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Policy 828 (fraud) reviewed; committee requests clarity on CFO controls and anti-retaliation wording
Summary
Committee reviewed the draft fraud policy required by federal funding. Members asked whether the authority statement should refer to the district or the board as entrusted with public funds, sought clarification on the frequency/scope of board review of CFO internal controls, and recommended anti-retaliation language mirror regulatory 'good faith'
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The policy committee reviewed Policy 828 (fraud), required to comply with federal funding regulations, and requested clarification and minor wording revisions before moving forward.
Trustees questioned an authority sentence that said the "board is entrusted with public funds" and asked whether the wording should refer to the district rather than the board. Members also asked staff to clarify the process and cadence by which the chief financial officer’s internal controls are reviewed and approved by the board; staff said they would consult with district counsel (Mr. Lekman) to provide specific guidance.
Jenna and others recommended revising anti-retaliation language to mirror the regulatory standard, replacing the draft’s term "legitimate concern" with the regulation’s phrase "good faith" to ensure consistency with cited federal rules. Trustees also suggested reordering a clause listing inappropriate destruction, removal or use of district property so the modifier "inappropriate" clearly applies to all listed actions.
Staff will return a revised draft addressing who is "entrusted" with public funds, the board’s role in reviewing internal controls, and anti-retaliation wording consistent with federal regulation.

