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

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

Legal Reference: Iowa Code §§ 279.33.

Cross Reference: 210.1   Annual Meeting
                                      206.4   Secretary-Treasurer
                                      704.1   Local - State - Federal - Miscellaneous Revenue

Initially Approved 03-08-1999                              
Last Reviewed 02-14-2024                                   
Last Revision  02-14-2024

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

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

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

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

Beginning in FY2024, unexpended and unobligated dollars that remain at the end of a fiscal year in addition to ongoing revenues may be transferred to the Teacher Salary Supplement (TSS) program from Professional Development Supplement (PDS), Talented and Gifted (TAG), and Teacher Leadership Supplement (TLS) without board action.

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

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

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

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

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

Initially Approved 03-08-1999                              
Last Reviewed 02-14-2024                                    
Last Revision  02-14-2024 

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

Governmental Fund Type

• General Fund – This fund is the chief operating fund of the district. It is used to account for all financial resources except those accounted for and reported in another fund.
• Special Revenue – These funds account for the proceeds of specific revenue sources other than trusts or major capital projects, that are legally restricted or committed to expenditure for specified purposes other than debt service or capital projects.
  • Management Levy Fund
  • Public Education and Recreation Levy Fund (PERL)
  • Student Activity Fund
• Capital Projects Fund – These funds are used to account for financial resources to acquire or construct major capital facilities or other capital assets (other than those of proprietary funds and trust funds) and to account for revenues from SAVE.
  • Physical Plant and Equipment Levy Fund (PPEL)
  • Secure and Advanced Vision for Education (SAVE)
• Debit Service Fund – This fund is used to account for the accumulation of resources for, and the payment of, general long-term debt principal and interest.

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

• Enterprise Fund
  • School Nutrition Fund
  • Child Care Fund
  • Internal Service Fund
  • Community Education
  • Preschool (nonvoluntary, state)

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

• Trust
  • Expendable Trust Funds
  • Nonexpendable Trust Funds
  • Pension Trust Funds
• Custodial Funds

Non-Fiduciary Scholarship Fund

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

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

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

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

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

Cross Reference: 704      Revenue
                                      705      Expenditures

Initially Approved 03-08-1999                              
Last Reviewed 02-14-2024                                   
Last Revision  02-14-2024

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

Fund Balance Reporting

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

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

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

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

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

Assigned Fund Balance reflects amounts that are constrained by the government’s intent to be used for specific purposes but meet neither the restricted or committed forms of constraint. Unless the amount is negative, the assigned fund balance is the residual classification for the governmental funds other than the general fund. If the amount is negative, then the residual amount is shown as unassigned.

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

It is the responsibility of the superintendent and/or treasurer 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

Initially Approved   08-08-2011                     
Last Reviewed  02-14-2024                               
Last Revision 02-14-2024

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

Initially Approved   03-08-2023                     
Last Reviewed  10-25-2023                                
Last Revision 

Prior to certification of the budget, the board will review the projected revenues and expenditures for the school district and make adjustments where necessary to carry out the education program within the revenues projected. The budget of the school district is the authority for the expenditures of the school district for the fiscal year for which the budget was adopted and certified. It is the responsibility of the superintendent to operate the school district within the budget.

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

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

It is the responsibility of the board treasurer, in conjunction with the superintendent, to prepare the budget for review by the board prior to the April 30 deadline each year. 

The District will provide all of the information necessary for the Proposed Property Tax Statement to the Department of Management by March 15.

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

Prior to the adoption of the proposed budget by the board, the public is apprised of the proposed budget for the school district.  Prior to the adoption of the proposed budget by the board, members of the school district community will have an opportunity to review and comment on the proposed budget.  A public hearing for the proposed budget of the board is held each year in sufficient time to file the adopted budget no later than April 30.

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

The board will adopt and certify a budget for the operation of the school district to the county auditor by April 30.  It is the responsibility of the board secretary to file the adopted and certified budget with the county auditor and the Iowa Department of Management.

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

It is the responsibility of the superintendent and the board treasurer 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
                                      

Initially Approved 03-08-1999                              
Last Reviewed 02-14-2024                                   
Last Revision   02-14-2024

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 educational materials fees will be charged and the amount of the materials fees.

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

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

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

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

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

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

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

Initially Approved 03-08-1999                              
Last Reviewed 05-22-2024                                   
Last Revision  05-22-2024

DEBT LIMITS

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

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

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

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

PURPOSES AND USES OF DEBT

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

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

• General Obligation Bonds
• General Obligation Capital Loan Notes
• Bond Anticipation Notes
• Revenue Anticipation Notes
• School Infrastructure Sales, Services and Use Tax Revenue Bonds
• Lease Purchase Agreements, including Certificates of Participation

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

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

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

DEBT STANDARDS AND STRUCTURE

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

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

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

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

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

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

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

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

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

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

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

DEBT ISSUANCE

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

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

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

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

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

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

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: 701.2      Transfer of Funds
                                     

Initially Approved 03-10-2014                              
Last Reviewed 10-25-2023                                   
Last Revision                   

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

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

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 the school district audit.  The compensation of the 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; 12C; 22.1, .14; 28E.2; 257; 279.29; 283A; 285; 502.701; 633.123 .

Cross Reference: 206.4   Treasurer
                                       704      Revenue

Initially Approved 03-08-1999                              
Last Reviewed 10-25-2023                                   
Last Revision   10-25-2023

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

Initially Approved 03-08-1999                              
Last Reviewed 10-25-2023                                   
Last Revision                   

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

Initially Approved 03-08-1999                              
Last Reviewed 10-25-2023                                   
Last Revision   05-12-2021

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 the 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 single 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 must have prior approval from the school board or its designee before 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 expect in unique circumstances pre-approved by the school board. If approved, the requestor shall be responsible for preparing all materials and information related to the online fundraising campaign and keep 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

Initially Approved 05-12-2021                              
Last Reviewed 05-22-2024                                   
Last Revision 05-22-2024

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 $5,000.
• For goods and services costing at least $5,001 and up to $60,000, 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, $60,000, 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 shall be based on the total 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 CCSD’s policy 802.3 – Emergency Repairs to IASB sample policy 802.3 – Emergency Repairs.

The district shall comply with all federal and state laws and regulations required for procurement, including the selection and evaluation of contractors.  The superintendent or designee is responsible for developing an administrative process to implement this policy, including, but not limited to, procedures related to suspension and debarment for transactions subject to those requirements.

Legal Reference: Iowa Code §§ 26; 28E; 72.3; 73; 73A; 285; 297; 301.
                                      261 I.A.C. 54.
                                      281 I.A.C. 43.25.

Cross Reference: 801.4   Site Acquisition
                                      802      Maintenance, Operation and Management
                                      802.3   Emergency Repairs
                                      803      Selling and Leasing

Initially Approved 03-08-1999                              
Last Reviewed 10-25-2023                                   
Last Revision 10-25-2023

Board members and employees of the school district are expected to use school district credit/procurement cards for the actual and necessary expenses incurred in the performance of board or work related duties.  Actual and necessary expenses incurred in the performance of such duties may include, but are not limited to, materials and supplies, fuel for school district transportation vehicles, payment of fees or other costs related to professional development, lodging and meals while in travel status, and other expenses required in the performance of duties.  School district credit/procurement cards may not be used for personal expenses or in conjunction with personal rebate cards.  See Procurement Card Rules for additional guidance 401.10E1.

Board members and employees using a school district credit/procurement card must submit a detailed itemized receipt and account code in addition to the credit/procurement card receipt indicating the date, purpose, and nature of the expense for each claim item.  Failure to provide a proper receipt will make the board member or employee responsible for expenses incurred.  In exceptional circumstances, the Board may allow a claim without proper receipt.  Written documentation explaining the exceptional circumstances such as district procurement card denial is maintained as part of the school district’s record of the claim.

The Board, through its routine audit and approval process, will assess and determine whether the school district credit/procurement cards are being used in accordance with the terms of this policy and its corresponding procedures (401.10E1, 401.10E2).

Board members and employees of the school district who use personal credit cards for actual and necessary expenses incurred in the performance of board or work related duties will be reimbursed in accordance with Board policies regarding board member and employee compensation.  Board members and employees may not use personal credit cards for such expenses to gain credit card points/rewards for the personal benefit of the Board member or employee.  When a personal credit card is used, the employee must reimburse the school district an amount equal to the reward percentage that the school district would have earned if the school districts credit/procurement card had been used.  See Reimbursement Schedule for additional guidance 401.10E2.

Legal Reference: Iowa Constitution, Art. III, § 31.
                                      Iowa Code §§ 279.8, .29, .30.
                                       281 I.A.C. 12.3(1).

Cross Reference: 216.3  Board of Directors’ Member Compensation and Expenses
                                       401.7  Employees Travel Compensation       

Initially Approved:  03-12-2001                    
Last Reviewed:  10-25-2023                         
Last Revision:  04-10-2019                  

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

Claims for payment of freight, postage, printing, water, lights, telephone, rents, registration/fees, payment of salaries, and non-employee referees employed pursuant to the terms of a written contract may be paid by the board secretary prior to formal audit and approval by the board.  In addition, the board secretary, upon approval of the board president, may issue warrants for approved travel expenses and other verified bills filed with the board secretary when the board is not in session prior to payment of these claims and prior to audit and approval by the board.  The board secretary will examine the claims and verify the bills.

The board secretary will determine to the board 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 board secretary to bring claims to the board.

The board president and board secretary may sign warrants by use of a signature plate, rubber stamp, or electronic signature.  If the board president is unavailable to personally sign warrants, the vice president may sign warrants on behalf of the president.

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

Legal Reference: Love v. City of Des Moines, 210 Iowa 90, 230 N.W. 373 (1930).
                                      Iowa Code §§ 279.8, .29, .30, .36; 291.12; 721.2(5).
                                      281 I.A.C. 12.3(1).
                                      

Cross Reference: 705.4      Expenditures for a Public Purpose

Initially Approved 03-08-1999                              
Last Reviewed 10-25-2023                                   
Last Revision 10-25-2023

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 through the use of the district requisition process.  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

Initially Approved   10-9-2019                                  
Last Reviewed      10-25-2023                                    
Last Revision

The payroll period for the school district is monthly.  All contracted and non-contracted (substitutes) personnel are paid on the 19th 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 payroll clerk to issue payroll to employees in compliance with this policy.

Legal Reference: Iowa Code §§ 20; 91A.

Cross Reference: 706.2   Payroll Deductions

Initially Approved 03-08-1999                              
Last Reviewed 05-22-2024                                   
Last Revision   11-13-2019

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

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

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

It is the responsibility of the superintendent and/or treasurer 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: 406.5   Licensed Employee Group Insurance Benefits
                                      406.6   Licensed Employee Tax Shelter Programs
                                      412.4   Classified Employee Tax Shelter Programs
                                      706.1   Payroll Periods

Initially Approved 03-08-1999                              
Last Reviewed 05-22-2024                                   
Last Revision   05-22-2024

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

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

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

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

Legal Reference: 29 U.S.C. Sec. 2 13(a)
                                      29 C.F.R. Part 541

Cross References: 409.8   Licensed Employee Unpaid Leave
                                       

Initially Approved 03-08-1999                            
Last Reviewed 05-22-2024                                      
Last Revision    05-22-2024  

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

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

The board treasurer 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 treasurer to publish these reports in a timely manner.

Legal Reference: Iowa Code §§ 279.8; 291.7.

Cross Reference: 206.4   Treasurer
                                      210.1   Annual Meeting
                                      

Initially Approved 03-08-1999                              
Last Reviewed 05-22-2024                                   
Last Revision   05-22-2024

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.

Initially Approved 03-08-1999                              
Last Reviewed 05-22-2024                                   
Last Revision  05-22-2024

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

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

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

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

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

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

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

Cross References: 401.12 Employee Use of Cell Phones
                                          705.4   Expenditures for a Public Purpose
                                         707.6   Audit Committee

Initially Approved 02-26-2007                            
Last Reviewed 10-25-2023                                             
Last Revision   05-12-2021

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

School nutrition program facilities are provided to serve students and employees when school is in session and during school-related activities. They may also be used under the supervision of the food service director 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 law and board policy.

The school nutrition program is operated on a nonprofit basis. The revenues of the school nutrition program will be used only for the operation or improvement of such programs. Supplies of the school nutrition program will only be used for the school nutrition program.

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

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

The district shall comply with all federal and state laws and regulations required for procurement, including the selection and evaluation of contractors. The superintendent or designee is responsible for developing an administrative process to implement this policy, including, but not limited to, procedures related to suspension and debarment for transactions subject to those requirements and prohibitions on purchasing food products misbranded as meat or egg products, or cultivated-protein food products in accordance with applicable laws.

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

Cross Reference: 710.2 Free or Reduced Cost Meals Eligibility
                                         710.3 Vending Machines
                                         710.4 Meal Charge Policy
                                         

Initially Approved 03-08-1999                              
Last Reviewed 08-14-2024                                   
Last Revision   08-14-2024

SCHOOL FOOD PROGRAM – SCHOOL NUTRITION PROGRAM CIVIL RIGHTS COMPLAINTS PROCEDURE

USDA Child Nutrition Programs in Iowa

Procedures for Handling a Civil Rights Complaint

1. Civil rights complaints related to the National School Lunch Program, School Breakfast Program, Afterschool Care Snack Program, Summer Food Service Program, Seamless Summer Option, or Child and Adult Care Food Program are written or verbal allegations of discrimination based on USDA protected classes of race, color, national origin, sex, age, and disability. 
2. Any person claiming discrimination has a right to file a complaint within 180 days of the alleged discrimination. See below for additional Iowa Civil Rights information. A civil rights complaint based on the protected classes listed in #1 above must be forwarded to the address on the nondiscrimination statement. 
3. All complaints, whether written or verbal, must be accepted by the School Food Authority (SFA)/Sponsor/Organization and forwarded to USDA at the address or link on the nondiscrimination statement within 5 calendar days of receipt. An anonymous complaint should be handled the same way as any other. Complaint forms may be developed, but their use cannot be required. If the complainant makes the allegations verbally or in a telephone conversation and is reluctant or refuses to put them in writing, the person who handles the complaint must document the description of the complaint. 
4. There must be enough information to identify the agency or individual toward which the complaint is directed and indicate the possibility of a violation. Every effort should be made to obtain at least the following information: 
   
   • Name, address and telephone number or other means of contacting the complainant;
   • The specific location and name of the organization delivering the program service or benefit;
   • The nature of the incident(s) or action(s) that led the complainant to feel there was discrimination;
   • The basis on which the complainant feels discrimination occurred (race, color, national origin, sex, age, or disability);
   • The names, titles, and addresses of people who may have knowledge of the discriminatory action(s); and
   • The date(s) when the alleged discriminatory action(s) occurred or, if continuing, the duration of such action(s).
5. USDA is the cognizant agency for the Child Nutrition Programs listed and therefore is the first contact for the six protected classes listed in #1 above, for complaints received within 180 days. Civil rights complaints must be submitted to the USDA Office of Civil Rights within five calendar days of receipt and no later than 180 days of the discriminatory act. The link for submission of a complaint is: program.intake@usda.gov 
6. In Iowa, protected classes also include sexual orientation, gender identity, religion or creed and complaints can be filed up to 300 days of occurrence. The address for Iowa complaints is: Iowa Civil Rights Commission, Grimes State Office building, 400 E. 14th St. Des Moines, IA 50319- 1004; phone number 515-281-4121, 800-457-4416; website: https://icrc.iowa.gov/.

Bureau of Nutrition and Health, IDOE, 12/2021

Legal Reference:            42 U.S.C. §§ 1751 et seq.
                                       Iowa Code . 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

Initially Approved 10-26-2022                              
Last Reviewed 10-25-2023                               
Last Revision                   

Students enrolled and attending school in the school district who meet the United States Department of Agriculture (USDA) eligibility guidelines will be provided the school nutrition program services at no cost or at a reduced price. The school district shall make reasonable efforts to prevent the overt identification of, students who are eligible for free and reduced price meals.

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

It is the responsibility of the food service director to determine the eligibility of students for free or reduced price school nutrition programs, in accordance with criteria established by state and federal law. If school personnel have knowledge of a student who is in need of free or reduced-price meals, school personnel shall contact the food service director.

If a student owes money for five or more meals, the food service director may contact the student’s parent or guardian to provide information regarding the application for free or reduced price meals.  The school is encouraged to provide reimbursable meals to students who request reimbursable meals unless the students’ parent or guardian has specifically provided written direction to the school to withhold a meal from the student. 

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

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