Committee updates federal-fiscal compliance policy, adds whistleblower, monitoring and record-retention language

The Central York Policy Committee on July 21 voted to forward revisions to Policy 626 (Federal Fiscal Compliance) to the full board for first reading. The changes add specific federal-compliance requirements, whistleblower protections and revised record-retention periods.

The draft updates the district’s financial-management language to reflect that a single-audit or program-specific audit is required in years when the district expends $1,000,000 or more in federal awards; staff said the district’s federal spending has been near that threshold in recent years. The policy now enumerates financial-management standards the district must maintain, including accurate financial reporting “as stated in federal regulations,” accounting records that identify sources and uses of funds, segregation of duties and steps to safeguard property and personally identifiable information (the draft added explicit cybersecurity language).

Record-retention language was changed from five years to a three-year minimum from submission of a final financial report, with an added clarification that property and equipment records acquired with federal funds must be retained for three years after final disposition; committee members asked staff to reorder paragraphs so litigation retention language clearly extends retention beyond the three-year minimum when required. The committee also approved additions requiring the district to maintain documentation supporting that costs charged to federal awards are reasonable and necessary.

The revisions add subrecipient monitoring duties — including assessing risk of fraud and noncompliance and monitoring grant recipients for compliance with federal, state, and local law — and a new mandatory-disclosure requirement that applicants, recipients or subrecipients must disclose credible evidence of certain federal criminal violations (for example, fraud or violations of the False Claims Act) to federal oversight entities. The policy now spells out whistleblower protections, listing authorized disclosure outlets (superintendent/designee, federal agency personnel, inspector general, U.S. Department of Justice or a court or grand jury) and requires written notification of employee rights under the whistleblower law, with notices posted on the district website and in each school building.

Action taken: the committee accepted the revised Policy 626 and forwarded it to the full board for first reading. Committee members asked staff to make two edits before final reading: swap the order of the litigation-retention paragraph so it directly follows property/equipment retention, and correct several typographical errors called out during the meeting.

Next steps: staff will forward the draft for first reading and incorporate the paragraph-order change and typographical corrections before the final board packet. The committee noted several new citations to 2 CFR sections added to the guidance language.