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Public Meeting Announcement: Development Workshop for School Board Policies: 10/8/2025

RULE TITLE: Inspector General

RULE NUMBER: Policy 1.092

SUBJECT AREA TO BE ADDRESSED: The proposed revised policy updates section 1.092.1 to expressly provide the OIG is independent from District administration, section 1.092.2 - adds new definitions for “Conflict subject”, “Conflict-free investigator”, “Entities contracting with the Board”, “External entity”, “Independence/Independent”, “Individuals substantially affected”, “Misconduct”, “Non-misconduct complaint”, “OIG activities”, “Sufficient conflict complaint”, “Suspected”; re-organized definition for “Fiscal misconduct”; removed definition for “wrongdoing”, section 1.092.3 – adds language to cover all established areas of OIG work covered by existing standards; states statutory authority supporting OIG independence as non-administration; establishes policy prohibiting OIG employees’ documented ethical violations; clarifies “campaign activities” for prohibition on OIG engagement in School Board member or candidates for School Board  campaigns; section 1.092.4 – removes term “other good cause” to add clarity and better harmonize removal section with Florida statutes governing agency inspectors general; section 1.092.5 – reiterates OIG independence from District administration; corrects citation to Whistle-blower’s Act statute ; re-organizes internal referral section and clarified Inspector General’s discretion to refer employee misconduct allegations; includes provision for Inspector General to schedule Board workshops to review investigations to harmonize with proposed revisions to Board Policy 1.091 and audit committee’s oversight of investigations; adds charter school foundations to OIG auditing duties; expands indicators to include misconduct and fiscal misconduct; includes auditing of policies to include security measures;  aligns audit responsibilities with new definitions; clarifies and expands contract review duties to include third-party contracts with charter schools and interlocal agreements; removes “wrongdoing” from CARES preamble and adds existing language from investigative duties section;  clarifies CARES distribution list recipients; removes disciplinary action for not reporting to CARES; references OIG duty via Board policy to follow up on implementation of recommendations; clarifies that only suspected criminal activity must be reported to law enforcement; applies misconduct to abuse of authority provision; adds inspections and reviews to activities requiring accessibility and cooperation with OIG; adds volunteers to list of individuals OIG can interview; clarifies both District employees and vendors must provide the OIG access to information; adds investigations, inspections, and reviews to corrective action monitoring duty; moves ten working days response deadline from due process section; adds administrative subpoena power; adds CARES reference to hotline policy; section 1.092.6 – harmonizes section with Florida statues regarding adverse personnel based on following Policy 1.092; removes language duplicative of code of ethics; section 1.092.7 – reformats entire section regarding complaints against conflict subjects; applies new definitions and process to maximize OIG independence for complaints against Superintendent, Inspector General, OIG employees; General Counsel; and School Board members; creates a conflict complaint form; process for receiving and evaluating conflict complaints, including the appointment of a point of contact for instance in which the Inspector General or OIG employees are named as conflict subjects; clarifies and relabels specific complaints to be referred to external entities; section 1.092.8 – incorporates CARES into the efficient coordination of OIG referrals; section 1.092.9 – Includes CFA standards in conducting OIG affairs; clarifies requirements for review of draft audits and reports; harmonizes OIG reporting requirements with auditing, review, and investigation standards and Florida statute; includes individuals substantially affected and entities contracting with the Board in the draft report response process; in compliance with Florida statue excludes individuals with independent review processes the from the draft report response process; exempts individuals substantially affected and entity contracting with the Board from draft review and response process if criminal investigation will be jeopardized;  mandates summaries of investigative reports with substantiated or unsubstantiated allegation will be posted on the OIG website; unfounded allegations will not be posted; section 1.092.12 – updates to confidentiality requirements to conform to Florida statutes.

All revisions reflect updated abbreviation of “OIG” and syntax throughout the entirety of Board Policy 1.092.

CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)

 

RULE TITLE: Whistle-Blower Protection Policy

RULE NUMBER: Policy 3.28

SUBJECT AREA TO BE ADDRESSED: The proposed revised policy updates section 3.28.1 – expands purpose and intent to match §§112.3187-.3188, Fla. Stat., clarifies that unfounded reports are not protected, recognizes the appropriate local official as the only person to receive protected disclosures; section 3.28.2 – orders definitions alphabetically, adds new definitions for “final report”, “appropriate local official” and “sufficient complaint”, section 3.28.3 – specifies protected disclosure subsection, identifies appropriate local official as the only person to receive protected disclosures, harmonizes disclosures against IG or OIG employees with process against “conflict subjects” outlined in Board Policy 1.092.7, outlines prohibited retaliatory actions, removes duplicative and confusing language regarding complaints to the Board or Superintendent now clarified early in policy statement;  section 3.28.4. – affirms statutorily required hotline and adds the centralized complaint and referral evaluation system (CARES) as a place where protected disclosure can be made; section 3.28.5 – removes inapplicable timelines required only of state agencies, specifies what is required in final reports, removes language regarding disciplinary recommendations and section regarding anonymous complaints; section 3.28.6 – further clarifies IG’s obligation to report superintendent’s decision, harmonizes role of “conflict investigator” in final reports regarding of disclosures against “conflict subjects” as defined in Board Policy 1.092.2.c. -.2.d; section 3.28.7 – identifies employees and other persons protected against adverse personnel action or retaliation after protected disclosure, removes legally inapplicable investigatory process and timelines required only of state agencies; section 3.28.9 – provides School District’s exclusive remedy for prohibited adverse personnel action as required under §112.3187(8)(b), Fla. Stat., removes inapplicable and redundant reporting language now that exclusive remedy has been identified; section 3.28.10 – clarifies the requirements of “good faith” for protected disclosures and provides notice of potential disciplinary action for employees’ false reports, removes volunteers and students from the false reports disciplinary notice; section 3.28.11 – adds Whistle-blower’s Act to bases for confidentiality.

Revisions further reflect updated syntax throughout all sections of the policy.    

CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)

PUBLIC MEETING NOTICE:  Development Workshop of the proposed rule is anticipated to be held on October 8, 2025. The Workshop will follow other Board meetings that are scheduled to begin at 2 p.m. in the Boardroom at 3300 Forest Hill Boulevard, West Palm Beach, Florida.  AGENDA:  An agenda will be available by October 2, 2025 on the District’s web site at:

https://go.boarddocs.com/fl/palmbeach/Board.nsf/goto?open&id=DLSHCX47E934

https://go.boarddocs.com/fl/palmbeach/Board.nsf/goto?open&id=DLSHEZ4836DC

Pursuant to the provisions of the American with Disabilities Act, any person requiring special accommodations to participate in this hearing is asked to advise the agency at least 48 hours in advance by contacting Toni Sinclair, Board Clerk at 561-434-8136.  A person may submit written comments (12 copies) about the proposed action to the Clerk no later than the time of the public hearing.  This hearing is open to the public and public comment is accepted on this matter.  Please contact the Clerk at the number provided prior to noon the day of the meeting, or by submitting a blue card to the Clerk at the meeting prior to start of meeting.