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Cannon County Schools to Review Federal Recording Requirement for Large Capital Projects
Summary
District staff told the Cannon County Board of Education that a new U.S. Department of Education reporting and "recording" requirement could require recording some school capital projects at the register of deeds if individual projects exceed $1,000,000; staff will verify figures and report back in January.
Cannon County Board of Education members heard detailed guidance Dec. 12 about a new U.S. Department of Education reporting and recording requirement that may require the district to record certain large capital projects at the county register of deeds.
District staff said the requirement was rolled out first at a Federal Programs Institute in September and later communicated to districts by the state education department in October. The rule, as described to the board, affects capital projects — including recent HVAC work — and triggers an additional recording step when an individual project at a campus totals $1,000,000 or more.
"So the reporting, there were 2 HVAC projects. This applies specifically to, capital projects and, guidance we've been given includes HVAC as a capital project to those buildings," said Miss Stephanie (board member), who presented the item and summarized the guidance for the board. Staff said the district must report for at least the next 15 years and separate out how much money was spent on certain projects at Cannon County High School, Cannon County Elementary and Cannon County Middle School.
Staff explained the recording step is intended to protect the federal government's financial interest: if a property on which federal funds were spent leaves district ownership within the 15-year period, the federal government could seek to recoup part of those funds. The district was told the U.S. Department of Education and the state department do not provide a recording template; some other districts have shared templates through state consultants.
Miss Stephanie said she was still verifying figures with the district finance staff and expected an update in January. She said staff were attempting to exclude costs the district does not regard as property improvements, for example a cooling-tower rental, when calculating whether a project meets the $1,000,000 recording threshold.
Board members did not take a formal vote during the workshop. The board directed staff to verify the cost allocations, determine whether any individual project reaches the $1,000,000 threshold, and return with an update at the January meeting.
The discussion makes clear the district will need to track federal spending on capital projects more granularly going forward and could face additional administrative steps — recording documents at the register of deeds — for large projects that receive federal aid.
