to develop the annual capital assets listing in a manner similar to the initial capital assets listing process in B above.  At least every three years, someone other than the person in custody of the capital assets in the building/department/room will perform the capital assets physical count for the building/department/room. 

  2. Upon completion of the annual capital assets listing, the capital assets listing is reconciled to the capital assets management system data base.    

  3. Capital assets found to have been excluded from the data base are added to the capital assets management system.  The capital assets management system process should be reviewed to prevent future incidents of excluding a capital asset. 

  4. Capital assets unaccounted for are reported to the superintendent who contacts the supervisor of and the individual in charge/control/custody of the capital asset.  The individual in charge/control/custody of the capital asset has thirty days to account for the capital asset.     

  5. Capital assets unaccounted for after thirty days are reported to the superintendent for appropriate action and documentation.  "Appropriate action" may include discipline, up 

  6. to and including discharge, and may require the employee/person in charge/control/custody of the capital asset to replace the asset.

  7. The superintendent is responsible for documenting the reasons each asset was not reconciled to the capital assets management system.    

 

 D. Addition/acquisition of capital assets.  

  1. The school district's purchasing policy and administrative regulations must be followed when acquiring capital assets.  The school district's policy and administrative regulations must be followed for receiving a gift of capital assets.   

  2. The capital assets addition/acquisition documentation must be completed for each additional capital assets with an addition/acquisition cost of equal to or greater than ($ capitalization threshold).  The following information should be collected, if applicable:

  • Name of location-building/department/room;

  • Location-building/department/room code;

  • Balance sheet accounting/class code;

  • Government or BTA program;

  • Addition/acquisition date;

  • Check/purchase order number or gift;

  • Bar code identification number assigned to and placed on the capital asset;

  • Serial/model number;                    

  • Cost-historical;

  • Fair market value on acquisition date (donated assets only);

  • Estimated useful life;

  • Vendor;

  • Purchasing fund and function;

  • Description of capital asset;

  • Department/person charged with custody, 

  • Method of addition/acquisition-purchase, trade, gift etc., 

  • Quantity;

  • Replacement cost; 

  • Addition/acquisition authorization; and,

  • Function for depreciation.

3. Capital assets acquired in a month must be entered into the capital assets management system in the same month.

4. The actual costs of construction in progress, other than infrastructure, is entered into the capital assets management system in the month in which costs are incurred until the total cost of addition/acquisition is entered.  Upon completion of construction, the total costs accumulated over the period of construction are reclassified to buildings. 

5. Capital assets acquired in a month must be entered into the capital assets management system in the same month.

 

E. Relocation/transfer of machinery and equipment capital assets.

  1. A capital assets relocation/transfer documentation must be completed prior to removing machinery and equipment capital assets from their current location.  The following information must be collected:

  • Relocation/transfer date;

  • Quantity;

  • Bar code identification number; 

  • Current location-building/department/room code;

  • Name of current location-building/department/room;

  • New location-building/department/room code;

  • Name of new location-building/department/room;

  • Date placed at new location-building/department/room;

  • Department/person charged with custody; and

  • Relocation/transfer authorization.

     2. Capital assets relocated/transferred in a month must be entered into the capital assets management system in the same month.

 

F. Disposal of capital assets

  1. A Capital Assets disposal documentation must be completed prior to disposing of real property.  The following information must be collected:

  • Disposal date;

  • Quantity;

  • Bar code tag identification number;

  • Legal description, 

  • Location/Address;

  • Purchaser;

  • Disposal methods for real property trade, sale, stolen, etc.; and,

  • Disposal authorization.

     2.  Capital assets disposed of in a month must be entered into the capital assets management system in the same month.

     3.  When assets are sold or disposed of, it is necessary to calculate and report a gain or loss in the statement of activities.  The gain/loss              is calculated by subtracting the net book value (historical cost less any accumulated amortization) from the net amount realized on                the sale or disposal.

 

G. Lost, damaged or stolen capital assets. 

  1. A Lost, Damaged or Stolen Capital Assets Report must be completed when a capital asset has been lost, damaged or stolen. The following information must be collected:

  • Date of loss, damage or theft;

  • Employee/person discovering; 

  • Quantity;

  • Description of capital asset;

  • Bar code tag identification number; 

  • Location-building/department/room; 

  • Description of loss, damage, etc.;

  • Filing of police report-yes or no;

  • Filing of insurance report-yes or no;

  • Sent for repair-yes or no;

  • Date returned from repair;

  • Date returned to location-building/department/room; 

  • Department/person charged with custody; and,

  • Authorization.    

  1. Capital assets damaged, lost or stolen in a month must be entered into the capital assets management system in the same month.

    

H. Capital assets reports

  1. Annual reports for June 30 each year.      

  • Capital assets listing including the following items:

  • Balance sheet accounting/class code;

  • Purchasing fund, function and depreciation function;

  • Bar code tag identification number;

  • Description of the capital asset;

  • Historical cost or other;

  • Location;

  • Current year depreciation/expense; and,

  • Accumulated depreciation/amortization.

     2.  Capital assets listing by location/building;

     3.  Capital assets listing by department/employee/person charged with custody; and,

     4.  Capital assets listing by replacement cost.  

 

  

NOTE:  This sample administrative regulation provides a sample capital asset management system.  It is important the administrative regulations adopted by a school district reflect is its actual practice. The school district may choose to employ a service provider to conduct the annual capital assets physical count, annual capital assets listing and to implement a capital assets management system for capital assets required to be capitalized under board policy.  Should the board employ a service provider, it is important to have the school attorney review the request for proposals and to draft the service provider contract.

This sample administrative regulation provides for valuing capital assets at historical cost as required by GAAP.  This administrative regulation also requires the school district to maintain the replacement value of capital assets.  Should the school district decide not to maintain replacement values for its capital assets, the requirement should be deleted from the administrative regulation. 

Some school districts in completing their initial capital assets listing consider a room a unit.  For example, 25 student desks, one teacher's desk, one teacher's chair, wastebasket, two storage/file cabinets and so forth could be considered a room unit with a value of $35,000.  The unit is included as one item on the capital assets listing.

This may be a difficult element of a capital assets management system.  Capital assets have a tendency to be moved around and the employees moving them generally do not remember to complete the paperwork or even to inform the superintendent.  A quality annual reconciliation process must be done to ensure a valid capital  assets listing.  Some school districts require a designated person at each building to complete the paperwork upon the disposal of a capital asset.  School districts with a local area network can save paperwork by allowing each building to enter the information regarding disposal of capital assets as long as the appropriate checks and balances exist to verify the information.    

The school auditor may, at a minimum, require a capital assets listing with the historical or other cost basis and balance sheet accounting/class code for each capital asset in the capital assets listing.  It is important for the school district to consult with the district’s auditor prior to determining the school district's requirements for this annual report.  The other items listed above are optional unless recommended by the school auditor to meet the school district's needs.

The capital assets listing total dollar amount must equal the amount entered on the school district's Certified Annual Report (CAR).  This amount is calculated as follows:

  • Capital assets listing prior year by balance sheet accounting/class code

  • Additions/Acquisitions by balance sheet accounting/class code

  • Disposal by balance sheet accounting/class code                      

  • Capital assets listing current year by balance sheet accounting/class code

The last three reports may be used by school districts for many different purposes.  For example, the "capital assets listing by location/building" and “capital assets listing by department/employee/person charged with custody" are used by school districts for the annual capital assets listing reconciliation to compare the actual capital assets in a building or department/room with the information in the capital assets management system.  

 

 

Approved:          10/21/2019                   Reviewed:                     Revised:   

727.2 Capital Assets - Management Definition Systems

Back trending/standard costing - an estimate of the historical original cost using a known average installed cost for like units as of the estimated addition/ acquisition date.  This cost is only applied to the capital assets initially counted upon implementation of the capital assets management system when the historical original cost cannot be determined.  It is inappropriate to apply the back trending/standard costing method to any capital assets acquired after the assets management system implementation date.

Balance sheet accounting/class codes - the codes set out for assets in the Iowa Department of Education Uniform Accounting Manual.  They are:  200-capital assets; 211- land and land improvements; 221-site improvements; 222-accumulated depreciation on site improvements; 231-buildings and building improvements; 232-accumulated depreciation on buildings and building improvements; 241-machinery and equipment; 242-accumulated depreciation on machinery and equipment, 251-works of art and historical treasures; 252-accumulated depreciation on works of art and historical treasures, 261-infrastructure, 262-accumulated depreciation on infrastructure, and 271-construction in progress.

Book value - the value of capital assets on the records of the school district, which can be the cost or, the cost less the appropriate allowances, such as depreciation.

Buildings and building improvements - a capital assets account reflecting the addition/acquisition cost of permanent structures owned or held by a government and the improvements thereon. 

Business-type activities – one of two classes of activities reported in the government-wide financial statements.  Business-type activities are financed in the whole or in part by fees charged to external parties for goods or services.  These activities are usually reported in enterprise funds. 

Capital expenditures/expenses - expenditures/expenses resulting in the addition/acquisition of or addition/acquisition to the school district's capital assets.

Capital assets - Capital assets with a value of equal to or greater than ($ capitalization threshold) based on the historical cost include:  long-lived assets obtained or controlled as a result of past transactions, events or circumstances.  Capital assets include buildings, construction in progress, improvements other than facilities, land, machinery and equipment, and intangible assets.

Capitalization policy - the criteria used by the school district to determine which capital assets will be reported as capital assets on the school district’s financial statements and records

Capitalization threshold - The dollar value at which a government elects to capitalize tangible or intangible assets that are used in operations and that have initial useful lives extending beyond a single reporting period.

Capitalized interest - interest accrued and reported as part of the cost of the capital assets during the construction phase of a capital project.  The construction phase extends from the initiation of pre-construction activities until the time the asset is placed in service.  

Construction in progress - buildings in the process of being constructed other than infrastructure.

Cost - the amount of money or other consideration exchanged for goods or services.

Depreciation/Amortization - expiration in the service life of capital assets, other than wasting assets, attributable to wear and tear, deterioration, action of the physical elements, inadequacy and obsolescence.  In accounting for depreciation/amortization, the cost of a capital asset, less any salvage value, is prorated over the estimated service life of such an asset, and each period is charged with a portion of such cost.

Fixtures - attachments to buildings that are not intended to be removed and cannot be removed without damage to the buildings.  Those fixtures with a useful life presumed to be as long as that of the building itself are considered a part of the building.  Other fixtures are classified as machinery and equipment.  

General capital assets - capital assets that are not capital assets of any fund, but of the governmental unit as a whole.  Most often these capital assets arise from the expenditure of the financial resources of governmental funds.

General capital assets account group (GFAAG) - a self-balancing group of accounts established to account for capital assets of the school district, not accounted for through specific proprietary funds.

Government activities – activities generally financed through taxes, intergovernmental revenues, and other non-exchange revenues.  These activities are usually reported in governmental funds and internal service funds.

Government-wide financial statements – Financial statements that incorporate all of a government's governmental and business-type activities, as well as its nonfiduciary component units.  There are two basic government-wide financial statements the statement of net assets and the statement of activities.  Both basic government-wide financial statements are presented using the economic resources measurement focus and the accrual basis of accounting.

Historical (acquisition) cost - the actual costs expended to place a capital asset into service.  For land and buildings, costs such as legal fees, recording fees, surveying fees, architect fees and similar fees are included in the historical cost.  For machinery and equipment, costs such as freight and installation fees and similar fees are included in the historical cost.

Improvements – In addition made to, or change made in, a capital asset, other than maintenance, to prolong its life or to increase the efficiency or capacity.  The cost of the addition or change is added to the book value of the asset.

Improvements other than buildings - attachments or annexation to land that are intended to remain so attached or annexed, such as sidewalks, trees, drives, tunnels, drains and sewers.  Sidewalks, curbing, sewers and highways are sometimes referred to as "betterments," but the term "improvements" is preferred.

Infrastructure – long-lived capital assets that normally are stationary in nature and normally can be preserved for a significantly greater number of years than most capital assets.  Examples of infrastructure assets include; roads, bridges, tunnels, drainage systems, tater and sewer systems, dams, and lighting systems. 

Investment in general capital assets - an account in the GFAAG representing the school district's investment in general capital assets. The balance in this account generally is subdivided according to the source of the monies that finance the capital assets addition/acquisition, such as general fund revenues and special assessments.  

Land and buildings - real property owned by the school district.

Machinery and equipment - capital assets which maintain their identity when removed from their location and are not changed materially or consumed immediately (e.g., within one year) by use.  Machinery and equipment are often divided into specific categories such as:  transportation machinery and equipment which includes school buses and school district owned automobiles, trucks and vans; other motor machinery and equipment which includes lawn maintenance machinery and equipment, tractors, motorized carts, maintenance machinery and equipment, etc.; other machinery and equipment which includes furniture and machinery and equipment contained in the buildings whose original cost is equal to or greater than ($ capitalization threshold), and capital assets under capital leases and capital assets being acquired under a lease/purchase agreement. 

Proprietary funds – Funds that focus on the determination of operating income, changes in net assets (or cost recovery), financial position, and cash flows.  There are two different types of proprietary funds:  enterprise funds and internal service funds.

Replacement cost - the amount of cash or other consideration required today to obtain the same capital assets or its equivalent.

 

Approved:          10/21/2019                   Reviewed:                     Revised: