USDB audit prompts committee to seek strategic plan, internal controls consultancy and code clarifications

The Utah Schools for the Deaf and the Blind (USDB) standing committee spent the bulk of its September meeting reviewing a recently released internal audit and voted on a set of recommendations intended to clarify governance, strengthen internal controls and align policy and finance structures.

Nut graf: Committee members and USDB leadership said the audit identified gaps in organizational structure, policy completeness, data accuracy and internal controls. The committee unanimously asked staff to return with specific recommendations on the advisory council’s role, strategic planning, possible consolidation of certain accounts, and to seek board support for an internal-audit consultancy to build internal controls and reporting systems.

Committee discussion and votes USDB Interim Superintendent Subhashinda Hart led an overview of the audit, grouping recommendations into four “buckets”: organizational structure, competency/accountability/metrics, policy completeness, and data and funding accuracy. Hart said those pieces together form a “skeleton” for the agency and recommended a strategic plan, an internal control environment and a policy-calendar process as the primary steps forward.

Board members repeatedly asked for clarity on the advisory council’s role. The audit noted that the USDB advisory council currently acts in ways similar to school community councils (SCCs) and that USDB policy, foundation donations, enrichment funds and other donated accounts are not consistently aligned or clearly documented. Assistant Superintendent Deborah Jacobson explained that foundations are typically legally separate entities from LEAs and that arrangements vary; Chief Audit Executive Debbie Davis said clearer code and policy language would help reduce confusion.

The committee approved several motions: first, it asked staff to return with information on the advisory council’s role and whether following SCC guidelines would narrow or expand the council’s scope; what logistical or policy changes would be required to address audit recommendations including combining certain accounts; and how responsibilities between the advisory council and the foundation should be defined. That motion passed unanimously.

The committee also moved, and unanimously passed, a recommendation that the full board support the superintendent’s request to engage the Utah State Board of Education internal audit section as a consultant to help develop internal controls for USDB. Committee members and interim leadership indicated that an internal controls consultant would help set up a control environment, identify critical administrative functions for risk assessment, and align personnel and performance measures with a strategic plan. The internal-audit team is expected to consider this consultancy request at its next audit meeting; committee members noted the earliest full-board action could be in October.

Strategic plan, organizational structure and code language Committee members directed staff to return with recommendations for additional strategic-plan work including participants, budget and timeline; the motion passed unanimously. Members emphasized that a strategic plan would provide the basis for aligning all funding sources (school land trust, donated funds, foundation funds, enrichment funds) with organizational priorities.

A separate motion addressing statutory clarity moved through several iterations. Committee members asked staff and legal counsel to propose language that would clarify lines in the 2025 code that both (a) create USDB “as a subdivision of the state board and a single public school agency” and (b) elsewhere refer to appointment of a superintendent of USDB. The final committee recommendation that passed unanimously asked the full board to adopt and support the audit requirements to bring both financial and programmatic systems under the agency and to recommend code changes that would allow the state superintendent of public instruction to appoint an assistant (or designate an agency-level position) to function as the on-the-ground superintendent for USDB. Committee members and audit staff emphasized the objective is clarity of authority and reduction of overlapping reporting lines, not an immediate personnel change.

Clarifications about funds and accountability Committee members queried the relationship between donated funds, foundation accounts, and enrichment funds. Committee members and staff agreed this is a key area of confusion the audit highlighted: historically, donated funds had sometimes been held at division levels and later combined, while the advisory council currently approves enrichment expenditures though foundation-donated funds are managed separately by the foundation board. Assistant Superintendent Jacobson and Chief Audit Executive Davis said these differences reflect typical variations across LEAs and that clearer policy and internal control documentation is needed.

Other points and next steps - Implementation path: Interim Superintendent Hart described three priorities: (1) create clear organizational structure and strategic plan; (2) establish internal controls and risk assessments; and (3) develop and maintain up-to-date policies and a policy calendar. Hart said these steps would drive accountability, allow performance metrics to be aligned to agency goals, and improve transparency about who is served and how services are funded. - Timeline and process: The committee requested staff return with recommended language, policy and logistical changes and a timeline and budget for strategic-plan work. The committee also voted to recommend the full board support the internal audit consultancy; the audit section will consider the request and, if approved, work as a consultant to design internal controls and reporting mechanisms.

Ending: The committee voted unanimously on the package of recommendations and instructed staff and legal counsel to draft proposed rule or statutory language as necessary. Members signaled intent to convene follow-up meetings to review the strategic plan work, advisory-council role definition and policy updates.