I. Introduction
During the 2001-02 school year, the district served approximately 997 students in its three schools consisting of one elementary, one middle, and one high school. Twelve percent of its students were classified as English learners and sixty-one percent qualified for free and reduced price meals. Based on these student demographics, the district educates a significant number of students who need supplemental support and excellent instructional programs to compete successfully with students who have no such barriers to learning.
Currently, Emery Unified School District is under state receivership to rectify a downward financial spiral that began in 1999-00 and culminated in 2001-02 with special legislation that provided the district with a state emergency loan. Specifically, Assembly Bill 96, authored by Assemblywoman Aroner, signed by the Governor, and chaptered (Chapter 135) in July 2001, provided Emery with an immediate loan of $1.3 million and an additional line of credit of $1 million.
On August 6, 2001, the Emery governing board voted to accept the state emergency loan, prompting the immediate appointment of a State Administrator. The next day, on August 7, the Superintendent appointed Mr. Henry Der to the position of State Administrator to act on the Superintendent’s behalf in assuming the powers of the governing board and the day-to-day operations of the district. The governing board’s authority, then, became advisory in nature.
Shortly, thereafter, the Superintendent formally appointed the Fiscal Crisis and Management Assistance Team (FCMAT) as fiscal advisor to the district, as required by the provisions of AB 96. The 2001-02 budget act appropriated $1 million to FCMAT to assist the district with recovery efforts. In September 2001, loan funds totaling $1.3 million were disbursed to the district. To date, the district has not drawn down any of the line of credit.
As a condition of receiving a state emergency loan of the magnitude received by Emery, the State Administrator is required, pursuant to current law, to prepare and submit for the Superintendent’s approval the following reports and plans: (1) a one-time Management Review and Recovery Plan, (2) an annual Multi-Year Financial Recovery Plan, and (3) an annual report on the financial condition of the district.
The first Multi-Year Financial Recovery Plan was submitted and approved by the Superintendent in April 2002. It is scheduled for revision each September with the submission of the annual report on the financial condition of the district, which includes the final budget for that fiscal year.
This document contains the district’s Management Review and Recovery Plan. The plan is a compilation of the work performed by FCMAT and presented in a July 6, 2001 report entitled Emery Unified School District: Comprehensive Fiscal Assessment and additional work performed by the management review team, consisting of FCMAT consultants and the State Administrator, during the fall of 2001 through the summer of 2002.
Scope of Management Review and Recovery Plan
The Management Review and Recovery Plan covers the functional areas that are key to successful district management, including financial management, personnel management, facilities management, community relations, and technology. The district does not operate a transportation program, therefore, this functional area was excluded from the management review. The Management Review and Recovery Plan also addresses key audit findings from the district’s most recent audit, year-end 2000-01, and the previous audit.
The purpose of the Management Review and Recovery Plan is to (1) identify areas needing improvement in district management and operations and (2) commit the district to specific strategies and actions that will result in improvements within specified timelines. The Management Review and Recovery Plan, therefore, complements the Multi-Year Financial Recovery Plan by ensuring the implementation of sound administrative practices and policies that will prevent the recurrence of conditions that led to fiscal crisis, and enable the district to return to solvency as planned in the Multi-Year Financial Recovery Plan.
The management review team conducted interviews with district personnel and community members, visited school facilities, observed district operations, and reviewed policies, procedures, manuals, regulations, various records and reports, and administered questionnaires to district staff to ascertain their understanding of various internal control and compliance procedures.
For a detailed fiscal chronology, please refer to Appendix A of this report.
II. Community
Involvement and Relations
Emery Unified School District has a history of support from and collaboration with the city of Emeryville, members of the business community, and community-based organizations. Many Emery High School graduates return to Emeryville as adults and enroll their children in district schools. Families who live outside of Emeryville seek to enroll their children in district schools because they feel district schools provide a safe learning environment. In the 1999-2000 and 2000-2001 school years, the fiscal crisis compromised and undermined the longstanding working relationship the district had with the city and with major stakeholder groups. In short, the city and key community members lost confidence in district administration and the Board of Education. Many community members supported both state intervention and the recall of a majority of school board members.
Because resources will be extremely limited during the initial years of financial recovery, community involvement and positive relations between the district and key stakeholder groups are critical to rebuild public confidence in the district and to foster support for district programs serving at-risk students.
Training of Advisory Board Members
City of Emeryville officials and leading community members have stated that they seek the re-establishment of a viable, independent school district. Elected by the voters of Emeryville, the Advisory Board of Education shares the community’s stated goals, which are leadership and oversight of the school district.
All of the district’s Advisory Board members have had relatively short tenures. Only one current board member has more than one year of experience. Three members were elected in the August 2001 recall election, and the fifth was elected in the November 2001 election. As a whole, the Advisory Board believes it has the mandate of the Emeryville voters to undertake the normal responsibilities of an elected school board and is anxious to assume authority of the district as early as possible. However, because of their relatively short tenure, current Advisory Board members are responsible for learning and practicing systematically the appropriate roles and responsibilities of board members in order to ensure that a fiscal or organizational crisis does not recur when local control is restored. The Advisory Board needs to exercise care and patience in learning its responsibilities and not allow its desire to assume local control as early as possible to interfere with or compromise this learning process.
Action # 1
The State
Administrator shall:
a. Ensure the Advisory Board of Education completes the 10-part California School Boards Association (CSBA)-led Masters of Governance.
Time line: Started in 2001-2002 with completion in 2002-2003. Cost paid by FCMAT.
b. Guide Advisory Board members through the development and implementation of the budget calendar in 2002-2003 for the 2003-2004 annual budget.
c. Assess Advisory Board member participation in budget development during 2002-2003 and, as appropriate, provide assistance for improvements in participation during 2003-2004 and future years.
Time line: Starting in 2002-2003 and continue until Advisory Board resumes full authority and responsibility for the district
d. Conduct study sessions for the Advisory Board on key programs and policy issues to ensure thorough understanding by Advisory Board members.
Time line: Started in 2001-2002 and continue until Advisory Board resumes full authority and responsibility for the district
e. Provide additional training sessions, as appropriate, to enhance Advisory Board understanding of financial recovery.
f. As the process of updating board policies and procedures begins in 2002-2003, provide Advisory Board members with opportunities to emulate best practices by exemplary boards of education.
Time line: Starting in 2002-2003 and continuing until the Advisory Board resumes full authority and responsibility for the district
Parent/Guardian Involvement
Emery Unified is a typical urban school district with a high number of racial and ethnic minority students and of students who participate in the free and reduced lunch program. To the extent that at-risk conditions in student homes and neighborhoods influence academic outcomes, student behavior and participation in the classroom and parent/guardian involvement in a student’s education are critical to counterbalance these conditions and to ensure consistent student attendance. Active parent involvement can include taking students to school on time, assisting or monitoring student homework assignments, participating in parent clubs and school site councils, permitting and monitoring student participation in after-school activities and tutoring programs, and maintaining communication with a student’s teacher to monitor student progress. Home and/or workplace pressures and stresses have prevented many parents from becoming fully involved in their students’ education. Parents have indicated that before and during the fiscal crisis, district and site administration was inaccessible and sometimes unfriendly to parents. Further, because of the English-language barrier, many parents of English-language learner students were uncomfortable accessing, participating, or being fully involved in the school site and in other activities benefiting their children and their children’s academic performance.
Action #2
The State
Administrator and the Principals shall:
a. Clearly articulate standards of student behavior and attendance to parents at the beginning of and throughout the school year so parents will support their children in school attendance, appropriate classroom participation and learning support activities.
b. Institute and enforce contracts with parents of out-of-district students so that student behavior and attendance rules are adhered to and fulfilled.
c. Ensure full parent participation in school site councils and regularly convene school site council meetings so that parent concerns are fully considered and reflected in key decisions, as specified in state law.
d. Support each school site’s parent club so that parents feel empowered and are successful in their school volunteering and fundraising activities.
e. Develop a plan in 2002-2003 to inform and fully engage parents of English-language learners in the different aspects of parent involvement and participation.
f. Conduct outreach activities to community-based and other groups that serve or have membership comprised of parents of English-language learners.
g. Maintain and expand homework assignments and other student activities on the Web so that parents are fully informed about activities in which they can support their children.
h. To the extent funds are available, maintain and expand teacher visits to homes.
Time line: Begin in 2002-2003 and ongoing thereafter
Partnership with City of Emeryville
AB 96 authorizes the State Administrator to enter into a lease agreement with the city of Emeryville for use of school facilities during nonschool hours. The State Administrator, FCMAT and the City Manager have held a series of meetings to identify the major issues to be included in a /long-term lease agreement. To complement the relationship that will evolve from the long-term lease agreement, the State Administrator and City Manager convened the Education and Youth Services Task Force. This task force was formed to identify long-term collaborative activities between the district and city and to develop a master plan for youth to enhance programs and development of facilities that will benefit student learning and civic involvement. In order for the partnership with the city to succeed and flourish, the district should lay the foundation for and commit itself to sustain such a partnership over many years. City officials have expressed frustration that in the past, the district has not always adhered to agreements consistently or effectively. The district faces the challenge of regaining the city’s confidence and demonstrating that it has the will and capacity to behave in a fiscally and administratively responsible manner.
Action #3
The State
Administrator shall:
a. Draft a long-term lease agreement consistent with major issues identified to date, submit this document to the City Council, Advisory Board of Education, stakeholder groups and citizens for review and comment, and prepare the final draft for final approval by the State Superintendent of Public Instruction, and City Council by the beginning of 2002-2003 school year.
Time line: Complete in 2002-2003
b. Participate fully with the city and representatives of stakeholder groups in the development of a master plan for youth to identify and enhance academic and nonacademic opportunities for district students and to explore additional development of joint use facilities.
Time line: Started in 2001-2002 and continue until 2003-2004
c. Continue monthly meetings of the City School Committee to review and monitor closely implementation of the anticipated long-term lease agreement and master plan for youth. As appropriate and necessary, utilize City School Committee meetings to discuss and resolve any issue or misunderstanding related to the implementation of the lease agreement and master plan.
Time line: Started in 2001-2002 and continue thereafter
d. Systematically solicit comment from city officials on all required reports and documents related to state administration and submitted to the State Superintendent of Public Instruction, such as the Multi-Year Financial Recovery Plan and the Annual Report of the Financial Condition of the District, to strengthen the city’s confidence in the district.
Time line: Started in 2001-2002 and continue until the Advisory Board resumes full authority and responsibilities for the district
e. Work closely with the city to identify and implement other funding strategies to support district programs and students.
Time line: Start in 2002-2003 and continue until 2004-2005
Community Support for Teaching and Learning
Business, arts and other community members have long maintained a strong interest in the success of the district and students. The Emery Education Foundation has raised funds to support mini-grants to teachers for enrichment activities and scholarships for high school graduates. Most recently, Emery Education Foundation consented to be the fiscal agent for the Bill & Melinda Gates Foundation grant funds to support the Math, Science, and Technology Initiative, benefiting all district schools. The 45th Street Artist Collective has sponsored arts programs at district schools and supported Arts is Education exhibits. Since state administration began, the Emeryville Chamber of Commerce has created the Business Education Committee to support district schools and students. The Business Education Committee has undertaken the major task of cosponsoring the Volunteer Academic Mentor Program, including actively recruiting community members as mentors. Leading members of these and other community groups understand the challenging budgetary decisions the district must make in order to fulfill the goals and objectives of the Multi-Year Financial Recovery Plan. These leading community members and groups will gain more confidence in the district if the district complies fully with the Multi-Year Financial Recovery Plan. These community members and groups know that additional funding sources and programs to support teaching and learning in the district will be needed to meet the education needs of at-risk students.
Action #4
The State
Administrator shall:
a. Continue to maintain and nurture its collaborative, working relationship with leading community members and groups.
b. With cooperation of the Advisory Board of Education and City of Emeryville, convene a community wide funding committee to explore, identify and implement strategies that will produce new funding sources to support teaching and student support services.
c. Regularly inform leading community members and groups about district efforts and progress to achieve fiscal solvency through presentations and discussions at board and/or monthly meetings of these respective groups.
Time line: Start in 2002-2003 and continue until Advisory Board resumes full authority and responsibilities for the district
Community and Other Partnerships to Improve Student Outcomes and Opportunities
In January 2002, the district, City of Emeryville and Bay Area Coalition for Equitable Schools entered into a Partnership Agreement to establish the Math, Science and Technology Initiative to improve the quality of teaching and student learning at all three schools so that district graduates will be well-prepared academically to have numerous postsecondary education options. Additionally, the county office has provided assistance and support to the initiative. At present, a significant number of Anna Yates Elementary School students choose not to attend Emery Middle School Academy because of negative perceptions about the quality of academic programs. For similar reasons, a significant number of Emery Middle School Academy students elect not to attend Emery High School. This unsatisfactory student matriculation through district schools creates fiscal and educational instability and leaves district schools vulnerable to students who are not well rounded in district expectations and standards for academic and personal behavior. Certain out-of-district high school students choose to attend Emery High School because they have easy access to participation in sports teams, but they do not maintain or achieve an adequate focus on their academic studies. The Math, Science and Technology Initiative will require greater performance by both teachers and students and will fundamentally change the type of out-of-district students who seek to attend district schools. Further, the Initiative will require the assistance of university and college partners to help better prepare district students for postsecondary education opportunities.
Action #5
The State
Administrator and principals shall:
a. Maintain their commitment to fulfill the goals and objectives of the Math, Science and Technology Initiative.
b. Beginning in 2002-03, and continuing in succeeding years, make clear to all out-of-district student applicants the academic and student behavior expectations of the Math, Science and Technology Initiative.
c. Require out-of-district students and their parents to enter into a contract to abide by initiative expectations and standards; cease contractual relationship with out-of-district students and parents if expectations and standards are violated or are not fulfilled by the student.
d. Maintain and expand working relationship with UC Berkeley and other local colleges and universities to grow academic outreach programs to benefit district students.
Time line: Begin in 2002-2003 and complete in 2004-2005
III. Financial
Management & Operations
Good financial management involves a sound
system of budget development, monitoring and reporting, and comprehensive
internal controls that include proper segregation of duties and expenditure
controls.
The annual school district budget plan is a
management tool for managing finances and allocating resources to support the
district’s educational goals, programs, and supporting services. The budget is
the first step in controlling expenditures to achieve educational goals. Internal controls provide the checks and
balances that are necessary to guard against errors, omissions, misuse or
improper allocation of public funds.
Without a strong system of internal controls embedded in a comprehensive
set of financial management policies, procedures, and practices the potential
is significant for financial abuse, neglect, faulty management decision-making
and resulting harm to educational programs.
Emery’s financial woes stem from financial
mismanagement and, also, find root in large misses in budgeting for such items
as average daily attendance counts. In
addition to the questionable business practices of the former superintendent,
the district neglected to tend to basic internal control and other good
financial management procedures such as:
v
budgeting an appropriate level of reserves
v
ensuring that Board of Education members, and
central and site managers received timely and accurate financial reports that
would have enabled them to make timely and effective decisions in areas over
which they had discretion
v
controlling expenditures by identifying and
mitigating unnecessary expenditures, encroachments on the general fund, and
budget variances and contingencies; ensuring that funds were available and
expended on allowable costs; establishing a system of expenditure approval and
payment that also provided for segregation of duties; encumbering and
reflecting unpaid purchase orders and other obligations in the financial
reports
v
ensuring receipt of budgeted revenues and
identifying other revenue opportunities, especially, reimbursement
opportunities for current eligible expenditures
v
maintaining current and accurate account
records, monthly reconciliation of bank accounts and cash in the county
treasury, and cash flow positions
v
establishing a position control system
v
maintaining adequate and current policies and
procedures for board and staff use in budget development, enactment, and
administration
The condition of the
district’s budgets – deficit spending, large negative fund balances – prior to
the tenure of the State Administrator indicated that the business office staff
may have lacked the appropriate technical skills to develop and monitor the
budget, control expenditures, ensure that revenues were received as
anticipated, and adhere to a system of internal controls. Certainly, financial
staff had not received proper training, cross training, or supervision. The
budget’s status also indicated that the necessary leadership skills to evaluate
the district’s financial status and direct the work of the staff might have
been absent.
The district has made
significant progress to date in the area of financial management and
operations. In order for the district
to sustain its progress in regaining solvency, these accomplishments must be
maintained. The areas in which the
district has made progress are discussed below, followed by a discussion of
areas where action still needs to occur.
For a summary table of recovery actions recommended in this Management
Review and Recovery Plan, please refer to Appendix B. To effectuate these changes, the district proposes to reorganize
its central office operation. The
current structure is shown at the beginning of the Personnel Management section
and the proposed organization is shown in Appendix C.
Multiyear Financial Recovery Plan
In Spring 2002, the district obtained approval from the Superintendent of Public Instruction of a Multi-Year Financial Recovery Plan containing the district’s initial plan to maximize revenues and cut expenditures over a five-year period while still maintaining a quality education program. Since then, the district has implemented many of the expenditure cuts proposed for the first year, 2002-03, and monitored the variances between the plan’s assumptions and emerging realities in areas of student attendance, revenue, staffing and other potential major expenditures. The district will revise the plan each September based on modified assumptions and the resulting ability or need to accelerate state loan payments, augment programs, or make additional expenditure cuts.
The central goal of this Management Review and Recovery Plan is to implement sound policies and practices that will permit the district to achieve the financial goals detailed in the Multi-Year Financial Recovery Plan. Because the ultimate measure of success for this Management Review and Recovery Plan lies in the Multi-Year Financial Recovery Plan, the Multi-Year Financial Recovery Plan is incorporated herein Appendix D. Throughout implementation of this Management Review and Recovery Plan, the State Administrator should ensure that district actions are consistent with the goals of the Multi-Year Financial Recovery Plan.
Reserve
Level
In 2001-02, the district established a policy to maintain reserves at the state-recommended level of four percent of budgeted expenditures, transfers out and uses in order to meet contingencies posed by uncertain local and state conditions. This policy is reflected in the Multi-Year Financial Recovery Plan, which also shows that the district will erase its negative ending fund balance by 2003-04 and fully fund targeted reserves by 2004-05.
Position
Control
The district has adopted a position control system, using a spreadsheet and position control numbers. This will enable the district to know how much it is spending on personnel vis-à-vis budgeted amounts, and predict the financial impact of annual step and column increases, and salary negotiation proposals. This ability is crucial in that salaries and benefits account for a major portion of the district’s budget.
In 2003-04, the district will convert to new accounting software (Escape). This would be an opportune time to begin maintaining the position control system in the accounting software and integrate it with the payroll and human resource systems. An automated position control system would assist the district in developing salary and benefit budgets, monitoring expenditures, and preparing for salary negotiation by providing more timely and accurate information.
Expenditure Control and Internal Budget Monitoring
The district has virtually eliminated deficit spending in its 2002-03 budget. The district, also, has adopted and implemented procedures whereby all proposed expenditures are reviewed at different organizational levels for availability of funds, appropriateness of fund source, necessity, and consistency with the budget and the multiyear financial recovery plan and, on that basis, approved by the State Administrator. Once approved, purchase orders and other obligations are encumbered and reflected on financial statements. The district is giving greater scrutiny to special education expenditures, to stem the growing encroachment on the general fund while still providing appropriate services.
In 2001-02, in order
to establish better communication among central, site, and program managers,
the new district CBO met regularly with site and program managers to provide
information relevant to their respective program budgets and adjust their
budgets as appropriate. The CBO also
developed and implemented a program of regular
training for key school and district staff, including principals, grant
administrators, and program managers, related to the development, use and
monitoring of monthly budget reports they have begun to receive from the
business office. The purpose of the
training was to develop a clear understanding of the budget process,
corresponding staff responsibilities, and their ability to monitor the budget
areas over which they have discretion.
Revenue Control
In the past, it
appears there was little systematic effort to budget revenues and monitor to
ensure they were received as budgeted.
In addition, the district did not always budget and claim the maximum
revenues, especially reimbursement of current eligible expenditures. For more detail on this latter point, please
refer to topics related to audit findings and food services.
Currently, the
district is making a concerted effort to ensure that all budget estimates are
based on a thorough and accurate understanding of past receipts and reasonable
assumptions for future receipts. As a next step, it is important for the
district to establish and implement a procedure for revenue monitoring, as a
companion to expenditure monitoring, in order to obtain early warning for
deficit spending.
In 2002-03, district
enrollment unexpectedly declined by in excess of 100 pupils. The district is
developing financial and organizational plans to adjust to the reduction in
revenue limit funding that will follow in 2003-04. It is imperative that the district also determine the cause for
the enrollment decline and develop strategies to increase interest in district
programs and, hence, enrollment to levels that will ensure the long-term
viability of the district. In addition,
the district must continue to pursue new sources of revenue, specifically, new
grants and the local parcel tax proposal that is under discussion with
community members and officials.
Cash Disbursement
In the past, duties
were not segregated in the cash disbursement area, making it difficult to
detect errors and possible to create a fictitious transaction resulting in
payment. One person was in charge of
opening the mail, sorting and coding the bills for payment, recording the
expenditure in the general ledger system, initiating warrant processing,
maintaining custody of the signed check, and mailing the check payments to the
vendors. The district has since
implemented a system of internal controls consisting of checks and balances
that preclude a single person from handling incompatible functions, such as
custody and records keeping.
Cash Reconciliation
District staff did not
reconcile district bank accounts – notably, the revolving fund, cafeteria fund,
student body account and payroll taxes -- on any regular basis to ensure that
all transactions posted to the accounts were correct. The county office
reconciled cash in the county treasury account and submitted a monthly
statement to the district after six to eight weeks from the end of the
month. A district staff person was not assigned to review any district or county office reconciliation
as a second check for accuracy.
Related 2000-01 audit finding. The State Controller’s Office audit of the district’s 2000-01 activities produced a similar finding:
The auditors found that the district’s cash and payroll accounts were not reconciled on a regular basis. The district explained that this occurred because of software problems at the County Treasurer’s Office and that the payroll accounts would be reconciled to the financial system as part of the year-end closing process.
Action taken. In
2001-02, the CBO began regular reviews of the county office’s reconciliation of
district cash in the county treasury account.
The CBO and his staff began monthly reconciliation of all district bank
accounts, and the payroll accounts were reconciled to the financial system as
part of the year-end closing process.
Action #6
In
order to maintain progress made to date toward solvency, the State
Administrator and CBO shall:
a.
Fully fund the four percent reserve level by
2004-05
b.
Implement and monitor the Multi-Year Financial
Recovery Plan for changes in major variables affecting revenues and
expenditures; submit a revised plan each September until responsibility and
authority are returned to the elected district board
c.
Monitor implementation of the Management Review
and Recovery Plan for consistency with the Multi-Year Financial Recovery Plan
d.
Continue to follow expenditure control and other
internal control procedures, and provide on a scheduled basis financial reports
and related training to central, site and program managers on all financial
control systems; closely monitor special education encroachment
e.
Continue to implement a system of internal
controls that preclude a single person from handling incompatible functions,
such as check custody and record keeping in the cash disbursement area
f.
Continue implementation of encumbrance
system. Reflect P.O.s and encumbrances
in financial statements for proper budget monitoring.
g. Continue
to reconcile each district bank account and the cash account in the county
treasury on a monthly basis
Time line: Ongoing
Action
# 7
To further the district’s move to solvency, the
CBO shall:
a. Assign
a second staff person to review all reconciliation of district accounts and the
county cash account, and sign off on the review
b. Maintain
complete and accurate records and procedures to support development of revenue
estimates; develop and implement procedures for regular revenue monitoring and
reporting
c. Develop
and implement strategies to increase pupil enrollment and obtain new sources of
revenue
d. Analyze
variances in actual versus budgeted expenditures for payroll and reconcile
payroll accounts to the financial system on a regular basis, preferably monthly
but no longer than quarterly, as well as at year-end closing – to detect
errors, identify need for budget revisions, and ensure that payroll taxes are
properly accounted for and paid.
e. Maintain
the position control system and, further, evaluate the feasibility of an
automated position control system
Time
line:
Complete in 2002-2003 and maintain on an ongoing basis
Board Policies and Administrative Regulations
Board policies and district administrative
regulations provide guidance to the district staff on the implementation of
laws and regulations. These policies
and procedures can be more stringent than what would be required by laws and
regulations.
Emery’s board policies and district procedures
related to business and financial operations are outdated and incomplete. In a
review of section 3000 of the board policies, it was noted that the only recent
addition was in 1997 regarding investment policy. Below are examples of items
that are absent and need to be added to board policies and/or district
procedures:
1.
Written policy or procedure on conflict of
interest. Key management officials and
board members (or advisory board members) are not required to complete a
related-party questionnaire (Form 700). This form requires the full disclosure
of business ownership and affiliations.
The intent of disclosure is to identify and prevent conflicts of
interest in any business dealing with the district and ensure that all
resources are used appropriately. It
was found in FCMAT’s early work with the district that the former district
superintendent had entered into significant transactions with people/firms
related to or affiliated with him.
2.
Written board policy and guidelines regarding
fraud. There are no investigative and
reporting procedures for staff to follow when faced with the types of fraud,
improprieties, and irregularities that may occur in a district.
3.