Policies, plans and regulations updated during the school year

Filed in Archive by hanna.teal on November 21, 2016

Updating the district’s policy manual is an ongoing process. While a complete list of policies is posted to the Web site, the Board of Education has a policy committee who review, revise, and adopt district policies and regulations as needed throughout the school year.

Below are the policies and regulations reviewed and adopted by the Board of Education during the 2019-20 school year, beginning in July 2019.

5280 Interscholastic Athletics
5300 Code of Conduct
6240 Investments
6410 Authorized Signatures
6500 Allegations of Fraud
6500-R Allegations of Fraud Regulation
6640 Inventories of Capital and Noncapital Assets
6645 Capital Assets Accounting
6650 Claims Auditor
6650-R Claims Auditor Regulation
6660 Independent Auditor
6660-R Independent Auditor Regulation
6670 Petty Cash/Petty Cash Accounting
6670-R Petty Cash/Petty Cash Accounting Regulation
6680 Internal Audit Function
6690 Audit Committee
6705 Sweatshop-Free Purchasing
6705-E Sweatshop-Free Purchasing Exhibit
6830 Travel Expense Reimbursement
7100 Facilities Planning
7360 Construction Contracts, Bidding and Award
7365 Construction Safety
8112 Health and Safety Committee
8130 School Safety Plans and Teams
Archive

Policy 5280 | Interscholastic Athletics

View the PDF version of the Interscholastic Athletics Policy here.

Interscholastic athletics is an integral and desirable part of the secondary school educational program of the Bethlehem Central School District (the District). Individual and team sports shall be based upon comprehensive physical education instruction and intramural activities, seeking broad participation from all eligible secondary students. Lifetime or carryover sports are to be particularly encouraged and supported. Parity in the number and kind of sports activities for girls and boys is a clear objective of the District.

Student eligibility for participation on interscholastic teams shall include:

authorization by the school physician;
written consent from parent(s) or guardian(s); and
endorsement by the principal based on established rules and various league and State Education Department regulations.

Although the District will take reasonable care to protect student athletes, students may still sustain injuries. In order to most effectively ensure student safety, open communication between students, parents, and coaches about the child’s medical condition is critical. Coaches, and other appropriate staff, will receive guidance and training regarding recognition of injuries and removal of the student athlete from play in the event of injury. Parent(s) and/or guardian(s) and/or students are expected to report injuries so that the student’s health can be protected.

In the case of a suspected or actual head injury, a student must be removed from play immediately. In order to resume participation following injury, including head injury, the student needs to receive medical clearance. The superintendent, in consultation with appropriate District staff, including the school physician, will develop regulations and procedures to guide the process of return to play.

In recognition of the importance of appropriately managing head injuries, the Board of Education (the Board) authorizes the creation of a Districtwide Concussion Management Protocol that outlines procedures to follow in managing head injuries; as well as guidance in returning to play and/or activities following a concussion. The Concussion Management Protocol provides guidelines regarding the responsibilities of the school administrator, student, parent(s) and/or guardian(s), medical director, school nurse, athletic director, coach, athletic trainer, director of physical education, physical education teacher, classroom teacher, and guidance counselor, as appropriate.

In accordance with existing Regulations of the Commissioner of Education, the Board may permit students in grades 10-12 to receive credit towards high school graduation equivalent to physical education for participation in interscholastic athletics as well as approved nonscholastic activities. Such credit will, in addition to other requirements, be contingent upon proven cardiovascular and physical fitness and competency in lifetime or carryover sports. Standards for such fitness and competency shall be developed by the administration.

Cross-ref: 5405, Wellness Policy on Nutrition and Physical Education
5405R, Wellness Policy on Nutrition and Physical Education Regulation
5420, Student Health Services
5280.1, Concussion Management

Ref: Education Law §§ 305(42), 1709 (8-a); 3001-b 8 NYCRR §§135.4, 136.5
Guidelines for Concussion Management in the School Setting, New York State
Education Department, June 2012.
Concussion Management and Awareness Act, July 1, 2012.
Concussion Management Support Materials, www.nysphsaa.org
Santa Fe Indep. Sch. Dist. V. Doe, 520 U.S. 290 (2000) (constitutionality of
student-led prayers at interscholastic athletic activities)

Adoption date: September 3, 2013
Revised date: August 7, 2019

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Policy 5300 | Code of Conduct

View the PDF version of the Code of Conduct here.

Adoption Date: June 20, 2001
Revised: September 1, 2004
Revised: July 11, 2006
Reapproved: July 11, 2007
Reapproved: July 9, 2008
Reapproved: July 1, 2009
Amended and Reapproved: July 7, 2010
Amended and Reapproved: September 1, 2010
Amended and Reapproved: November 3, 2010
Amended and Reapproved: July 6, 2011
Amended and Reapproved: November 16, 2011
Amended and Reapproved: July 3, 2012
Reapproved: July 2, 2013 Reapproved: July 1, 2014
Amended and Reapproved: July 7, 2015
Reapproved: July 5, 2016
Re-approved: July 12, 2017
Amended and Reapproved: July 2, 2018
Amended and Reapproved: August 7, 2019

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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 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
Reapproved: July 5, 2016
Reapproved: July 12, 2017
Reapproved: July 2, 2018
Reapproved: August 7, 2019

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Policy 6410 | Authorized Signatures

View the PDF version of the Authorized Signatures Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) authorizes the signature on checks issued against all accounts of the 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 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.

Extraclassroom 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 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
Reapproved: August 7, 2019

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Policy 6500 | Allegations of Fraud

View the PDF version of the Allegations of Fraud here.

Covered Employees
All Board of Education members and officers, Bethlehem Central School District (the 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 District is required to disclose such information according to the reporting procedures found in Policy 6500-R, Allegations of Fraud Regulation.

Adoption date: February 28, 2007
Reapproved date: August 7, 2019

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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 Organizational Chart of the Bethlehem Central School District (the District). 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, the independent (external) auditor, the school attorney, members of the District Audit Committee, State Comptroller’s Office, or the president of the Board of Education (the Board).

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 District 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, the independent (external) auditor, the school attorney, or the president of the Board. All complaints will be reported to the Board 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 and/or wrongful conduct may also face appropriate disciplinary action.

Ref: Civil Service Law § 75-6

Adoption date: February 28, 2007
Revised date: August 7, 2019

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Policy 6640 | Inventories of Capital and Noncapital Assets

View the PDF version of the Inventories of Capital Assets Accounting 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 noncapital assets that are at greater risk for misappropriation.

All equipment and property should be clearly labeled as property of the District 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 noncapital 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;
Assistive Technology assets;
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 noncapital 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
Revised date: August 7, 2019

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Policy 6645 | Capital Assets Accounting

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

Accounting of Fixed Assets

The school business administrator of the Bethlehem Central School District (the District) 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:

Maintain a physical inventory of assets;
Establish accountability; and
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 purposes (GASB #34) and categories of assets is as follows:

Land

Land improvements

$ 5,000

$25,000

Buildings and improvements

$50,000

Furniture and equipment

Vehicles

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 Noncapital Assets
6900, Disposal of District Property

Adoption date: February 28, 2007
Revised date: August 9, 2017
Reapproved date: August 7, 2019

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Policy 6650 | Claims Auditor

View the PDF version of the Claims Auditor Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) will annually designate and appoint a claims auditor for the District. The claims auditor shall serve at the pleasure of, and 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:

that the proposed payment is for a valid and legal purpose;
that the obligation was incurred by an authorized District official;
that the items for which payment is claimed were in fact received or, in the case of services, that they were actually rendered;
that the obligation does not exceed the available appropriation; and
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 date: October 4, 2006
Revised date: August 9, 2017
Reapproved date: August 7, 2019

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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 Bethlehem Central School District (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 Board), the clerk or treasurer of the Board, 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 shall designate and appoint a claims auditor on an annual basis at the District’s reorganizational meeting in July.

Primary Relations

Board of Education
The claims auditor is an employee of, and directly responsible to, the Board. 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, but is not expected to attend regularly.

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

Chief Business and Financial Officer
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.

Duties and Responsibilities

The claims auditor is directly responsible to the Board. When the position of claims auditor has been established, and a qualified claims auditor has been appointed, the powers and duties of the Board 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 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.

Track the numerical sequence of checks being approved.
Prove the mathematical accuracy of all computations. This should include verification of extensions and additions and the recalculation of any discount.
Determine that the charges are not duplicates of items already paid.
Compare the voucher with the purchase order.
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.
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 bills 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.
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.
Observe whether the official who gave rise to the claim has indicated his/her approval.
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. Exceptions shall be reported to the Board.

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 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:

The number of the voucher or purchase order;
The name of the claimant;
The amount allowed;
The fund and the appropriation account chargeable; and
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
Reapproved date: August 7, 2019

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Policy 6660 | Independent Auditor

View the PDF version of the Independent Auditor Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) shall appoint annually at its organizational meeting an independent certified 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 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, Capital Projects, Debt Service, School Lunch, Special Aid, and Classroom Activities Fund.

A certified written report shall be submitted to the Board 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 date: October 4, 2006
Revised date: August 7, 2019

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Policy 6660-R | Independent Auditor Regulation

View the PDF version of the Independent Auditor Regulation here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) 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:

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 and reporting on the fairness of the additional supplementary information when considered in relation to the financial statements taken as a whole.
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.
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 standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States; and the audit requirement of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).
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.
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.
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.
Informing the Board of any material errors, fraud, or illegal acts that come to the auditor’s attention.
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.
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.
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
Revised date: August 7, 2019

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Policy 6670 | Petty Cash/Petty Cash Accounts

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

The Board of Education (the Board) of the Bethlehem Central School District will annually establish a petty cash fund of $100 and designate the chief business and financial officer 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 fund 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 a form available for audit.

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

Cross-ref: 6700, Purchasing

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

Adoption date: June 19, 2002
Revised date: August 7, 2019

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

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

The custodian of each petty cash fund in the Bethlehem Central School District will be responsible for the following method of record keeping:

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

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

Petty cash funds will be reauthorized by Board of Education (the Board) action at the organization meeting of the Board in July.

Adoption date: June 19, 2002
Revised date: August 7, 2019

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Policy 6680 | Internal Audit Function

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

The Board of Education (the Board) of the Bethlehem Central School District (the District) 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 intermunicipal 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 of Education 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
Reapproved date: August 7, 2019

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Policy 6690 | Audit Committee

View the PDF version of the Audit Committee Policy here.

Purpose

The Board of Education (the Board) of the Bethlehem Central School District (the District) 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 District are prohibited from serving on the committee.

Policy

The Audit Committee shall:

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;
Receive and review the resulting internal audit reports, and propose recommendations to the Board for action as may be necessary and appropriate;
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;
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 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.

It is not the intent of the Board that the Audit Committee participate in or be responsible for the day-to-day operations of the District or in the decisions that are the responsibility of the superintendent or chief business and financial officer, or the other District’s administrators.

Ref: Education Law §2116-c

Adoption date: October 19, 2005
Reapproved date: August 7, 2019

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Policy 6705 | Sweatshop-Free Purchasing

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

The Bethlehem Central School District (the 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:

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;
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 is normally provided; and
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:

that a bid not complying with the above requirements will be rejected;
that determination of compliance will be solely at the discretion of the District; and
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 to said vendor by a manufacturer or supplier.

Adoption date: September 18, 2002
Reapproved date: August 7, 2019

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Policy 6705-E | Sweatshop-Free Purchasing Exhibit

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

Policy

Please be advised that the Bethlehem Central School District (the 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 that 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. 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:

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;
that if the laws of the country in which the particular product or material for the product was produced provided for compulsory education, no person required to attend upon such education was employed during the hours when such education is normally provided; and
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 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 to 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 suppliers 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
Revised date: August 7, 2019

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Policy 6830 | Travel Expense Reimbursement

View the PDF version of the Travel 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 date: February 28, 2007
Revised date: February 8, 2018
Reapproved date: August 7, 2019

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Policy 7100 | Facilities Planning

View the PDF version of the Facilities Planning Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) is ultimately responsible for the regular operation and orderly development of the District’s physical plant. In carrying out this responsibility, the Board is concerned with both short-term and long-range planning.

The Board delegates to the superintendent the responsibility for formulating and implementing, subject to approval by the Board, the following plans for school building facilities:

Comprehensive long-range facilities development plan – This plan shall be kept current and re-evaluated at least annually. It will include an appraisal of the following:

a. educational philosophy of the District, with resulting administrative organization and program requirements;

b. present and projected pupil enrollments;

c. space use and state-rated pupil capacity of existing facilities;

d. priority of need of maintenance, repair, or modernization of existing facilities, including consideration of the obsolescence and retirement of certain facilities; and

e. the provision of additional facilities.

2. Five year capital facilities plan – This plan will include the following:

a. a yearly breakdown of the estimated expenses for construction, additions, alterations, major repairs, system replacement and repairs, and maintenance and energy consumption; and

b. a Districtwide building inventory including the number and type of facilities; the age, capacity, use, and size of each building; and each buildings safety ratings, energy sources, probable useful life, major system repairs needed, and asbestos reports.

Ref: 8 NYCRR Part 155 (Educational Facilities)

Adoption date: June 19, 2002
Revised date: August 7, 2019

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Policy 7360 | Construction Contracts, Bidding and Award

View the PDF version of the Construction Contracts, Bidding and Award Policy here.

All construction contracts for the Bethlehem Central School District (the District) in excess of $20,000 and purchases of equipment at a cost in excess of $10,000 must be advertised, bid on, and awarded to the lowest responsible bidder in accordance with the District’s policy and procedures for competitive bidding. No school building may be erected, purchased, repaired, enlarged, or remodeled at an expense that will exceed $100,000, nor may an advertisement for bids for the execution of the plans and specifications for a school building be placed, until the plans and specifications have been submitted to and approved by the commissioner of Education. Such plans and specifications will show in detail the ventilation, heating, and lighting of such buildings. Construction documents that have been modified subsequent to the commissioner’s approval may not be advertised for bid until the commissioner has approved such modifications. The successful contractor will enter into a formal contract, prepared by the District attorney, detailing all aspects of the construction to take place.

Every District contract for construction, alteration, or repair of any public building or public works, or for the manufacture, sale, or distribution of material, equipment, or supplies, shall contain provisions prohibiting discrimination on account of race, creed, color, religion, national origin, disability, marital status, age, sex, sexual orientation and/or gender identity.

All contractors to whom a contract has been awarded must provide a performance bond obtained through a bonding company licensed to do business in New York State. The required amount of such bond shall be included in the Statement of General Conditions set forth in the advertisement or notice for bids.

All contractors shall guarantee that prevailing rates of wage, as provided for in the Labor Law §220, shall be paid to all workers on public projects in the District.

Ref: Education Law §§408; 2556
General Municipal Law §§101; 103; 103-d; 106; 108; 109
Labor Law §§220; 220-e; 222; 222-a

Adoption date: June 19, 2002
Revised date: August 7, 2019

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Policy 7365 | Construction Safety

View the PDF version of the Construction Safety Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) recognizes the District’s responsibility to provide a safe school environment for students and staff during construction and maintenance projects.

The superintendent shall be responsible for ensuring that District procedures for safeguarding the safety and health of students and staff are consistent with state law and regulation, including the Uniform Code of Public School Building Inspections, Safety Rating and Monitoring and the Uniform Safety Standards for School Construction and Maintenance Projects. Specifically, the superintendent shall be responsible for the following items at the specified phase of the construction project.

Preconstruction

Ensuring proper planning for the safety of building occupants during construction or maintenance activities.
Hiring a New York State-licensed architect or engineer for projects costing more than $5,000.
Ensuring safety issues are addressed for bid specifications and contract documents.
Providing notice to parents, staff, and the community in advance of any construction project costing $10,000 or more to be conducted in an occupied school building. The notice is to be given at least two months prior to the date on which construction is to begin, except in the case of emergency construction projects, in which case notice will be given as soon as practical. The notice will provide information on the District’s obligation to provide a safe school environment during construction projects. The notice may be given by publication in the District newsletter, direct mailings, or by holding a public hearing on the project.
Revising the District’s emergency management plan, when appropriate, to accommodate the construction process, including a revised emergency exit plan and emergency evacuation and relocation procedures during the construction process.

During Construction

Monitoring of construction and maintenance activities to check for safety violations and to ensure that certificate of occupancy requirements are continuously maintained.
Ensuring that all areas to be disturbed through renovation or demolition are tested for lead and asbestos.
Investigating and responding to health and safety complaints.
Conducting fire drills during construction to familiarize students and staff with revised emergency procedures.
Ensuring compliance with statutory and regulatory requirements regarding noise abatement, exits, ventilation, air quality, fire and hazard prevention, chemical fumes, gases and other contaminants, asbestos and lead paint abatement, and radon testing and mitigation.

Postconstruction

Conducting a walk-through inspection with the Health and Safety Committee to confirm the area is ready to be reopened for use.

Cross-Ref.: 7100, Facilities Planning
8110, School Building Safety
8112, Health and Safety Committee
8130, School Safety Plans and Teams

Ref: Education Law §§ 409-d (Comprehensive Public School Building Safety Program;
409-e (Uniform Code of Public School Buildings Inspection, Safety Rating
and Monitoring)
8 NYCRR Part 155.4 (Uniform Code of Public School Building Inspections, Safety
Rating and Monitoring); 155. 5 (Uniform Safety Standards for School
Construction and Maintenance Projects)
9 NYCRR Parts 600-1250 (Uniform Fire Prevention & Building Code)

Adoption date: June 19, 2002
Reapproved date: August 7, 2019

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Policy 8112 | Health and Safety Committee

View the PDF version of the Health and Safety Committee Policy here.

The Board of Education (the Board) of the Bethlehem Central School District (the District) recognizes the importance of the participation of District staff and parents in promoting a safe, secure, and healthy school environment. In accordance with the Commissioner’s Regulations, the Board or designee will appoint a Health and Safety Committee composed, at a minimum, of representation from District officials, staff, and bargaining units.

The committee will participate in monitoring the condition of occupied school buildings to ensure that they are safe and maintained in a state of good repair. The superintendent will ensure that the committee is appropriately involved in all of the activities required by the Commissioner’s Regulations. Specifically, the committee will:

Participate in the investigation and disposition of health and safety complaints.
Ensure that at least one member of the committee participates in the annual visual inspection.
Consult with District officials in completing safety ratings of all occupied school buildings.
Monitor safety during school construction projects, including periodic meetings to review issues and address complaints related to health and safety resulting from the project.
Upon completion of a construction project, conduct a walk-through inspection to ensure the area is ready to be reopened for use.

Expanded Health and Safety Committee

During construction projects, the Health and Safety Committee will be expanded to include the architect, construction manager, and contractor. This expanded committee will:

Participate in the investigation and disposition of health and safety complaints regarding the construction or maintenance project.
Meet periodically to review issues and address complaints regarding health and safety arising from construction.
Monitor safety during construction projects.
After the work is completed, conduct a walk-through inspection to confirm that the area is ready to be reopened for use.

Cross-Ref.: 7365, Construction Safety
8110, School Building Safety
8220, Buildings and Grounds Maintenance and Inspection

Ref.: 8 NYCRR Part 155.4 (Uniform Code of Public School Building Inspections, Safety
Rating and Monitoring)

Adoption date: June 19, 2002
Revised date: August 7, 2019

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Policy 8130 | School Safety Plans and Teams

View the PDF version of the School Safety Plans and Teams Policy here.

Emergencies and violent incidents in schools are critical issues that must be planned for and addressed in an expeditious and effective manner. The Board of Education (the Board) of the Bethlehem Central School District (the District) recognizes its responsibility to maintain a comprehensive Districtwide School Safety Plan and Building-Level Emergency Response Plan(s) regarding crisis intervention and emergency response and management.

Taken together, the District and building plans shall provide a comprehensive approach to addressing school safety and violence prevention, and provide the structure where all individuals can fully understand their roles and responsibilities for promoting the safety of the entire school community. The plans shall be designed to prevent or minimize the effects of serious violent incidents and emergencies and to facilitate the District’s coordination with local and county resources. The plans shall also address risk reduction/prevention, response, and recovery with respect to a variety of emergencies and violent incidents in District schools.

In accordance with state law and regulation, the District shall have the following school safety teams and plans to deal with crisis intervention and emergency response and management:

Comprehensive Districtwide School Safety Team and Plan

The Board will appoint a Districtwide school safety team that includes, but is not be limited to, a representative from the Board; student, teacher, administrator, and parent organizations; school safety personnel; and other school personnel. This team shall be responsible for the development and review of a comprehensive Districtwide school safety plan. The plan shall cover all District buildings and shall address crisis intervention and emergency response and management at the District level. It shall include all those elements required by law and regulation. The Board will annually approve the Districtwide school safety plan.

A copy of the plan shall be available in the District offices for inspection by the public.

Building-Level Emergency Response Teams and Plans

Each principal shall be responsible for annually assigning a school safety team that includes representation from teachers, administrators, school safety personnel, other school personnel, local law enforcement officials, and local ambulance and other emergency response agencies. The school safety team shall be responsible for the development and review of a building-level emergency response plan for each District building. The plan(s) shall address communication, emergency response, and evacuation at the building level and shall include all procedures required by law and regulation.

Within each building, the school safety team shall designate:

an emergency response team that includes appropriate school personnel; local law enforcement officials; and representatives from local, regional, and/or state emergency response agencies to assist the school community in responding to a serious violent incident or emergency; and
a post-incident response team that includes appropriate school personnel, medical personnel, mental health counselors, and other related personnel to assist the community in coping with the aftermath of a serious violent incident or emergency.

The principal shall be responsible for conducting at least one test every school year of the emergency response procedures under this plan including procedures for sheltering and early dismissal.

To maintain security, and in accordance with law, the building-level emergency response plan(s) shall be confidential and shall not be subject to disclosure under the Freedom of Information Law or any other law.

Team Appointments

On an annual basis, the members of the District level team will be appointed by the Board while the building principal will assign the building-level team members. The Board and the principals will make an effort to include other persons beyond those groups identified in law and policy who can contribute to ensuring continuity among the plans.

Annual Review and Report

Each plan shall be reviewed by the appropriate school safety team by September 1st every year and updated as needed. In conducting the review, the building-level teams shall consider any changes in personnel, local conditions, and other factors, including an evaluation of the results of the annual test of the emergency response procedures that may necessitate updating of plans.

The superintendent shall be responsible for filing the District-level school safety plan and any amendments to the plan with the commissioner of Education within thirty days after their adoption. Each principal shall be responsible for filing the building-level safety plan for his or her building and any amendments to the plan with the appropriate local law enforcement agency and the state police within thirty days after their adoption.

Cross-Ref: 5300, Code of Conduct
8134, Emergency Closings

Ref: Education Law §2801-a (school safety plans)
Executive Law §2B (state and local natural and manmade disaster preparedness)
8 NYCRR Part 155 (Educational Facilities)
Project SAVE Guidance Document for School Safety Plans, New York State
Education Department, April 2001

Adoption date: June 19, 2002
Revised date: August 7, 2019

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