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Independent review finds Milwaukee School District investigations followed policy but recommends clearer code of ethics and broader oversight
Summary
Rumpf Associates told the Milwaukee School District board its review of fraud, waste and abuse protocols found investigators followed existing procedures but recommended a consolidated code of ethics, formal involvement of multiple functional areas in investigations, improved board reporting and a modified audit/advisory committee charter.
An independent review of the Milwaukee School District's fraud, waste and abuse (FWA) procedures found that investigators generally adhered to existing policies but that the district should consolidate policy language and strengthen checks and balances, presenters told the board June 17.
Tom Rumpf of Rumpf Associates said the firm sampled 167 hotline tips submitted between Jan. 1, 2022 and April 2, 2025; it reviewed a random sample of 36 tips and detailed reviews of 20 completed investigations. "All the investigations that we sampled adhered to the existing policies and procedures," Rumpf said, while adding that the policies themselves are fragmented across several administrative procedures and an employee handbook.
Rumpf presented four priority findings: develop and implement a comprehensive, consolidated code of ethics; formally involve other functional areas (legal, HR, finance and others) in investigations when appropriate; improve how completed investigations are reported to the board while preserving whistleblower confidentiality; and modify the audit committee charter so FWA reporting is coordinated with the Committee on Accountability, Finance and Personnel.
Paul Geib, the district's chief auditor, and Matt Chasen of the Office of Accountability and Efficiency thanked the reviewers and said the office will work to implement the recommendations. Board members who spoke said the report confirmed a need to change policy language and to shift culture away from a punitive posture toward clearer guidance and routine training.
The item was presented for information; no board action was required at the meeting. Rumpf recommended regular training on the code of ethics for all employees, periodic refreshers, and formal mechanisms to ensure the board receives context on investigations without compromising confidentiality.
