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District 128 lawyers recommend standardized bylaws, financial reporting for booster clubs after Title IX audit
Summary
Attorney update on Title IX audit recommends clearer district oversight of Libertyville High School booster clubs, requiring updated bylaws, standardized financial reports and mandatory annual meetings with school leaders to help monitor fundraising and spending.
Attorneys who worked on Community High School District 128's Title IX audit presented an update Oct. 14 recommending stronger, standardized oversight of parent booster clubs at Libertyville High School.
The recommendation came as part of a broader Title IX action-plan update presented to the district's Program and Personnel Committee by Brian Kelly, staff member, and Elizabeth Kelly, attorney.
District staff told the committee that Libertyville High School currently has eight separate parent booster organizations and that coach-led fundraisers also operate at both Libertyville and Vernon Hills high schools. The auditors said they collected bylaws and financial reports over the summer and found some missing or outdated information that could be clarified by requiring standardized bylaws and regular financial reporting.
"Moving forward, booster clubs will need to submit fundraising activities for approval much like a coach would," Brian Kelly said. He described a proposed oversight step that would require booster groups to meet annually with a school principal and the athletic director to review fundraising processes and spending.
Elizabeth Kelly, one of the attorneys who led the audit work, characterized the booster-club financials she reviewed as, in her words, "fairly unremarkable" and said nothing stood out as a clear legal violation in the documents she sampled. She also noted constraints in federal guidance on how private fundraising interacts with Title IX compliance and discussed recent federal-level changes: she said federal guidance that previously suggested outside private dollars could trigger Title IX obligations was rescinded earlier this year.
Why it matters: booster clubs can influence sporting and extracurricular opportunities by supplying equipment and facilities. District leaders told the committee they want a consistent, district-level understanding of booster spending so they can better assess whether extracurricular opportunities are "substantially similar" across programs, as required by Title IX case law and guidance.
Committee discussion focused on operational detail. Board member Raul Deshmukh asked whether the district should encourage a single umbrella booster organization to provide an easier oversight path; Elizabeth Kelly said there is no one-size-fits-all legal answer and recommended the district consider a committee or district-facilitated forum to coordinate separate booster groups. Board members also asked whether the district must independently audit every booster club; Kelly said the district is not required to audit every penny, but it should have sufficient reporting to understand where private funds are going.
The presentation identified next steps as adopting standardized bylaw expectations, setting a reporting cadence for booster finances, and developing the annual review process with principals and athletic directors. No formal policy change was adopted at the meeting; the item was an update and discussion for the board to consider ahead of any formal action.
Ending: The committee did not vote on an immediate policy change; staff said they would return with detailed drafts of bylaw templates and reporting forms for review in future meetings.
