main content starts here

Fiscal Management (Series 6000)

All policies are listed in policy number order. If you would like to search the page by policy title or policy number, hit the Control and F keys (Command and F if you’re on a Mac) at the same time and type in your keyword or policy number. Otherwise the Fiscal Management Policies are as follows:


Policy 6110 | Budget Planning

View the PDF version of the Budget Planning Policy here.

The superintendent of the Bethlehem Central School District (the District) Schools, with the assistance of the chief business and financial officer, shall be responsible for preparation of the budget. This shall include developing a budget calendar in accordance with regulation 6110-R, and adhering to that calendar. The budget calendar shall be approved by the Board of Education (the Board) in advance of the preparation of the District’s annual budget.

The budget shall be designed to reflect the Board’s objectives for the education of the children of the District. It shall be carefully organized and planned to provide adequate accounting for each program expenditure, and to use reasonable and conservative funding estimates. Revenue and other funding sources will be reasonably estimated and identified, such that the adopted budget will be balanced and will maintain the overall financial health of the District. A multiyear financial plan will also be reviewed, in order to best anticipate any threats to the longer-term financial health of the District.

The budget for the ensuing school year shall be thoroughly reviewed and approved by the Board before its presentation to the voters for final adoption.

Cross-ref:

  • 2260, Citizens Advisory Committees

Ref:

  • Education Law §§ 1608(2)-(4); 1716(2)-(4); §1804(4); 1906(1); 2002(1); 2003(1); 2004(1); 2022(2); 2601-a
  • Fiscal Management (NYSSBA, 1997)

Adoption date: June 19, 2002
Revised date: May 22, 2019

[back to top of page]


Policy 6110-R | Budget Planning Regulation

View the PDF version of the Budget Planning Regulation here.

The budget calendar prepared by the superintendent of the Bethlehem Central School District (the District) shall include:

  • a schedule that which sets forth all important meetings and dates, including deadlines for budget proposals from within the District;
  • commencement dates and deadlines for certain budgetary tasks, such as the estimation of all revenues and income expected to be received by the District; and
  • events such as the preliminary dates for the consideration of the tentative budget by the Board of Education (the Board).
  • As part of the budget planning process, the superintendent or chief business and financial officer will evaluate:
  • the educational philosophy, goals, and objectives of the District and their modification where required;
  • the District’s educational program and support services such as transportation, operations and maintenance, and District-wide administrative services;
  • census and enrollment projections;
  • the condition of the physical plant for operation and maintenance needs and new construction;
  • debt service schedules; and
  • estimated revenue from sources other than the property tax, such as state and federal aid.

Adoption date: June 19, 2002
Revised date: May 22, 2019

[back to top of page]


Policy 6120 | Budget Hearing

View the PDF version of the Budget Hearing Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) will hold an annual budget hearing at which it will present a detailed proposed budget for the following school year. The purpose of the budget hearing is to inform the public of the contents of the budget and to provide an explanation and justification for the decisions the proposed budget reflects.

The budget hearing will be held not less than seven nor more than fourteen days prior to the annual District meeting, at which the District’s voters will vote on the budget. The proposed budget will be completed at least seven days before the budget hearing. A copy of the proposed budget may be obtained by any District resident (not just District taxpayers) at each school during certain designated hours on each day (other than a Saturday, Sunday, or holiday) during the fourteen day period immediately preceding the annual District meeting and election.

Notice of the date, time, and place of the annual budget hearing will be contained in the notice of the annual meeting.

Cross-ref:

  • 1050, Annual District Meeting and Election
  • 2120.1, Candidates and Campaigning

Ref:

  • Education Law §§1608; 1716; 1804(4); 1906(1); 2002(1); 2003(1); 2004(1); 2002(1); 2601-a(2)

Adoption date: June 19, 2002
Reapproved date: May 22, 2019

[back to top of page]


Policy 6130 | Accounting Policy

View the PDF version of the Accounting Policy here.

Statement of Philosophy

The Board of Education of the Bethlehem Central School District (the District) recognizes that accurate and systematic financial records are imperative to support decision-making responsibilities and for accountability of responsible stewardship for public monies.

Accounting systems shall conform to the Office of the New York State Comptroller School Districts Accounting and Reporting Manual, and will safeguard District funds in accordance with regulation 6130-R and other fiscal policies of the District.

Cross reference:

  • 6150, Budget Transfers
  • 6670, Petty Cash/Petty Cash Accounts
  • 5252, Student Activities Funds Management
  • 6240, Investments

Adoption date: February 28, 2007
Revised date: May 22, 2019

[back to top of page]


Policy 6130-R | Accounting Policy Regulation

View the PDF version of the Accounting Policy Regulation here.

System of Accounts

Purpose
The accounting system of the Bethlehem Central School District (the District) shall provide an accurate, clear, and complete record of all financial transactions for which the Board of Education (the Board) is accountable.

Uniform System of Accounts
The system of accounts shall conform to the system prescribed pursuant to Section 36 of the General Municipal Law, Office of the New York State Comptroller School Districts Accounting and Reporting Manual, and Section 2116-a of the Education Law. Additional accounts and/or records that may be useful in yielding fiscal information to assist the Board and administration in its decision making may supplement this system.

Fixed Assets
The method of accounting for general fixed assets shall be in conformance with those prescribed by the Office of the New York State Comptroller School Districts Accounting and Reporting Manual.

Classification of Expenditures

Legal Requirements
All expenditures are reported under the account classifications provided in the State Uniform System of Accounts for School Districts in order to satisfy legal reporting requirements and to facilitate compilation of comparative financial statistics for various local, state, and national agencies and research organizations. These standard account classifications are related to the District’s budget categories in a manner that facilitates the recording and reporting of expenditures for budget control purposes.

Encumbering
Section 170.2(k) of the Commissioner’s Regulations states it is the duty of the Board to keep the incurred obligations within the amount of the available appropriation. Requisitions shall be encumbered against available funds. When sufficient funds are not available, a transfer of funds or approval must accompany the request.

To maintain budgetary control and to arrive at an accurate estimate of uncommitted appropriations, all known obligations must be encumbered early in the fiscal year (i.e., known obligations such as utilities, BOCES, debt service, salaries, fringe benefits and service contracts).

Transfer of Funds
The Board authorizes transfers between and within functional unit appropriations in accordance with Policy 6150, Budget Transfers.

Petty Cash Funds

Establishment
A petty cash account may be established at the discretion of the Board. The specific amount to be available and the person responsible for each fund shall be designated annually by the Board.

The Safeguarding of District Funds

Bonding
The Board will provide a public school system faithful performance bond, or blanket position bond for all employees and officers, as required by Subdivision 2 of Section 11 of the Public Officers Law and Subdivision 2(d) of Section 170 of the Commissioner’s Regulations. Annually, the Board will specify any additional amounts to be placed upon specific positions.

Cash in School Buildings
District employees are personally responsible for all monies that they collect during the course of their assigned duties. Employees who receive monies on behalf of the District other than the District treasurer must issue prenumbered receipts in triplicate (CR 170.2(i)).

All money shall be kept in a sealed bank bag and stored within the building safe until deposited. Deposits shall be made promptly but no later than 5 business days after receipt.. The principal in each building is directly responsible for the enforcement of this policy and informing all those under his/her direction.

Treasurer’s Receipts
A prenumbered receipt form shall be used by the District treasurer and other persons authorized to receive money. The District treasurer shall receipt all monies paid over to his/her custody with prenumbered duplicate receipts (Commissioner’s Regulation 170.2(h)). The District treasurer shall issue prenumbered receipt forms in triplicate to others authorized to receive monies in the first instance (Commissioner’s Regulation 170.2(i)).

Cash Accounting
The District’s accounting system shall provide for adequate control of all monies belonging to the District. The treasurer’s receipt numbers, as well as the source and amount of the revenue, shall be entered into the cash receipts journal and as journal entries for ACH (Automatic Clearing House) and wire transactions. A monthly report of all journal entries for all funds will be provided in the treasurers report, which is provided to the Board monthly. Revenue entries must be maintained on a gross basis.

Extraclassroom Activity Funds

Activity Accounts
An organization within the District whose activities are conducted by students and whose financial support is raised other than by taxation or through charges of the Board shall be known as an extraclassroom activity and the monies received as Extraclassroom Activity Funds. Annually, the Board will appoint, upon the recommendation of the superintendent, those members of the staff to serve as auditors and internal accounts personnel.

Regulation of Activities and Monies
The regulations of the establishment, conduct, operation, and maintenance of records concerning extraclassroom activities will be those outlined in District policy and in accordance with NYS Education Department’s Safeguarding, Accounting, and Auditing of Extraclassroom Activity Funds  and in conformance with Section 172 of the Commissioner’s Regulations.

Check Signature

Internal Control
The District treasurer must maintain, at all times, control of his/her signature plate. The administration of the District will establish, and the District treasurer will maintain procedures, that will ensure adequate internal control and protection against misuse and /or loss of the check signature plate used to sign authorized checks drawn against the District. All checks must receive the single signature of the District treasurer or the single signature of the deputy treasurer if one is appointed by the Board.

Storage of Blank Checks
The safeguarding of unused checks shall be the responsibility of the District treasurer. The storage of unused/blank checks shall be maintained in such a manner as to restrict their availability and offer protection against theft.

Scholarships and Trust Funds

Accounting
The accounting of all scholarship and trust funds given to the District are under the supervision of the Board and will be maintained in the Trust and Agency Fund.

Scholarships
Scholarship funds shall be administered by the superintendent or his/her designee, in accord with the donor’s request or procedures established by a designated faculty and administration committee approved by the Board.

Trust Funds
Gifts will be set up as a trust fund for the purpose of receiving and disbursing cash perthe donor’s request and in accordance with, Education Law, Section 1709 (12 and 12-a) and Comptroller’s Opinion No. 65-367.

Audit of Claims

Payments Prior to Audit
Payments of claims for public utility services, postage, freight, and express charges may be made in advance of audit in accordance with Section 1724.3 and 2524.2 of the Education Law.

Board of Education
No claim against the District shall be paid except for compensation for services of an employee or officer or for principal and interest on indebtedness unless it has been audited and allowed by the Board. Following approval, an abstract of the audited claims shall be drawn in the form of a warrant authorizing and directing the District treasurer to make payments in accordance with Sections 1724.2, 2523.4, and 2524 of the Education Law.

Internal Claims Auditor
When the office of claims auditor has been established and filled, all powers and duties of the Board with respect to auditing, allowing, or rejecting all claims against the District shall be exercised only by the auditor in accordance with Section 1709.20(a) and 2526 of the Education Law.

Certification of Payrolls

Responsibility
The Board, consistent with the provisions of Education Law 1720.2 and Section 170.2(b) of the Regulations of the Commissioner of Education, will annually designate the person(s) to be responsible for the certification of payrolls.

Bond and Note Register

Responsibility
The District treasurer shall keep a complete record of each issue of bonds and notes authorized. The record shall include the dates of issue for the obligations; the type thereof; the amount of each obligation; the banks from which the money was borrowed; the rate of interest; the amount of principal and interest paid; and the dates of maturity.

Cash Flow Management

Responsibility
The Board authorizes its District treasurer to manage all activities associated with cash flow management consistent with the Office of the State Comptroller’s guide, “Investing and Protecting Public Funds”.

Investments
The District’s cash flow management program shall include procedures for investing monies, consistent with the District’s investment policy (see 6240 & 6240-R).

Borrowings
The use of an open competitive system of bidding and/or quoting for the borrowing shall be conducted as prescribed in the provisions of Article VIII of the State Constitution and the Local Finance Law regulating the issuance of obligations.

Travel and Conferences
Reimbursement for authorized travel and conference attendance will be made in the manner prescribed by Section 77(b) of the General Municipal Law (see 6830).

Periodic Financial Reports

Cash Reconciliation
The District treasurer shall report to the Board the cash position and reconciliation of each account of the District on a monthly basis in compliance with the Commissioner’s Regulations, Section 170.2(o).

Budget Status
The District treasurer shall submit a budget status report monthly to the Board for each operating fund detailing the condition of each budget revenue and appropriation category. This shall be in at least the detail prescribed by the Commissioner’s Regulations, Section 170.2(p).

Annual Financial Statement
Notice that the annual financial statement for all funds is available in the District Office for public review shall be published by the Board in a public newspaper, in compliance with Education Law, Sections 1721 and 2528. Publication shall be in the format prescribed by the Commissioner’s Regulations, Section 170.2(s). This statement shall review the finances and transactions of the District for the preceding school year.

Annual Audit
An annual audit of all funds of the District shall be made by a certified public accountant or by a public accountant. The Board shall adopt a resolution accepting the audit report and file a copy of this resolution and the audit, including the Management Letter, with the commissioner of Education as required by Commissioner’s Regulations, Section 170.2(r). The clerk shall publish an official notice within ten days of receipt of the audit report.

The annual audit should include an examination of documents, records, and accounts conducted in accordance with Generally Accepted Accounting Principles (GAAP).

Adoption date: February 28, 2007
Revised date: May 22, 2019

[back to top of page]


Policy 6131 | Online Banking Services

View the PDF version of the Online Banking Services Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) requires clear, complete, and detailed accounting of all financial transactions for which the Board is held accountable. The transferring of funds via online banking services between various accounts and the transfer of funds from District accounts to non-District accounts for various purposes are financial transactions to be properly monitored and controlled.

The following are online banking activities the District engages in:

  1. viewing bank account information;
  2. interfund transfers;
  3. the remittance of employee payroll tax withholdings and other deductions;
  4. the paying of the District’s debt obligations;
  5. the remittance of employee payroll direct deposit;
  6. transfer of district funds into investments; and
  7. transfer of the library’s portion of school taxes to them.

The District accountant will have the authority to process online banking transactions. All transactions processed by the district accountant will be verified by the District treasurer. Secondary authorizations are required for any wires or ACH disbursements.

A bank transfer summary will be completed for any transfers indicating the line item code, the amount of monies, and the purpose for the transferring of funds. The District treasurer (or, if absent, the chief business and financial officer) will verify the accuracy and legitimacy of online transfers and keep a copy of the verified transfer summary on file. The District accountant will be responsible for the proper accounting of the transactions.

Adoption date: September 19, 2007
Revised date: May 22, 2019

[back to top of page]


Policy 6135 | Fund Balance Policy

View the PDF version of the Fund Balance Policy here.

The following policy has been adopted by the Board of Education (the Board) of the Bethlehem Central School District (the District) in order to address the requirements of Governmental Accounting Standards Board (GASB) Statement No. 54, Fund Balance Reporting and Governmental Fund Definitions. This policy will help the District assess if it is maintaining adequate fund balances and reserves in order to:

  1. Provide sufficient cash flow for daily financial needs;
  2. Secure and maintain investment grade bond ratings;
  3. Offset significant economic downturns or revenue shortfalls; and
  4. Provide funds for unforeseen expenditures related to emergencies.

GASB Statement No. 54 changed the classification of fund balance in order to bring greater clarity and consistency to fund balance reporting. Effective for financial statements for periods ending June 30, 2011, fund balance is reportable in five new categories as follows:

Nonspendable Fund Balance

The nonspendable fund balance amount represents the portion of the fund balance that is not in a spendable format in the current period either because of their form or because they must be maintained intact. Examples include inventories, prepaid items, and the principal of endowments.

Restricted Fund Balance

The restricted fund balance amount represents the portion of fund balance that is subject to an externally and legally enforceable purpose. The restrictions are imposed by creditors, grantors, laws and regulations of other governments, or through constitutional provision or enabling legislation. Examples include workers’ compensation, employee benefits accrued liability, and tax certiorari reserves (by virtue of the State Comptroller’s Regulation of the establishment, funding, and use of reserves).

Committed Fund Balance

The committed fund balance amount represents the portion of the fund balance that is constrained for a specific purpose by the District, through the adoption of a formal resolution by the Board. Committed funds also require the Board to take formal action to subsequently remove or change the constraints. Although the action to constrain the resources must occur prior to fiscal year end, the amount may be determined in the subsequent period. The state comptroller does not believe that school districts will typically have restrictions that will be accounted for in this category.

Assigned Fund Balance

The assigned fund balance amount represents amounts that are intended to be used for specific purposes, but are not restricted or committed. Examples include appropriated fund balance and outstanding encumbrances.

Unassigned Fund Balance

Funds in this category represent funds that are not classified in any of the other four categories. Typically, only the General Fund will contain unassigned fund balance.

The Board recognizes that Real Property Tax Law, Section 1318, limits the amount of unexpended surplus funds to no more than 4 percent of the next year’s budgeted appropriations. Under GASB Statement 54, the 4 percent limitation is interpreted to be applied to unrestricted fund balance (total of the committed, assigned, and unassigned classifications) minus appropriated fund balance, amounts reserved for insurance recovery, amounts reserved for tax reduction, and encumbrances included in committed and assigned fund balance.

The Board of Education affirms its authority to establish restricted, committed, and assigned funds, by authorizing the purpose for which the funds will be used. However, the Board delegates the authority to assign amounts to be used for specific purposes to the chief business and financial officer (CBFO). The amount of the assignments shall be determined based upon the CBFO’s review of detailed supporting calculations, and such detail will be presented for approval by the Board.

In situations where both restricted and unrestricted resources are available for expenditure (within the five categories of fund balance), the District’s policy is to allow the CBFO to determine the order of the expenditure of funds, on an annual basis (first option is the GASB Statement 54 presumption if not specified; the second option grants maximum flexibility in managing the 4 percent limitation.

Adoption Date: June 15, 2011
Reapproved date: May 22, 2019

[back to top of page]


Policy 6150 | Budget Transfers

View the PDF version of the Budget Transfers Policy here.

The transfer of funds between and within functional unit appropriations of the General Fund of the Bethlehem Central School District is commonly required during the school year. The superintendent, in accordance with the Commissioner of Education’s Regulations, is authorized to make budget transfers between line item accounts.

Ref:

  • Education Law §1718
  • 8 NYCRR §170.2(l)

Adoption date: June 19, 2002
Revised date: May 22, 2019

[back to top of page]


Policy 6231 | Title I/PSEN Programs and Services

View the PDF version of the Title I/PSEN Programs and Services Policy here.

Title I

The Board of Education (the Board) of the Bethlehem Central School District (the District) may apply for Title I of the Elementary and Secondary Education Act (ESEA) funding for projects designed to meet the special educational needs of educationally deprived children. Such funding shall be used to provide appropriate programs and services to participating students in basic and more advanced skills. In particular, funds may be used for the following:

  1. year-round services and activities, including intensive summer school programs;
  2. purchasing appropriate equipment and/or instructional materials;
  3. employment of special instructional personnel, school counselors, and/or other pupil services personnel;
  4. employment and training for NYS teaching assistants;
  5. training of teachers, librarians, other instructional and pupil services personnel, and early childhood education professionals when appropriate;
  6. construction, if necessary, of school facilities;
  7. parental involvement activities;
  8. planning for, and evaluation of, Title I programs; and
  9. other activities permitted under federal regulations.

With the approval of the State Education Department, the District may use up to and including 5 percent of such funds for “innovation projects to promote quality” in the District’s Title I program. Such projects may include the following:

  1. continuation of services to those students who participated in the program in any previous year;
  2. continuation of services for a period not to exceed two additional years to participating students who are transferred to areas/schools that are ineligible for such funding, as part of a desegregation plan;
  3. incentive payments to schools that have demonstrated significant progress and success in attaining Title I goals;
  4. training of teachers and librarians in the special educational needs of eligible students, and in the integration of Title I programs into regular classroom programs;
  5. programs that encourage innovative approaches to parental involvement, or rewards to or expansion of exemplary parental involvement programs; and
  6. encouraging community and business involvement in meeting the needs of eligible children.

PSEN

The Board must submit for approval a plan for the expenditure of its Pupils with Special Educational Needs (PSEN) funds, which are state funds that must be expended only for project activities for eligible students in the school year for which funds are appropriated. PSEN serves as a funding source for all school districts based upon the number of educationally deficient students in each district.

The Board directs the administration to follow all applicable State Education Department guidelines for completing budget forms for the operation of Title I/PSEN projects.

Ref:

  • 8 NYCRR Part 149
  • 34 CFR Part 75; §200.34(c)(1)(i) (ESEA Title I Program in Local Educational Agencies)
  • Applicant’s Guide and Instructions for Consolidated Application and the Program Information Report, The University of the State of New York (1989)
  • Pupils With Compensatory Educational Needs: Questions and Answers July 1987, The University of the State of New York (1987) Chapter 1 Policy Manual, The University of the State of New York (1990)

Adoption date: June 19, 2002
Reapproved date: May 22, 2019

[back to top of page]


Policy 6240 | Investments

View the PDF version of the Investments Policy here.

The Board of Education (the Board) recognizes its fiduciary responsibility under §39 of the General Municipal Law (GML) requiring a comprehensive investment policy outlining the policy of the Bethlehem Central School District (the District) with regard to the investing, monitoring and reporting of the District’s funds.

Therefore, the Board directs the superintendent of schools or his/her designee to ensure that procedures and regulations are followed to safeguard District funds and to minimize risk, to ensure that investments mature when cash is required to finance operations and to ensure a competitive rate of return. In accordance with this policy, the treasurer or his/her designee is authorized to invest and/or deposit all funds, including proceeds of obligations and reserve funds, in time-deposit accounts, certificates of deposit, short-term government securities, repurchase agreements or other investment instruments permitted by law, subject to the investment regulations approved by the Board of Education.

All participants in the investment process shall seek to act responsibly as custodians of the public trust and shall avoid any transaction that might impair public confidence in the District’s ability to govern effectively. Investments shall be made with prudence, diligence, skill, judgment, and care, under circumstances then prevailing that a knowledgeable and prudent person acting in like capacity would use, not for speculation, but for investment, considering the safety of the principal as well as the probable income to be derived. Furthermore, all participants involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions.

This policy will be reviewed annually by the Board and may be amended from time to time in accordance with the provisions of §39 of the General Municipal Law.

Ref:

  • Education Law §§1604-a; 1723-a; 3651; 3652
  • Local Finance Law §165.00
  • General Municipal Law §§6-c-6-e; 6-j-6-n; 10; 11; 39

Adoption date: June 19, 2002
Amended date: July 7, 2015
Re-approved: July 5, 2016
Re-approved: July 12, 2017
Re-approved: July 2, 2018

[back to top of page]


Policy 6240-R | Investments Regulation

View the PDF version of the Investments Regulation here.

Delegation of Authority

The Treasurer is authorized to invest all available Bethlehem Central School District (the “District”) funds, including proceeds of obligations and Reserve Funds, in the permitted investment instruments as defined in this regulation.

Securing Deposits and Investments

All deposits and investments at a bank or trust company, including all demand deposits, certificates of deposit and special time deposits (hereinafter, collectively, “deposits”) made by officers of the Bethlehem Central School District that are in excess of the amount insured under the provisions of the Federal Deposit Insurance Act shall be secured by:

  1. A pledge of “eligible securities” with an aggregate “market value” (as provided by the GML, Section 10) that is at least equal to the aggregate amount of deposits by the officers. Eligible securities include the following:
    1. Obligations issued, or fully insured or guaranteed as to the payment of principal and interest, by the United States of America, an agency thereof or a United States government-sponsored corporation.
    2. Obligations issued or fully insured or guaranteed by the State of New York; obligations issued by a municipal corporation, school district or district corporation of this State; or obligations of any public benefit corporation that under a specific State statute may be accepted as security for deposit of public moneys.
  2. A pledge of a pro rata portion of a pool of eligible securities, having in the aggregate a market value at least equal to the aggregate amount of deposits from all such officers within the State at the bank or trust company.
  3. An “eligible surety bond” payable to the government for an amount at least equal to 100 percent of the aggregate amount of deposit and the agreed-upon interest if any, executed by an insurance company authorized to do business in New York State, whose claims-paying ability is rated in the highest rating category by at least two nationally recognized statistical rating organizations. The Board of Education shall approve the terms and conditions of the surety bond.
  4. An “eligible letter of credit,” payable to the Bethlehem Central School District as security for the payment of 140 percent of the aggregate amount of deposits and the agreed-upon interest, if any. An “eligible letter of credit” shall be an irrevocable letter of credit issued in favor of the Bethlehem Central School District, for a term not to exceed 90 days, by a qualified bank (other than the bank where the secured money is deposited). A qualified bank is either one whose commercial paper and other unsecured short-term debt obligations (or, in the case of a bank that is the principal subsidiary of a holding company, whose holding company’s commercial paper and other unsecured short-term debt obligations) are rated in one of the three highest rating categories by at least one nationally recognized statistical rating organization, or one that is in compliance with applicable federal minimum risk-based capital requirements.
  5. An “irrevocable letter of credit” issued in favor of the Bethlehem Central School District by a federal home loan bank whose commercial paper and other unsecured short-term debt obligations are rated in the highest rating category by at least one nationally recognized statistical rating organization, as security for the payment of 100 percent of the aggregate amount of deposits and the agreed-upon interest, if any.

Diversification

To the extent feasible, investments and deposits shall be made in and through local or regional financial institutions. Concentration of investments in a single financial institution should be avoided. Diversification of investments and deposits is encouraged.

Designations of Depositories

Depositories are approved by the Board of Education at the annual reorganizational meeting.

Collateralization and Safekeeping

All investments made pursuant to this investment policy will comply with the following conditions:

  1. Collateral
    1. Savings accounts, money market accounts, time deposit accounts and certificates of deposit will be fully secured by insurance of the Federal Deposit Insurance Corporation or by obligations of New York State, the United States, New York State school districts and federal agencies whose principal and interest are guaranteed by the United States. The market value of collateral will at all times exceed the principal amount of the certificate of deposit. Collateral will be monitored no less frequently than on a weekly basis.
    2. Collateral will not be required with respect to the direct purchase of obligations of New York State, the United States and federal agencies, the principal and interest of which are guaranteed by the United States Government.
  2. Delivery of Securities
    1. Payment of funds may only be made upon receipt of collateral or other acceptable form of security, or upon the delivery of government obligations whether such obligations are purchased outright, or pursuant to a repurchase agreement. Written confirmation of delivery shall be obtained from the custodial bank.
    2. Every Repurchase Agreement will make payment to the seller contingent upon the seller’s delivery of obligations of the United States to the Custodial Bank designated by the District, which shall not be the repurchase, or in the case of a book-entry transaction, when the obligations of the United States are credited to the Custodian’s Federal Reserve account. The seller will not be entitled to substitute securities. Repurchase Agreements shall be for periods of 30 days or less. The Custodial Bank shall confirm all transactions in writing to insure that the District’s ownership of the securities is properly reflected in the records of the Custodial Bank.
  3. Written Contracts
    1. Written contracts are required for certificates of deposit and custodial undertakings and Repurchase Agreements. With respect to the purchase of direct obligations of U.S., New York State, or other governmental entities in which monies may be invested, the interests of the District will be adequately protected by conditioning payment on the physical delivery of purchased securities to the District or custodian, or in the case of book- entry transactions, on the crediting of purchased securities to the Custodian’s Federal Reserve System account. All purchases will be confirmed promptly in writing to the school district.
    2. The following written contracts are required:
      1. Written agreements will be required for the purchase of all certificates of deposit.
      2. A written contract will be required with the Custodial Bank(s).
      3. Written contracts shall be required for all Repurchase Agreements. Only credit-worthy banks and primary reporting dealers shall be qualified to enter into a Repurchase Agreement with the District.

The written contract will stipulate that only obligations of the United States may be purchased and that the District shall make payment upon delivery of the securities or the appropriate book-entry of the purchased securities. No specific Repurchase Agreement will be entered into unless a Master Repurchase Agreement has been executed between the District and the trading partners. While the term of the Master Repurchase Agreement may be for a reasonable length of time, a specific Repurchase Agreement will not exceed thirty (30) days.

Permitted Investments

Permitted investments include the following:

  1. Savings Accounts or Money Market Accounts of designated banks;
  2. Certificates of Deposit issued by a bank or trust company located in and authorized to do business in New York State;
  3. Demand Deposit Accounts in a bank or trust company located in and authorized to do business in New York State;
  4. Obligations of New York State;
  5. Obligations of the United States Government (U.S. Treasury Bills and Notes);
  6. Repurchase Agreements involving the purchase and sale of direct obligations of the United States; (No more than 30% of the Bethlehem Central School District’s total invested funds at the time of investment may be invested in Repurchase Agreements.)
  7. All funds may be invested in Revenue Anticipation Notes or Tax Anticipation Notes of other Districts and municipalities, with the approval of the State Comptroller.

Authorized Financial Institutions and Dealers

  1. The Board will designate a commercial bank or trust company authorized to do business in the State of New York to act as Custodial Bank of the District’s investments. However, securities may not be purchased through a Repurchase Agreement with the Custodial Bank.
  2. When purchasing eligible securities, the seller will be required to transfer the securities to the District’s Custodial Bank.

Purchase of Instruments

The chief business and financial officer or treasurer (or other officer having custody of money) is authorized to contract for the purchase of investments:

  1. Directly, from an authorized trading partner,
  2. By participation in a cooperative investment agreement with other authorized municipal corporations pursuant to Article 5-G of the General Municipal Law and in accordance with Article 3-A of the General Municipal Law.

All purchased obligations, unless registered or inscribed in the name of the local government, shall be purchased through, delivered to and held in the custody of a bank or trust company. Such obligations shall be purchased, sold, or presented for redemption or payment by such bank or trust company only in accordance with prior written authorization from the officer authorized to make the investment. All such transactions shall be confirmed in writing to the Bethlehem Central School District by the bank or trust company.

Any obligation held in the custody of a bank or trust company shall be held pursuant to a written custodial agreement as described in General Municipal Law Section 10(3)(a). The agreement shall provide that securities held by the bank or trust company, as agent of, and custodian for, the Bethlehem Central School District, will be kept separate and apart from the general assets of the custodial bank or trust company and will not be commingled with or become part of the backing of any other deposit or other bank liability. The agreement shall also describe how the custodian shall confirm the receipt and release of the securities. Such agreement shall include all provisions necessary to secure the local government’s perfected interest in the securities, and the agreement may also contain other provisions that the governing board deems necessary. The security and custodial agreements shall also include all other provisions necessary to provide the Bethlehem Central School District with a perfected interest in the securities.

The chief business and financial officer or treasurer (or other officers having custody of money) can direct the bank or trust company to register (and hold the evidences of investments in investments in the name of its nominee), or may deposit or authorize the bank or trust company to deposit, or arrange for their deposit, with a federal reserve bank or other book-entry transfer system operated by a federally regulated entity. The records of the bank or trust company shall show, at all times, the ownership of such evidences of investments, and they shall be, when held in the possession of the bank or trust company, at all times, kept separate from the assets of the bank or trust company. All evidences of investments delivered to a bank or trust company shall be held by the bank or trust company pursuant to a written custodial agreement as set forth in General Municipal Law Section 10(3)(a), and as described earlier in the section. When any such evidences of investments are so registered in the name of a nominee, the bank or trust company shall be absolutely liable for any loss occasioned by the acts of such nominee with respect to such evidence of investments.

Courier Service

The chief business and financial officer (or officer authorized by law to make deposits) may, subject to the approval of the Board of Education by resolution, enter into a contract with a courier service for the purpose of causing the deposit of public funds with a bank or trust company. The courier service shall be required to obtain a surety bond for the full amount entrusted to the courier, payable to the Bethlehem Central School District and executed by an insurance company authorized to do business in the State of New York, with a claims-paying ability that is rated in the highest rating category by at least two nationally recognized statistical rating organizations, to insure against any loss of public deposits entrusted to the courier service for deposit or failure to deposit the full amount entrusted to the courier service.

The Bethlehem Central School District may agree with the depositary bank or trust company that the bank or trust company will reimburse all or part of, but not more than, the actual incurred by the Bethlehem Central School District in transporting items for deposit through a courier service. Any such reimbursement agreement shall apply only to a specified deposit transaction, and may be subject to such terms, conditions and limitations as the bank or trust company deems necessary to ensure sound banking practices, including, but not limited to, any terms, conditions or limitations that may be required by the banking department or other federal or State authority.

Annual Review and Amendments

This policy will be annually reviewed by the Board and may be amended from time to time in accordance with the provisions of section 39 of the General Municipal Law.

Internal Controls

  1. The chief business and financial officer or designee will authorize the purchase and sale of all securities and execute contracts for investments and deposits on behalf of the District. Oral directions concerning the purchase or sale of securities will be confirmed in writing. The District will pay for purchased securities upon the simultaneous delivery or book-entry thereof.
  2. The District will encourage the purchase and sale of securities through a competitive process involving telephone solicitation or group e-mails for at least three quotations.
  3. The independent auditors will audit the investment proceeds of the District for compliance with the provisions of this Investment Regulation.
  4. Investment reports will be furnished monthly to the Board of Education if any investments are made using permitted investments as defined in Permitted Investments, Section A, #4, 5, 6 or 7.

Definitions

Agent Bank: A commercial bank or trust company under contract with the Bethlehem Central School District to receive, pay for, safeguard and account for investment securities purchased by the Bethlehem Central School District. Other responsibilities will be defined in the agent bank agreement.

Banks: As defined in Article III of the State Banking Law.

Broker/Dealer: A financial firm, other than a commercial bank, engaged in the sale of U.S. Treasury obligations. Certificate of Deposit: A negotiable receipt from a commercial bank or trust company for deposit of funds for a specified period of time at a specified rate of interest. A certificate of deposit ranges from 14 days to one year, and the minimum amount is generally $100,000.

Collateral: Securities pledged to secure repayment of certificates of deposit and money market accounts.

Joint Custody Accounts: Account for the handling of securities purchased or held as collateral maintained in the names of both the district and the financial institution with whom they are dealing. The account is maintained by a third party (trust department is acceptable), which would provide written confirmation of securities held to the District. Written joint custody agreements are required, specifying such points as failure of the financial institution to return funds to the District at maturity and authorizing the custodian to release securities directly to the District.

Mark to Market: The act of determining the current value of the securities.

Primary Dealer: The largest and soundest broker/dealers as designated by the Federal Reserve Bank.

Repurchase Agreement: Consists of a broker/dealer or bank selling U.S. Treasury securities for cash to the Bethlehem Central School District and, at the same time, agreeing to buy them back on an established date and at an agreed upon price including interest. These short-term investments usually range from overnight to six months in term. Repurchase Agreements start at $100,000. Payment is made against the delivery of the securities. Delivery is required.

Treasury Obligations: Consist of U.S. Government Treasury Bills, Bonds and Notes.

Treasury Bills: Short-term, direct obligations of the U.S. Government that are usually issued with maturities of three months, six months, or one year. Bills are offered in bearer form and are issued in amounts of $10,000 and up, in multiples of $5,000. Bills do not bear a stated interest rate; the interest is calculated by taking the difference between the discount price paid at purchase and the face amount (par) collected at maturity.

Treasury Bonds and Notes: Direct obligations of the U.S. Government to pay a specified rate of interest for a specified period of time on the face value (par) of the instrument. Interest is paid semiannually, and the life of the notes is usually limited to ten years or under; bonds generally have maturities of 10-30 years. Treasury notes with a maturity through three years can usually be purchased in $5,000 denominations and require a $5,000 minimum purchase. Treasury notes with a term longer than three years, and Treasury Bonds, can usually be purchased in $1,000 denominations and require a $1,000 minimum purchase.

Ref:

  • Education Law §§1604-a; 1723-a; 3651; 3652
  • Local Finance Law §165.00
  • General Municipal Law §§6-c-6-e; 6-j-6-n; 10; 11; 39

Adoption date: June 19, 2002
Re-approved: July 7, 2010
Revised: July 6, 2011
Re-approved: July 3, 2012
Re-approved: July 2, 2013
Re-approved: July 1, 2014
Re-approved: July 7, 2015
Re-approved: July 5, 2016
Re-approved: July 12, 2017
Re-approved: July 2, 2018

[back to top of page]


Policy 6410 | Authorized Signatures

View the PDF version of the Authorized Signatures Policy here.

The Board of Education authorizes the signature on checks issued against all accounts of the school district to be that of the Treasurer or, in his/her absence, the Deputy Treasurer.

The Board hereby authorizes the use of check signing machines with safeguards for the school district’s protection and with facsimile signatures of the Treasurer and Deputy Treasurer. Said machines shall be maintained in the exclusive and secured possession of the Treasurer and Deputy Treasurer, respectively.

The Treasurer/Deputy Treasurer shall be present and shall control the affixing of his/her signature when checks are run. He or she should maintain a log of checks signed and should verify the sequence of check numbers that are used. The signing of blank checks is expressly forbidden.

Extra classroom activity fund checks shall be signed by the Central Treasurer of the extracurricular activity fund, upon review of a payment authorization form signed by both the Student Treasurer and the Club Faculty Advisor, along with appropriate supporting documentation.

Contracts authorized by Board resolution shall be signed by the Board President or in his/her absence the Vice-President, unless a different signatory is identified in the Board resolution. Purchase orders for goods and/or services identified in the various budget codes of the school district budget may be executed by the Purchasing Agent responsible for the procurement of such goods and/or services.

The Board authorizes the payment in advance of audit of claims for all postage, in accordance with law.

Ref:

  • Education Law §§1720; 1724; 2523
  • 8 NYCRR §§170.1(c)(d); 172

Adoption date: June 16, 2010

[back to top of page]


Policy 6500 | Allegations of Fraud

View the PDF version of the Allegations of Fraud Policy here.

Covered Employees

All Board members and officers, District employees and third party consultants are required to abide by the District’s policies, administrative regulations and procedures in the conduct of their duties. All applicable federal and /or state laws and regulations must be adhered to in the course of District operations and practices. Any individual who has reason to believe that financial improprieties or wrongful conduct is occurring within the School System is required to disclose such information according to the following reporting procedures.

Adoption date: February 28, 2007

[back to top of page]


Policy 6500-R | Allegations of Fraud Regulation

View the PDF version of the Allegations of Fraud Regulation here.

Reporting Process

The reporting procedures will follow the chain of command as established within the department or school building or as enumerated in the District’s Organizational Chart. The report will be made to the employee’s immediate supervisor. In the event that the allegations concern the immediate supervisor, the report shall be made to the next level of supervisory authority.

If the chain of supervisory command is not sufficient to ensure impartial, independent investigation, the allegation will be reported as applicable, to the Internal Auditor, or the independent (External) Auditor, or the School Attorney, or members of the District Audit Committee, or State Comptroller’s office, or the President of the Board of Education.

Investigation and Reporting

Upon receipt of an allegation, the board or its designated employee(s) will conduct a thorough investigation of the charges. To the extent possible, within legal constraints, all reports will be treated in a confidential manner. Disclosure may be necessary to complete a thorough investigation of the charges and/or to notify law enforcement officials. Any such disclosure will be provided on a “need-to-know” basis. Written records of the allegation and resulting investigation and outcome will be maintained in accordance with law.

If the District has knowledge of, or reason to know of, any occurrence of financial improprieties/fraud and /or wrongful conduct, the District will investigate such conduct promptly and thoroughly, even in the absence of a written report.

Based upon the results of the investigation, if the District determines that a school employee has engaged in financial improprieties/fraudulent and/or wrongful actions, appropriate disciplinary measures will be applied. These measures will be in accordance with legal guidelines, District policy and regulation, and any applicable collective bargaining agreement and may include termination of employment. Third parties who are found to have engaged in financial improprieties/fraud and/or wrongful conduct will be subject to appropriate sanctions.

In the event of an unresolved complaint and/or unsatisfactory determination by the investigating party, the complainant may appeal the determination by notifying, as applicable, the Internal Auditor, or the Independent (External) Auditor, or the School Attorney, or the President of the Board of Education. All complaints will be reported to the Board of Education to determine further action.

Prohibition of Retaliation

The Board prohibits any retaliatory behavior directed against those individuals who, in good faith, report allegations of suspected financial improprieties/fraud and/or wrongful conduct as well as witnesses and/or any other individuals who participate in the investigation. Any act of retaliation is prohibited and subject to appropriate disciplinary action by the District.

Knowingly Makes False Accusations

Any individual who knowingly makes false accusations against another individual as to allegations of financial improprieties/fraud may also face appropriate disciplinary action.

Ref:

  • Civil Service Law § 75-6

Adoption date: February 28, 2007

[back to top of page]


Policy 6640 | Inventories of Capital and Non-Capital Assets

View the PDF version of the Inventories Policy here.

In order to provide accountability, oversight, and for assessing adequacy of insurance coverage, in accordance with “The Uniform System of Accounts for School Districts” and the recommendations of the State Comptroller’s Office, an inventory of fixed assets and other equipment and property of the District, valued at $100 or more, shall be maintained by building and department administrators, in the manner prescribed by the business office, with a copy of the property register provided to the business office. The lower threshold is intended to apply to those non-capital assets that are at greater risk for misappropriation.

All equipment and property should be clearly labeled as “Property of the Bethlehem CSD” by the department making the acquisition. Moveable equipment or property subject to capitalization pursuant to policy 6645 shall also be tagged with an identifying asset number.

Classroom and office furniture is not required to be inventoried; however, because these items are typically purchased as part of a capital project, the capital project costs will be distinguished by component and included within depreciable assets.

  • Capital and non-capital assets subject to inventory would include the following items:
  • School buses and other moving vehicles (trucks and vans, automobiles, mowers, trailers, etc.);
  • Tools and smaller equipment used by Operations and Maintenance and Transportation;
  • Technology assets maintained by the Technology department;
  • Assistive Technology assets maintained by the Special Education department;
  • Health Office equipment;
  • Science Department Lab Tools and Equipment;
  • Automatic External Defibrillators (AED) units;
  • Musical instruments; and
  • Athletic and physical education (P.E.) equipment

The business office shall develop and maintain a system of internal controls for all fixed assets and other inventoried District property, including a property register that shall be updated on an ongoing basis. Transfers of assets between departments are infrequent, but an updated location description should be noted during the annual reconciliation.

Departments are expected to inventory and monitor all capital and non-capital assets under their control. Such inventory should occur on a periodic basis, at least annually, with a report identifying all updated records to the school business administrator. The business office will ensure that periodic verifications of the records maintained at the department level are conducted, and may use the assistance of outside service providers in carrying out this responsibility.

Ref:

  • Uniform System of Accounts for School Districts – Fiscal Section
  • General Municipal Law § 36

Cross-ref:

  • 6645, Capital Assets Accounting
  • 6900, Disposal of District Property

Adoption date: August 9, 2017

[back to top of page]


Policy 6645 | Capital Assets Accounting

View the PDF version of the Capital Assets Accounting Policy here.

Accounting of Fixed Assets

The school business administrator shall be responsible for accounting for general fixed assets according to the procedures outlined by Generally Accepted Governmental Accounting Standards and the Uniform System of Accounts for School Districts. These records and accounts will serve to:

a. Maintain a physical inventory of assets;

b. Establish accountability; and

c. Determine replacement costs to provide appropriate insurance coverage.

All fixed assets carrying a minimum value as specified below by category, that have a useful life of five years or more, and are tangible assets that are not appreciably affected by use or consumption, shall be recorded.

Valuation

All assets will be recorded at cost (or fair market value if a donated asset) at the time of acquisition. The capitalized cost shall be the invoiced price including all necessary costs incurred to place the asset in service (i.e.: shipping, handling, freight, duties, registration fees, installation costs or insurance during transit).

Capitalization ($ Threshold)

Assets with a useful life of five years or more, and meeting the threshold listed below will be capitalized. The threshold to be used for financial reporting (GASB #34) purposes and categories of assets is as follows:

                   

Land                                                                            $5,000

Land Improvements                                                  $ 25,000

Buildings and improvements                               $ 50,000

Furniture and equipment                                       $ 5,000

Vehicles                                                                     $5,000

Restricted, grant-acquired assets                             $5,000

Some assets may, individually, fall below the capitalization threshold, but may be purchased in large quantities by the District (typically as part of a capital project or a technology acquisition). The District may choose to capitalize these assets as a group, as determined by the school business administrator.

Depreciation Method

All assets will be depreciated over their estimated useful life, using the straight-line method, with the half year convention. The useful life will be estimated in the year of acquisition. Salvage value will only be assigned if deemed material, typically in excess of 10 percent of the asset’s cost.

Cross-ref:

  • 6640, Inventories of Capital and Non-Capital Assets
  • 6900, Disposal of District Property

Adoption date: August 9, 2017

[back to top of page]


Policy 6650 | Claims Auditor

View the PDF version of the Claims Auditor Policy here.

The Board of Education will annually designate and appoint a claims auditor for the District. The claims auditor shall serve at the pleasure of the Board. The claims auditor shall report directly to the Board.

The claims auditor is responsible for formally examining, allowing or rejecting all accounts, charges, claims or demands against the District. The auditing process should determine:

1. that the proposed payment is for a valid and legal purpose;

2. that the obligation was incurred by an authorized District official;

3. that the items for which payment is claimed were in fact received or, in the case of services, that they were actually rendered;

4. that the obligation does not exceed the available appropriation; and

5. that the submitted voucher is in proper form, mathematically correct, does not include previously paid charges, and is in agreement with the purchase order and contract upon which it is based.

The claims auditor shall provide periodic written reports as may be requested by the Board.

Ref:

  • Education Law §§1604 (35); 1709(20-a); 1724; 2509; 2526; 2554(b)
  • 8 NYCRR §170.2
  • Matter of Levy, 22 EDR 550 (1983)

Adoption date: October 19, 2005
Revised: October 4, 2006
Revised: August 9, 2017

[back to top of page]


Policy 6650-R | Claims Auditor Regulation

View the PDF version of the Claims Auditor Regulation here.

The claims auditor is responsible for formally examining all accounts, charges, claims or demands against the District.

Qualifications

Legal

The legal qualifications for appointment to the position of Claims Auditor in central and union-free school districts and city school districts in cities having a population of 125,000 or less are contained within Sections 1709-20(a) and 2526 of the Education Law, respectively.

Under these sections, individuals eligible for appointment to this office may not be a member of the Board of Education, the clerk or treasurer of the Board of Education, the superintendent of the District, the official of the District responsible for business management, the person designated as purchasing agent or clerical/professional personnel directly involved in accounting and purchasing functions of the District.

Knowledge and Skills

Although the Board recognizes that specific training is not required by law, experience and training in the areas of accounting and auditing are desirable.

The claims auditor needs to be fully knowledgeable in state and local bidding laws and regulations, as well as Board policies and regulations.

Appointment

The Board of Education shall designate and appoint a claims auditor on an annual basis at the District’s re-organizational meeting.

Primary Relations

Board of Education

The claims auditor is an employee of the Board of Education and is directly responsible to the Board of Education. The claims auditor shall serve at the pleasure of the Board, and the position of claims auditor may be abolished by the Board at any time. The claims auditor may, at times, be requested to attend meetings of the Board of Education, but is not expected to attend regularly.

Superintendent of Schools

The claims auditor shall recognize that the superintendent of schools is the chief executive officer of the District. The claims auditor, while not responsible to the superintendent of schools, shall work cooperatively with the superintendent and his/her staff in the best interest of the District.

Assistant Superintendent of Business

The claims auditor shall recognize that the chief business and financial officer is the chief business official of the District. The claims auditor, while not responsible to the chief business and financial officer, shall work cooperatively with that administrator and his/her staff in the best interest of the District.

Business Office Staff Members

The claims auditor is responsible for approving and allowing payment of claims, which have been processed and recommended by the business office. The claims auditor shall work cooperatively with the business office staff to ensure legal and business-like payment of claims.

In the event of a difference of opinion regarding the approval of a claim for payment that cannot be resolved by reviewing the questioned claim with the appropriate business office personnel (such as the chief business and financial officer ), the opinion of the claims auditor shall prevail and the item should be referred to the Board of Education.

Duties and Responsibilities

The claims auditor is directly responsible to the Board of Education. When the position of claims auditor has been established, and a qualified claims auditor has been appointed, the powers and duties of the Board of Education with respect to auditing, allowing or rejecting all accounts, charges, claims or demands against the District shall devolve upon and thereafter be exercised by such auditor, during the continuance of such office (Ed. Law 1709-20(a), 2526).

All claims must be presented to and approved prior to the payment by the claims auditor charged with the auditing function. Education Law allows certain claims (public utility services, postage and freight, and express charges) to be paid in advance of audit if the Board of Education authorizes, by resolution, such claims to be paid in advance. All such claims must then be presented for audit.

When the claims are delivered to the claims auditor for approval, he/she should ascertain that at least the following tests have been performed prior to releasing the claim for payment.

1. Track the numerical sequence of checks being approved.

2. Prove the mathematical accuracy of all computations. This should include verification of extensions and additions and the recalculation of any discount.

3. Determine that the charges are not duplicates of items already paid.

4. Compare the voucher with the purchase order.

5. Verify that the voucher is properly itemized. Vouchers for supplies or materials should show items as weight or quantity, size, grade, unit price, and total, as well as any other data appropriate to the commodity purchased (such as underlying contract/bid/quote documents). Vouchers for multiple deliveries of items, such as gasoline or fuel oil, should be supported by delivery tickets signed by the person accepting the delivery and identifying the equipment, storage area or building in which each delivery was made. Delivery tickets furnish added proof that the District actually did receive the items for which it is paying.

6. Determine that sufficient detail exists to properly describe the claim. A simple rule to remember on itemization is that the voucher must contain sufficient detail to permit a satisfactory audit by a person who is entirely unfamiliar with the transaction. Vouchers claiming reimbursement for authorized expenses incurred by District personnel, in addition to a copy of the authorization, should show the reason for incurring the expense as well as details of the various items, such as travel, lodging and meals. Where possible, receipted bulls should be attached to expense vouchers — a hotel bill is a good example of this type of bill. When a personal car is used for travel, the voucher should indicate the purpose of travel, the number of miles traveled, the dates and points of travel and the rate per mile. The rate per mile should be the rate established by resolution of the Board and/or labor contracts. Expense vouchers should be submitted by the person incurring the expense and not by another individual as a part of general claims for all persons traveling to a common destination.

7. Review the written request for travel advances for proper authorization prior to forwarding the request to the treasurer. When the claim for reimbursement is filed, the claims auditor should, in addition to tests previously mentioned for travel claims, make certain that the value of the advance has been deducted from the amount of the final claim. Where the amount of such advance exceeds the amount of the final claim, the voucher should be returned to the business office for recovery of the amount due to the District.

8. Observe whether the official who gave rise to the claim has indicated his/her approval.

9. Verify that the voucher is accompanied by the receipt from the employee who actually received the materials or equipment for which the claim is made. Normally, this is transmitted through signing and dating the receiving copy of the purchase order.

The claims auditor shall provide periodic written reports as may be requested by the Board of Education. Exceptions shall be reported to the Board of Education.

The audit of a voucher by the claims auditor should not be a casual review, but a deliberate and thorough process to determine that the proposed payment is proper and just. In summary, the audit process should ascertain that:

A. The proposed payment is for a valid and legal purpose, as per applicable policies, laws, rules and regulations;

B. The obligation was incurred by an authorized District official and the goods or services for which payment is claimed were, in fact, received; and

C. The voucher is in proper form and mathematically correct, meets legal requirements, does not include any charges for taxes from which the District is exempt, includes any discounts to which the District is entitled, does not include charges previously claimed and paid, and is in agreement with an attached purchase order.

The foregoing discussion is limited to vendor claims for goods and services, and to claims for travel of officers and employees. However, the Board of Education may, in its option, designate the claims auditor to review and certify payrolls in accordance of the provision of Section 170.2(b) of the Regulations of the Commissioner of Education.

Certification

The claims auditor is required to provide the treasurer with evidence that claims have been audited and are eligible for payment. The evidence is provided through a warrant or order on which the audited vouchers have been listed. The warrant or order is directed to the treasurer and is certified by the claims auditor.

A warrant or order should specify:

1. The number of the voucher or purchase order;

2. The name of the claimant;

3. The amount allowed;

4. The fund and the appropriation account chargeable; and

5. Any other information that might be deemed essential.

After conveying the warrant to the treasurer, the claims auditor should keep on file for reference a copy of the warrant bearing the signed certification. A copy of the suggested warrant certification is provided in exhibit 6650-E.

Ref:

  • Education Law §§1709(20-a): 1724; 2509; 2526; 2554(b)
  • NYCRR, §170.2

Adoption date: October 19, 2005
Revised date: August 9, 2017

[back to top of page]


Policy 6650-E | Claims Auditor Certification of Warrant

View the PDF version of the Claims Auditor Certification of Warrant here.

Adoption date: October 19, 2005

[back to top of page]


Policy 6660 | Independent Auditor

View the PDF version of the Independent Auditor Policy here.

The Board of Education shall appoint annually at its organizational meeting an independent certified public accountant or an independent public accountant to serve for one year as auditor and shall set the annual fees for such audit. The Board-designated independent certified public accountant or independent public accountant shall review and report annually on the financial accounts of the district. The accounts to be audited shall include the General Fund, Trust and Agency, Construction, Cafeteria, Federal Aid, Classroom Activities Fund and Payroll Fund.

A certified written report shall be submitted to the Board of Education by the date specified in Section 2116-a of the education law each year by the said Independent Auditor concerning the condition and status of the accounts upon completion of the annual audit.

Ref:

  • Education Law §§ 1700; 2526

Adoption date: October 19, 2005
Revised: October 4, 2006

[back to top of page]


Policy 6660-R | Independent Auditor Regulation

View the PDF version of the Independent Auditor Regulation here.

The Board of Education will annually designate and appoint an independent auditor for the district. The independent auditor shall serve at the pleasure of the Board. The Board shall, at least once every five years, consider proposals from interested parties (including the incumbent).

The independent auditor is responsible for:

  1. . Expressing an opinion as to whether the Board’s financial statements are fairly presented, in all material respects, in conformity with accounting principles generally accepted in the United States of America and reporting on the fairness of the additional supplementary information when considered in relation to the financial statements taken as a whole.
  2. Auditing internal control related to the financial statements and compliance with laws, regulations and the provisions of contracts or grant agreements, noncompliance with which could have a material effect on the financial statements in accordance with Government Auditing Standards.
  3. Auditing internal control related to major programs and expressing an opinion on compliance with laws, regulations and the provisions of contracts or grant agreements that could have a direct and material effect on each major program in accordance with the Single Audit Act Amendments of 1996 and OMB Circular A-133, Audits of States, Local Governments and Non-Profit Organizations.
  4. Advising about appropriate accounting principles and their application and assistance in the preparation of the Board’s financial statements, including the schedule of expenditures of federal awards.
  5. Examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements and judgment about the number of transactions to be examined and the areas to be tested.
  6. Planning and performing the audit to obtain reasonable rather than absolute assurance about whether the financial statements are free of material misstatement, whether caused by error or fraud.
  7. Informing the Board of any material errors, fraud or illegal acts that come to the auditor’s attention.
  8. Testing of documentary evidence supporting the transactions recorded in the accounts, which may include tests of the physical existence of inventories, and direct confirmation of receivables and certain other assets and liabilities by correspondence with selected individuals, creditors and financial institutions.
  9. Obtaining an understanding of the design of relevant controls that have been placed in operation, as well as assessing control risk. Tests may be performed to assess the effectiveness of certain controls that are considered relevant to preventing and detecting errors and fraud that are material to the financial statements and to preventing and detecting misstatements resulting from illegal acts and other noncompliance matters that have a direct and material effect on the financial statements.
  10. Informing the district of any matters involving internal control and its operation that are considered to be reportable conditions under standards established by the American Institute of Certified Public Accounts. Reportable conditions involve matters relating to significant deficiencies in the design or operation of the internal control that, in the independent auditor’s judgment, could adversely affect the entity’s ability to record, process, summarize and report financial data consistent with the assertions of management in the financial statements.

Adoption date: October 19, 2005

[back to top of page]


Policy 6670 | Petty Cash/Petty Cash Accounts

View the PDF version of the Petty Cash/Petty Cash Accounts Policy here.

The Board of Education will annually establish a petty cash fund of $100 and designate the Assistant Superintendent of Business as the person responsible for such fund. This action will be taken at the Annual Organizational Meeting held each July. Other petty cash funds may be established at the discretion of the Board.

Deposits to each petty cash funds may be made from time to time in amounts that shall not exceed payments made in cash from the fund, as indicated by receipts, receipted bills or other evidence of payment in form available for audit.

Payments from the funds may be made for materials, supplies or services only when payment is required upon delivery.

Petty cash funds established for ten-month activities which will not operate during July and/or August will be closed prior to June 30th of each fiscal year.

Cross-ref:

  • 6700, Purchasing

Ref:

  • Education Law §§1604(26); 1709(29)
  • 8 NYCRR §170.4

Adoption date: June 19, 2002

[back to top of page]


Policy 6670-R | Petty Cash/Petty Cash Accounts Regulation

View the PDF version of the Petty Cash/Petty Cash Accounts Regulation here.

The Petty Cash Treasurer of each petty cash fund will be responsible for the following method of record keeping:

  1. deposits to petty cash will be made in amounts which shall not exceed payments made in cash from the fund;
  2. payments made from the funds will be indicated by receipts, receipted bills or other evidence of payments in form available for audit;
  3. disbursements will be acknowledged by the signature of the individual receiving payment;
  4. each disbursement will be properly budget coded prior to the disbursement of funds; and
  5. a request to replenish the petty cash fund will be accompanied by a summary sheet, signed by the Bursar of the fund, with all expenditures properly accounted.

The Bursar will disburse petty cash only for payment for materials, supplies and services, only when payment is required upon delivery.

Petty cash funds will be closed out on June 30 and reestablished by Board of Education action at the organization meeting of the Board in July.

Adoption date: June 19, 2002

[back to top of page]


Policy 6680 | Internal Audit Function

View the PDF version of the Internal Audit Function Policy here.

The Board of Education recognizes its responsibility to ensure sound fiscal management of the district. To this end, the Board establishes an internal audit function to include:

  • Development of a risk assessment of district operations, including but not limited to a review of financial policies and procedures and the testing and evaluation of district internal controls;
  • An annual review and update of such risk assessment; and
  • Preparation of reports, at least annually or more frequently as the Board may direct, which analyze significant risk assessment findings, recommend changes for strengthening controls and reducing identified risks, and specify time frames for implementation of such recommendations.

To fulfill this function, the district may use inter-municipal cooperative agreements, BOCES shared services, or independent contractors as long as such personnel or entities performing the internal audit function comply with the Regulations of the Commissioner and meet professional auditing standards for independence between the auditor and the district. The district may also use existing personnel to fulfill this function but only if such persons shall not have any responsibilities for other business operations of the district while performing such function.

Personnel or entities performing this function shall report directly to the Board. The district’s audit committee shall assist in the oversight of this internal audit function.

Ref:

  • Education Law §2116-b

Adoption date: October 19, 2005

[back to top of page]


Policy 6690 | Audit Committee

View the PDF version of the Audit Committee Policy here.

Purpose

The Board of Education will designate and appoint an Audit Committee for purposes of overseeing and carrying out the Board’s audit policies and the performance of related duties and responsibilities. Three members shall be appointed to serve on the committee on an annual basis. A quorum of the Audit Committee shall be two members of the Committee. Employees of the school district are prohibited from serving on the committee.

Policy

The Audit Committee shall:

  1. Recommend internal and independent audit plans to the Board, specifying the areas of District operations to be reviewed for compliance with legal and regulatory requirements, operating efficiency and effectiveness;
  2. Receive and review the resulting internal audit reports; and propose recommendations to the Board for action as may be necessary and appropriate;
  3. Receive and review the report of the independent auditor on any findings commented on during the annual audit report, and the management response thereto, and propose recommendations to the Board for action as may be necessary and appropriate;
  4. Oversee the selection of the claims auditor, internal auditor and the independent auditor, pursuant to the relevant Board policies, and make recommendations to the Board for appointment to said positions.

The audit committee may conduct an executive session in accordance with law and Commissioner’s regulations. Any member of the board of education who is not a member of the audit committee may be allowed to attend an executive session if authorized by a resolution of the board of education.

It is not the intent of the Board of Education that the Audit Committee participate in or be responsible for the day to day operations of the School District or in the decisions that are the responsibility of the Superintendent of Schools or Assistant Superintendent for Business, or the other District’s administrators.

Ref:

  • Education Law §2116-c

Adoption date: October 19, 2005

[back to top of page]


Policy 6700 | Purchasing

View the PDF version of the Purchasing Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) views purchasing as serving the educational program by providing necessary supplies, equipment and related services. Purchasing will be centralized in the business office under the general supervision of the purchasing agent designated by the Board.

It is the goal of the Board to purchase competitively, without prejudice or favoritism, and to seek the maximum educational value for every dollar expended. Competitive bids or quotations shall be solicited in connection with purchases pursuant to law. The General Municipal Law requires that purchase contracts for materials, equipment and supplies involving an estimated annual expenditure exceeding $20,000 and public work contracts involving an expenditure of more than $35,000 will be awarded only after responsible bids have been received in response to a public advertisement soliciting formal bids. Purchases of the same commodity cannot be artificially divided for the purpose of avoiding the threshold. Similar procurements to be made in a fiscal year will be grouped together for the purpose of determining whether a particular item must be bid.

Any purchases funded by federal grants and programs must be in compliance with the requirements of Title 2: Grants and Agreements, of the Code of Federal Regulations (CFR), Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), §§200.318-200.326.

The District’s purchasing activity will strive to meet the following objectives:

A) To effectively supply all administrative units in the school system with needed materials, supplies, and contracted services;

B) To obtain materials, supplies and contracted services at the lowest prices possible consistent with the quality and standards needed as determined by the purchasing agent in conformance with state law and regulation and in cooperation with the requisitioning authority. The educational and physical welfare of the students is the foremost consideration in making any purchase;

C) To ensure that all purchases fall within the framework of budgetary limitations and that they are consistent with the educational goals and programs of the District;

D) To maintain an appropriate and comprehensive accounting and reporting system to record and document all purchasing transactions; and

E) To ensure, through the use of proper internal controls, that loss and/or diversion of District property is prevented.

Opportunities shall be provided to all responsible suppliers to do business with the District. Suppliers whose place of business is situated within the District may be given preferential consideration only when bids or quotations on an item or service are identical as to price, quality, and other factors.

Where permitted by law, purchases will may be made through available cooperative BOCES bids, or by “piggybacking” onto contracts of the United States or agencies thereof or the federal General Services Administration (GSA), the New York State contracts of the Office of General Services (OGS), departments or agencies of New York State, any New York State county, or any state or any county or political subdivision or district therein, or county contracts whenever such purchases are in the best interests of the District or will result in cost savings to the district. In addition, the District will make purchases from correctional institutions and severely disabled persons through charitable or non-profit-making agencies, as provided by law.

It is the District’s responsibility to review each “piggybacking” contract corresponding to a proposed purchase, upon the advice of counsel as necessary, to determine whether the original contract does not conflict with state law or regulation, and meets the following requirements:

A. the contract must have been let by the United States, or any agency thereof, any state, or any other political subdivision or district therein;

B. the contract must have been made available for use by other governmental entities, including New York State local governments;

C. the contract must have been let to the lowest responsible bidder or on the basis of best value, in a manner consistent with General Municipal Law §103. Those main elements are: (a) public solicitation of bids or offers; (b) secure or confidential bids or offers; (c) use of a common standard for bidders or offers to compete fairly; and (d) awarded to the lowest responsible bidder, or responsible offeror of best value, which optimizes quality, cost and efficiency.

In accordance with law, the Bethlehem Central School District (the District) shall give a preference in the purchase of instructional materials to vendors who agree to provide materials in alternative formats. The term “alternative format” shall mean any medium or format for the presentation of instructional materials, in addition to traditional print textbook, that is needed as an accommodation for a disabled student enrolled in the District (or program of a BOCES), including but not limited to Braille, large print, open and closed captioned, audio, or an electronic file in a format compatible with alternative format conversion software that is appropriate to meet the needs of the individual student.

The Board is also aware of the need to reduce exposure of students and staff to potentially harmful chemicals and substances used in cleaning and maintenance. In accordance with law, regulation and guidelines set forth by the Office of General Services (OGS), the District will purchase and utilize environmentally sensitive cleaning and maintenance products in its facilities whenever feasible. Environmentally sensitive cleaning and maintenance products will be procured in accordance with standard purchasing procedures as outlined in this policy and regulation. Cleansers purchased must, first and foremost, be effective so that the District may continue to purchase non-green products as necessary.

In order to ensure that the District avails itself of advantageous purchasing opportunities, the Board authorizes the director of technology and information systems to represent the District in applying for federal programs designed to discount prices for goods and services. Specifically, the director of technology and information systems will abide by the rules and regulations associated with applying for telecommunications service discounts through the Universal Service Fund (E-Rate), in addition to complying with the local purchasing policies set forth by the Board. As with all purchasing activity, appropriate documentation of the application and purchase through any federal program will be maintained by the business office.

Competitive Bidding

Purchase contracts and public works contracts subject to competitive bidding will be awarded to the lowest responsible bidder. However, the Board authorizes that purchase contracts may be awarded on the basis of best value, as defined in State Finance Law §163. Other exceptions to competitive bidding are outlined below.

In addition, the Board authorizes the receipt of sealed bids for purchase contracts in electronic format, pursuant to the provisions of General Municipal Law §103(1), which addresses proper documentation, authentication, security, and confidentiality of electronic bids.

The District shall comply with the requirements of General Municipal Law §103-g, which prohibits, with few exceptions, competitive bidding contracts with entities that invest significantly in the Iranian energy sector, as outlined in the accompanying regulation.

Exceptions to Competitive Bidding

Competitive bidding, even if the dollar value of the purchase meets the threshold established above, is not required in the following circumstances:

A. emergencies where time is a crucial factor

B. procurements for which there is no possibility of competition (sole source items); or

C. professional services that require special skill or training (see policy 6741 for guidance on purchasing professional services); or

D. purchases such as surplus or second-hand items from governmental entities, certain food and milk items, or goods and services from municipal hospitals; or

E. where the District is purchasing through (or is “piggybacking” onto) the contract of another governmental entity, where the original contract complies with the requirements of New York State law for competitive bidding.

Purchasing when Competitive Bidding Not Required

Goods and services that are not required by law to be procured by the District through competitive bidding will be procured in a manner so as to ensure the prudent and economical use of public monies, in the best interests of the taxpayers, to facilitate the acquisition of goods and services of maximum quality at the lowest possible cost under the circumstances, and to guard against favoritism, improvidence, extravagance, fraud and corruption.

Alternative proposals or quotations will be secured by requests for proposals, written or verbal quotations or any other appropriate method of procurement, except for procurements:

A. under a county contract;

B. under a state contract;

C. under a federal contract;

D. under a contract of another political subdivision;

E. of articles manufactured in state correctional institutions (correction LAN, 184 & 186); or

F. from agencies for the blind and severely disabled.

“Piggybacking” onto the contract of other governmental agencies is permitted where the original contract is in conformance with the goals of this section.

General Purchasing Provisions

The superintendent of schools, with the assistance of the purchasing agent, shall be responsible for the establishment and implementation of the procedures and standard forms for use in all purchasing and related activities in the District. Such procedures shall comply with all applicable laws and regulations of the state and the commissioner of education.

No Board member, officer or employee of the District shall have an interest in any contract entered into by the Board or the District, as provided in Article 18 of the General Municipal Law.

Comments will be solicited from those administrators involved in the procurement process before enactment of the District’s policies regarding purchasing and from time to time thereafter.

The Board shall annually review and, when needed, update this policy and corresponding regulation.

The unintentional failure to fully comply with the provisions of section 104-b of the General Municipal Law or the District’s policies regarding procurement will not be grounds to void action taken nor give rise to a cause of action against the District or any officer or employee of the District.

Cross-ref: 9120.1, Conflict of Interest

Ref:
Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (Public Law 111-195)
Education Law §§305(14); 409-i; 1604(29-a); 1709(4-a)(9)(14)(22); 2503(7-a); 2554(7-a)
General Municipal Law §§102; 103; 103-g; 104; 104-b; 109-a; 800 et seq.
State Finance Law §§ 97-g(3), (4), (5); 163; 163-b; 165-a
County Law §408-a(2)
8 NYCRR Part 114
Code of Federal Regulations (CFR), Part 200

Adoption date: January 5, 2011
Re-adoption date: July 6, 2011
Re-approved: July 3, 2012
Re-approved: July 2, 2013
Re-approved: July 1, 2014
Re-approved: July 7, 2015
Re-approved: July 5, 2016
Re-approved: July 12, 2017
Re-approved: July 2, 2018
Revised date: October 17, 2018

[back to top of page]


Policy 6700-E | Purchasing Exhibits

View the PDF version of the Purchasing Exhibits here.

Explanations of Other Methods of Competition to be Used for Non-Bid Procurements

Emergencies: Informal solicitation of quotes or otherwise, to the extent practicable under the circumstances.

Leases of Personal Property: Section 1725 of the Education Law requires that a District will be subject to competitive bidding requirements for purchase contracts when it enters into a lease of personal property.

Second-Hand Equipment from Federal and State Governments: Section 103(6) of the General Municipal Law provides a statutory exception to the competitive bidding requirement by permitting the purchase of surplus and second-hand supplies, materials or equipment without competitive bidding from the federal or state governments or from any other political subdivision or public benefit corporation with the state.

Certain Food and Milk Purchases: Section 103(a) and (10) of the General Municipal Law provides a statutory exception to the competitive bidding requirement by permitting a Board of Education to separately purchase eggs, livestock, fish and dairy products (including milk), juice, grains and varieties of fresh fruits and vegetables directly from producers, growers or certain processors without bidding.

Certain Municipal Hospital Purchases: Section 103(8) of the General Municipal Law provides a statutory exception to the competitive bidding requirement by permitting the purchase of goods, supplies and services from municipal hospitals under joint contracts and arrangements entered into pursuant to section 2803-a of the Public Health Law.

Sole Source: Section 103 of the General Municipal Law provides a statutory exception to the competitive bidding requirement in limited situations where there is only one possible source from which to procure goods or services required in the public interest (such as in the case of certain patented goods or services or public utility services).

Adoption date: June 19, 2002
Re-approved: January 5, 2011
Re-approved: July 1, 2014
Revised date: July 1, 2015
Re-approved: July 5, 2016
Re-approved: July 12, 2017
Revised date: October 17, 2018

[back to top of page]


Policy 6700-R | Purchasing Regulation

View the PDF version of the Purchasing Regulation here.

The following sets forth the procedures for the procurement of goods and services by the Bethlehem Central School District (the District):

I. Definitions

Best Value: optimizing quality, cost and efficiency. The basis for best value shall reflect, whenever possible, objective and quantifiable analysis, and may also take into consideration small businesses or certified minority- or women-owned businesses as defined in State Finance Law §163.

Purchase Contract: a contract involving the acquisition of commodities, materials, supplies or equipment. With respect to the district’s best value determinations, the term purchase contract includes contracts for service work, but excludes contracts necessary for the completion of a public work contract covered by the prevailing wage provisions of article 8 of the Labor Law, such as for building construction.

Public Work Contract: a contract involving services, labor or construction

II. General Municipal Law

The General Municipal Law requires that purchase contracts for materials, equipment and supplies involving an estimated annual expenditure exceeding $20,000 and public work contracts involving an expenditure of more than $35,000 will be awarded only after responsible bids have been received in response to a public advertisement soliciting formal bids. Similar procurements to be made in a fiscal year will be grouped together for the purpose of determining whether a particular item must be bid.

III. Competitive Bidding Required

A. Method of Determining Whether Procurement is Subject to Competitive Bidding

1. The District will first determine if the proposed procurement is a purchase contract or a contract for public work.

2. If the procurement is either a purchase contract or a contract for public work, the District will then determine whether the amount of the procurement is above the applicable monetary threshold as set forth above.

3. The District will also determine whether any exceptions to the competitive bidding requirements (as set forth below) exist (refer to section IV).

4. All advertised bids shall include the following statement required by General Municipal Law 103-g: “By submission of this bid, each bidder and each person signing on behalf of any bidder certifies, and in the case of a joint bid each party thereto certifies as to its own organization, under penalty of perjury, that to the best of its knowledge and belief that each bidder is not on the list created pursuant to paragraph (b) of subdivision 3 of section 165-a of the state finance law.”

B. Contract Combining Professional Services and Purchase

In the event that a contract combines the provision of professional services and a purchase, the District, in determining the appropriate monetary threshold criteria to apply to the contract, will determine whether the professional service or the purchase is the predominant part of the transaction.

C. Opening and Recording Bids; Awarding Contracts

The purchasing agent or departmental directors will be authorized to open and record bids. Contracts will be awarded to the lowest responsible bidder or a purchase contract bid of best value (as recommended by the purchasing agent), who has furnished the required security after responding to an advertisement for sealed bids.

In order to be considered a responsible bidder, entities must certify that they are not on the list created and maintained by the State Office of General Services cataloging significant investment in the Iranian energy sector. Such statement may be submitted electronically pursuant to General Municipal Law §103(1).

Entities that cannot make this certification may only be awarded the bid if:

1. The entity’s investment activities in Iran were made before April 12, 2012; the investment activities in Iran have not been expanded or renewed after that date; and the entity has adopted, publicized, and is implementing a formal plan to cease the investment activities in Iran and to refrain from engaging in any new investments in Iran; or

2. The District makes a determination, in writing, that the goods or services are necessary for the District to perform its functions and that, absent such an exemption, the District would be unable to obtain the goods or services for which the contract is offered.

In addition, the Board of Education (the Board) authorizes the receipt of sealed bids for purchase contracts in electronic format, pursuant to the provisions of General Municipal Law §103(1), which addresses proper documentation, authentication, security, and confidentiality of electronic bids.

D. Documentation of Competitive Bids

The District will maintain proper written documentation which will set forth the method in which it determined whether the procurement is a purchase or a public work contract. Proper written documentation will also be required when a contract is not awarded to the vendor submitting the lowest bid, setting forth the reasons therefore.

E. Determination of Best Value

Goods and services procured and awarded on the basis of best value are those that the District determines optimize quality, cost, and efficiency, among responsive and responsible bidders or offerors. Where possible, the determination shall be based on an objective and quantifiable analysis of clearly described and documented criteria as they apply to the rating of bids or offers.

In evaluating and determining to accept a higher priced offer, the District generally should use a cost-benefit analysis to show quantifiable value or savings from non-price factors that offset the price differential of the lower price offers. These non-price factors can include, but are not limited to, reliability of a product or service, efficiency of operation, energy efficiency of a product, difficulty/ease of maintenance, useful lifespan, ability to meet needs regarding timeliness of performance, and experience of a service provider with similar contracts.

The District must document its evaluation of the non-price factors in writing. The basis for the District’s best value award must reflect, whenever possible, objective and quantifiable analysis.

F. Purchase of Instructional Materials

In accordance with Education Law, the District shall give a preference in the purchase of instructional materials to vendors who agree to provide materials in alternative formats (i.e., any medium or format for the presentation of instructional materials, in addition to a traditional print textbook, that is needed as an accommodation for a disabled student enrolled in the district, including but not limited to Braille, large print, open and closed captioned, audio or an electronic file in an approved format).

The District will establish and follow a plan to ensure that every student with a disability who needs his or her instructional materials in an alternative format will receive those materials at the same time that they are available to non-disabled students.

G. Leases of Personal Property

In addition to the above-mentioned competitive bidding requirements, section 1725 of the Education Law requires that the District will be subject to competitive bidding requirements for purchase contracts when it enters into a lease of personal property. This includes bus leases as well.

H. Environmentally Sensitive Cleaning and Maintenance Products

The District will purchase and utilize environmentally sensitive cleaning and maintenance products whenever feasible. The Purchasing Agent will consult with the Green Guidelines provided by the Office of General Services.

Any legal issues regarding the applicability of competitive bidding requirements will be presented to the school attorney for review.

IV. Exceptions to Competitive Bidding Requirements

The District will not be subject to competitive bidding requirements when the Board of Education, in its discretion, determines that one of the following situations exists:

A. Emergency situations where:

1. the situation arises out of an accident or unforeseen occurrence or condition;

2. a District building, property, or the life, health, or safety of an individual on District property is affected; or

3. the situation requires immediate action that cannot await competitive bidding.

However, when the Board passes a resolution that an emergency situation exists, the District will make purchases at the lowest possible costs, seeking competition by informal solicitation of quotes or otherwise, to the extent practicable under the circumstances.

Documentation: The District will maintain records of verbal (or written) quotes, as appropriate;

B. When the District purchases surplus or second-hand supplies, materials or equipment from the federal or state governments or from any other political subdivision or public benefit corporation within the state.

Documentation: The District will maintain market price comparisons (verbal or written quotes) and the name of the government entity;

C. When the District separately purchases eggs, livestock, fish and dairy products (other than milk), juice, grains and species of fresh fruits and vegetables directly from New York State producers or growers or associations of producers and growers, subject to the requirements of General Municipal Law section 103(9) and Commissioner’s Regulations section 114.3.

Documentation: The District will maintain documentation consistent with section 114.3 of the Regulations of the Commissioner of Education;

D. When the District separately purchases milk directly from licensed milk processors employing less than forty (40) people. The amount expended in any fiscal year by the District may not exceed an amount equal to twenty-five cents multiplied by the number of days in the school year multiplied by the total enrollment of the District or exceed the current market price.

Documentation: The District will maintain documentation consistent with section 114.4 of the Regulations of the Commissioner of Education;

E. When the District purchases goods, supplies and services from municipal hospitals under joint contracts and arrangements entered into pursuant to section 2803-a of the Public Health Law.

Documentation: The District will maintain the legal authorization, Board authorization and market price comparisons;

F. When there is only one possible source from which to procure goods or services required in the public interest.

Documentation: The District will maintain written documentation of the unique benefits of the item or service purchased as compared to other items or services available in the marketplace; that no other item or service provides substantially equivalent or similar benefits; and that, considering the benefits received, the cost of the item or service is reasonable, when compared to conventional methods. In addition, the documentation will provide that there is no possibility of competition for the procurement of the goods; or

G. When the District purchases professional services that require special skill or training, such as but not limited to, audit, medical, legal or insurance services, or property appraisals.

Documentation: The District will use an RFP process for any professional services in excess of $20,000.

V. Quotes When Competitive Bidding Not Required

Goods and services that are not required by law to be procured by the District through competitive bidding will be procured in a manner so as to ensure the prudent and economical use of public monies in the best interests of the taxpayers. Alternative proposals or quotations will be secured by requests for proposals, written or verbal quotations or any other appropriate method of procurement, as set forth below.

A. Methods of Documentation

1. Verbal Quotations: the telephone log or other record will set forth, at a minimum: the date, item or service desired, price quoted, name of vendor, and name of vendor’s representative;

2. Written Quotations: vendors will provide, at a minimum: the date, description of the item or details of service to be provided, price quoted, and name of contact.

3. Requests for Proposals: the District will utilize (an RFP process) to engage professional services providers for any professional services in excess of $20,000.

Refer to Exhibits 6700-E.1 and 6700-E.2 for further requirements as to type and number of quotes or other required documentation.

B. Purchases/Public Work: Methods of Competition to be Used for Non-Bid Procurements; Documentation to be Maintained

The District will require the following methods of competition be used and sources of documentation maintained when soliciting non-bid procurements in the most cost-effective manner possible:

1. Purchase Contracts up to $20,000 and Public Work Contracts up to $35,000: refer to Exhibit 6700-E.1 for required number of verbal or written quotes, depending on dollar volume of purchases.

2. Emergencies: Verbal quotes, insofar as practicable under the exigent circumstances. Documentation will include notations of verbal quotes.

3. Property, Casualty and Liability Insurance: “Requests for Proposals” (RFPs) should be issued on a seven (7) year cycle.

4. Professional Services: Documentation will include an RFP if services exceed $20,000 and written proposals if services are less than $20,000.

5. Second Hand Equipment from Other Governments: Documentation will include market price comparisons (verbal or written quotes) and the name of the government.

6. Written Quotes for Certain Food and Milk Purchases: Documentation will be consistent with sections 114.3 and 114.4 of the Regulations of the Commissioner of Education.

7. Certain Municipal Hospital Purchases: Documentation will include the legal authorization, Board authorization, and market price comparisons.

8. Sole Source: Documentation will include, among other things, the unique benefits of the patented item as compared to other items available in the marketplace; that no other item provides substantially equivalent or similar benefits; and that considering the benefits received, the cost of the item is reasonable, when compared to conventional methods. In addition, the District will document that there is no possibility of competition for the procurement of the goods.

VI. Exceptions to Competitive Bidding Requirements

The district will not be required to secure alternative proposals or quotations for those procurements:

A. under a county contract;

B. under a state contract;

C. under a federal contract;

D. under a contract of another political subdivision;

E. of articles manufactured in state correctional institutions; or

F. from agencies for the blind and severely disabled.

“Piggybacking” onto the contract of other governmental agencies is permitted where competitive bidding requirements would otherwise apply, and the original contract is in conformance with the goals of the District’s policy and regulation for purchasing when competitive bidding is not required. Factors relevant to the decision to piggyback” may include cost, staff time, delivery arrangements, quality of goods and services, and suitability of such goods and services to the District’s needs. The District will keep documentation indicating why “piggybacking” is in the best interests of the District, copies of the original contract, and that the originating contract was let in a manner consistent with applicable competitive bidding requirements.

VII. Procurements from Other than the “Lowest Responsible Dollar Offeror”

The District will provide justification and documentation of any contract awarded to an offeror other than the lowest responsible dollar offeror, setting forth the reasons why such award is in the best interests of the District and otherwise furthers the purposes of section 104-b of the General Municipal Law.

VIII. Internal Control

The Board authorizes the superintendent of schools, with the assistance of the purchasing agent, to establish and maintain an internal control structure to ensure, to the best of their ability, that the District’s assets will be safeguarded against loss from unauthorized use or disposition, that transactions will be executed in accordance with the law and District policies and regulations, and recorded properly in the financial records of the District.

Comments will be solicited from those administrators involved in the procurement process before enactment of the District’s regulations regarding purchasing and from time to time thereafter.

All District regulations regarding the procurement processes will be reviewed by the Board at least annually.

No person employed by the district shall participate in the selection, award, or administration of any contract on behalf of the District for the purchase, sale or lease of real or personal property, services of any nature, or for insurance with any business in which an immediate family member has a financial or other interest in, or a tangible personal benefit from, said business. (# 9120.1, Conflict of Interest).

Any proposed purchases from businesses owned by an employee of the District must be reviewed and approved in advance by the chief business and financial officer.

The unintentional failure to fully comply with the provisions of section 104-b of the General Municipal Law or the District’s regulations regarding procurement will not be grounds to void action taken or give rise to a cause of action against the District or any officer or employee of the District.

Re-adoption date: January 5, 2011
Re-adopted date: July 1, 2014
Re-approved: July 7, 2015
Re-approved: July 5, 2016
Re-approved: July 12, 2017
Revised date: October 17, 2018

[back to top of page]


Policy 6705 | Sweatshop Free Purchasing

View the PDF version of the Sweatshop Free Purchasing Policy here.

The Bethlehem Central School District is opposed to the abuses of child labor and otherwise substandard working conditions in the manufacturing of products and materials offered for sale to school districts, and in an effort to ensure that apparel utilized by the district is not manufactured in such conditions, it hereby promulgates the following policy:

To be eligible to be vendor or other supplier of apparel to the district, a vendor, either directly or by its supplier or manufacturer, must as a part of its bid documents, affirmatively state to the district the following:

  1. that no person younger than the age allowed by the law of the country in which the particular product, or material for the product was produced, was employed or otherwise engaged in the production or manufacturing of the apparel and that in no event, was a person younger than the age of fourteen years, so employed;
  2. that if the laws of the country in which the particular product or material for the product was produced provide for compulsory education, no person required to attend upon such education was employed during the hours education in normally provided; and
  3. that the manufacturer of the particular product or of the materials for said product is otherwise in full compliance with the laws, rules and regulations governing the involved workplace, including, but not limited to, laws, rules and regulations governing or relating to wage and benefit levels.

In addition, such a vendor must, as part of its bid, acknowledge the following:

  1. that a bid not complying with the above requirements will b rejected.
  2. that determination of compliance will be solely at the discretion of the school district.
  3. that the vendor will be held strictly responsible for the information provided pursuant to this requirement whether such is upon said vendor’s direct knowledge or based upon affirmations or information provided by said vendor by a manufacturer or supplier.

Adoption date: September 18, 2002

[back to top of page]


Policy 6705-E | Sweatshop Free Purchasing Exhibit

View the PDF version of the Sweatshop Free Purchasing Exhibit here.

Sweatshop Free Purchasing Exhibit

Policy

Please be advised that the school district has adopted a policy to ensure that apparel purchased or otherwise acquired by it, is manufactured and supplied by employers that do not utilize underage labor or maintain or allow sweatshop conditions in its manufacture or the manufacture of the materials used in same.

Pursuant to the above-mentioned policy, the district will only use vendors or other suppliers that comply with its terms and conditions as set forth more particularly below and which otherwise meet the requirement of law relative to competitive bidding. Accordingly, the district will require that all covered vendors provide specific information regarding the work conditions under which the involved merchandise was manufactured and failure to provide all such information will disqualify that vendor from consideration in the bidding process. In addition, should it come to light a bid is let that the information provided by the successful bidder was false or erroneous, the contract or awarded may be terminated.

Standards

To be eligible to be a vendor or other supplier of apparel to the district, a vendor, either directly or by its supplier or manufacturer, must as part of its bid documents, affirmatively state to the district by execution and submission of this statement with its bid, the following:

  1. that no person younger than the age allowed by the law of the country in which the particular product, or material for the product was produced, was employed or otherwise engaged in the production or manufacturing of the apparel and that in no event, was a younger than the age of fourteen years, so employed;
  2. that if the laws of the country in which the particular product or material for the product was produced for compulsory education, no person required to attended upon such education was employed during the hours when such education is normally provided; and
  3. that the manufacturer of the particular product or of the materials for said product is otherwise in full compliance with the laws, rules and regulations governing the involved workplace.

Failure to Comply

Any bid not complying with the above requirements will be rejected.

Determination of compliance will be solely at the discretion of the school district.

The vendor will be held strictly responsible for the information provided pursuant to this requirement whether such is upon said vendor’s direct knowledge or based upon affirmations or information provided said vendor by a manufacturer or supplier.

This document is part of your bid and must be signed and submitted with that bid. By signing this document you affirmatively state that you and your supplies and manufacturers are in compliance with this policy and that you acknowledge the penalties for failure to provide same or for falsely or erroneously providing same whether directly, or through the statements of your supplier or manufacturer.

Adoption date: September 8, 2002

[back to top of page]


Policy 6800 | Payroll Procedures

View the PDF version of the Payroll Procedures Policy here.

The Board of Education recognizes the importance of the payroll function to the effective administration of the district. The Board is also aware that this is an area at risk of fraud and abuse. The Board directs the Superintendent to establish procedures to reasonably ensure the accuracy and integrity of the payroll system.

A duly certified payroll is one that has been examined and approved by the Superintendent of Schools, or designee. It shall be the responsibility of the Assistant Superintendent for Business and his/her staff to prepare all payrolls.

The Superintendent will initiate a periodic test to verify the accuracy and appropriateness of the district payroll. The test shall confirm that individuals listed on the payroll are currently employed by the district, and that the title, hours worked, and wages listed are correct. The test shall also confirm that individuals listed as employees are indeed employees and not independent contractors. (The procedure for determining employment status is outlined in policy 9500, Compensation and Benefits.) The Board will evaluate the results of the test and determine if improvements need to be made.

Payroll procedures will also be reviewed periodically by the internal auditor. The internal auditor will report findings and recommendations to the Board. It is the intention of the Board to take reasonable and necessary steps to safeguard the district’s payroll.

Cross-ref:

  • 9500, Compensation and Benefits

Ref:

  • Education Law Article 11; §§ 1604;1719;2116-a
  • Retirement and Social Security Law §34
  • 2 NYCRR §§315.3

Adoption date: 7-9-08

[back to top of page]


Policy 6830 | Travel Expense Reimbursement

View the PDF version of the Expense Reimbursement Policy here.

Bethlehem Central School District (the District) employees, officials, and members of the Board of Education (the Board) will be reimbursed for reasonable, actual, and necessary out-of-pocket expenses that are legally authorized and incurred while traveling for school-related activities.

Only expenses necessary to the purpose of the travel are reimbursable. The Business Office will issue tax exemption certificates as appropriate.

The Board will consider and determine which meetings and conferences may be attended by Board members. The District superintendent will determine, in the first instance, whether attendance by District staff at any conference or professional meeting is in the best interest of the District and eligible for reimbursement of expenses under this policy.

To obtain reimbursement, the claimant must complete and sign a claim form, attach all receipts or other expense documentation, and proof of attendance together with a copy of the approved conference attendance request form, and submit the same to the appropriate administrator. Reimbursement will only be made after such claim has been audited and allowed.

Transportation

To be eligible for reimbursement, transportation must be by a reasonable and economical method. Mileage will be reimbursed at the federal Internal Revenue Service rate. Gasoline will not be reimbursed. Parking and tolls are eligible.

Lodging

To be eligible for reimbursement, lodging must be at an accommodation that is reasonably priced and economical. Reasonable is determined based on the predetermined rate secured by the organization sponsoring the event, or within the federal travel reimbursement rate for a specified region/location.

Meals

To be eligible for reimbursement, meals and tips must reasonable, and within the federal travel reimbursement rates for a specified region/location, including adjustments as may be required for the first or last day of travel. Alcoholic beverages are not reimbursable.

Personal Expenses

The District does not reimburse persons traveling on District-related business for personal expenses including, but not limited to, entertainment, health club facilities, and telecommunications/internet costs unrelated to District business.

Cross-ref 9170, Meals and Refreshments

Ref: Education Law §§1604(27); 1709(30); 1804; 2118; 3023; 3028
General Municipal Law §77-b

Adoption date: June 19, 2002 
Revised: February 28, 2007
Revised: February 8, 2018

[back to top of page]


Policy 6900 | Disposal of District Property

View the PDF version of the Disposal of District Property Policy here.

Building administrators and supervisors shall be responsible for identifying obsolete or surplus equipment and supplies in their areas of responsibility. Annually, a determination shall be made of equipment and materials that are obsolete and cannot be salvaged or utilized effectively or economically by the District. Such items shall be sold at the highest possible price or discarded, under the direction of the school business administrator.

Following authorization from the school business administrator, the administrator or supervisor shall make arrangements with the director of Operations and Maintenance (O&M) for all items, except technology property, to be disposed of. For technology items, arrangements should be made with the director of Technology. The directors of O&M and Technology will be responsible for determining the appropriate means for disposal of property, as described below.

Sale is not always the most appropriate means of disposal. Thus, the school business administrator and the directors of O&M and Technology are authorized to reassign surplus equipment and supplies and/or materials in the following manner:

1. Transfer items to another building or department where needed;

2. Transfer items to a centralized storage area for potential usefulness; or

3. Use as a trade-in for new equipment.

If these methods are exhausted, sale of the property is appropriate. Upon approval by the school business administrator, items may be sold in the following manner:

1. Sell items in a public sale, as competition usually results in the best price and is a good indicator of the District’s efforts to obtain the highest price possible. In the event of a public sale, notice of availability of such equipment and requests for bids shall be disseminated through the District-designated service for asset disposal. The general public, as well as staff members who are not Board members, officers, or involved in the purchasing or sale function, shall be eligible to bid on the equipment and/or supplies. If an employee in the purchasing or sale function wishes to bid on the equipment and/or supplies, written authorization from the chief business and financial officer is required.

2. Sell remaining items as scrap, for the best obtainable amount.

If items do not sell and the asset has no discernable value, the items can be donated to a governmental or nonprofit organization, or discarded in the safest, least expensive manner.

Disposal of Textbooks

Textbooks may lose their value to the educational program because of changes in the curriculum or may contain outdated material and /or be in poor condition.

The assistant superintendent for instruction (or their designee) is authorized to dispose of textbooks in the following manner: sale of textbooks; donation to governmental or nonprofit organization, or dispose as trash.

All proceeds from the sale of District equipment, supplies, and/or textbooks shall be deposited into the General Fund.

Ref:

  • General Municipal Law §§51;800 et seq.

Cross-ref:

  • 6645, Capital Assets Accounting
  • 6640, Inventories of Capital and Non-Capital Assets

Adoption date: February 28, 2007
Revised date: August 9, 2017

[back to top of page]