Each year at its annual meeting, the board will designate by resolution the name and location of the Iowa located financial depository institution or institutions to serve as the official school district depository or depositories. The maximum deposit amount to be kept in the depository will be stated in the resolution. The amount stated in the resolution must be for all depositories and include all of the school district's funds.

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

Legal Reference:
Iowa Code §§ 12C2; 279.33

Cross Reference:
210.1 Annual Meeting
206.4 Treasurer [or 206.3, Secretary-Treasurer]
704.1 Local - State - Federal - Miscellaneous Revenue

Approved: 04/11/22        Reviewed: 03/21/22              Revised: 07/21/14

When the necessity for a fund has ceased to exist, the balance may be transferred to another fund or account by board resolution. School district monies received without a designated purpose may be transferred in this manner. School district monies received for a specific purpose or upon vote of the people may only be transferred, by board resolution when the purpose for which the monies were received has been completed. Voter approval is required to transfer monies to the general fund from the capital projects fund and debt service fund.

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

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

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

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

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

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

Legal Reference:
Iowa Code §§ 24.21-.22; 257.10, 279.8; 279.42; 298A.
289 I.A.C. 6

Cross Reference:
701.3 Financial Records
703 Budget
704.2 Sale of Bonds

Approved: 05/15/23        Reviewed: 03/21/22             Revised: 05/15/23

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

Governmental fund type:

• General fund
• Special revenue fund
  • Management Levy fund
  • Public Education and Recreation Levy fund (PERL)
  • Student activity fund
• Capital projects fund
  • Physical Plant and Equipment Levy fund (PPEL)
  • Secure and Advanced Vision for Education (SAVE)
• Debt service fund

Proprietary fund type:

• Enterprise fund
  • School nutrition fund
  • Child care fund
• Internal service fund

Fiduciary funds:

• Trust
  • Expendable trust funds
  • Nonexpendable trust funds
  • Pension trust funds
• Custodial Funds

Account groups:

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

The general fund is used primarily for the education program.  Special revenue funds are used to account for monies restricted to a specific use by law.  Capital projects funds are used to account for financial resources to acquire or construct major capital facilities (other than those of proprietary funds and trust funds) and to account for revenues from SAVE. A debt service fund is used to account for the accumulation of resources for, and the payment of, general long-term debt principal and interest.  Proprietary funds account for operations of the school district operated similar to private business, or they account for the costs of providing goods and services provided by one department to other departments on a cost reimbursement basis.  Fiduciary funds are used to account for monies or assets held by the school district on behalf of, or in trust for, another entity.  The account groups are the accounting records for capital assets and long-term debt.

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

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

Legal Reference:
Iowa Code §§291; 298; 298A.
281 I.A.C. 98

Cross Reference:
704 Revenue
705 Expenditures

Approved: 04/11/22        Reviewed: 03/21/22              Revised: 07/21/14

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.

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

Legal Reference:
Iowa Code §§ 257.31(4); 279.8; 297.22-.25; 298A.

Cross Reference:
701.3 Financial Records
703 Budget
704 Revenue

Approved: 04/11/22
Reviewed: 03/21/22
Revised: _____

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

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

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

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

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

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

Legal Reference:    Iowa Code §§ 257.7, 31; 279.8
 

Prior to certification of the budget, the board will review the projected revenues and expenditures for the school district and make adjustments where necessary to carry out the education program within the revenues projected.

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

• the amount of revenues to be raised by taxation;
• the amount of revenues from sources other than taxation;
• an itemization of the amount to be spent in each fund; and,
• a comparison of the amount spent and revenue received in each fund for like purposes in the two prior fiscal years.

It is the responsibility of the superintendent to prepare the budget for review by the board prior to the April 15 deadline each year.

Prior to the adoption of the proposed budget by the board, the public is apprised of the proposed budget for the school district. Prior to the adoption of the proposed budget by the board, members of the school district community will have an opportunity to review and comment on the proposed budget. A public hearing for the proposed budget of the board is held each year in sufficient time to file the adopted budget no later than April 15.

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

The board will adopt and certify a budget for the operation of the school district to the county auditor by April 15. It is the responsibility of the board secretary to file the adopted and certified budget with the county auditor and other proper authorities.

The board may amend the budget for the fiscal year in the event of unforeseen circumstances. The amendment procedures will follow the procedures for public review and adoption of the original budget by the board outlined in these policies.

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

Legal Reference:
Iowa Code §§ 24; 257; 279.8; 297; 298; 618.

Cross Reference:
214 Public Hearings
703 Budget
704 Revenue
705 Expenditures

Approved: 04/11/22        Reviewed: 03/21/22             Revised: 07/21/14

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

Legal Reference:
Iowa Code § 24.9.

Cross Reference:
703 Budget
704 Revenue

Approved: 04/11/22        Reviewed: 03/21/22              Revised: 07/21/14

Revenues of the school district are received by the board treasurer or their designee. Other persons receiving revenues on behalf of the school district will promptly turn them over to the board treasurer or their designee.

Revenue, from whatever source, is accounted for and classified under the official accounting system of the school district. It is the responsibility of the board treasurer to deposit the revenues received by the school district in a timely manner. School district funds from all sources will not be used for private gain or political purposes.

Tuition fees received by the school district are deposited in the general fund. The tuition fees for kindergarten through twelfth grade during the regular academic school year are set by the board based upon the superintendent'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. Educational materials fees received by the school district are deposited in the general fund. It is the responsibility of the superintendent to recommend to the board when materials fees will be charged and the amount of the educational materials fees.

Rental fees received by the school district for the rental of school district equipment or facilities are deposited in the general fund. It is the responsibility of the superintendent to recommend to the board a fee schedule for renting school district property.

Proceeds from the sale of real property are placed in the physical plant and equipment levy (PPEL) fund. The proceeds from the sale of other school district property are placed in the general fund.

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

• Goods and services directly and reasonably related to the educational mission;
• Goods and services offered only to students, employees or guests, which cannot be provided by private enterprise at the same or lower cost;
• Use of vehicles for charter trips offered to the public, full- or part-time, or temporary students;
• Goods and services which are not otherwise available in the quantity or quality required by the school district;
• Telecommunications other than radio or television stations;
• Sponsoring or providing facilities for fitness and recreation;
• Food service and sales; and,
• Sale of books, records, tapes, software, educational equipment, and supplies;
• Items displaying the emblem, mascot, or logo of district or that otherwise promote the identity of the District and its programs if sold on district property;
• Souvenirs and programs relating to events sponsored by or at the district if sold on district property; and
• Goods, products or professional services which are produced, created or sold incidental to the district's teaching, research and missions.

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

Legal Reference:
Iowa Code §§ 12C; 23A; 24.9; 257.2; 279.8; 41; 282.2, .6, .24; 291.12, 297.9-.12, .22; 301.1.

Cross Reference:
701.1 Depository of Funds
703 Budget
803 Selling and Leasing
905 Use of School District Facilities & Equipment

Approved: 04/15/24        Reviewed: 04/15/24         Revised: 04/15/24

DEBT LIMITS

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

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

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

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

PURPOSES AND USES OF DEBT

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

Capital Financing
The school district may issue long-term debt for capital projects as authorized by Iowa law, which include, but are not limited to, the costs of planning, design, land acquisition, buildings, permanent structures, attached fixtures or equipment, and movable pieces of equipment. Capitalized interest may be included in sizing any capital project debt issue.  The types of debt instruments to be used by the school district include:
·         General Obligation Bonds
·         General Obligation Capital Loan Notes
·         Bond Anticipation Notes
·         Revenue Anticipation Notes
·         School Infrastructure Sales, Services and Use Tax Revenue Bonds
·         Lease Purchase Agreements, including Certificates of Participation
 
Working Capital Financing
The school district may issue debt for working capital for operations after cash flow analysis has determined that there is a mismatch between available cash and cash outflows.  The school district shall strive to repay working capital debt by the end of the fiscal year in which the debt was incurred.  A Working Capital Reserve may be included in sizing any working cap

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 be limited to:

1. post-issuance compliance procedures (including proper use of proceeds, timely expenditure of proceeds, proper use of bond financed property, yield restriction and rebate, and timely return filing);
2. proper maintenance of records to support federal tax compliance;
3. investments and arbitrage compliance;
4. expenditures and assets;
5. private business use; and
6. designation of primary responsibilities for federal tax compliance of all bond financings.

Financial Disclosure
The school district is committed to full and complete financial disclosure, and to cooperating fully with rating agencies, institutional and individual investors, other levels of government, and the general public to share comprehensible and accurate financial information.  The school district is dedicated to meeting secondary disclosure requirements on a timely and comprehensive basis, as promulgated by the Securities and Exchange Commission.

The Official Statements accompanying debt issues, Annual Audits, and Continuing Disclosure statements will meet the standards articulated by the Municipal Securities Rulemaking Board (MSRB), the Government Accounting Standards Board (GASB), the Securities and Exchange Commission (SEC), Generally Accepted Accounting Principles (GAAP) and the Internal Revenue Service (IRS).  The treasurer shall be responsible for ongoing debt disclosure as required by any Continuing Disclosure Certificate for any debt issue and for maintain compliance with disclosure standards promulgated by state and federal regulatory bodies
 

 
Legal Reference:          
Iowa Code §§ 74-76; 278.1; 298; 298A.
 
Cross Reference:        
701      Financial Accounting System
704      Revenue
 
Approved: 04/11/22        Reviewed: 03/21/22                       Revised                
 

1.    Role of Compliance Coordinator/Board Treasurer

The board treasurer shall:
a)     Be responsible for monitoring post-issuance compliance;
b)     Maintain a copy of the transcript of proceedings or minutes in connection with the issuance of any tax-exempt obligations and obtain records that are necessary to meet the requirements of this regulation;
c)     Consult with bond counsel, a rebate consultant, financial advisor, IRS publications and such other resources as are necessary to understand and meet the requirements of this regulation;
d)     Seek out training and education to be implemented upon the occurrence of new developments in the area and upon the hiring of new personnel to implement this regulation.

2.  Financing Transcripts’ Filing and Retention

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

a)     Form 8038;
b)     Minutes, resolutions and certificates;
c)     Certifications of issue price from the underwriter;
d)     Formal elections required by the IRS;
e)     Trustee statements;
f)      Records of refunded bonds, if applicable;
g)     Correspondence relating to bond financings; and
h)     Reports of any IRS examinations for bond financings.

3.  Proper Use of Proceeds

The board treasurer shall review the resolution authorizing issuance for each tax-exempt obligation issued by the school district and the school district shall:

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

4.      Timely Expenditure and Arbitrage/Rebate Compliance

The board treasurer shall review the Tax-Exemption Certificate (or equivalent) for each tax-exempt obligation issued by the school district and the expenditure records provided in Section 2 of this regulation, above and shall:

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

5.      Proper Use of Bond Financed Assets

The board treasurer shall:

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

6.      General Project Records 
For each project financed with tax-exempt obligations, the board treasurer shall maintain, until three years after retirement of the tax-exempt obligations or obligations issued to refund those obligations, the following:

a)     Appraisals, demand surveys or feasibility studies;
b)     Applications, approvals and other documentation of grants;
c)     Depreciation schedules;
d)     Contracts respecting the project.

Approved: 04/11/22        Reviewed: 03/21/22        Revised

School district funds in excess of current needs are invested in compliance with this policy.  The goals of the school district's investment portfolio in order of priority are:

• To provide safety of the principal;
• To maintain the necessary liquidity to match expected liabilities; and
• To obtain a reasonable rate of return.

In making investments, the school district will exercise the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use to meet the goals of the investment program.

School district funds are monies of the school district, including operating funds.  "Operating funds" of the school district are funds which are reasonably expected to be used during a current budget year or within fifteen months of receipt.  When investing operating funds, the investments must mature within three hundred and ninety-seven days or less.  If, during the current budget year an amount of public funds will exceed operating funds by at least thirty-three percent, the amount of public funds that exceed operating funds by greater than thirty-three percent may be invested in certificates of deposit at federally insured depository institutions which mature within sixty-three months or less, in accordance with state and federal laws.  When investing funds other than operating funds, the investments must mature according to the need for the funds.

The board authorizes the treasurer to invest funds in excess of current needs in the following investments.

• Interest bearing savings, money market, and checking accounts at the school district's authorized depositories;
• Iowa Schools Joint Investment Trust Program (ISJIT);
• Obligations of the United States government, its agencies and instrumentalities;
• Certificates of deposit and other evidences of deposit at federally insured Iowa depository institutions;
• Repurchase agreements in which underlying collateral consists of investments in government securities.  The school district must take delivery of the collateral either directly or through an authorized custodian.  Repurchase agreements do not include reverse repurchase agreements;
• Prime bankers' acceptances that mature within two hundred seventy days and that are eligible for purchase by a federal reserve bank.  At the time of purchase no more than ten percent of the investment portfolio can be in these investments and no more than five percent of the investment portfolio can be invested in the securities of a single issuer;
• Commercial paper or other short-term corporate debt that matures within two hundred seventy days and that is rated within the two highest classifications, as established by at least one of the standard rating services, with no more than five percent at the time of purchase placed in the second highest classification.  At the time of purchase no more than ten percent of the investment portfolio can be in these investments and no more than five percent of the investment portfolio can be invested in the securities of a single issuer; and,
• An open-end management investment company registered with the federal securities exchange commission and commonly referred to as a money market mutual fund.  The money market mutual fund will use only the investments individually authorized by law for school districts.

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

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

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

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

It will also be the responsibility of the superintendent, in conjunction with the treasurer, to develop a system of investment practices and internal controls over the investment practices.  The investment practices are designed to prevent losses, to document the officers' and employees' responsibility for elements of the investment process and address the capability of the management.

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

Cross Reference:
206.4 Treasurer
704 Revenue

Approved: 04/11/22        Reviewed: 03/21/22            Revised: 07/21/14

The board believes gifts, grants, and bequests to the school district may be accepted when they will further the interests of the school district. The board will have sole authority to determine whether the gift furthers the interests of the school district.

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

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

Legal Reference:
Iowa Code §§ 279.42; 565.6.

Cross Reference:
217 Gifts to Board of Directors
402.4 Gifts to Employees
508.1 Class or Student Group Gifts

Approved: 04/11/22        Reviewed: 03/21/22            Revised: 07/21/14

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

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

It is the responsibility of the board secretary to keep student activity accounts up-to-date and complete.
Any unencumbered class or activity account balances will automatically revert to the activity fund when a class graduates or an activity is discontinued.

Legal Reference:
Iowa Code § 279.8

Cross Reference:
504 Student Activities
701 Financial Accounting System

Approved: 04/11/22        Reviewed: 03/21/22        Revised: 07/21/14

Fundraising can foster a sense of community and pride in the school district through group efforts to accomplish a common goal.  The school board believes fundraising campaigns can further the interests of the district.  Care must be taken to help ensure fundraising efforts are done properly and safely to benefit the school community.  The school board is responsible for approving all district affiliated and student fundraising.  Any person or entity acting on behalf of the district and wishing to conduct a fundraising campaign for the benefit of the district shall begin the process by seeking prior approval from the board or its designee.  Any fundraising efforts conducted using the district’s resources, name, logos, symbols, or imagery will be conducted in accordance with all policies, regulations and rules for fundraising within the district.

District Affiliated Fundraising

There are times when the school board may decide to engage in district affiliated fundraising efforts to benefit the school district.  All district affiliated fundraising efforts will fulfill a public purpose and will not benefit only one individual or family, except in unique circumstances pre-approved by the school board.  The use of district owned resources to conduct fundraising efforts will be in accordance with all applicable laws and regulations and other relevant district policies and procedures.

Money or items raised by any district affiliated fundraising campaign will be the property of the district only upon acceptance by the board and will be used only in accordance with the terms for which they were given, as agreed to by the board.

Student Fundraising

Students may raise funds for school-sponsored events with the permission of the school board.  The school board delegates to the Superintendent the authority to approve routine student fundraising as deemed appropriate.  Collection boxes for school fund raising mush have prior approval from the school board or its designee before being placed on school property.  All funds generated from district-sponsored student fundraising will be placed in the district’s student activity fund.  The Superintendent will develop necessary regulations to ensure the safety and equity of student fundraising efforts.

Online Fundraising

The use of the district’s name, logos, symbols, or imagery for online fundraising will be subject to the approval of the Superintendent.  All online fundraising efforts will fulfill a public purpose, and will not benefit only one single individual or family except in unique circumstances preapproved by the school board.  If approved, the requestor shall be responsible for preparing all materials and information related to the online fundraising campaign and keeping district administration apprised of the status of the campaign.

All items and money generated from online fundraising are subject to the same controls and regulations as other district property and shall be deposited or inventoried accordingly.  No money raised or items purchased shall be distributed to individual employees.

Legal Reference:
Iowa Code §§ 279.8; 279.42; 565.6.

Cross Reference:
508.1 Class or Student Group Gifts
504.5 Student Fundraising
704.4 Gifts – Grants – Bequests
904.2 Advertising and Promotion
 
Approved:  4/15/24                    Reviewed:     4/15/24        Revised: 4/15/24 

All district affiliated fundraising will be approved by the school board.  Once approved, funds collected related to district affiliated fundraising will be placed in the appropriate fund in accordance with applicable laws and board policies.  Prior to approval of district affiliated fundraising efforts, the board will consider:

• 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;
• Equity in funding; and
• Other factors deemed relevant or appropriate by the district.

Student Fundraising

Student fundraising can enhance a student’s educational experience, but it must not be at the expense of the safety and education of the district’s students.  The following are additional regulations to assist the administration in developing procedures necessary for successful fundraising efforts:

• Students will not be asked to solicit door to door.
• Students who do not wish to engage in fundraising efforts will be provided an alternative community service option to apply toward credit of funds raised.  The alternative option will not be unduly burdensome or onerous when compared to the fundraising activity.
• All funds generated due to a student fundraising activity will be deposited into the district’s student activity funds, pursuant to applicable laws and board policies.
• Funds raised for a participatory student activity will be equally applied to all students regardless of their participation in the fundraising efforts.
• All funds generated from district sponsored student fundraising efforts will be deposited into a private purpose trust fund designated by the board for such purpose.
• No school district employee or other individual affiliated with the district may deposit student fundraising funds into any other account.
• All funds received from student fundraising are the property of the district.

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 $5000. 
• For goods and services costing at least $5001 and up to $40,000, 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, $40,000, 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 [Insert your district’s Emergency Repairs policy here] to IASB sample 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: 2/20/23            Reviewed: 2/20/23           Revised: 02/20/23

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.

Cross References

Approved: 2/20/23            Reviewed: 2/20/23           Revised: 02/20/23

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.
 

Cross References

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

The board authorizes the business manager, upon approval of the superintendent, to issue payment for verified bills, for reasonable and necessary expenses, when the board is not in session. The board secretary will examine the claims and verify bills. The board will approve the bills at its next regular meeting.

The secretary will determine to the secretary's satisfaction that the claims presented to the board are in order and are legitimate expenses of the school district. It is the responsibility of the secretary to bring claims to the board.
The board president and board secretary may sign warrants by use of a signature plate or rubber stamp If the board president is unavailable to personally sign warrants, the vice president may sign warrants on behalf of the president.

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

Love v. City of Des Moines, 210 Iowa 90, 230 N.W. 373 (1930).
Iowa Code §§ 279.8, .29, .30, .36; 291.12; 721.2(5) (2005).
281 I.A.C. 12.3(1).
1980 Op. Att'y Gen. 102, 160, 720. 1976 Op. Att'y Gen. 69.
1972 Op. Att'y Gen. 130, 180, 392, 456, 651.
1936 Op. Att'y Gen. 375.

Cross Reference:     705     Expenditures

Approved: 04/11/22        Reviewed: 03/21/22     Revised     2/23/2011

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.

Legal References:
Iowa Constitution Art. III, sec. 31;
Iowa Code §§ 68A.505; 279.8; 721.2.
281 I.A.C. 98.70

Cross References:
401.7 Employee Travel Compensation
704.1  Local-State-Federal-Miscellaneous Revenue
704.5 Student Activities Fund
705.1 Purchasing-Bidding
705.2 Purchasing on Behalf of Employees
705.3 Payment for Goods and Services
707.5  Internal Controls
905.1 Community Use of School District Facilities & Equipment

Approved: 04/11/22        Reviewed: 03/21/22            Revised:

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.

The requirements stated in the Master Contract between employees in a certified collective bargaining unit and the board regarding payroll periods of such employees will be followed.

Legal Reference:
Iowa Code §§ 91A.

Cross Reference:
706.2 Payroll Deductions

Approved: 04/11/22        Reviewed: 03/21/22        Revised: 07/21/14

Ease of administration is the primary consideration for payroll deductions, other than those required by law.  Payroll deductions are made for federal income tax withholdings, Iowa income tax withholdings, federal insurance contributions, and the Iowa Public Employees' Retirement System (IPERS). In addition, any employee may elect to have payments withheld for district related and mutually agreed upon group insurance coverage and/or tax-sheltered annuity program.

Written requests for the purchase of or a change in tax-sheltered annuities shall be on file in the payroll department thirty (30) days prior to the desired effective date. Requests for reductions in gross wages for contributions to tax-sheltered annuities shall conform to the standards of the Internal Revenue Service, and all other governing and regulatory agencies in effect at the time of the request.  Deductions for tax-sheltered annuities may be revoked thirty (30) days after receiving a written notice from the employee.

The district may deduct wages as required or allowed by state or federal law or by order of the court of competent jurisdiction.  

It is the responsibility of the superintendent or superintendent's designee to determine which additional payroll deductions will be allowed.

Payroll deduction requirements stated in the employee handbook, if any, will be followed.
 

Legal Reference:
Iowa Code §§ 91A.2(4), .3; 294.8-.9, .16.

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

Approved: 04/15/24        Reviewed: 04/15/24            Revised: 04/15/24

The district provides leaves of absences to allow employees to be absent from work to attend to important matters outside of the workplace. As public employers, school districts are expected to record and monitor the work that employees perform and to conform to principles of public accountability in their compensation practices.

Consistent with principles of public accountability, it is the policy of the district that, when an employee is absent from work for less than one work day and the employee does not use accrued leave for such absence, the employee’s pay will be reduced or the employee will be placed on leave without pay if:

• the employee has not sought permission to use paid leave for this partial-day absence,
• the employee has sought permission to use paid leave for this partial-day absence and permission has been denied,
• the employee’s accrued paid leave has been exhausted, or,
• the employee chooses to use leave without pay.

In each case in which an employee is absent from work for part of a work day, a deduction from compensation will be made or the employee will be placed on leave without pay for a period of time which is equal to the employee’s absence from the employee’s regularly scheduled hours of work on that day.

Legal Reference:
29 U.S.C. Sec. 213(a)
29 C.F.R. Part 541

Cross References:
409.2 – Employee Leaves of Absence

Approved: 04/15/24      Reviewed: 04/15/24            Revised: 04/15/24

The district recognizes the importance and value of fulfilling timely reporting requirements.  Regularly providing updated financial information assists the board in making informed decisions for the future financial health of the district.

At the annual meeting the treasurer will give the annual report stating the amount held over, received, paid out, and on hand in the general and all other funds.  This report is in written form and sent to the board with the agenda for the board meeting.  The treasurer will also furnish the board with a statement from each depository showing the balance then on deposit.  It is the responsibility of the treasurer to submit this report to the board annually.

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

Following board approval, each month the schedule of bills allowed by the board is published in a newspaper designated as a newspaper for official publication.  Annually, the total salaries paid to employees regularly employed by the school district will also be published in a newspaper designated as a newspaper for official publication.  It is the responsibility of the board secretary to publish these reports in a timely manner.

Legal Reference:
Iowa Code §§ 279.8; 291.7.

Cross Reference:
206.3 Secretary [or 206.3, Secretary-Treasurer]
210.1 Annual Meeting
707 Fiscal Reports

Approved: 04/15/24        Reviewed: 04/15/24             Revised: 04/15/24

In accordance with state law, to review the funds and accounts of the school district, the board will employ an independent auditor certified in the state of Iowa to perform an annual audit of the financial affairs of the school district. The superintendent or designee will use a request for proposal procedure in selecting an auditor. The administration, will cooperate with the auditors. Annual audit reports will be filed with the State Auditor and remain on file as permanent records of the school district.

Legal Reference:
Iowa Code § 11.6.

Cross Reference:
701 Financial Accounting System
707 Fiscal Reports

Approved: 04/15/24        Reviewed: 04/15/24            Revised: 04/15/24

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 and business manager shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the school district subject to review and approval by the board. Administrators shall be alert for any indication of fraud, financial impropriety, or irregularity within the administrator’s area of responsibility.

Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor. 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 s/he 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.

Legal References:
American Competitiveness and Corporate Accountability Act of 2002, Pub. L. No. 107-204.
Iowa Code §§ 11, 279.8.

Cross References:
401.12 Employee Use of Cell Phones
707.6 Audit Committee

Approved: 04/15/24        Reviewed: 04/15/24             Revised: 04/15/24

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: Board members, administrators and public members. The audit chair is selected by the 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.

Legal References:
American Competitiveness and Corporate Accountability Act of 2002, Pub. L. No. 107-204.
Iowa Code ch. 11, 279.8.

Cross References:
208 Ad Hoc Committees
707.5 Internal Controls
   
Approved: 4/11/22
Reviewed:3/21/22
Revised: _____

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 building principal for food service to employee groups, parent-teacher meetings, civic organizations meeting for the purpose of better understanding the schools, and senior citizens in accordance with board policy.

The school food program is operated on a nonprofit basis. The revenues of the school food program will be used only for paying the regular operating costs of the school food program. Supplies of the school food program will only be used for the school food program.

The board will set, and periodically review, the prices for school lunches, breakfast and special milk programs. It is the responsibility of the superintendent to make a recommendation regarding the prices of school lunch, breakfast and milk.

It is the responsibility of business manager to administer the program and to cooperate with the superintendent and head cook for the proper functioning of the school food program.

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

Cross Reference:
710.2 Free or Reduced Cost Meals Eligibility
710.3 Vending Machines
710.4 Meal Charge Policy
905 Use of School District Facilities and Equipment

Approved: 04/11/22        Reviewed: 03/21/22             Revised: 07/21/14

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 the school lunch, breakfast and supplemental foods, will be provided the school food program services at no cost or at a reduced cost.

It is the responsibility of the district meal application validator to determine if a student qualifies for free or reduced cost school food services. Students, whom the principal believes are improperly nourished, will not be denied the school food program services simply because the paperwork has not been completed.

Employees, students and others will be required to purchase tickets for meals consumed. It is the responsibility of the superintendent to develop administrative regulations for implementing this policy.

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

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

Approved: 04/11/22        Reviewed: 03/21/22        Revised: 07/21/14

Food served or purchased by students during the school day and food served or purchased for other than special circumstances is approved by the superintendent. Vending machines in the school building are the responsibility of the building principal. Purchases from the vending machines, other than juice machines, will not be made during the lunch periods.

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

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

Cross Reference:
504.5 Student Fund Raising
710 School Food Services

Approved: 04/11/22        Reviewed: 03/21/22            Revised: 07/21/14

The Colo-NESCO Community School District Food Service department is a self-operating and self-sustaining program.  In order to maintain financial stability and equality for all lunch paying students I the school district, this policy regarding lunch accounts will be followed.  The State of Iowa Nutrition Program recommends that negative balances are not acceptable; however, a general fund subsidy for negative balances could be appropriate.  The Board of Education desires the Colo-NESCO Community School District Food Service department to be self-supporting and therefore discourages general fun subsidies.

Breakfast and Lunch Policy – Staff & Grades Pre-K-Twelfth Grade
Adults will not be allowed to charge any meals or ala carte items.  Adults must have cash or money in their account to make a purchase.

Students will be reminded by the cashier when their account balance falls below $5.00.

Adults/Parents/Guardians are encouraged to maintain a positive account balance.  We encourage parents/guardians to use the online payment system.

Upon the first negative balance of any amount incurred, the building secretary/food service secretary will contact the parent/guardian by phone, email, or a written notice indicating to the parent/guardian the balance owed.  This will be done at a minimum of once weekly.

If a negative balance of $40.00 or greater is reached, a letter will be sent home from the building secretary/food service secretary to the parent/guardian stating that his/her child has a negative balance and that options are to make payment arrangements or have the child bring a sack lunch to school.  

If payment is still not made after reaching $80.00, the parent will be sent a certified letter from the business office stating that payment must be made immediately

A contact from the building secretary/food service secretary will continue to be made weekly for any negative balances.  

The Superintendent and/or building Principal may call any families with negative balances totaling $100.00 or more. Families that reach a negative balance of $200.00 or more may be turned over to collections.

Please note that money needs to be available in a child’s lunch account in order for extra meals, extra/snack milks, or ala carte items to be purchased. This applies to all students, including students from families participating in the free and reduced program.

Negative balances will be carried over to the following school year.  These negative balances must be paid in full prior to school starting as part of the school registration process. The school district and the Food Service department reserve the right to take any other reasonable action, including legal action, to collect the balance due in any student’s account.

Legal Reference:
42 U.S.C. §§ 1751 et seq.
7 C.F.R. §§ 210 et seq.
U.S. Dep’t of Agric., Sp 46-2016, Unpaid Meal Charges: Local Meal Charge Policies (2016).
U.S. Dep’t of Agric., Sp 47-2016, Unpaid Meal Charges: Clarification on Collection of Delinquent Meal Payments (2016).
U.S. Dep’t of Agric., Sp 57-2016, Unpaid Meal Charges: Guidance and Q&A (2016).
Iowa Code 283A.
281 I.A.C. 58.

Cross Reference:
710.1 School Food Program
710.2 Free or Reduced Cost Meals Eligibility
710.3 Vending Machine

Approved: 02/20/23        Reviewed: 02/20/23          Revised 02/20/23     

The Colo-NESCO School District accepts donations for negative student meal accounts.  If an individual or organization wishes to make payment for negative lunch accounts, the check should be made out to Colo-NESCO School District with negative lunch balances cited in the memo area of the check.  If the District receives a check with the instructions to apply payment to a specific student(s) account, the District will follow the guidance in the instructions.

All other donations will be equally pro-rated across all student accounts exceeding the negative -$20.00 policy in the following order:  accounts of students who qualify for free lunches, accounts of students who qualify for reduced lunches, all remaining funds will be prorated across all remaining meal accounts with a balance over -$20.00.

If donations are received and there is not a negative balance in food service lunches, the funds will be held and applied monthly per policy guidelines.

Approved: 03/18/23        Reviewed:       Revised    

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

Transportation of students who require special education services will generally be provided as for other students, when appropriate. Specialized transportation of a student to and from a special education instructional service is a function of that service and, therefore, an appropriate expenditure of special education instructional funds generated through the weighting plan.

Transportation of a student to and from a special education support service is a function of that service, and is specified in the individualized education program (IEP) or the individualized family service plan (IFSP). When the IEP or IFSP team determines that unique transportation arrangements are required and the arrangements are specified in the IEP or IFSP, the school district will provide one or more of the following transportation arrangements for instructional services and the AEA for support services:

• Transportation from the student's residence to the location of the special education and back to the student's residence, or child care placement for students below the age of six.
• Special assistance or adaptations in getting the student to and from and on and off the vehicle, en route to and from the special education.
• Reimbursement of the actual costs of transportation when by mutual agreement the parents provide transportation for the student to and from the special education.

The school district is not required to provide reimbursement to parents who elect to provide transportation in lieu of agency-provided transportation.

A student may be required, at the board's discretion, to meet a school vehicle without reimbursement up to three-fourths of a mile. The board may require the parent to transport their children up to two miles to connect with school bus vehicles at the expense of the school district when conditions deem it advisable. It is within the discretion of the board to determine such conditions. Parents of students who live where transportation by bus is impracticable or unavailable may be required to furnish transportation to and from the designated attendance center at the expense of the school district. Parents, who transport their children at the expense of the school district, are reimbursed at the rate per mile set by the state.

Transportation arrangements made by agreement with a neighboring school district will follow the terms of the agreement. Students, who choose to attend a school in a school district other than their resident school district, will provide transportation to and from the school at their own expense.

Legal Reference:
20 U.S.C. §§ 1401, -1701 et seq.
34 C.F.R. Pt. 300 et seq.
Iowa Code §§ 256B.4; 285; 321.
281 I.A.C 41.412

Cross Reference:
501.16 Homeless Children and Youth
507.8 Student Special Health Services
603.3 Special Education
711 Transportation

Approved: 04/11/22        Reviewed: 03/21/22             Revised: 07/21/14

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 video cameras on school buses used for transportation to and from school as well as for field trips, curricular or extracurricular events. The video cameras will be used to monitor student behavior and may be used as evidence in a student disciplinary proceeding. The videotapes are student records subject to school district confidentiality, board policy and administrative regulations.

It is the responsibility of the superintendent, in conjunction with the building principal, to develop administrative regulations regarding student conduct and discipline when utilizing school district transportation.

Legal Reference:
Iowa Code §§ 279.8; 285; 321.

Cross Reference:
503 Student Discipline
506 Student Records
804.6 Use of Recording Devices on School Property

Approved: 04/11/22        Reviewed: 03/21/22            Revised: 07/21/14

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, will ride both to and from the event in the school vehicle unless arrangements have been made with the building principal prior to the event. A student's parent may personally appear and request to transport the student home from a school-sponsored event in which the student traveled to the event on a school district transportation vehicle.

It is the responsibility of the superintendent to make a recommendation to the board annually as to whether the school district will provide the transportation authorized in this policy. In making the recommendation to the board, the superintendent will consider the financial condition of the school district, the number of students who would qualify for such transportation, and other factors the board or superintendent deem relevant.

Legal Reference:
Iowa Code §§ 256B.4; 285.1-.4; 321.
281 I.A.C 41.412

Cross Reference:
504 Student Activities
711 Transportation

Approved: 04/11/22            Reviewed: 03/21/22        Revised: 07/21/14

The school district may use school vehicles for transportation to and from summer extracurricular activities. The superintendent will make a recommendation to the board annually regarding their use.

Transportation to and from the student's attendance center for summer school instructional programs is within the discretion of the board. It is the responsibility of the superintendent to make a recommendation regarding transportation of students in summer school instructional programs at the expense of the school district. In making the recommendation to the board, the superintendent will consider the financial condition of the school district, the number of students involved in summer school programs, and other factors deemed relevant by the board or the superintendent.

Legal Reference:
Iowa Code § 285.10.
281 I.A.C. 43.10.
281 I.A.C 41.412

Cross Reference:
603.2 Summer School Instruction
711 Transportation
   
Approved: 4/11/22
Reviewed: 3/21/22
Revised: ___