Public Meeting Announcement: Development Workshop for School Board Policies: 11/5/2025
RULE TITLE: Inspector General
RULE NUMBER: Policy 1.092
SUBJECT AREA TO BE ADDRESSED: Revisions* to Board Policy 1.092 – Inspector General include the following changes by section:
Section 1.092.1 – expressly states the OIG is independent from District administration, section; Section 1.092.2 – updates and 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”; 1.092.2.f – clarified definition of “external entity” to better harmonize with Board Policies 1.092.5.f.vii (formally 1.092.9.b. – Reporting of Work Activities) and 1.092.5.f.viii (subpoena power); 1.092.2.g.i-iv. – re-organizes definition for “Fiscal misconduct”; 1.092.2.i. – removes definition for “Wrongdoing”; Section 1.092.3. – adds language to cover all established areas of OIG work covered by existing standards; 1.092.3.i.ii. – further expanded “campaign activities” to include campaigns of candidates for School Board, revised policy now includes prohibits OIG engagement in Board member and Board candidate campaigns; 1.092.3.e. – states statutory authority supporting OIG independence as non-administration; 1.092.3.g. – establishes policy statement regarding OIG’s tolerance of any OIG employees’ documented ethical violations; Section 1.092.4.c. – removes term “other good cause” to add clarity and better harmonize removal provision with Florida statutes governing agency inspectors general (see §20.055(3)(c), Fla. Stat. – for cause removal including “concerns regarding performance, malfeasance, misfeasance, misconduct, or failure to carry out [statutory] duties”); Section 1.092.5. – clarifies OIG’s functions, authorities, and powers to align with law and practices and principles in the areas of investigations, audits, reviews, inspections, and CARES administration; 1.092.5.a.i. – reiterates OIG independence from District administration; 1.092.5.a.v. – corrects citation to Whistle-blower’s Act statute; 1.092.5.a.ix.A-C. – re-organizes internal referral section and clarifies Inspector General’s discretion to refer employee misconduct allegations; 1.092.5.a.xi. – includes provision for Inspector General to schedule Board workshops to review investigations to harmonize with proposed revisions to Board Policy 1.091 eliminating audit committee’s investigative role; 1.092.5.b.i. – adds charter school foundations to OIG auditing duties; 1.092.5.b.ii.E. – expands indicators to include misconduct and fiscal misconduct; 1.092.5.b.ii.F. – includes auditing of policies to include security measures; 1.092.5.b.v. – aligns audit responsibilities with new “misconduct” definition; 1.092.5.c. – clarifies and expands contract review duties to include third-party contracts with charter schools and interlocal agreements; 1.092.5.d. – removes “wrongdoing” from CARES preamble and adds existing language from investigative duties section; 1.092.5.d.x. – clarifies CARES distribution list recipients; 1.092.5.d.xiii. – removes disciplinary action for not reporting to CARES; 1.092.5.e.iii – references OIG duty via Board policy to follow up on District’s implementation of recommendations; 1.092.5.e.v. – clarifies that only suspected criminal activity must be reported to law enforcement; 1.092.5.e.vi. – applies misconduct to abuse of authority provision; 1.092.5.f.i. – adds inspections and reviews to activities requiring accessibility and cooperation with OIG; 1.092.5.f.ii. – adds volunteers to list of individuals OIG can interview; 1.092.5.f.iv. – clarifies both District employees and vendors must provide the OIG access to information; 1.092.5.f.vi. – adds investigations, inspections, and reviews to corrective action monitoring duty; 1.092.5.f.vii. – moves ten working days response deadline from due process section (see 1.092.9.b.ii current version); 1.092.5.f.viii. – provides for OIG’s use of administrative subpoena power; 1.092.5.g.ii. – removes language mandating referral to Office of Professional Standards if false complaint discovered; 1.092.5.h. – adds CARES reference to hotline policy; Section 1.092.6 – harmonizes section with Florida statues (see §112.3187, Fla. Stat.) regarding adverse personnel for following Policy 1.092; 1.092.6.a. – clarified language regarding when employees are responsible for reporting fraud, waste, and abuse; 1.092.6.a.i-ix. – removes language duplicative of code of ethics; Section 1.092.7 – increases OIG efficiency and independence by reformatting entire section including new definitions and processes to maximize OIG independence for complaints against Superintendent, Inspector General, OIG employees; General Counsel; and School Board members (i.e., “Conflict Subjects”); 1.092.7.a.-b. – applies new definitions from 1.092.2 for “Conflict Subjects”, “Conflict-free Investigator”; 1.092.7.c. – creates a conflict complaint form; 1.092.7.d-i. – creates a process for receiving and evaluating conflict complaints; including the appointment of a point of contact for instance in which the Inspector General, OIG employees, or both, are named as conflict subjects; 1.092.7.j-m. – 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 – aligns OIG’s reporting of work activities with Florida law and existing standards for internal OIGs; 1.092.9.a. – includes Florida Commission on Law Enforcement Accreditation (CFA) standards in conducting OIG affairs; 1.092.9.b.i. – clarifies requirements for review of draft audits and reports; 1.092.9.b.ii. – harmonizes OIG reporting requirements with auditing, review, and investigation standards and Florida statutes regarding confidentiality; 1.092.9.b.iii. – follows legal mandates including individuals substantially affected and entities contracting with the Board in the draft report response process (see §§20.055(6)(e) and .055(7)(e), Fla. Stat.); 1.092.9.c. – comports with Florida law (see §20.055(1)(c), Fla. Stat.) excludes individuals with independent review processes the from the draft report response process; 1.092.9.d. – exempts individuals substantially affected and entity contracting with the Board from draft review and response process if criminal investigation will be jeopardized; 1.092.9.f. – mandates summaries of investigative reports with substantiated or unsubstantiated allegation will be posted on the OIG website, clarifies that unfounded allegations will not be posted; Section 1.092.12 – updates confidentiality requirements to conform to Florida statutes.
*Including using “OIG” in place of “Office of Inspector General” and minor edits to grammar, syntax, and punctuation to clarify existing policy language
PURPOSE AND EFFECT: To align current Inspector General policy with existing statutory framework for internal OIGs, as well as follow standards, practices, and recommendations of the Association of Inspectors General and Florida Commission on Law Enforcement Accreditation to enable the OIG to function more efficiently and effectively.
RULEMAKING AUTHORITY: Fla. Stat. §§ 120.81 (1)(a); 1001.32(2); 1001.41 (1), & (2), & (5); 1001.42 (29)
LAWS IMPLEMENTED: Fla. Stat. §§ 112.3187-.3188; 119.0713(2); 286.011; 1001.20(4)(e); 1001.32 (2); 1001.41; 1001.42 (6), (7), (8), (12), (13), & (15); 1001.43(2), (6), (9) & (10)
CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)
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RULE TITLE: Whistle-Blower Protection Policy
RULE NUMBER: Policy 3.28
SUBJECT AREA TO BE ADDRESSED: Revisions* to Board Policy 3.28 – Whistle-blower Protection Policy include the following changes by section:
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.
PURPOSE AND EFFECT: The policy revision aligns the current Whistle-blower Protection Policy with Florida’s Whistle-blower’s Act for local governments, ensuring protection for individuals who make protected disclosures, and providing the exclusive remedy for claims of adverse personnel action taken in response to a protected disclosure.
RULEMAKING AUTHORITY: Fla. Stat. §§ Fla. Stat. §§120.81(1)(a), 1001.32(2), 1001.41, 1001.42, 1012.22
LAWS IMPLEMENTED: Fla. Stat. §§ Fla. Stat. §§112.3187 -.3188, 120.569, 120.57, 447.401, 1001.20(4)(e), 1001.32 (2), 1012.22
CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)
THE PRELIMINARY TEXT of the proposed rule development may be obtained without cost from the School District’s web site at:
https://go.boarddocs.com/fl/palmbeach/Board.nsf/goto?open&id=DMMKDG515B96
PUBLIC MEETING NOTICE: Development of the proposed rule is anticipated to be considered at the School Board Special Meeting (which includes Policies) on November 5, 2025. This Special Meeting will follow other Board meetings including a workshop and they are estimated 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 30, 2025 on the District’s web site at http://www.boarddocs.com/fl/palmbeach/Board.nsf/Public 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.