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Wednesday, November 10, 2010

Audit Response re: Policy Enforcement

Finding number five from the State Accountability Audit was:
The School Board and District management have not implemented sufficient policies and controls to ensure the District complies with state laws, its own policies, or addresses concerns identified in prior audits.
So what have they done to address this finding?

According to the "High Level" summary, the response has been:
ACTIONS TAKEN:
• The Audit & Finance Committee is meeting one additional time each month to focus on the Audit response; and 3 to 4 oversight work sessions of the whole board will be added
• An Ethics Officer was appointed and an Ethics Program is being developed
• Board Policies and Superintendent procedures are being assessed
• Organization and reporting changes were made in summer 2009 to improve controls and accountability.
There is more detailed information in the Audit Response Log, but nothing that specifically addresses the finding that the District lacks controls to ensure compliance with District Policies.

Who has the duty of enforcing District Policy? The Board used to claim that it was the superintendent's job to enforce Policy, but that's absurd since she is the person most directed by Policy. The State Auditor wrote: "The Board also is responsible for ensuring District staff carry out programs in compliance with Board policy and state and federal laws and regulations and for making sound financial decisions that are in the best interest of the public.". The Board and the District agreed with this finding, so now everyone acknowledges that it is the Board's responsibility to enforce Policy.

Now comes the question of HOW the Board enforces Policy. If a Board member became aware of a policy violation, how would that Board member go about enforcing compliance? There is absolutely no procedure or process for that. None at all. I do know that the Board member could not, acting individually, direct the superintendent to comply with the policy because no Board member, individually, can speak with the authority of the Board. So how does it happen?

Maybe that's the work of the Ethics Officer.

Let's find out. Let's try reporting Policy violations to Board members and see what happens. Pick a routinely violated policy - there are plenty to choose from - and report it to your Board representative. Make it clear that you are reporting the Policy violation to the Board because it is the Board's duty to enforce Policy. Make it clear that you fully expect the Board member to take action to ensure compliance with District Policy. Go ahead and reference the accountability audit as the place where you got the idea that ensuring compliance is their job.

Let's see which Board members take action and which don't. Let's see what action they take.

2 comments:

Michael H said...

Charlie: "I do know that the Board member could not, acting individually, direct the superintendent to comply with the policy because no Board member, individually, can speak with the authority of the Board. So how does it happen?

Maybe that's the work of the Ethics Officer."

Since the Ethics Officer is appointed by the Superintendent (per policy), how exactly is that officer going to direct the Superintendent to comply with anything?

Melissa Westbrook said...

This was brought up by Director DeBell who said that one Board member would also have to oversee the Ethics Officer. That said the Board doesn't direct the Superintendent or staff on much so I don't know how much good this will do.