Public Meeting Announcement: Development Workshop for School Board Policies: 9/10/2025
RULE TITLE: Audit Committee
RULE NUMBER: Policy 1.091
SUBJECT AREA TO BE ADDRESSED: The proposed revised policy updates section 1.091.1 citation to statutory authorities establishing the audit committee, section 1.091.2 - adds new definitions for “management” and “OIG activities”, section 1.091.3 - clarifies committee authority to remove investigation function and identifies information committee requires for “OIG activities”, section 1.091.4. - re-organizes and further harmonizes committee responsibilities with the Inspector General policy (1.092) and Principles and Standards for Offices of Inspectors General/Government Accountability Office Government Auditing Standards, creates a risk acceptance process for committee to review or initiate management’s acceptance of risks, section 1.091.5 - updates committee chair and vice-chair’s terms of service, section 1.091.6 - opens non-voting committee representative opportunities to all bargaining units – Revisions further reflect updated syntax throughout all sections of the policy.
CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)
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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 “zero tolerance” policy for OIG employees’ documented ethical violations; clarifies “campaign activities” for prohibition on OIG engagement in Board member 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.
CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)
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RULE TITLE: Fraud; RULE NUMBER: Policy 2.61
SUBJECT AREA TO BE ADDRESSED: The proposed revised policy renames the policy “Fraud and Other Fraudulent Misconduct” and updates section 2.61.1 to include related deceptive acts and the inchoate offense of attempted fraud or concealment of fraud; section 2.61.2 – expands scope of policy to include charter school officers and employees and District volunteers; section 2.61.3 – adds new definitions for “Fraud” and “Management” including six (6) new examples of fraudulent misconduct prohibited under the policy; 2.61.4 – strengthens fraud policy statement to include unauthorized or deceptive conduct regardless of actual loss or harm to the District; section 2.61.5 – describes management responsibilities using specific examples of controls; mandates management report instances of fraudulent misconduct to CARES; limits additional management investigation after reporting fraud; requires management cooperation with OIG in detecting, reporting, and investigating fraudulent misconduct; section 2.61.6 – reiterates employee responsibilities in detecting, reporting, and investigating fraudulent misconduct; section 2.61.7 – reorganizes section Inspector General’s authority; clarifies complaint procedure to use CARES; references Inspector General’s authority to conduct fraud investigations pursuant to Board Policies 1.092 (Inspector General) and 3.28 (Whistle-blower Protection Policy) to investigate fraud and fraudulent misconduct; removes reporting requirement as duplicative of 1.092.9 (Reporting of [OIG] Work Activities) ; expands and defines non-retaliation protections for reporting of fraud via reference to Inspector General policy; references due process section of Inspector General policy as the mechanism for disposing of false complaints of fraud.
CONTACT: Teresa Michael, Inspector General (teresa.michael@palmbeachschools.org)
PUBLIC MEETING NOTICE: Development Workshop of the proposed rule is anticipated to be held on September 10, 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 September 4, 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.