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Committee removes vendor name from whistleblower policy, debates anonymity and compliance officer placement
Summary
The committee agreed to remove an explicit vendor reference (Lighthouse) from the whistleblower policy and route reports to a district compliance officer; members debated whether that routing preserves whistleblower anonymity and where the compliance officer should sit in the organization.
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Committee members discussed edits to policies on fraud and whistleblower reporting that remove a named third-party vendor and instead place the primary responsibility with a district compliance officer.
"So we are ditching Lighthouse and going..." the chair said while reading the proposed language. The draft adds that the compliance officer may not disclose the identity of a whistleblower without the whistleblower’s consent unless disclosure is unavoidable in the investigation of the alleged violation. Several members expressed concern that removing a neutral first-stop could undermine anonymity; a committee member asked whether routing through the compliance officer means the officer will "always know who the whistleblower would be." Staff and members clarified that reports will flow through the compliance officer and can be referred to a contracted third party for investigation where necessary.
Members also clarified organizational placement: the draft designates the superintendent to appoint the director of communications and operations as the district compliance officer. The committee viewed the change as an administrative cleanup to reflect current titles and noted they are not removing the option to contract investigations externally.
Separately, the committee discussed Title IX complaint flows when contracting with an external vendor and reaffirmed that appropriate procedures would still involve third-party contract investigators when used. The group asked administration to return a redlined draft addressing privacy concerns and the compliance officer’s role in intake and referral to external investigators.
The committee voted to post the revised policy language for public review along with the other policies on the agenda.

