[Music] I'll give it a minute. Welcome. Okay. >> Okay. 9:00 I think we'll go ahead and get started. Uh Joyce, if you do the roll call, please.
>> Dave Tally >> here. >> Mark by Master, he's absent. Um Alyssa Doin >> here. >> Um Michael Dixon, he's absent. Darina Bowman >> here. >> Leandre Camel >> here.
>> Frank Barbie who's also absent. We have quorum. >> Great. Thank you. Okay. Now we'll do introductions and uh we'll go down at the end as always. We'll start with Patricia. >> Good morning. Patricia Morales from the Office of General Counsel.
>> Gordon Longhoffer Classroom Teachers Association President. >> Oscar Strep inspector general's office. Bob Bliss, Office of Inspector General. >> Randy Law, Inspector General's Office. >> Tracy Shear, Inspector General's Office. >> Dave Tally, audit committee.
>> Teresa Michael, Inspector General. >> Carrie High, Council to Inspector General. >> Joyce Edison, Executive Secretary to Inspector General. >> Christina Daniels, Inspector General's Office. >> Leandre Camel, auditing committee.
>> Arena Bowererman, audit committee. Allison Castellano, high school principal, principal of Spanish River High School. >> Okay. And virtually. Alyssa. >> Yes. Alyssa Dovin, audit committee. >> Great. Thank you. Okay.
>> Free elementary principal. >> Hey. Hey. What? >> Tasha Burke Pier. I work in operations. >> Gloria Branch, school board member. Okay, that's it. Okay. Well, welcome to
all of you. Um, we'll first take an approval of the agenda. Are there any additions or deletions? Okay. I'll I'll recommend an approval of the agenda. >> Motion to approve. >> Motion to approve.
>> We need a second. >> Second. >> Discussion. All in favor? All opposed? Passes. uh take a minute and uh review the minutes of the August 15th meeting. And when you've had a chance to look at that, I'll uh ask for approval of those.
I have a motion. >> Motion to approves. Need a second. >> Second >> discussion. All in favor? All opposed? Passes 4. Public comments. >> Hearing none, we'll move on to the
inspector general report. Terry. >> Good morning, everyone. >> Morning. >> First of all, I'd like to um welcome our new principal representative from uh Spanish River, Dr. Costalano. Appreciate you coming. um looking forward to getting a principal's
insight. Um I know a lot of times we are problematic or we cause a lot of um concerns or or or work for you and that's not what we want to do. So we are always open um to get your insight to get the principal's input on what's
going on. That's very important to us because we don't we don't know all the time understand everything. So giving us some context would very appreciate it. So, please feel free to speak up on on topics and um to give us your insight and as always and pass it on to the
other principles. We'd like to hear, you know, if they have questions or concerns. So, >> Mr. Law will let you know that I I do that. >> Yeah. >> Thank >> I've been giving my input, but now I'm glad to be part of the committee to be here with all of you. So, hopefully if
there are changes or things that need to be made that I can help communicate that as well. I appreciate it. >> Yeah, I appreciate that. and Mr. Longhoffer, the president of CTA, welcome. We normally see you at board meetings, so it's a little different to see you first thing in the morning, but and the same thing with the teachers as
well because we understand that uh this also affects them. >> Absolutely. >> And um you know, I have a neighbor that lives down the street that's a teacher, so every time I'm walking my dog, she makes sure that she lets me know when we are are are making the mark or not. So um we want to hear from you as well. I
appreciate any comments. >> I appreciate that, Miss Michael. Thank you. >> Thank you. All right. Um, as far as us, we're going to have a very short um, meeting. Well, a hopefully short meeting and very painless. Um, we had a long board meeting or fairly long um, on
Wednesday. But this year, this is the time of year for the annual report. And I know everybody's so excited because an IG annual report is just the thing that everybody has been wanting to look at. And I understand there's five people that read it and one of those is my
mother. Um so and she's very proud of me by the way. Um a little bit on the the the annual report. It is a big deal to IG's. It's our bra books. Um but it's also a way for us to demonstrate to the public um
as well as the district of what we've been able to accomplish. and our IG annual report is a little different than most annual reports that you will see is because we have a lot of the background information. That's because there's a lot of misunderstandings or or um uh
kind of urban legends about what IG's do and don't do. And so we try to add a lot of educational to this as well because that's also a function of the IG's office. Um so we have some changes and new additions to the the IG the report. We
have backgrounds we have statistics and then finally um appreciation to the staff who actually do the work. First of all one of the changes now this report has a certification and affirmation and if you will see I think it's like on the third or fourth page
where I signed electronically that I affirmed that everything in here is true and accurate. um as being in this field for now going on 29 years, I can tell you that I don't know if every IG could actually sign an affirmation on their
their report. Uh but this report is also used as a basis for my evaluation. So, I wanted to have an affirmation in there to let you know that you can rely on this information, that it's not misleading, that it's accurate, and I certify that so that when you do my
evaluation, this is the information from there. I do have to admit that I I dropped the ball. We um well, there's one issue that I know of, and that's the admission of Alex Sosa, who is our new auditor. Um, I apologize to Alex uh that
for some reason his bio did not get in there. So, I made sure that we have his full bio here right now so he gets his recognition. Uh, he's one of our new auditors, but he's doing an amazing job. And again, Alex, I I apologize. Uh, but
we already printed it and fraud waste. Um, I'm reprinting these things would not be good. So, um, but I do apologize. He's doing an excellent job. So, Alex, here's your your uh kudos. >> Point of inquiry, Mr. Chairman.
>> I noticed in the first line there that it says that Alex Sosa earned a bachelor's degree in bit business administration from the University of Florida. That wouldn't be the reason, would it, Madam G that you left him out? >> Well, he didn't go to St. Leo, so you know, um
>> anything to do with >> Alex, go Gators. >> Hang tough, bud. Hang tough. Go go go go Monarchs, Lions, or whatever my university has changed their name to right now, but remember my school is undefeated in football. We don't have a
team, but we're undefeated. But uh here's the background um for the introductions in the office. One of the is the function of purpose of the office and this is transparency and accountability. So that's what the purpose of the report is and the
educational inform a informative um one thing that a lot of people don't realize is that the IG office is the only office that reports to the board through um myself. So all the other employees report to the superintendent
then to the board but we are independent and the staff in policy um it states that they report to the board through me. So, and that's so that we have nobody here that in this office that has any type of influ in influence or has
any problems with what um could be deemed pressure from district management. Here's the different functions. A lot of people don't realize the different functions that the IG's office and which unit they do. Um the audit section just
lists what the different areas that they handle. um audit of course they do the plan. They have the internal funds audits, audits and reviews. They handle the risk assessment. The investigation section is in charge of the CARES um process. They also do investigations. They do the safety inspections and they
have CFA accreditation. Our contracts and QA attends committees and solicitations, completes contract reviews, monitors all the follow-ups to the reports, the recommendations, and they also handle the peer review and quality assurance. And lastly, our legal department, i.e. legal beagle sitting
next to me. Uh he reviews all the reports for legal sufficiency, does the policy development, he handles public records because that's extremely important. Um public records is a very complicated um process and making sure that you handle that. I would not trust
anybody but an attorney to handle that function because you can really make some mistakes. And then he also goes over with all the investigations with the the individual investigators to make sure that they're hitting all the marks legally. All right. Cares. All right. Everybody
everybody loves CARES. All right. And one of the things I want to tell you that um since I've been here, I've not had one new idea in my little head. Um everything that I've done here changed here is something that somebody else has done except for the naming of CARES.
That was came from my little head. >> That was all me. All right. But everything else are things that IGS do everywhere else. So I'm not innovative. I'm not I'm not breaking any new ground. Um but I did come up with the CARES title. Since CARES has started, we've
processed over 2,500 complaints and each complaint is reviewed by the director of investigations, inputed by our our CARES intake staff, and then approved by myself. And as you can see, this is the breakdown of how the cases the complaints have come in. Quite a few of
the cases um are referred out to other people. I know there's been some concern that I have trying to take over the the district and I have a power grab and you can tell there that no, there's 612 complaints that are referred out to management because they are not related
to misconduct of a level that requires the IG um to take over. There's also um an agreement that I have with um Office of Professional Standards that when you're talking about teacher education or certifications or classroom management or things of
that nature, um I can't judge, you know, what is good classroom management. I I I'm used to nuns, you know, at at a parochial school. So, I would never judge how teachers today and what they have to deal with. Plus, I'm very old. Um but if you take a look you see how
things have have gone through the the CARES investigations this year they completed 13 investigations. Uh 10 of those investigations had substantiated findings. Um four cases were regarding selling snacks. And I know that this
sounds rather trivial. Um but the um teacher selling snacks in a classroom causes numerous problems. One of which jeopardizes federal grant funding. We receive a great deal of money from the federal government. And if we are
selling snacks that are not um approved by the the nutrition um I I forgot what the name what's it called? >> Guidelines. The nutritional guidelines. >> Nutritional guidelines. Um then we could lose those millions of dollars. It also causes disruption in the classrooms. The
kids are fighting over food. They're eating. they're coming in late because they're stopping by the local snack bar, you know, i.e. teachers classroom. So, it does cause some problems. Uh we had two cases involving fundraising violations, one of which was referred to
law enforcement because it was um obvious that the u employee was using the money for their own personal gain. Uh we had one case of improper use of a purchase card. um one scheme involving supplements um which continues to be a
problem with um supplements being misused um and then two cases of uh falsifying time sheets. We also had uh two cases that were unsubstantiated in uh use of improper
public funds. Um and an employee it was alleged that an employee uh evaluation was improperly mod uh evaluation was modified and it we did not find that. Um and then one unfounded. Um and when the difference between unsubstantiated and
unfounded, unfounded was there was absolutely no evidence that this occurred. um unsubstantiated is that the that that the propoundance of evidence showed that it didn't happen, but there was some indications of some um problems that could have come forward, but it's
unsubstant it was not meeting the threshold. And then we have the school safety inspections. Last year we did 33 of those. Um and those are the breakdowns and we're going to be going over the results of the safety inspections at a closed door session because it's just not proper for us to discuss the the
finer details. Um do I have any questions about the investigation section? I have uh director Restrepo here. That that's nice to know that the director has no questions about his own work. Okay.
Okay. Accreditation. Um this year we went through our accreditation. We are credited by the Commission for Florida Law Enforcement. Um that is a it's an optional um accreditation. We we're not forced to do that. But this is a standard that we do want to meet. Um
it's the same accrediting board that the school police goes through. And this is will be our third our second reacredititation, our third time going through the process. And we did an amazing job and I'm very proud of the staff that um put forth the work in that
and keeping all of those rules in line. And this just assures um because not everything that we do is written in our policy. I know that we've gone through a lot of policy development and a lot of board members and a lot of the public and have asked questions about well
where is it written? Why do you you know why you know we don't know that you're doing that. How do we know that you're doing it? Well, the standards require it. And in order for us to keep the accreditation, we have to maintain those standards. All right. Next to audit. Um our audit
department which is ran by director Randy Law. Um this year they had four audits. The first one um was the Lakeworth High School band which had four main findings. diverting funds, inadequate documentation, and student safety and money collection
procedure violations. Um, this year we also had did our unannounced cash counts of 15 schools. Very happy to see that no missing money. Um, we had no and no findings at seven of those schools. That's that's excellent to hear. Uh we did have some non-compliances related to
documentation and delayed deposits and that's something that continues to be an issue but um it's addressed and and it's not to the point where I think somebody's holding it for months on end or using it as their own piggy banks but again the longer
the longer the money is sitting um at the school the the greater the chance that we have missing money. So that's always uh then we had an audit of the safety inspections program and that's the to ensure that the inspections are being performed by certified inspectors. We had 8% deficiencies
were resolved, but there's still problems. And then we had some deficiencies that remain uncorrected from 1 to 6 years and and you know even 11 to 29 years. And those are are some structural type um issues that um are
just not going to be changed because we're not using it for that reason. They're um either a facility or a building that you know it they're coming up with a safety issue, but nobody's using it for that reason. So it's just continues to be a violation and this is
something that we are going to look at doing a risk acceptance on to kind of get rid of these these findings. All right. And then finally the internal funds. Um we every year uh the school every school has a audit and this year
we had 18 schools with no significant non-compliances. And I really want to give those schools kudos because if you made it through Randy Law's team with no significant uh non-compliances, that's pretty good. >> Yeah. Um the dispersements, we had some
issues with improper documentation. uh no consultant agreements for vendors and that isn't so much you know you're worried about a issue on paperwork is that sometimes you have somebody that's not been vetted that has not gone through the the process that for Jessica
Lunsford act so we we don't know who these vendors are and if they are uh you know somebody that should not be around children so that's why those are so very important uh we also had some money collection issues untimely deposits fundraising procedures that again it
continues the it we have a lot of volunteers. You have a lot of teachers. It's their first time um doing a fundraiser and you know the the principles can't be on top of everybody at all times. Um and so that you do have some things that come through but I
think each year we are making some progress. And then lastly the leasing of facilities agreements not properly executed. That's an issue with sometimes they're just not signed. Um and again there's you have some um problems as as far as risk is concerned as when you
have somebody that's um supposedly leasing our our facilities but we don't have an agreement with them. And of course audit made it through their peer review and I want to congratulate um the audit staff and u
Mr. Bliss who's who sets up the peer review. Um we have when we are peerreed for the audit and contract oversight um section they are audited they are looked at through the standards or the green book by the association of inspector
general and the government accounting um office that which otherwise called the yellow book. U the the reviewers were here in April and they came back and gave us said that we're meeting all standards and we did an excellent job. Um so I'm very proud of of the whole
team. Um auditors have papers for papers for papers and they sign off on every paper couple of times. So that to meet all those standards is is is really amazing. And then we have our contract compliance
oversight section. Uh that's Mr. Bliss and they attend well he attends because he's the whole unit. uh 21 contract meetings with an estimated contract value of over 140 million. He also attends the cork construction oversight and the independent certax oversight
committees. And additionally, he also um looks at all of the recommendations that are found in audits and investigations and he follows up on those recommendations um until they're completed and we can
close it out. And that's the end of the annual report. See how I see how I condensed that. All right. Do I have any questions about the annual report and anything that we're doing here? >> I don't have any questions. I just have
a comment. I think this is an excellent document and uh congratulations to you and your whole staff for uh doing such a wonderful job. >> Thank you very much. I I I really appreciate the the the um kind words that it really is the staff's work. Um I
just signed the the reports and the checks. Um and I do want to point out that um on our cover of our annual report, we have the superintendent on it. Um I didn't ask his permission. I informed him that his picture is on there and he has no choice in the
matter. Um but he said that he was honored. I don't know if I believe that. Um, but I do want to thank the staff for all of their hard work. I wish I could give everybody a raise, but that's not going to happen. We heard about the budget. Um, so, um, I will do what I
can, um, for the staff in my way to make things, you know, to show my appreciation, but you guys do a very thankless job. And I think you all understand that. Nobody ever looks at us and goes, "Yay, the IG's here." So, I understand that because I say that when
you walk into my office, too. Um, but thank you very much staff. I do appreciate the work. >> Are there any questions or comments of the members? >> If not, I'll recommend a motion to approve. >> Leandre. Motion to approve and accept
this um annual report um of the inspector general from the office of inspector general. Do I have a second? >> Second. >> Discussion. All in favor? All opposed? passes 40. Before we go on, I'd just like the
minutes to reflect that our CFO, Heather Frederick, has joined us for the meeting. So, nice to have you. Okay, we will go on now to the update of the internal funds audit. Randy, >> thank you, Mr. Chair. Uh, this year's uh
internal funds audit is progressing smoothly. Uh, up until last week, we have completed 19 out of the 177 schools field work. And then I checked the status uh this morning the past four days the auditors finished another five
schools. So a total of 24 schools are field audit been completed. Uh we expect to have uh all the schools uh audits completed in you know timely you know by mid-March or something like that. So there shouldn't be any problem. And then
in terms of the audit findings, they're very similar to what happened last year because of every year there's a lot of uh turnovers in bookkeepers. They mean this new additional training to you know uh get up to speed with the work. So no
material findings so far all about the same. Uh in addition to the internal funds, I just want to add another updates is in addition to doing the internal funds audit, the auditors are also trying to uh complete other
outstanding performance audit. We have another six uh performance audits are ongoing. Most of them have been completed about 80% of the of the work. So hopefully we will have all those six performance already completed you know
in the next a few months and then present to the audit committee for review and approval. Uh, any other questions? >> You said six. Outstanding. Six. Six. Okay. >> Okay. Thank you, Randy. Next, we'll go
to uh board policy review. Uh, Carrie High Esquire. >> Good morning, everybody. >> Morning. Sticking with the um this morning's theme of of keeping stuff rolling, uh we will um I'll be presenting our final uh policy review
that um that you all will hopefully have to see for for a little while, at least a year or two. Um today we're going to be covering the the whistleblower uh protection policy, which is board policy 3.28. Just noteworthy, the prior policies that
you all have reviewed uh two of which um the uh audit committee policy pertaining to you as well as the fraud policy have both advanced to the uh development stage and they are set for a board vote on October 8th. The inspector general
policy, there were some some questions and some points of discussion during the workshop um week before last. So, we're reworkshopping that one on the 8th along with this one pending your approval today. So, first question, what would the OIG council's policy review be without a scrivener's error to update?
What would it be? It would be not fun and the audit committee loves to have fun. So, line 106, I'm this is my Mayel to you all. Line 106 in your copy should state section 2G1
and two of this policy. I believe right now it erroneously reads section 2D 1 and two. Um the reason for that is because I I actually placed all of our definitions in alphabetical order and I just neglected to update that. So um my
bad scrier's error corrected in your copy and it will be corrected in time for workshop. So here we go. Whistleblower protection. What we've really done this time, um, much like the other policies, is we're really working to align all of our, uh, district and
board board policies operating within the district with Florida law. Uh, there is a pretty substantial section in Florida law regarding public and private whistleblowers. We obviously as a public institution fall under the uh, whistleblowers act for for public
employees. That's section 112 3187 through 112 31895. And the premise for whistleblower protection, just, you know, by way of a little bit of a history lesson here, is we provide confidentiality to anyone who makes what the law deems to be a
protected disclosure. And that is very strictly defined under section 112 3187. And when we receive any sort of report or complaint or or really anything that comes into our office, whether the complainant or reporter is requesting
whistleblower protection, our investigations team analyzes it to see if it meets the definition of protected disclosure. If it does, right, we have a thorough process where where we vet it and we do our level best because we have to to comply with the law and protect
the confidentiality of that person's name and identity. um whether or not we decide to conduct an investigation. So the number one purpose behind this policy is to protect very specific groups of complaintants or reporters
confidentiality. The second thing is we protect people. This policy rather protects people who make protected disclosures from any subsequent retaliation be that in the form of uh adverse personnel action such as a demotion or a firing or or really anything that can be causally connected
to that protected disclosure. Our policy is designed to provide an avenue or a mechanism for them to to be protected and seek remedies or redress for that. So as we go through this really think about those two things. protection of the reporter's confidential their name,
their identity, as well as protecting and providing an avenue if they believe they've been retaliated against based on that protected disclosure. Excuse me. the the main crux for some of the uh removal of a lot of the language that was in this policy is based on the
original drafters um I'm not denigrating them but but com conflating protections that are provided to state agencies we are not a state agency we do a lot of things similar to what state agencies do and certainly we've done our best to advance the
spirit of the state agency practices but when we tried to proverbally squeeze is kind of that square peg of state agency practices into the round hole of the district. We've run into some issues and so what I've done and what I'm proposing is applying the appropriate standard,
right, and revising this. So we put in the language from the policy that applies to local governments because that's what the board is. Again, it serves in that quasi judicial quasi legislative capacity, but it is a local government unit as opposed to a state agency for purposes of whistleblower. So
you'll see that a lot of these changes and a lot of the removal of some of the the language that was there, it's so that we align with the law. Um, and specifically that law is only 112 3187 to 1123188 because all of those subsequent
sections, they apply to other entities that aren't local governments. And you'll see that correction in line 12 uh through 22. So specifically, we're really going to start rolling now. Specifically, we have used the appropriate terminology um to to designate the person who is responsible
for receiving whistleblower. We call them whistleblower complaints, but really what they are legally speaking is protected disclosures. That person by our policy has always been the inspector general, but the language that's used by the statute is appropriate local
official. Somehow we settled on locally designated official in the original version. I'm not sure how that happened. uh I wasn't part of that, but I've changed that term to appropriate local official and provided a very precise and clear definition that the appropriate local official here for the school
district as far as it relates to whistleblower complaints is the inspector general. Additionally, we've added a new definition for sufficient complaints and and what that really does is it just merely codifies the language from the Florida statute that that defines
protected disclosures. And that statute is 1123187 parent 5A and parent 5B. We sort of call them in the office the two prongs right and that specifically defines the type of complaints that if they are brought forward or again it doesn't have to be a
complaint it can be a report hey something happened you know I want to make sure that that that you're made aware of this because I believe it affects the health safety and welfare or I believe it is an example of gross mismanagement or misfeasence or malfeasance and again when we perform our analysis we view it for sufficiency
so we've added this definition of sufficient complaint and it's pulled right directly from the statute. And lastly, we've really streamlined everything by also consolidating reporting procedures to create because we've really worked hard, at least over my time here, to centralize things in
this district for many years. I think that um people sort of embrace the idea of having a decentralized model. And the larger that a place gets and and the more pressure we feel to comply with with laws and rules and regulations that are being handed down either from
Tallahassee or Washington DC, it helps to have something that's centralized so that folks know where to go. They know who to speak to to make sure that that their problems are addressed. So you'll see some streamlining. All right. Number one, we have removed a section that says rights of employees. And before everyone
gets upset, we've actually integrated those rights into a section called exclusive remedy. And that exclusive remedy is pulled directly from section 112 3187 8B. And that's lines 228 through 234. So
understand we haven't removed any rights, but we've clarified what someone has to do if they want to again make a protected disclosure. If they have made a protected disclosure and subsequently they believe they've been retaliated against, this is the section they will
go to for the exclusive remedy to receive relief. And that is promulgated by statute. It's driven by specifically the district's relationship with uh the department of administrative hearings or DOA. We we have a contract with them
that that says, look, if somebody claims whistleblower retaliation, they have to have their case heard here as part of their exhaustion of administrative remedies. There's been some recent case law that's come out of the fourth district court of appeal in the past I think it's been about a year,
right, Patricia? The decision I think so. So, we're talking with folks from general counsel's office. Um and again we are just aligning our policy with what the law requires and more importantly what the courts have said the law means. So that's some
reorganization that's taken place. We've also consolidated. All right. And and really what we've taken is we've taken all of those um inapplicable provisions that I mentioned a couple slides ago that relate to um state agencies whistleblowers. We've wiped those out
because they're not applicable to local governments. And we've created sections that flow, in my opinion, much better through 3.287, 3.288, and 3.289. And that again really spells out the rights, and it more closely mirrors the the whistleblower uh statute in in in
substance and and um and really structure. The um the last thing is the investigative closure and the reporting procedures that that we've created. When the appropriate local official or the IG
receives a report or a complaint, what we obviously again make sure happens is that we screen those, we vet those, and in the event that it turns out to be a protected disclosure that is worthy of investigation. What we do, and this is following the
spirit of the law for state agencies, is we have since the beginning of this policy adopted a practice where we notify the superintendent and let the highest ranking manager, our CEO, let him know what our investigation bore out
and and and let him or her know what decisions or let him know what possible um risks are faced and what possible decisions can be made. And this again requires that there be notice of that provided back to us that it was
received. And if there is any action taken, we can then take it back to our disclosure. We can then let that whistleblower know, hey, you came in, you disclose something to us. It was obviously uh it was something that we've looked at. It's meritorious. Here's what
the superintendent has decided to do, if anything. And again, it just closes that loop and ensures that we're both advancing really the protection part of of a whistleblower uh confidentiality because we will be the the go-between to let that person know. The superintendent's never going to know who
that person is if we've done our job. And we will also be in that position to adhere to the fidelity of the law, which means if you're a whistleblower, you're reporting something that is very important that needs to be addressed. And if we find that that is the case, it is addressed.
And lastly, uh, renumbered sections 9 through 11 just to to really create more of a a logical sequence, um, that that goes handtohand with this consolidation. So, here we go. Report submission, right? We clarified, I've said this a couple times now, hopefully you're with me, that the IG is the appropriate local
official, and she or he, whoever the IG is, will be responsible for processing and receiving any complaints if you want to trigger the protection under this policy. that's marked in a couple different sections because we really want to make sure that folks understand that that that's who you need to go to.
Um, investigation standards and and this is one of the things that's that's stuck in in I know in the inspector general's craw and my craw a little bit as well. Um, there was some language in here that much like CARES, completely inappropriate that related to the IG
making disciplinary recommendations in our final reports or or even making recommendations regarding reinstatement for employment and and or or or anything related to possible retaliation. Those have number one, they're inappropriate, but that second one has been rendered
moot because that is no longer what what the IG does. Again, DOA would be the the entity responsible for making any decisions there. So, we've removed that removed that language. We also removed sort of the nonsensical anonymity provision because if you think about it,
if if someone's making an anonymous report to us, their identity is already confidential, right? So, we've removed that as well. Um, lastly, closure notification. And I mentioned this before, but we've enhanced this procedure to make it much
more clear. And basically, again, any written report that we provide to the superintendent. Superintendent will review and then based on whatever decision is made by the superintendent after review, we will send that back to the reporter or the person who disclosed to us the um that law violation or or
again incident that that was worthy of protection. Um here we go. We uh we've we've protected excuse me we have now clarified the protection and this is basically these are the ways in which whistleblower um folks can make their
disclosures but but understand that merely because this is from statute. It has to contain a protected disclosure. So we just really spelled this out and made it much more clear and and I'm proud because we added cares to part of this um basis uh that people can use
when they are making a protected disclosure. So that can be a voluntary written complaint, participation in investigation, again where you make a protected disclosure, you know, merely being a witness, you know, merely being somebody who says, "Oh, yeah, you know, that's that's the person that um that
that uh that I report to. Um but yeah, I don't know anything about this complaint." That wouldn't be enough to render someone um protected by either the statute or this policy. Uh refusing to participate in prohibited actions and then complaints with supervisors. All of that's codified in lines 190 through
205. And again, this has come directly from section 112 3187 parent 7 local government whistleblower. Um, and I just mentioned this, we've added uh protection to disclosures that are made not only through the hotline. That's all the statute requires is that we have a
hotline and hotline's kind of old school. You know, you think of calling on the red telephone, but um we also have CARES. We also have a platform where someone can can upload uh uh documentation. You know, they can fill out a report online if they don't want to actually speak to someone or if they prefer to speak to someone, they can
speak to someone in in multiple languages. That's all part of that hotline concept, but we also have CARES as as you all are aware. Lastly, this is our last slide, and I'm trying to cook. Um personal knowledge, excuse me, good faith requirements. This was um this was something that was built
into the policy to begin with, but we've clarified it because it it really just said, you know, you got to act in good faith. But but we have taken existing statutory language specifically involving the enforcement of uh code of ethics violations. The legislature, I
think it was session before last, year before last, they adopted some requirements involving ethics violations and it requires firsthand knowledge. you know, they go so far as to require that that the complaints be, you know, sworn to and not based on hearsay and and
stuff that could be problematic later on, but that's the legislaturator's issue. We've just said if you are making a report, you need to have personal knowledge and a reasonable ground for believing that what you're disclosing constitutes a violation. And we've butressed that by saying, "Hey,
sometimes people will make disclosures. Sometimes people will complain of things. And if we deem it protected disclosure, we look at it and we find out that it really wasn't what the person thought. So we have to unsubstantiate that allegation. As long as it's made in good faith, you're not
subject to any kind of disciplinary action. Right? We we we want you to know that that when we vet these things, we are considering right the idea that you might not have all the facts, but you certainly have enough personal knowledge and you're bringing it with what the law would call clean hands.
The other side of that is this. We kind of define what constitutes a non-g good faith, right? And that would be a false report. And that would be where somebody presents something recklessly or maliciously or or or brings forth a complaint that that on its face we look at it and say, "Wow, if this is proven
to be true, it constitutes a a protected disclosure." But once we peel back the layers of the onion, start talking to people, we start finding out, oh no, that that complaint was made because somebody was upset about a totally separate issue and they wanted to get the person that's a subject of this
investigation. And normally those end up becoming unfounded. And and again if it can be demonstrated not by us but by the folks who are responsible for discipline and and maintaining professional standards, if they believe it was brought with malicious intent or or they
believe it's it's something that was done so recklessly or with knowing disregard for the truth, that could present the consequence. Um but that's out of our hands. Um I think that covers it. I don't have any pictures of flying monkeys. Um, you're
welcome, but there are some in the annual report if you've noticed. And that covers it. I would just make one recommendation is that where you mention and specifically call out CARES that you just refer to it as a platform because you did mention
that it's not just CARES, it's a platform and you don't know when you're going to change it potentially. And then that way you don't have to actually go back and change policy just to update the name. That's just a recommendation. >> Right on. >> Thank you. >> Okay. Yes, sir.
>> A question and three more scribner notes. >> Oh, boy. >> As I say, you you you won the award. Yes, sir. >> I I would be the grammar inspector general at times. >> Um, the question is, can I get a uh can I get the digital version of this
presentation for these notes? This is this is incredibly good information for me as we look at uh how CARES and how whistleblower protections are evolving so that we can go ahead and update our processes with members as they bring concerns to us. >> Absolutely. Okay, that would be great.
>> Yeah, Miss Edison will she'll make that available. >> You got my email address. So, thank you so much. The other thing is the uh the scriber notes. Yes, sir. Uh line 12 >> of the of the of the changes. >> We'll get right into my digital version. >> You let me know when you're there, Mr. High.
Yes, sir. I'm ready. >> Line 12. Um, the word two ahead of the red insert probably needs to be deleted as a matter of grammar. >> Okay. >> Because >> what two is that? Doesn't that make sense? >> Yeah, exactly.
Um, next line 48, spelling of remuneration. Near the end of that line, Oh, that's renumeration. Oh my goodness. Okay. Yeah. >> I'm I don't even know if that's a word, but >> I feel like Yeah, we um for wages or
other Yeah, remuneration. That was that was part of our ethics presentation last week. This is really embarrassing, but yes, >> it's all right. Sadly, I found out that there are a number of words in common use now that I just would have never used and and still refuse to. >> Can we Yeah, that might be one of them,
but hey, um you know, far be it for me to to pass any judgment. just I will correct. >> We're all in this together and trying to make sure language is accurate because um when the words are down as as the code if it were as it were then all of a sudden we have to live by them even if
the comma is misplaced. Um and the last thing would be on line 106 probably need to leave in the word in ahead of section 2 G.1 number one through two. >> Got it. >> That's it. Thank you very much.
>> Thank you very much Mr. Longhoffer. Okay. Yes. Um I apologize. I'm new. So if I missed uh something, I would just like further clarification on um why on
line 269 we're taking out the information um on the student and the code of conduct. I know that as principles we see cares reports come in that are put in by angry parents or
angry people and I understand this is to protect employees which is why the word volunteer is taken out but to me there are students that you know go and put false things in on a teacher or you know
could be obviously we're protected here under if a teacher is doing something with regards to a principal. But my question would be, is that somewhere else to where it's not needed here? Because I just have a concern that people don't always use this care system
appropriately and they use it as retaliation. That's what I see as a principal. You know, a student has an issue with a an assistant principal and, you know, we keep our doors open. and there's witnesses and then next thing you know I receive a car's report on
this assistant principal that the student and parent went and put in as retaliation because this student receives some sort of consequence. So I'm just wondering why that line and that it was taken out. The simple answer is and I think you sort of asked it is
more properly addressed elsewhere and and that would be quite frankly in the code of conduct and through whatever it is that >> false allegation against okay >> and go this this was one of those things where really pretty much from from when we really started discussing the need to
overhaul whistleblower protection again the intent I think was to really let people know that this is something we take seriously you don't abuse it you're not supposed to be reckless and we wanted to include everyone than that. But just like you noted, the the policy and the law is designed to protect employees, former employees, applicants
for employment and contractors. Students don't fall into that category. And as the IG said, it's really our company line that we we don't tread into matters involving student discipline at all. However, if someone does that, I think it can be more readily addressed in another section. So that was why we
pulled it out. >> Our branch, >> thank you. Uh so where is it? um somewhere else. >> I'm sorry. >> Where where would that be when you said it is somewhere else in the report? >> Oh, no. I Yeah, I wasn't referring to in
in the policy. It it's it's more um properly addressed most likely in the student code of conduct itself or with however the district or campus level management uh decides to address the student's role in filing some kind of false report.
>> Okay. I definitely would want to know where that is. Thank you. >> You're welcome. >> Other questions or comments of Carrie >> hearing? None. I'll recommend a motion to approve. >> Motion to approve.
>> Is there a second? >> Second. >> Discussion. All in favor? >> I. >> All oppose. Passes 4. Okay, next item is investigations. There
are two listed here and these were previously sent to you by Joyce. Um, are there any uh general comments? >> Hearing none, our next meeting is scheduled for Friday, October 17th. And if there's no further business, I'll
entertain a motion to adjourn. >> Mr. Tally, there is no school that day, but just FYI. >> Oh, okay. Thank you. >> Motion to adjourn. >> Okay. Second.
>> Okay. Thank you. >> I think we set close to a world record for a fast meeting. Thank you all for coming and have a good weekend.