The Concord School District Board voted to sign the U.S. Department of Education’s general assurances and to submit a cover letter clarifying the district’s legal position on broad or unsettled federal guidance.

Superintendent Tim Herbert told the board he had concerns about one section of the assurances that could require compliance with “any other statute, administrative rule, executive order, [or] dear colleague letter” over the coming year; he said legal counsel advised attaching a cover letter that conditions compliance on whether guidance is lawful and enforceable.

“I would recommend that we sign the assurances,” Superintendent Tim Herbert said, adding that the district would attach a cover letter stating it will comply “to the extent that the things you’re doing are lawful and upheld by a court.”

Board Member Miss Robinson moved to authorize the superintendent and the board chair to sign the assurances and to submit the superintendent’s proposed cover letter; Miss Sadowski seconded. After brief questions from other board members about the stricken language and editing of the Department of Education document, the motion passed with an aye vote.

Board members discussed several specifics raised in the assurances packet: the board president and superintendent said the packet had stricken language on items such as White House executive orders and other provisions flagged during national debates, and Superintendent Herbert pointed to the Davis Bacon references and other standard grant compliance requirements as reasons districts normally sign assurances to secure federal funding.

Several board members asked how broadly the phrase “non‑regulatory guidance” might be applied. Miss Micah asked whether the revised draft the board received used strikethrough formatting rather than a clean copy. Superintendent Herbert and other staff said they had not been provided a clean copy and that, per counsel’s recommendation, the district would submit the assurances with an accompanying letter clarifying the district’s legal stance if the Department of Education did not accept the attachment.

The board’s action authorizes the chair and superintendent to sign each required page of the assurances document and to file the cover letter. District staff said the move would preserve the district’s eligibility for approximately $8 million in federal grants pending the Department of Education’s reception of the district’s attachment.

No board action altered the text of the assurances themselves; the vote authorized submission on the district’s terms. The board’s discussion and the superintendent’s letter will accompany the signed assurances as part of the district’s required federal grant documentation.