The quantity and quality of learning programs are directly dependent on the effective, efficient management of allocated funds. It follows that achievement of the school system's purposes can best be achieved through excellent fiscal management.

As trustee of local, state, and federal funds allocated for use in public education, the Committee will fulfill its responsibility to see that these funds are used wisely for achievement of the purposes to which they are allocated.

Because of resource limitations, there is sometimes a temptation to operate so that fiscal concerns overshadow the educational program. Recognizing this, it is essential that the District take specific action to make sure education remains central and that fiscal matters are ancillary and contribute to the educational program. This concept will be incorporated into Committee operations and into all aspects of school system management and operation. 

In the District’s fiscal management, it is the Committee’s intent:

1. To engage in thorough advance planning, with staff and community involvement, in order to develop budgets and to guide expenditures so as to achieve the greatest educational returns and the greatest contributions to the educational program in relation to dollars
   expended. 
2. To establish levels of funding that will provide high quality education for the students.
3. To use the best available techniques for budget development and management.
4. To provide timely and appropriate information to all staff with fiscal management responsibilities.
5. To establish maximum efficiency procedures for accounting, reporting, business, purchasing and delivery, payroll, payment of vendors and contractors, and all other areas of fiscal management.

Adopted: March 27, 2013

Revised:

The Committee shall prepare an annual operating and maintenance budget using accounts itemized in conformance with the chart of accounts utilized and required by the Massachusetts Department of Elementary and Secondary Education or its successor.

The Regional School District's budgetary process, and the timing of and method of appropriation of funds in regard thereto, shall be governed by the provisions of G. L. c. 71 §16(m) and c. 71 §16B and other applicable provisions of G. L. c. 71 and any special laws or regulations relating thereto. 

Legal references:

M.G.L. 71:16(m); 71:16B

Regional Agreement Section VII, Paragraph A and B

Adopted: March 27, 2013

Revised:

The Committee shall prepare a budget on a fiscal year basis for the District in the following manner:

1. The District budget process shall be initiated annually on or about October 1 and shall provide opportunity for the Selectmen and Finance Committee of each member town to have input into its preparation. On or about January 15th, the Committee shall complete its proposed budget for the ensuing year. Said proposed budget shall be approved by majority vote, with at least one Committee member from each member town voting in the affirmative. Said proposed budget shall be posted in the Town Hall of each member town, shall be provided to each member town's public library, and shall be submitted to the Selectmen and Finance Committee members of each member town.
2. Said proposed budget shall contain a notice stating when and where a public hearing will be held. The public hearing shall be held in any District school building. The notice of the public hearing shall be posted in all member towns and published consistent with G.L. chapter 71, section 38N in a newspaper having general circulation in the region. Upon request of the Finance Committee and/or the Board of Selectmen of any member town, the Committee shall arrange to meet with such Finance Committee and/or Board of Selectmen for the purpose of discussing the proposed budget. Said proposed budget shall be in reasonable detail, itemized at least as follows: central administration, expenses of instruction, transportation, operation of school plant, maintenance of school plant, capital outlay, and debt and interest charges. All non-recurring expenditures shall be itemized. Enrollment, staffing, total expenditures and assessments for the past five (5) years shall be included. The Finance Committee or the Board of Selectmen of a member town may request further information.
3. Consistent with G.L. chapter 71, section 16B the Committee shall adopt by a two-thirds (2/3) vote of all its members a budget with such changes as may have resulted from conferences and/or the public hearing. Within thirty (30) days from the date on which the budget is adopted, the treasurer of the District shall certify to the treasurer of each member town that town's assessed share of such budget.
4. The budget and assessments shall be so constructed as to show debt service, transportation, operating, and capital costs. It shall also list all sources of revenue used to reduce operating costs as described in Section IX. 
5. The process and the requirements for the approval or disapproval of the budget by the member towns will be consistent with the terms and conditions of chapter 71, section 16B, as well as 603 CMR section 41, et seq, as those terms and conditions may be amended. 

Legal references:

M.G.L. 71:16B

Regional Agreement Section VII, paragraph C

Adopted: March 27, 2013

Revised:

The budget for the operation of the District's schools, including payments of principal and interest on bonds and other evidence of indebtedness issued by the District, shall be apportioned to the member towns via the method set out in Section IX or the Regional Agreement and subject to the following definitions:

1. Budget
   As defined by this document, the budget is the amount of money voted by the Committee to finance the District schools and which will be assessed to the member towns.
2. The budget shall be comprised of various costs, each as herein defined as follows:
   1. "Operating costs" include all costs not included in capital costs, transportation costs, or debt service, as defined below, but operating costs include interest and principal on revenue anticipation notes. Operating costs include the net costs of evening, graduate and extension courses or any other types of courses, including vocational education programs, which are offered by the District to persons other than pupils attending a regular district school program in any of the grades K-12, inclusive.
   2. "Capital costs" will include all capital outlay appearing in the 7000 DESE function codes.
   3. "Transportation costs" include all costs associated with transporting the District's students to and from school.
   4. "Debt service" includes all costs that are used for payment of principal and interest on bonds or other obligations issued by the District except revenue anticipation notes.

Adopted: March 27, 2013

Revised:

File DBJ

Monomoy Regional School District

Regional School District Budget Transfer Authority

 

In keeping with the need for periodic reconciliation of the school department's budget, the Committee will consider requests for transfers of funds as they are recommended by the Superintendent.

 

The Committee wishes to be kept abreast of the need for these adjustments so that it may act promptly and expedite financial record-keeping for the school system.

 

All requests for transfers between the major accounts (as defined in the Department of Elementary and Secondary Education Chart of Accounts) must be submitted to the School Committee for approval. Transfers between line items within a major account must be reported to the School Committee as part of the Director of Business and Finance's quarterly report at the business meetings of the School Committee or the School Committee's finance subcommittee.

 

All funds in the general account not expended by the close of the fiscal year will be placed in an excess and deficiency fund not to exceed five percent of the operating budget. Any added funds shall be returned to the member municipalities as outlined in M.G.L. Chapter 71, Section 16B1/2.

Legal references:

MGL 71:16B1/2

 

Adopted: March 27, 2013

Revised: 8/11/2021

 

The School Committee will encourage the administration to seek and secure all possible sources of state, federal, and other special funds that will enhance the educational opportunities for the children in our schools.

The Superintendent will keep informed of all possible funds available to the school system under the various state and federal programs, and in what manner these funds can best be used in the school system.

The Superintendent will be responsible for seeking out and coordinating the development of proposals for all specially funded projects and for submitting the proposals to the Committee for approval. 

The Superintendent or designee is authorized to sign all reports for these projects and will be responsible for the proper expenditure of funds received for such projects.

Legal references:

M.G.L. 44:53A

P.L. 874 Impact Aid

Dept. of Elementary and Secondary Education 603 CMR 32:00; 34:00

Adopted by the MRSC March 27, 2013

Purpose

To ensure Monomoy Regional School District efficiently and appropriately manages its grant-funded programs, this policy sets a framework for evaluating grant opportunities, tracking grant activity, and processing grant revenues and expenditures. Effective grant management helps promote the pursuit of grants that are in the District’s best interest and assure timely reimbursements to optimize cash flow, and to guard against year-end account deficits. As a legal contract, every grant agreement must be fulfilled in accordance with its prescribed terms and conditions, as well as all applicable federal, state, and local regulations. Failure in this regard exposes the District to legal and financial liabilities and compromises future grant funding.

Applicability

This district-wide policy applies to the grant applicant in each department applying for or receiving grant funding. It further applies to the grant-related responsibilities of the School Committee, Superintendent, District Administrators, District Accountant, Treasurer, and Administrative Assistants to the Superintendent other District and School Administrators.

Policy

All departments are encouraged to solicit grant funding for projects and programs consistent with the District’s goals. All district grant applications must receive pre-approval by the Superintendent. To be eligible for preapproval, there must be sufficient staff available to effectively administer the grant program and perform its required work scope, along with adequate matching requirements (both cash and in-kind).

No department shall expend grant funds until a fully executed grant agreement has been accepted and approved for expenditure by the Superintendent. Further, no grant funds shall be used to supplant an existing expense for the purpose of diverting current funds to another use.

Operating departments have primary responsibility for seeking grant opportunities, preparing applications, and managing awarded programs. The District Accountant is responsible for consulting with applicant on grant budgetary matters, accounting for grants in the general ledger, monitoring grant expenditures for consistency with award requirements, tracking the timeliness of reimbursement requests, and distributing monthly reports of grant expenditures to departments. The District Accountant will also maintain a database utilizing the financial software for all grants and grant activity from inception to closure.

Grant Opportunity Assessment

Well in advance of a grant application’s due date, the departmental applicant will assess the opportunity in consultation with the appropriate District Administrator and District Accountant. Below are the factors to be considered, at minimum.

Programmatic:

• Alignment of the grant’s purpose with the District's and department’s strategic priorities
• Department's capacity to administer the grant through to closeout
• Office space, facilities, supplies, or equipment required
• Ongoing impact of the grant program after it is completed
• Compliance and audit requirements, particularly as they may differ from the District’s

Financial:

• Total anticipated project cost
• Expenditure requirements and anticipated cash flow schedule
• Required cost matching shares and sources, including cash and in-kind
• Staffing requirements, including salary and benefit increases for multi year grants
• Administration and indirect recapture amounts
• Program income potential
• Continuation plan to address the potential future loss of grant funding, which may include alternative funding proposals or plans for reducing or terminating program positions or components after grant closeout.

Grant Application and Award Acceptance

Prior to filing any grant application the applicant will submit a meeting agenda item requesting

pre-approval from the Superintendent with a report summarizing the grant and how it complies with this policy. The applicant will submit the grant application, signed by the Superintendent or he/her designee to the grantor and forward a copy to the District Accountant. When an applicant receives notice of any grant award, he or she will submit the approval notification for the Superintendent to formally accept and thereby approve the expending of grant funds. The applicant will then send copies of the signed agreement to the grantor and the District Accountant.

Upon receipt of the grant documents, to record the grant activity separately from regular expenses, the District Accountant will create new general ledger accounts identifying them by name and including the CFDA (catalogue of federal domestic assistance) number for any federal grants and will request from the Business Manager the addition of the new general ledger accounts.

When notified of any amendment or adjustment by the grantor, the applicant will immediately forward the information to the District Accountant, who will make adjustment(s) to the grant’s budget in the general ledger.

Grant Financial Management

At the start of a new grant, the District Accountant and applicant will discuss its requirements and the timing of reimbursement requests (e.g., at the time of expenditure, monthly or quarterly), when applicable.

The applicant will ensure all expenditures made are allowable and consistent with each grant award’s requirements. Purchase Orders will be generated with accurate general ledger expense codes for the grant. Invoices will be signed and submitted to the Business Office for payment processing. The applicant will also ensure the proper payroll account codes for grant-funded employees are included on the department’s payroll report to the Business Office and Treasurer as part the regular payroll process. All employees funded by grants that require a Time and Effort Sheet shall complete and submit to the District Accountant as specified by grant.

Because required retirement system remittances and/or general fund benefit reimbursements vary by grant, the District Accountant will calculate these for each grant and notify applicant of the resulting amounts to include on the AP submissions.

To minimize the use of advance district funds, every applicant will provide to the District Account the need for reimbursements requests as often as the grant’s guidelines allow and always no later than June 30th. The District Accountant will prepare all required reports and requests as detailed in the agreement and submit these to the grantor.

The District Accountant will monitor each grant’s deficit balance to assure it is temporary and receives reimbursement within the grant’s allowable timeline and always prior to year-end. The Treasurer will match reimbursements received electronically or by check with their requests and credit the proper revenue lines.

Grant Closeout

Upon completion of the project work or grant period, whichever comes first, the applicant will verify that all grant requirements have been met and will communicate to the District Accountant. The District Accountant initiates a grant closeout process that includes a final report and either a final reimbursement request or notification of the amount to be refunded to the grantor. 

Upon closeout, the District Accountant will put the general ledger’s grant account into inactive status and will reconcile the applicant’s report with the general ledger’s record of grant activity. The applicant will subsequently submit the final reimbursement request to the grantor or, if a refund is due, the District Accountant will add the refund amount to the AP warrant.

Within 30 days of any grant closeout or the year-end closure, whichever is earlier, the District Accountant will determine if the grant account has been over expended and will either apply the expense to the operating budget or propose an appropriation from other available funds.

Audit

All grant activities are subject to audit by the particular grantors, the District Accountant, and Monomoy Regional School District’s independent auditor. The District Accountant will maintain all grant documents and financial records for seven years after their closeouts or for the lengths of time specified by the grantors, whichever period is longer.

  

Adopted: June 27, 2018

Revised:

File: DFA

Monomoy Regional School District

INVESTMENT POLICY

The Monomoy Regional School District intends to set forth investment objectives, establish guidelines and define responsibilities for the investment of the District’s funds. The District funds are to be invested in a manner which will meet the daily, weekly and monthly cash flow demands of the District, conform to the state statutes governing the investment of public funds also to provide maximum security of said funds taking into account the three principles of municipal investment policy: safety, liquidity and yield.

Objective

Massachusetts General Laws (MGL) establishes the framework under which the District Treasurer is required to maintain funds in his/her custody. The primary statutes are as follows:

•  MGL Chapter 44, Section 55       Public funds on deposit; limitations; investments

•  MGL Chapter 44, Section 55A    Liability of depositor for losses due to bankruptcy

•  MGL Chapter 44, Section 55B     Investment of public funds

•  MGL Chapter 44, Section 54           Investment of trust funds

MGL Chapter 44, Section 55B requires the District Treasurer "to invest all funds except those required to be kept uninvested for purposes of immediate distribution." MGL further requires that "invested funds be placed so as to achieve the highest rate of interest reasonably, accounting for safety, liquidity and yield."

The objective of this Investment Policy is to set general guidelines for the investment of the Districts available Operating, Reserves and Trust funds. The guidelines for each type of fund are as follows:

1. Operating Funds: First and foremost, preserve capital of the overall portfolio through diversification and prudent selection of investment instruments, while maintaining sufficient liquidity to meet all operating and debt service requirements.

2. Reserve Funds: Preserve capital and maintain liquidity while attaining slightly better rate of return than that of the operating funds as a result of more flexible investment opportunities provided by state law. 

3. Trust Funds: Emphasis on safety, trust funds have a longer horizon thus providing more flexible investments as provided by state law.                          

Responsibilities

1. The Monomoy School Committee has the responsibility to set guidelines and criteria for investments of District Funds.

2. Primary responsibility for the administration of this policy resides with the District Treasurer, as custodian of District funds in accordance with Massachusetts General Law.

3. The Treasurer makes all the decisions regarding the management of the investment program and if the Treasurer wishes to deviate from the terms of this policy the Treasurer shall obtain written approval or through a presentation in front of the School Committee to obtain that approval.

4. The District Treasurer is required to establish, maintain and document internal control policies and procedures surrounding the handling and maintaining of all funds in conjunction with all statutes, this policy and reasonable business practices.  These internal controls will be designed to safeguard these funds as well as to provide appropriate accountability of these funds for both internal and external financial reporting purposes. 

5. The Treasurer shall be bonded as required by law.

6. The Treasurer shall be responsible for monitoring changes to the General Law governing the type and method of investing District funds referred to in this investment policy.

Authority

District funds may be maintained only in the following:

1. Operating Funds:

1. Certificates of Deposit with a maximum maturity of one year or less issued by commercial banks, mutual savings banks, savings and loans and cooperative banks. 

2. Money Market Deposit Accounts with commercial banks, mutual savings banks, savings and loans and cooperative banks.

3. Repurchase Agreements with a maturity of less than 90 days, issued by a bank and secured by U.S. Government or Agency obligations.

4. Pooled Investments Funds operated under the authority of the State Treasurer

5. U.S. Treasury instruments or U.S. Government Agency obligations with a maximum maturity of one year. If Treasurer wants to go longer he/she would have to seek permission as outlined in the Responsibilities section

B. Stabilization Funds: Same criteria as the Operating Funds but emphasis on yield which would point the              Treasurer to higher yielding CD’s

C. Trust Funds: Same criteria as the Operating Funds and Stabilization Funds but state law allows for                      more  flexibility of these funds.

If the District Treasurer determines that there is a need to deviate from the accepted financial instruments outlined in this policy he/she shall consult with the Superintendent and Business Manager and together present to the proposal for School Committee approval.

Reporting

The district treasurer will inform the Finance Sub-Committee of any changes to the district’s investments.   

The business manager will provide quarterly reports to the school committee on the performance of the district’s investments.

 Legal references:

Chapter 44, Section 55 -Deposition of Public Funds

Chapter 44, Section 55A -Liability

Chapter 44, Section 53F -Compensatory Balances

Chapter 44, Section 55B -Requirement to Invest

Adopted: 1/26/2023

Revised:

The treasurer and the assistant treasurer are authorized to sign check withdrawals and to sign the appropriate bank forms for the District.

Legal references:

M.G.L. 71:16A

Adopted by the MRSC March 27, 2013

Each employee of the school system or school committee member who is assigned the responsibility of receiving and dispensing school funds will be bonded individually or covered by a blanket bond. The cost of the bond will be paid by the District.

Legal references:

M.G.L. 40:5 71:16A

Adopted: March 27, 2013

Revised:

1. Operating Costs. Operating costs needed to support the district's budget will be reduced by all general fund revenues and state aid. Member town assessments will then be prepared as follows:
   1. Each member town will contribute to the District no less than its minimum required local contribution as determined by the Commissioner pursuant to G.L. chapter 70.
   2. Any excess costs needed to support the district's budget will be assessed to the member towns on the basis of the town's foundation enrollment.
   3. Excess costs will be assessed to each member town on the basis of the combined three-year rolling average of foundation enrollment for each member town. That is, the foundation enrollment figures as published by the DESE for each member town for the past three years will be averaged, as will the total of the foundation enrollments of all of the member towns for the past three years. Each member town will be assessed the same percentage of the excess costs as that member's foundation enrollment for the past three years relates to the foundation enrollment
      for the entire District during those three years.
2. Capital Costs. Except as expressed in subsection E below (which pertains to the assessment of capital costs and debt service on facilities that are in existence at the time of creation of the District until such time that there is one regional high school and one regional middle school), capital costs shall be assessed to the member towns on the basis of the three year rolling average of each town's foundation enrollment as described in Section DC, A, 4 above. 
3. Transportation Costs. Transportation costs will be assessed to the member towns based upon the number of students residing in each town who attend the District's schools based on the average of the most recent three years' October 1 enrollment figures as reported to DESE. 
4. Debt Service. Except as expressed in subsection E below (which pertains to the assessment of capital costs and debt service on facilities that are in existence at the time of creation of the District until such time there is one regional high school and one regional middle school), debt service costs will be assessed to the member towns as follows: 
   1. Debt service costs attributable to the high school and the middle school will be assessed to the member towns using the three year rolling average of each town's foundation enrollment as described in Section IX,A,4 above.
   2. Debt service costs attributable to the District's elementary schools will be assessed to the member towns based upon the mechanism described in paragraph E below which utilizes the most recent three years' October 1 enrollment figures.
5. Notwithstanding the terms and conditions of subsections B and D above, until such time as there is one regional high school and one regional middle school, expenditures on capital items and debt service which are attributed to facilities that are in existence at the time of the creation of the District and which are under the care and custody of the District, regardless of whether they are owned by the District or leased to the District, will be assessed to the member towns using the following approach. The number of students who reside in each of the member towns who attend the facility in question based upon the average of the most recent three years' October 1 enrollment figures as reported to DESE will be identified. Each member town will then be assessed a percentage of the capital and debt service expenditures attributable to that facility. This percentage will be the same percentage as the number of students from that town who are enrolled in the facility in question, using the three year average referenced in this paragraph, bears to the two towns' combined enrollment in that facility. If the construction of a new high school is undertaken after the creation of the District, the capital costs and debt service attributed to said construction, and the planning for same, will be assessed under subsections B and D above, despite the fact that the completion of the new high school will occur prior to there being one regional middle school. If a renovation of and/or addition to the building which is known at the time of creation of the District as the Chatham Middle School/High School is undertaken for purposes of converting said building to a District middle school, the capital costs and debt service
   attributed to said renovation/addition, and the planning for same, will be assessed under subsections B and D above. However, the capital costs and debt service attributable to this building continuing to be used as a middle school for the Chatham students while the Harwich Middle School is still in operation will be assessed consistent with this paragraph E.
6. The payment of the assessed share of costs by each member town, as computed by the Committee according to the methods specified in Section DC, shall be made by each member town's Treasurer by check or electronic transfer payable to the District in five equal installments by the first business day of each August, November, February, May, and June.

Legal references:

Dept. of Elementary and Secondary Education 603 CMR 10:00

Adopted: March 27, 2013

Revised:

An audit of the school department's accounts shall be conducted annually.

Upon the completion of each audit, a report there on shall be made to the Chairperson of the School Committee, and a copy sent to the Chairperson of the Selectmen.

The Committee will consider recommendations made by the auditor for maintaining an efficient system for recording and safeguarding the District’s assets.

Legal references:

M.G.L. 71:16E

 

Adopted: March 27, 2013

Revised:

 

The Monomoy Regional School District is committed to protecting its revenue, property, information, and other assets from any attempt, either by members of the public, contractors, vendors, agents or its own employees, to gain by deceit, financial or other benefits at the expense of the taxpayers.

District Officials and employees must, at all times, comply with all applicable laws and regulations. The District will not condone the activities of officials or employees who achieve results through violation of the law or unethical business dealings. The District does not permit any activity that fails to stand the closest possible public scrutiny.

This policy sets out specific guidelines and responsibilities regarding appropriate actions that must be followed for the investigation of fraud and other similar irregularities.

Definitions

Occupational fraud is defined by the Association of Certified Fraud Examiners as the use of one’s occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization’s resources or assets. There are three major categories of occupational fraud.

• Asset Misappropriations – Theft or misuse of an organization’s assets.
• Cash
  • Fraudulent Disbursements – Perpetrator causes organization to disburse funds through some trick or device (e.g. submitting false invoices/time card/sheets, expense reimbursement schemes, check tampering, etc.)
  • Skimming – Cash is stolen from an organization before it is recorded on the organization’s books and records.
  • Cash Larceny – Cash is stolen from an organization after it has been recorded on the organization’s books and records.
• Inventory and all other assets
  • Misuse – Misuse of an organization’s inventory or assets for personal use (e.g. District vehicles, computers, supplies, etc.)
  • Larceny – Inventory or other assets are stolen from an organization.     
• Corruption – Wrongfully use influence in a business transaction in order to procure some benefit for themselves or another person, contrary to duty to employer or the rights of another.
  • Conflicts of Interest – An undisclosed economic or personal interest in a transaction that adversely affects the employer. 
  • Bribery – The offering, giving, receiving, or soliciting of anything of value to influence an official act or business decision.
  • Illegal Gratuities – A party who benefits from an official act or a business decision gives a gift to a person who made the decision.  An illegal gratuity does not require proof of an intent to influence.
  • Economic Extortion – An employee demands that a vendor/contractor/etc. pay to influence an official act or a business decision.                                                                                                                                             
• Fraudulent Statements – Falsification of an organization’s financial statements.

Other similar irregularities is defined as any activity involving questionable behavior or business dealings by members of the public, contractors, vendors, agents or government employees, that put government revenue, property, information and other assets at risk of waste or abuse.

Applicability

This policy applies to School Committee members and employees of the Monomoy Regional School District as well as any business or individual doing business with the district.

General Policy and Responsibility

1. All employees have a duty to report concerns they have or information provided to them about the possible fraudulent or corrupt activity of any employee, vendor or any other party with any association with the Monomoy Regional School District. Any person who has a reasonable basis for believing fraudulent or corrupt acts have occurred has a responsibility to report the suspected act immediately and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act. Concerns should be reported to any of the following:
1. Superintendent of Schools;
2. Director of Student Services;
3. Business Manager;
4. Facilities Director;
5. District Treasurer;
6. Any Principal in the District; or
7. Any School Committee member.
2. New employees are trained at the time of hiring about the District’s Code of Conduct and Fraud Policy. This training explicitly    covers expectations of all employees regarding:
   1. Their duty to communicate certain matters;
   2. A list of the types of matters, including actual or suspected fraud, to be communicated along with specific examples; and
   3. Information on how to communicate those matters. 
3. Retaliation and retribution will not be tolerated against any employee or member of the public who reports suspected fraudulent or corrupt activities. However, if an employee is determined to have acted maliciously or with deceit, the employee will be subject to disciplinary action, up to and including termination.
4. It is the district’s intent to fully investigate any suspected acts of fraud or other similar irregularity.  An objective and impartial investigation will be conducted regardless of the position, title, length of service, or relationship with the district of any party who might be or becomes involved in or becomes/is the subject of such investigation.
5. The School Committee and District Leadership Team are responsible for instituting and maintaining a system of internal control to provide reasonable assurance for the prevention and detection of fraud, misappropriations, and other irregularities.  The District Leadership Team should be familiar with the types of improprieties that might occur within their area of responsibility and be alert for any indications of such conduct.
6. If the complaint involves the Superintendent of Schools, the Chair of the School Committee shall establish an Ad-Hoc Subcommittee to review the complaint and recommend possible action by the School Committee.
7. If the complaint does not involve the Superintendent, the Superintendent has the primary responsibility for the investigation of all activity defined in this policy.
8. The Superintendent will notify the School Committee of a reported allegation of fraudulent or irregular conduct upon the commencement of the investigation to the extent practical. Throughout the investigation the School Committee will be informed of pertinent investigative findings.
9. In all circumstance where there are reasonable grounds to indicate that a fraud may have occurred, the Superintendent, subject to the advice of District Counsel, will contact the office of the District Attorney and/or the Police.
10. Upon conclusion of the investigation, the results will be reported to the members of the School Committee, and others as determined necessary.
11. The Superintendent will pursue every reasonable effort, including court ordered restitution, to obtain recovery of the District’s losses from the offender, or other appropriate source.
12. All vendors, contractors and suppliers must be active, in good standing and authorized to transact business in the Commonwealth of Massachusetts. Vendors, contractors and suppliers, who will be visiting District schools may be subject to background investigations including a criminal background check (CORI) and to screening, including verification of the individual's or company's status as a debarred party.

Investigation Procedures

1. All Employees

Any employee who has reason to suspect that a fraud has occurred, shall immediately notify his/her supervisor. If the employee has reason to believe that their supervisor may be involved or does not feel comfortable reporting the occurrence to their supervisor, the employee shall immediately notify one of the members of staff listed in General Policy and Responsibility, paragraph 1.

Employees have a duty to cooperate during an investigation.

Employees who knowingly make false allegations will be subject to discipline and possible termination of employment.

2. District Leadership/Elected Officials

Upon notification from an employee of suspected fraud, or if a member of the District Leadership Team has reason to suspect that a fraud has occurred, they shall immediately notify the Superintendent or the Chair of the School Committee. 

3. Superintendent

Upon notification or discovery of a suspected fraud, the Superintendent will promptly investigate the suspected fraud. In all circumstances, where there are reasonable grounds to indicate that a fraud may have occurred, the Superintendent will inform the School Committee. Subject to the advice of the District Counsel, the Superintendent will contact the Office of the District Attorney and/or the Police.

4. Contacts/Protocols

After an initial review and a determination that the suspected fraud warrants additional investigation, the Superintendent will notify the School Committee.  The Superintendent will coordinate the investigation with the School Committee and appropriate law enforcement officials.

5. Security of Evidence

Once a suspected fraud is reported, the Superintendent, in consultation with the District Counsel, shall take immediate action to prevent the theft, alteration, or destruction of relevant records. Such actions include, but are not necessarily limited to, removing the records and placing them in a secure location, limiting access to the location where the records currently exist, and preventing the individual suspected of committing the fraud from having access to the records. The records must be adequately secured until the Superintendent obtains the records to begin the audit investigation.

6. Personnel Actions

If a suspicion of fraud is substantiated by the investigation, disciplinary action shall be taken by the district.

7. Whistle-Blower Protection

Under Massachusetts General Law Chapter 149, paragraphs 148A, 185 and 187, no employer or person acting on behalf of an employer shall:

• Dismiss or threaten to dismiss an employee,
• Discipline or suspend, or threaten to discipline or suspend, an employee,
• Impose any penalty upon an employee; or
• Intimidate or coerce an employee

because the employee has acted in accordance with the requirements of this policy.  The violation of this section will result in discipline up to an including dismissal in accordance with the applicable federal, state, and local administrative laws.

8. Media Issues

Any District employee or elected official contacted by the media with respected to an audit investigation shall refer the media to the Superintendent. The alleged fraud or audit investigation shall not be discussed with the media by any person other than the through the Superintendent.

If the Superintendent is contacted by the media regarding an alleged fraud or audit investigation, they will consult the School Committee, before responding to a media request.

Neither the Superintendent nor the School Committee will discuss the details of any ongoing fraud investigation with the media that may compromise the integrity of the investigation.

9. Documentation

At the conclusion of the investigation, the results will be reported to the members of the School Committee, and others as determined necessary. If the report concludes that the allegations are founded, the report will be forwarded to the Office of the District Attorney and/or the Police.

10. Completion of the Investigation

Upon completion of the investigation, including all legal and personnel action, any records, documents and other evidentiary material will be returned by the Superintendent to the appropriate department.

Legal References:

Adopted: 7/14/2021

Revised:

The School Committee declares its intention to purchase competitively without prejudice and to seek maximum educational value for every dollar expended.

The acquisition of materials, equipment and services will be centralized in the Superintendent’s office of the District.

The Superintendent or designee will serve as purchasing agent. He/she will develop and administer the purchasing program for the schools in keeping with legal requirements and with the adopted school budget.

School purchases will be made only on official purchase orders approved for issuance by the appropriate unit head and signed by the Superintendent or Business Manager, with such exceptions as may be made by the Superintendent for emergency purchases.

Purchase orders for amounts less than $500.00 need the approval of the business manager. Purchase orders in excess of $500.00 need the approval of the business manager and the Superintendent. 

All purchases of materials and equipment as well as all contracts for construction or maintenance will comply with the requirements set forth in M.G.L. Chapter 30B.

Legal references:

M.G.L. 7:22A; 7:22B; 30B; 71:49A

Adopted: March 27, 2013

Revised:

The School Committee declares its intention to purchase Energy Star© equipment and appliances in the new Monomoy Regional High School to ensure they are energy efficient and to reduce energy loads in the new building.

Adopted: March 27, 2013

Revised: