Each year at its annual meeting, the Board will designate by resolution the name and location of the Iowa located financial depository institution or institutions to serve as the official District depository or depositories.  The maximum deposit amount to be kept in the depository will be stated in the resolution. The amount stated in the resolution must be for all depositories and include all of the District's funds.

It is the responsibility of the Board Secretary to include the resolution in the minutes of the meeting.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 08/19/2024

When the necessity for a fund has ceased to exist, the balance may be transferred to another fund or account by Board resolution.  District monies received without a designated purpose may be transferred in this manner.  District monies received for a specific purpose or upon vote of the people may only be transferred, by Board resolution when the purpose for which the monies were received has been completed.  Voter approval is required to transfer monies to the general fund from the capital projects fund and debt service fund.

It is the responsibility of the Board Secretary to make recommendations to the Board regarding transfers and to provide the documentation justifying the transfer.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 10/21/2024

Financial records of the District are maintained in accordance with generally accepted accounting principles (GAAP) as required or modified by law.  District monies are received and expended from the appropriate fund and/or account.  The funds and accounts of the District will include, but not be limited to:

Governmental fund type:
                  •     General fund
                  •     Special revenue fund
                        -     Management levy fund
                        -     Physical plant and equipment levy fund
                        -     Public education and recreation levy fund
                        -     Student activity fund
                  •     Capital projects fund
                  •     Debt service fund
                  •     State penny sales tax fund

Proprietary fund type:
                  •     Enterprise fund
                        -     School nutrition fund
                        -     Child care fund
                  •     Internal service fund

Fiduciary funds:
                  •     Trust or agency funds
                        -     Expendable trust funds
                        -     Nonexpendable trust funds
                        -     Agency funds
                        -     Pension trust funds

Account groups:
                  •     General fixed assets account group
                  •     General long-term debt account group

As necessary the Board may, by Board resolution, create additional funds within the governmental, proprietary, and fiduciary fund types.  The resolution shall state the type of fund, name of the fund, and purpose of the fund.

The general fund is used primarily for the education program.  Special revenue funds are used to account for monies restricted to a specific use by law.  Proprietary funds account for operations of the District operated similar to private business and they account for the costs of providing goods and services provided by one department to other departments on a cost reimbursement basis.  Fiduciary funds are used to account for monies or assets held by the District on behalf of, or in trust for, another entity.  The account groups are the accounting records for fixed assets and long-term debt.

It is the responsibility of the Superintendent to implement this policy and bring necessary changes in the maintenance of the District's financial records to the attention of the Board.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 10/21/2024

District accounting practices will follow state and federal laws and regulations, generally accepted accounting principles (GAAP), and the uniform financial accounting system provided by the Iowa Department of Education. As advised by the District's auditor, determination of liabilities and assets, prioritization of expenditures of governmental funds, and provisions for accounting disclosures shall be made in accordance with governmental accounting standards.

Governmental Accounting Standards Board (GASB) Statement No. 54 identifies the order of spending unrestricted resources applying the highest level of classification of fund balance - restricted, committed, assigned, and unassigned - while honoring constraints on the specific purposes for which amounts in those fund balances can be spent. A formal Board action is required to establish, modify, and/or rescind a committed fund balance. The resolution will state the exact dollar amount. In the event, the Board chooses to make changes or rescind the committed fund balance, formal Board action is required.

The Board authorizes the Superintendent to assign amounts to a specific purpose in compliance with GASB 54. An assigned fund balance should also be reported in the order of spending unrestricted resources, but is not restricted or committed.

It is the responsibility of the Superintendent to make recommendations to the Board regarding fund balance designations.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 10/21/2024

The amount of cash that may be kept in the school building for any one day is sufficient for that day's operations.  Funds raised by students shall be kept in the District office for a maximum of one day and then deposited in the student activity fund.

A minimal amount of cash is kept in the District office at the close of the day.  Excess cash shall be deposited in the authorized depository of the District.

It is the responsibility of the Superintendent to determine the amount of cash necessary for each day's operations and to comply with this policy.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 10/21/2024

District records are housed in the District office.  It is the responsibility of the Superintendent to oversee the maintenance and accuracy of the records.  The following records are kept and preserved according to the schedule below:

            •           Secretary's financial records – Permanently

            •           Treasurer's financial records – Permanently

            •           Minutes of the Board of Directors – Permanently

            •           Annual audit reports – Permanently

            •           Annual budget – Permanently

            •           Permanent record of individual pupil – Permanently

            •           Records of payment of judgments against the District – 20 years

            •           Bonds and bond coupons – 10 years

            •           Written contracts – 10 years beyond end of contract

            •           Cancelled warrants, check stubs, bank statements, bills, invoices, and related records – 5 years

            •           Minutes and recordings of closed meetings – 1 year

            •           Program grants – As determined by the grant

            •           Non-payroll personnel records – 7 years

            •           Payroll records – 3 years

Employees records are housed in the District office.  Employees records are maintained by the Superintendent, the building administrator, the employee's immediate supervisor, and the Board Secretary.

An inventory of the furniture, equipment, and other non-consumable items other than real property of the District is conducted annually under the supervision of the Superintendent.  This report is filed with the Board Secretary.

A perpetual inventory is maintained on consumable property of the District.

The permanent and cumulative records of students currently enrolled in the District are housed in the central administration office of the attendance center where the student attends.  Permanent records must be housed in a fireproof vault.  The building administrator is responsible for keeping these records current.  Records of students who have graduated or are no longer enrolled in the District are housed in the high school records room. These records will be maintained by the Superintendent.

The Superintendent may electronically store and/or back up or use any other reliable mass storage method to preserve District records and may destroy paper copies of the records if they are more than three (3) years old.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 11/18/2024

Prior to certification of the budget, the Board will review the projected revenues and expenditures for the District and make adjustments where necessary to carry out the education program within the revenues projected.

A budget for the District is prepared annually for the Board's review.  The budget will include the following:

            •           the amount of revenues from sources other than taxation;

            •           the amount of revenues to be raised by taxation;

            •           an itemization of the amount to be spent in each fund; and,

            •           a comparison of the amount spent and revenue received in each fund for like purposes in the two (2) prior fiscal years.

It is the responsibility of the Superintendent and Business Manager to prepare the budget for review by the Board prior to the April 15 deadline each year.

Prior to the adoption of the proposed budget by the Board, the public is apprised of the proposed budget for the District.  Prior to the adoption of the proposed budget by the Board, members of the District community will have an opportunity to review and comment on the proposed budget.  A public hearing for the proposed budget of the Board is held each year in sufficient time to file the adopted budget no later than April 15.

The proposed budget filed by the Board with the Board Secretary and the time and place for the public hearing on the proposed budget is published in a newspaper designated for official publication in the District.  It is the responsibility of the Board Secretary to publish the proposed budget and public hearing information at least ten (10) but no more than twenty (20) days prior to the public hearing.

The Board will adopt and certify a budget for the operation of the District to the county auditor by April 15.  It is the responsibility of the Board Secretary to file the adopted and certified budget with the county auditor and other proper authorities.

The Board may amend the budget for the fiscal year in the event of unforeseen circumstances.  The amendment procedures will follow the procedures for public review and adoption of the original budget by the Board outlined in these policies.

It is the responsibility of the Superintendent and the Board Secretary to bring any budget amendments necessary to the attention of the Board to allow sufficient time to file the amendment with the county auditor no later than May 31 of each year.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 11/18/2024

The budget of the District is the authority for the expenditures of the District for the fiscal year for which the budget was adopted and certified.  It is the responsibility of the Superintendent to operate the District within the budget.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 11/18/2024

Revenues of the District are received by the Board Treasurer.  Other persons receiving revenues on behalf of the District will promptly turn them over to the Board Treasurer.

Revenue, from whatever source, is accounted for and classified under the official accounting system of the District.  It is the responsibility of the Board Treasurer to deposit the revenues received by the District in a timely manner.  District funds from all sources will not be used for private gain or political purposes.

Tuition fees received by the District are deposited in the general fund.  The tuition fees for kindergarten through twelfth grade during the regular academic school year are set by the Board based upon the Superintendent's recommendation in compliance with the law.  Tuition fees for summer school, driver's education, and adult education are set by the Board prior to the offering of the programs.

The Board may charge materials fees for the use or purchase of educational materials.  Materials fees received by the District are deposited in the general fund.  It is the responsibility of the Superintendent to recommend to the Board when materials fees will be charged and the amount of the materials fees.

Rental fees received by the District for the rental of District equipment or facilities are deposited in the general fund.  It is the responsibility of the Superintendent to recommend to the Board a fee schedule for renting District property.

Proceeds from the sale or disposition of real property are placed in the fund which was used to account for the acquisition of the property.  If the District is unable to determine which fund was used to account for the acquisition of the property or if the fund no longer exists in the District, the proceeds from the sale or disposition of real property are placed in the physical plant and equipment levy fund. The proceeds from the sale or disposition of other District property are placed in the general fund.

The Board may claim exemption from the law prohibiting competition with private enterprise for the following activities:

• Goods and services directly and reasonably related to the educational mission;
• Goods and services offered only to students, employees or guests which cannot be provided by private enterprise at the same or lower cost;
• Use of vehicles for charter trips offered to the public, full- or part-time, or temporary students;
• Goods and services which are not otherwise available in the quantity or quality required by the District;
• Telecommunications other than radio or television stations;
• Sponsoring or providing facilities for fitness and recreation;
• Food service and sales; and,
• Sale of books, records, audios, software, educational equipment, and supplies.

It is the responsibility of the Superintendent to bring to the Board's attention additional sources of revenue for the District.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 11/18/2024

The Board may conduct an election for the authority to issue bonded indebtedness.  Revenues generated from an approved bond issue are used only for the purpose stated on the ballot.  Revenues received from the issuing of bonded indebtedness are deposited into the capital projects fund.

Once the purpose on the ballot is completed, any balance remaining in a capital projects fund may be retained for future capital projects in accordance with the purpose stated on the ballot or any remaining balance may be transferred by Board resolution to the debt service fund or the physical plant and equipment levy fund.  Use of excess funds in the account for another purpose requires the approval of the voters in the District community.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 12/16/2024

709A

SALE OF BONDS – POST ISSUANCE

1.   Role of Compliance Coordinator/Board Treasurer

      The Board Treasurer shall:

a)      Be responsible for monitoring post-issuance compliance;

b)      Maintain a copy of the transcript of proceedings or minutes in connection with the issuance of any tax-exempt obligations and obtain records that are necessary to meet the requirements of this regulation;

c)      Consult with bond counsel, a rebate consultant, financial advisor, IRS publications and such other resources as are necessary to understand and meet the requirements of this regulation;

d)      Seek out training and education to be implemented upon the occurrence of new developments in the area and upon the hiring of new personnel to implement this regulation.

2.  Financing Transcripts’ Filing and Retention

      The Board Treasurer shall confirm the proper filing of an IRS 8038 Series return and maintain a transcript of proceedings and minutes for all tax-exempt obligations issued by the school district including, but not limited to, all tax-exempt bonds, notes and lease-purchase contracts. Each transcript shall be maintained until 11 years after the tax-exempt obligation documents have been retired. The transcript shall include, at a minimum:

a)      Form 8038;

b)      Minutes, resolutions and certificates;

c)      Certifications of issue price from the underwriter;

d)      Formal elections required by the IRS;

e)      Trustee statements;

f)       Records of refunded bonds, if applicable;

g)      Correspondence relating to bond financings; and

h)      Reports of any IRS examinations for bond financings.

3.  Proper Use of Proceeds

     The Board Treasurer shall review the resolution authorizing issuance for each tax-exempt obligation issued by the school district and the school district shall:

a)      Obtain a computation of the yield on such issue from the school district's financial advisor;

b)      Create a separate Project Fund (with as many sub-funds as shall be necessary to allocate proceeds among the projects being funded by the issue) into which the proceeds of issue shall be deposited;

c)      Review all requisitions, draw schedules, draw requests, invoices and bills requesting payment

         from the Project Fund;

d)      Determine whether payment from the Project Fund is appropriate and, if so, make payment from the Project Fund (and appropriate sub-fund, if applicable);

            e)      Maintain records of the payment requests and corresponding records showing payment;

f)       Maintain records showing the earnings on, and investment of, the Project Fund;

g)      Ensure that all investments acquired with proceeds are purchased at fair market value;

h)      Identify bond proceeds or applicable debt service allocations that must be invested with a yield-restriction and monitor the investments of any yield-restricted funds to ensure that the yield on such investments do not exceed the yield to which such investments are restricted;

            i)       Maintain records related to any investment contracts, credit enhancement transactions and the

                     bidding of financial products related to the proceeds.

4.  Timely Expenditure and Arbitrage/Rebate Compliance

      The Board Treasurer shall review the Tax-Exemption Certificate (or equivalent) for each tax-exempt obligation issued by the school district and the expenditure records provided in Section 2 of this regulation, above and shall:

a)      Monitor and ensure that proceeds of each such issue are spent within the temporary period set forth in such certificate;

b)      Monitor and ensure that the proceeds are spent in accordance with one or more of the applicable exceptions to rebate as set forth in such certificate if the school district does not meet the "small issuer" exception for said obligation;

c)      Not less than 60 days prior to a required expenditure date, confer with bond counsel and a rebate consultant, if the school district will fail to meet the applicable temporary period or rebate exception expenditure requirements of the Tax-Exemption Certificate.  In the event the school district fails to meet a temporary period or rebate exception:

1.   Procure a timely computation of any rebate liability and, if rebate is due, file a Form 8038-T and arrange for payment of such rebate liability;

2.   Arrange for timely computation and payment of yield reduction payments (as such term is defined in the Code and Treasury Regulations), if applicable.

5.  Proper Use of Bond Financed Assets

      The Board Treasurer shall:

a)      Maintain appropriate records and a list of all bond financed assets.  Such records shall include the actual amount of proceeds (including investment earnings) spent on each of the bond financed assets;

b)      Monitor and confer with bond counsel with respect to all proposed bond financed assets;

1.   management contracts;

2.   service agreements;

3.   research contracts;

4.   naming rights contracts;

5.   leases or sub-leases;

6.  joint venture, limited liability or partnership arrangements;

7.   sale of property; or

8.   any other change in use of such asset.

c)      Maintain a copy of the proposed agreement, contract, lease or arrangement, together with the response by bond counsel with respect to said proposal for at least three years after retirement of all tax-exempt obligations issued to fund all or any portion of bond financed assets; and

d)      Contact bond counsel and ensure timely remedial action under IRS Regulation Sections 1.141-12 in the event the school district takes an action with respect to a bond financed asset, which causes the private business tests or private loan financing test to be met.

6.  General Project Records

      For each project financed with tax-exempt obligations, the Board Treasurer shall maintain, until three years after retirement of the tax-exempt obligations or obligations issued to refund those obligations, the following:

a)      Appraisals, demand surveys or feasibility studies;

b)      Applications, approvals and other documentation of grants;

c)      Depreciation schedules;

d)      Contracts respecting the project.

REVIEWED: 09/03/2025 – APPROVED: 09/15/2025

EXHIBIT B

DISCLOSURE AGREEMENT INVENTORY

Complete upon each new issuance

             4925-3022-6275-1\22770-004

The Board believes gifts, grants, and bequests to the District may be accepted when they will further the interests of the District.  The Board will have sole authority to determine whether the gift furthers the interests of the District.

Gifts, grants, and bequests are approved by the Board.  Once it has been approved by the Board, a Board member or the Superintendent may accept the gift, grant or bequest on behalf of the District.

Gifts, grants, and bequests once accepted on behalf of the District become the property of the District.  Gifts, grants, and bequests are administered in accordance with terms, if any, agreed to by the Board.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 12/16/2024

Revenue raised by students or from student activities is deposited and accounted for in the student activities fund.  This revenue is the property of and is under the financial control of the Board.  Students may use this revenue for purposes approved by the Superintendent or building principal.

 Whether such revenue is collected from student contributions, club dues or special activities or result from admissions to special events or from other fund-raising activities, all funds will be under the jurisdiction of the Board and under the specific control of the Superintendent or building principal.  They will be deposited in a designated depository and will be disbursed and accounted for in accordance with instructions issued by the Superintendent.

It is the responsibility of the Board Secretary to keep student activity accounts up-to-date and complete.

Any unencumbered class or activity account balances will automatically revert to the activity fund when a class graduates or an activity is discontinued.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 12/16/2024

The Board supports economic development in Iowa.  Purchases by the District will be made in Iowa for Iowa goods and services from a locally-owned business located within the District or from an Iowa-based company which offers these goods or services if the cost and other considerations are relatively equal and they meet the required specifications.

All Projects

It shall be the responsibility of the Superintendent to approve purchases, except those authorized by or requiring direct Board action.  The Superintendent shall have the authority to authorize purchases without competitive proposals for goods and services costing under $25,000 without prior Board approval.  For all purchases for goods and services costing more than $25,000, the Superintendent shall seek, at minimum, competitive quotations and shall submit all quotations to the Board for its review.

The Superintendent may coordinate and combine purchases with other governmental bodies to take advantage of volume price breaks. Joint purchases with other political subdivisions will be considered in the purchase of equipment, accessories or attachments with an estimated cost of $50,000 or more.

Public Improvement Projects

For public improvement projects where the estimated cost of the public improvement is less than the competitive quotation threshold under Iowa law, the Superintendent shall obtain quotes. Upon receipt of quotes, the Superintendent shall review and approve the quote that is in the district’s best interest.

The district will follow applicable Iowa law regarding obtaining competitive quotations and competitive bids for public improvement projects.

The Board and the Superintendent shall have the right to reject any or all quotations or bids, or any part thereof, and to seek additional quotations or bids.  The Board will enter into such contract or contracts as the Board deems in the best interests of the District.

The procurement of all supplies, equipment, and services shall be initiated by the issuance of an official purchase order signed by the Superintendent or by an authorized staff member.  Only those supplies, equipment, and services procured by formal contract shall be exempt.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 12/16/2024

REVISED: 03/24/2025 – APPROVED: 04/21/2025

1. Eddyville-Blakesburg-Fremont CSD must make available, upon request of the Federal awarding agency or pass-through entity, technical specifications on proposed procurements where the Federal awarding agency or pass-through entity believes such review is needed to ensure that the item or service specified is the one being proposed for acquisition.
2. Eddyville-Blakesburg-Fremont CSD must make available upon request, for the Federal awarding agency or pass-through entity preprocurement review, procurement documents, such as requests for proposals or invitations for bids, or independent cost estimates, when:
   1. Eddyville-Blakesburg-Fremont CSD’s procurement procedures or operation fails to comply with the procurement standards in this Part;
   2. The procurement is expected to exceed the Simplified Acquisition Threshold and is to be awarded without competition or only one bid or offer is received in response to a solicitation;
   3. The procurement, which is expected to exceed the Simplified Acquisition Threshold, specifies a "brand name" product;
   4. The proposed contract is more than the Simplified Acquisition Threshold and is to be awarded to other than the apparent low bidder under a sealed bid procurement; or
   5. A proposed contract modification changes the scope of a contract or increases the contract amount by more than the Simplified Acquisition Threshold.
3. Eddyville-Blakesburg-Fremont CSD is exempt from the pre-procurement review in paragraph (b) of this section if the Federal awarding agency or pass-through entity determines that its procurement systems comply with the standards of this Part.
   1. Eddyville-Blakesburg-Fremont CSD may request that its procurement system be reviewed by the Federal awarding agency or pass-through entity to determine whether its system meets these standards in order for its system to be certified. Generally, these reviews must occur where there is continuous high-dollar funding, and third party contracts are awarded on a regular basis;
   2. Eddyville-Blakesburg-Fremont CSD may self-certify its procurement system. Such self-certification must not limit the Federal awarding agency's right to survey the system. Under a self-certification procedure, the Federal awarding agency may rely on written assurances from Eddyville-Blakesburg-Fremont CSD that it is complying with these standards. Eddyville-Blakesburg-Fremont CSD must cite specific policies, procedures, regulations, or standards as being in compliance with these requirements and have its system available for review.

Awarded Contracts

1. 1. 1. Eddyville-Blakesburg-Fremont CSD will not award a contract to a party listed as debarred, suspended, or otherwise excluded in the System for Award Management (SAM). www.sam.gov (200.213)
      2. Contracts awarded shall contain the applicable contract provisions described in 2 CFR 200.326 and Appendix II to Part 200.
      3. Eddyville-Blakesburg-Fremont CSD will maintain written standards of conduct covering conflicts of interest and must provide for disciplinary action to be applied for violations of such standards as defined in 2 CFR 200.318 (c) (1).

REVIEWED: 10/19/2020 – APPROVED: 11/16/2020

  REVIEWED: 01/20/2025

2 CFR Part 200 Subpart B-General Provisions
200.113 Mandatory Disclosures

In compliance with Uniform Grant Guidance, in Title 2 Code of Federal Regulation (C.F.R.) Grants and Agreements, Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, this policy is adopted.

A non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Non-Federal entities that have received a Federal award including the term and condition outlined in Appendix XII—Award Term and Condition for Recipient Integrity and Performance Matters are required to report certain civil, criminal, or administrative proceedings to SAM. Failure to make required disclosures can result in any of the remedies described in §200.338 Remedies for noncompliance, including suspension or debarment. (See also 2 CFR part 180, 31 U.S.C. 3321, and 41 U.S.C. 2313.)

If an employee, elected official, board or commission member, volunteer, agent, etc. learns of a violation of Federal criminal law involving fraud, bribery, or gratuity potentially affecting a Federal grant, they will report the violation to: Mary McCrea, Human Resources, PO Box 429, 222 Walnut Street, Eddyville, IA 52553, 641-969-4226

The above named is/are responsible for reporting the violation to the relevant federal agency, or pass-through agency in writing, and in a timely manner.

REVIEWED: 10/19/2020 – APPROVED: 11/16/2020

  REVIEWED: 01/20/2025

Federally Financed and Assisted Construction"). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland "Anti-Kickback" Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, "Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States"). The Act provides that each contractor or sub­ recipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the federal awarding agency.

5. Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts awarded by the non-Federal entity in excess of $100,000 that involve the employment of mechanics or laborers must include a provision for compliance with 40 U.S.C. 3702 and 3704, as supplemented by Department of Labor regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40 hours. Work in excess of the standard work week is permissible provided that the worker is compensated at a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40 hours in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide that no laborer or mechanic must be required to work in surroundings or under working conditions which are unsanitary, hazardous or dangerous. These requirements do not apply to the purchases of supplies or materials or articles ordinarily available on the open market, or contracts for transportation or transmission of intelligence.

6. Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of "funding agreement" under 37 CFR§401.2(a) and the recipient or sub-recipient wishes to enter into a contract with a small business firm or nonprofit organization regarding the substitution of parties, assignment or performance of experimental, developmental, or research work under that "funding agreement," the recipient or sub-recipient must comply with the requirements of 37 CFR Part 401, "Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative Agreements," and any implementing regulations issued by the awarding agency.

7. Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387), as amended - Contracts and sub-grants of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended (33 U.S.C. 1251-1387). Violations must be reported to the Federal awarding agency and the Regional Office of the Environmental Protection Agency (EPA).

8. Debarment and Suspension (Executive Orders 12549 and 12689) - A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide exclusions in the System for Award Management (SAM), in accordance with the OBM guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), "Debarment and Suspension." SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.

1. Byrd Anti-Lobbying Amendment (31 U.S.C. 1352) - Contractors that apply or bid for an award exceeding $100,000 must file the required certification. Each tier certifies to the tier above that it will not and has not used Federal appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any Federal contract, grant or any other award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with non-Federal funds that takes place in connection with obtaining any Federal award. Such disclosures are forwarded from tier-to-tier up to the non­ Federal award.

10. See §200.322 Procurement of recovered materials.

§200.216 Prohibition on certain telecommunications and video surveillance services or equipment

1. 1. The district is prohibited from obligating or expending loan or grant funds to:
      1. Procure or obtain;
      2. Extend or renew a contract to procure or obtain; or
      3. Enter into a contract (or extend or renew a contract) to procure or obtain equipment, services, or systems that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. As described in Public law 115-232, section 889, covered telecommunications equipment is telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities).
         
         1. For purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunication equipment produced

by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology

Company (or any subsidiary or affiliate of such entities).

1. 1. 1. 2. Telecommunications or video surveillance services provided by such entities or using such equipment.
         3. Telecommunications or video surveillance equipment or services produced or provided by an entity that

the Secretary of Defense, in consultation with the Director of the National Intelligence of the Director of the Federal

Bureau of Investigation, reasonably believes to be an entity owned by or controlled by, or otherwise connected to,

the government of a foreign country.

1. 2. In implementing the prohibition under Public Law 115-232, section 889, subsection (f), paragraph (I), heads of executive agencies administering loan, grant, or subsidy programs shall prioritize available funding and technical support to assist affected businesses, institutions and organizations as is reasonably necessary for those affected entities to transition from covered communications equipment and services, to procure replacement equipment and services, and to ensure that communications service to users and customers is sustained.
   3. See Public Law 115-232, section 889 for additional information.
   4. See also §200.471.

REVIEWED: 10/19/2020 – APPROVED: 11/16/2020

REVISED: 06/17/2024 – APPROVED: 07/15/2024

A.    Any actual or prospective bidder, offeror, or contractor who considers himself to have been aggrieved in connection with the solicitation, evaluation, or award of a contract by the EBF School District may formally protest to the Superintendent of EBF School District. Such protests must be made in writing and received by the Superintendent of EBF School District. The protesting party must mail or deliver copies of the protest to the EBF School District, the State Agency, and other interested parties.

B.    In the event of a timely protest, the EBF School District shall not proceed further with the solicitation or award of the contract.

C.    A formal protest must be sworn and contain:

1. A specific identification of the statutory or regulatory provision that the protesting party alleges has been violated.
2. A specific description of each action by EBF School District that the protesting party alleges to be a violation of the statutory or regulatory provision that the protesting party has identified.
3. A precise statement of the relevant facts.
4. A statement of any issues of law or fact that the protesting party contends must be resolved.
5. A statement of the argument and authorities that the protesting party offers in support of the protest.
6. A statement that copies of the protest have been mailed or delivered to the State Agency and all other identifiable interested parties.

D.    The EBF School District may settle and resolve the dispute over the solicitation or award of a contract at any time before the matter is submitted on appeal. The EBF School District may solicit written responses to the protest from other interested parties.

E.    If the protest is not resolved by mutual agreement, the EBF School District shall issue a written determination that resolves the protest.

1. If the EBF School District determines that no violation of statutory or regulatory provisions has occurred, then the EBF School District shall inform the protesting party, the State Agency, and other interested parties by letter that sets forth the reasons for the determination.
2. If the EBF School District determines that a violation of any statutory or regulatory provisions has occurred in a situation in which a contract has not been awarded, then the EBF School District shall inform the protesting party, the State Agency, and other interested parties of that determination by letter that details the reasons for the determination and the appropriate remedy.
3. If the EBF School District determines that a violation of any statutory or regulatory provisions has occurred in a situation in which a contract has been awarded, then the EBF School District shall inform the protesting party, the State Agency, and other interested parties of that determination by letter that details the reasons for the determination. This letter may include an order that declares the contract void.

F.    The EBF School District shall maintain all documentation on the purchasing process that is the subject of a protest or appeal in accordance with the retention schedule of EBF School District.

REVIEWED:01/17/2022 – APPROVED: 02/21/2022

REVIEWED:01/20/2025

The Board authorizes the issuance of payment of claims against the District for goods and services.  The Board will allow the payment after the goods and services have been received and accepted in compliance with Board policy and the claims audited by the Board.

Claims for payment pursuant to the terms of a written contract may be paid by the Board Secretary prior to formal audit and approval by the Board.  In addition, the Board Secretary, upon approval of the Board President, may issue warrants for verified bills filed with the Board Secretary when the Board is not in session prior to payment of these claims and prior to audit and approval by the Board.  The Board Secretary will examine the claims and verify bills.

The Board Secretary will determine to the Board Secretary's satisfaction that the claims presented to the Board are in order and are legitimate expenses of the District.  It is the responsibility of the Board Secretary to bring claims to the Board for approval.  Thereafter, paid claims shall be entered on record in the regular minutes of the Board Secretary.

The Board President and Board Secretary may sign warrants by use of a signature plate or rubber stamp.  If the Board President is unavailable to personally sign warrants, the Vice President may sign warrants on behalf of the President.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 01/20/2025

Public Purpose

District funds are to be expended only for legitimate public purposes and not for private personal gain for which services of comparable value have not been rendered to the District. This is a requirement of the Iowa Constitution.

All funds received by the District are considered public funds and must be used to support the educational mission of the District. The best test to use when determining whether the expenditure is appropriate is called the “public scrutiny test.” The test is simple and merely asks whether the tax-paying public would view the expenditure as necessary to support public education. If you are already questioning whether the expenditure is appropriate, it may very well not be appropriate. Contact your supervisor if you have any questions about appropriate expenses.

The Board supports appropriate expenditures of District funds for District officers, directors, employees, and volunteers, as these are commonly granted benefits in public and private organizations which aid in recruitment of personnel, promote improvement of staff morale and cooperation, and assist in building a commitment to the District, thus assisting in creating a more productive learning environment. The following are considered appropriate expenditures provided they are awards or tokens from the District; not from the department or building level:

1. Food items, refreshments, and/or mementoes from the District for employee recruitment or recognition for service to the District.
2. District retirement appreciation function and or item to recognize retiring employees.
3. Recognition item upon the end of service by a Board member.
4. District volunteer appreciation events.
5. Food items and refreshments for Board members and staff during Board meetings and/or work sessions.
6. Food items and refreshments for Board committees, superintendent committees or committee meetings that include participation from the public during the meeting.

District awards or tokens of recognition shall be determined by the Superintendent/designee in advance and shall be paid for with District funds under the control of the Superintendent or designee. Public funds should not be used for the purchase of department or building level staff awards or tokens of recognition.

Sales Tax Exempt

The District is Iowa sales tax exempt. All items purchased by a public school for the school’s own use, qualify for an exemption from sales tax if the items purchased relate to the educational process. When making purchases, the staff member must inform the vendor that the purchase is sales tax exempt. A vendor can request a tax exemption form from the District. The District will not reimburse for sales tax paid on purchases made on behalf of the District.  When purchasing meals in Iowa, an effort must be made to have the meal purchase Iowa sales tax-exempt. Staff members must inform the restaurant before the order is placed that you are with the District and that the purchase should be sales tax exempt. If the restaurant is unable to comply and the purchase is within the district meal limits, the purchase will be an appropriate expense for reimbursement.

Examples of Appropriate and Inappropriate Use of Public Monies

This section identifies specific practices and procedures to be followed by all District employees when using public funds. The following list is intended to provide examples and may not be all inclusive.

FOOD AND REFRESHMENTS

1. Alcohol

   The purchase of alcohol is never an acceptable use of public monies.
    

2. Meetings, Trainings, and Professional Development

   Meals and snacks are normally a personal expense. Any meal or snack paid for with public funds must be a reasonable price and an integral part of employment duties.  Meals and snacks can be paid for with public funds if:
    

   1. The meeting is four (4) hours or more and separate breaks would be disruptive to the meeting objectives.
       
   2. The meeting is a breakfast, lunch or dinner meeting where the meeting is shorter than four hours in duration and attendance during meal time(s) is a requirement of an employee’s job duties.  The amount paid per meal shall not exceed $14 per person; exceptions may be approved by the Superintendent.
       
   3. Tips for meals are allowed but should not exceed 15%.
       
3. Board Meetings

   The Board meets at a time that is intended to be convenient for the general public. Meetings routinely span the normal dinner hour. Serving meals of reasonable value to Board members and staff required to attend Board meetings is considered an appropriate expense.
    

4. Coffee and Beverages

   Coffee and other beverages are normally a personal expense. A voluntary collection can be made from those who desire to have coffee and other beverages in the school/department. Except for meetings, trainings, and professional development (Item B), Board meetings (Item C), and public areas (Item H)), coffee and beverages shall not be purchased with public funds.
    

5. Employee Break Room Supplies

   Public funds should not be used to stock supplies such as plastic ware and paper products in employee break rooms. A voluntary collection can be made from those who desire to have such supplies.
    

6. Individual Receptions

   Receptions for individual employees should never be paid from public funds. This includes retirement dinners, staff meals, welcome aboard receptions, and similar gatherings where food and/or refreshments may be served. Voluntary collections can be taken from those attending such gatherings.
    

7. Acceptable Occasions

   The Superintendent may determine that the serving of food or refreshments is appropriate for selected occasions.  The annual retirement reception for all District employees is one example.
    

8. Public Areas

   In some cases, a building or part of a building is routinely open to the public for conducting District business.  Having refreshments of nominal value available to members of the public, such as coffee and other nominal snacks/beverages, are considered a courtesy and are authorized in these specific locations.
    

9. Student Incentives

   Incentives purchased for qualifying groups of students from public funds as part of an initiative, program, or recognition (e.g., rewards, honor roll) shall be of nominal value and authorized by the school administrator.

GIFTS

1. Employee Gifts

   Expenditures of public funds for gifts or gift cards to staff and employees are not authorized. This includes gifts purchased for staff birthdays or other personal occasions. Voluntary collections from staff would be an acceptable way of purchasing employee gifts.
    

2. Tokens/Clothing

   The purchase of tokens of appreciation, or personal clothing (e.g., coffee mugs, pens, tote bags, T-shirts/apparel, etc.) is not authorized.

FLOWERS

1.   Sympathy and Congratulations

   The use of public funds for the purchase of flowers is restricted to exceptional occasions where a public expression of sympathy or congratulations has been determined by the Superintendent to be in the best interests of the District. Written expressions of condolence are encouraged for all other occasions where flowers are not appropriate.
    

2. Individual Achievements

   Unless they are part of an award or graduation ceremony, flowers are not appropriate for individual achievements.
    

3. School Activities

   Flowers/decorations purchased for proms, dances, homecomings, etc., may be purchased out of school activity funds if authorized by the school administrator.

AWARDS AND RECOGNITIONS

1. District Awards and Recognitions

   At times, awards or recognitions are appropriate for presentation to District staff for years of service. District awards or recognitions shall be determined by the Superintendent/ designee in advance and shall be paid for with District funds.  Public funds should not be used for the purchase of department or building level staff awards or recognitions.
    

2. External Awards and Recognitions

   At times, awards are appropriate for presentation to people (e.g., volunteers) or organizations external to the District.  External awards or recognitions shall be determined by the Superintendent/designee in advance.

BREAK ROOM EQUIPMENT

Microwaves, refrigerators, coffee pots, toaster ovens and other similar equipment items may be procured with public funds for use in public reception areas and employee break rooms. Otherwise, these items must be purchased with personal funds. In all instances, all fire marshal safety restrictions must be observed. These items are not authorized in classrooms and offices.

HOLIDAY PARTIES, DECORATIONS AND CARDS

1. Holiday Decorations

   Office holiday decorations shall not be purchased with public funds.
    

2. Holiday Cards

   Holiday cards shall not be purchased with public funds.
    

3. Holiday Parties

   Staff holiday parties and meals are a personal expense. Voluntary collections may be taken to fund holiday events.  Public funds shall not be used for holiday parties.

STUDENT ACTIVITY FUNDS

Student Activity Funds are public funds and are to be used to finance a program of co-curricular school activities supplementing, but not replacing, the activities provided by the District. Student Activity Funds are derived from the student body as a whole and shall be so expended to benefit the student body as a whole.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 02/17/2025

​​​​​​​

The Board Secretary will report to the Board each month the receipts, disbursements, and balances of the various funds.  This report will be in written form and sent to the Board with the agenda for the Board meeting.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 02/17/2025

At the annual meeting, the Treasurer will give the annual report stating the amount held over, received, paid out, and on hand in the general and schoolhouse funds.  This report is in written form and sent to the Board with the agenda for the Board meeting. 

The Treasurer will also furnish the Board with a statement from each depository showing the balance then on deposit.

It is the responsibility of the Treasurer to submit this report to the Board annually.

REVIEWED: 11/18/2019 - APPROVED: 12/03/2019

REVISED: 02/17/2025 - APPROVED: 03/24/2025

Each month the schedule of bills allowed by the Board is published in a newspaper designated as a newspaper for official publication.  Annually, the total salaries paid to employees regularly employed by the District will also be published in a newspaper designated as a newspaper for official publication.

It is the responsibility of the Board Secretary to publish these reports in a timely manner.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 02/17/2025

To review the funds and accounts of the District, the Board will employ an auditor to perform an annual audit of the financial affairs of the District.  The Superintendent will use a request for proposal procedure in selecting an auditor.  The administration will cooperate with the auditors.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

The Board will maintain a comprehensive insurance program to provide adequate coverage against major types of risk, loss or damage, as well as legal liability.  The Board will purchase insurance at replacement values, when possible, after reviewing the costs and availability of such insurance.  The comprehensive insurance program is reviewed once every three (3) years.  Insurance will only be purchased through legally licensed Iowa insurance agents.

The District will assume the risk of property damage, legal liability, and dishonesty in cases in which the exposure is so small or dispersed that a loss does not significantly affect the operation of the education program or financial condition of the District.

Insurance of buildings, structures or property in the open will not generally be purchased to cover loss exposures below $5,000 unless such insurance is required by statute or contract.

The Board may retain a private organization for fixed assets management services.

Administration of the insurance program, making recommendations for additional insurance coverage, placing the insurance coverage, and loss prevention activities is the responsibility of the Superintendent.  The Superintendent is responsible for maintaining the fixed assets management system, processing claims, and maintaining loss records.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

The District will operate a school nutrition program in each attendance center.  The school nutrition program will include meals through participation in the National School Lunch Program.  Students may bring their lunches from home and purchase milk and other incidental items.

School nutrition program facilities are provided to serve students and employees when school is in session and during school-related activities.  They may also be used under the supervision of the building principals for food service to employee groups, parent-teacher meetings, civic organizations meeting for the purpose of better understanding the schools, and senior citizens in accordance with Board policy.

The school nutrition program is operated on a non-profit basis.  The revenues of the school nutrition program will be used only for the operation or improvement of such programs.  Supplies of the school nutrition program will only be used for the school nutrition program.

The Board will set, and annually review, the prices for school nutrition programs.  It is the responsibility of the Superintendent to make a recommendation regarding the prices of the school nutrition programs, in accordance with federal and state law.

It is the responsibility of the building principals to administer the program and to cooperate with the Superintendent and appropriate personnel for the proper functioning of the school nutrition program.

The District shall comply with all federal and state laws and regulations required for procurement, including the selection and evaluation of contractors.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

Students enrolled and attending school in the District, who meet United States Department of Agriculture eligibility guidelines will be provided the school nutrition program services at no cost or at a reduced cost.  The District shall make reasonable efforts to prevent the overt identification of students who are eligible for free and reduced price meals.

The District shall at least twice annually notify all families of the availability, eligibility criteria, and application procedures for free and reduced price meals in accordance with state and federal law.

It is the responsibility of the building principal to determine the eligibility of students for free or reduced price school nutrition programs, in accordance with criteria established by state and federal law.  If District personnel have knowledge of a student who is in need of free or reduced price meals, District personnel shall contact the building principal.

If a student owes money for five or more meals, the building principal may contact the student’s parent or guardian to provide information regarding the application for free or reduced price meals.  The District is encouraged to provide reimbursable meals to students who request reimbursable meals unless the student’s parent or guardian has specifically provided written direction to the District to withhold a meal from the student.

Employees will be required to pay for meals consumed.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

722

MEAL CHARGES

In accordance with state and federal law, the District adopts the following policy to ensure District employees, families, and students have a shared understanding of expectations regarding meal charges. The policy seeks to allow students to receive the nutrition they need to stay focused during the school day, prevent the overt identification of students with insufficient funds to pay for school meals, and maintain the financial integrity of the non-profit school nutrition program.

Payment of Meals

The District encourages parents and guardians to keep meal account balances current. Parents may deposit money in their family’s school lunch account at the school office or online. The District does understand that there can be extenuating circumstances and encourages the parent/guardian to contact the District to make payment arrangements should the need arise.

When the balance reaches $0.00 a student may no longer purchase a la carte items and can charge no more than $100.00 to this account for meals. When an account reaches this limit, a student in grades 7-12 shall not be allowed to charge further meals until the negative account balance is paid. Staff are not allowed to charge meals or have a negative balance.

Students who qualify for free meals shall never be denied a reimbursable meal, even if they have accrued a negative balance from previous purchases. Schools are encouraged to provide a reimbursable meal to students with outstanding meal charge debt. If an alternate meal is provided, the meal must be the same meal presented in the same manner to any student requesting an alternate meal.

Negative Account Balances

The District will make reasonable efforts to notify families when meal account balances are low. Additionally, the District will make reasonable efforts to collect unpaid meal charges classified as delinquent debt. The District will coordinate communications with the student’s parent or guardian to resolve the matter of unpaid charges. Parents or guardians will be notified of an outstanding negative balance once the student owes five meals or more. Parents or guardians will be notified by letter. Negative balances of more than

$100, not paid prior to the end of the semester will be turned over to the Superintendent or designee for collection. Options may include: collection agencies, small claims court, or any other legal method permitted by law.

Unpaid Student Meals Account

The District will establish an unpaid student meals account in a school nutrition fund. Funds from private sources and funds from the District flexibility account may be deposited into the unpaid school meals account in accordance with law. Funds deposited into this account shall be used only to pay individual student meal debt.

Communication of the Policy

The policy and supporting information regarding meal charges shall be provided in writing to:

• All households at or before the start of each school year;
• Students and families who transfer into the district, at time of transfer; and
• All staff responsible for enforcing any aspect of the policy.

Records of how and when the policy and supporting information was communicated to households and staff will be retained.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVISED: 11/21/2022 – APPROVED: 12/19/2022

REVIEWED: 03/24/2025

722A

DONATIONS TO FOOD SERVICE PROGRAM FOR APPLICATION TO DELIQUENT ACCOUNTS

The Eddyville-Blakesburg-Fremont Community School District accepts donations for negative student meal accounts. If an individual or organization wishes to make payment for negative lunch accounts, the check should be made out to Eddyville-Blakesburg-Fremont Community School District. If the District receives a check with instructions to apply payment to a specific student(s) account, the District will follow the guidance in the instructions. All other donations will be applied to unpaid balances in the following order:

1. Donations are first applied to students that have qualified for reduced lunches, first starting with the upper grades and working to the lower grades
2. If there are funds remaining, then they are applied to paid student negative balances starting with the upper grades and working to the lower grades
3. If there are funds remaining, then they are next applied to students that have qualified for free meals first starting with the upper grades first and working to the lower grades
4. If a donation is made, or any funds remain from a previous donation, and there are not any student meal accounts that are negative, then funds will be held and applied monthly per the policy guidelines.

REVIEWED: 04/17/2023 – APPROVED: 05/15/2023

REVIEWED: 03/24/2025

Elementary and middle school students living more than two miles from their designated school attendance centers and high school students living more than three miles from their designated attendance centers are entitled to transportation to and from their attendance center at the expense of the District.

Transportation of students who require special education services will generally be provided as for other students, when appropriate.  Specialized transportation of a student to and from a special education instructional service is a function of that service and, therefore, an appropriate expenditure of special education instructional funds generated through the weighted funds or IDEA federal funds designated for special education purposes.

Transportation of a student to and from a special education support service is a function of that service, and shall be specified in the individualized education program (IEP) or the individualized family service plan (IFSP).  When the IEP team determines that unique transportation arrangements are required and the arrangements are specified in the IEP or IFSP, the District will provide one or more of the following transportation arrangements for instructional services and the AEA for support services:

• Transportation from the student's residence to the location of the special education and back to the student's residence or child care placement for students below the age of six.
• Special assistance or adaptations in getting the student to and from and on and off the vehicle, en route to and from the special education location.
• Reimbursement of the actual costs of transportation when by mutual agreement the parents provide transportation for the student to and from the special education.

The District is not required to provide reimbursement to parents who elect to provide transportation in lieu of agency-provided transportation.

A student may be required, at the Board's discretion, to meet a school vehicle without reimbursement up to three-fourths of a mile.  The Board may require the parent to transport their children up to two miles to connect with school bus vehicles at the expense of the District when conditions deem it advisable.  It is within the discretion of the Board to determine such conditions.  Parents of students who live where transportation by bus is impracticable or unavailable may be required to furnish transportation to and from the designated attendance center at the expense of the District.  Parents, who transport their children at the expense of the District, are reimbursed at the rate per mile set by law.

Transportation arrangements made by agreement with a neighboring school district will follow the terms of the agreement.  Students who choose to attend a school in a school district other than their resident school district will provide transportation to and from the school at their own expense.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

The Board, in its discretion, may provide District transportation for extracurricular activities including, but not limited to, transporting student participants and other students to and from extracurricular events.

Students participating in extracurricular events, other than those held at District facilities, may be transported to the extracurricular event by District transportation vehicles or by another means approved by the Superintendent.  Students attending extracurricular events, other than those held at District facilities, may be transported to the extracurricular event by District transportation vehicles.

Students, who are provided transportation in District transportation vehicles for extracurricular events, will ride both to and from the event in the school vehicle unless arrangements have been made with the building principal prior to the event.  A student's parent may personally appear and request to transport the student home from a school-sponsored event in which the student traveled to the event on a District transportation vehicle.

It is the responsibility of the Superintendent to make a recommendation to the Board annually as to whether the District will provide the transportation authorized in this policy.  In making the recommendation to the Board, the Superintendent will consider the financial condition of the District, the number of students who would qualify for such transportation, and other factors the Board or Superintendent deem relevant.

REVIEWED: 11/18/2019 – APPROVED 12/03/2019

REVIEWED: 03/24/2025

The District may use District vehicles for transportation to and from summer extracurricular activities.  The Superintendent will make a recommendation to the Board annually regarding their use.

Transportation to and from the student's attendance center for summer school instructional programs is within the discretion of the Board.  It is the responsibility of the Superintendent to make a recommendation regarding transportation of students in summer school instructional programs at the expense of the District.  In making the recommendation to the Board, the Superintendent will consider the financial condition of the District, the number of students involved in summer school programs, and other factors deemed relevant by the Board or the Superintendent.

REVIEWED: 11/18/2019 – APPROVED 12/03/2019

REVIEWED: 03/24/2025

The Board has sole discretion to determine the method to be utilized for transporting non-resident and non-public students.  Non-resident students paying tuition may be, and resident students attending a non-public school accredited by the State Department of Education, will be transported on an established public school vehicle route as long as such transportation does not interfere with resident public students' transportation. Non-resident and non-public school students will obtain the permission of the Superintendent prior to being transported by the District.

Parents of resident students who provide transportation for their children attending a non-public school accredited by the Iowa Department of Education will be reimbursed at the established state rate.  This reimbursement is paid only if the District receives the funds from the state.  If less than the amount of funds necessary to fully reimburse parents of the non-public students is received by the District, the funds will be prorated.

The charge to the non-resident students is determined based on the students' pro rata share of the actual costs for transportation.  The parents of these students are billed for the student's share of the actual costs of transportation.  The billing is according to the schedule developed by the Superintendent.  It is the responsibility of the Superintendent to determine the amount to be charged and report it to the Board Secretary for billing.

Continued transportation of non-resident and non-public school students on a public school vehicle route will be subject to resident public school students' transportation needs.  The Superintendent will make a recommendation annually to the Board regarding the method to be used.  In making a recommendation to the Board, the Superintendent will consider the number of students to be transported, the capacity of the District vehicles, the financial condition of the District, and other factors deemed relevant by the Board or the Superintendent.

Non-resident and non-public school students are subject to the same conduct regulations as resident public students as prescribed by Board policy, and to other policies, rules or regulations developed by the District regarding transportation of students by the District.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

The District will conduct school bus safe riding practices instruction and emergency safety drills at least twice during the school year for students who utilize District transportation.  Each District bus vehicle will have, in addition to the regular emergency safety drill, a plan for helping those students who require special assistance to safety during an emergency. This will include, but not be limited to, students with disabilities.  District vehicle drivers are required to attend each safety drill.  Employees are responsible for instructing the proper techniques to be followed during an emergency, as well as safe riding practices.

All District personnel and designees must wear seat belts while operating District and private vehicles for District functions.  All District personnel must use the tire protective cage when inflating or deflating a tire used on District buses and tractors.

REVIEWED: 11/18/2019 – APPROVED 12/03/2019

REVIEWED: 03/24/2025

District buses will not operate when weather conditions due to fog, rain, snow, ice or other natural elements make it unsafe to do so.  Because weather conditions may vary throughout the District and may change quickly, the best judgment possible will be used with the information available.

The final judgment as to when conditions are unsafe to operate will be made by the Superintendent.  The Superintendent will be assisted by the actual on location decisions and reports of the drivers.

Several drivers each year will be specially designated to report weather and road conditions by bus radio when requested to do so.  Other employees and students will be notified by commercial radio, local television stations, and District alerts when school is cancelled or temporarily delayed.  When school is cancelled because of weather anywhere in the school district, all schools will be closed.

When weather conditions deteriorate during the day after school has begun, cancellation notices will be announced by commercial radio, local television stations, and District alerts.  Students will be returned to their regular drop-off sites unless weather conditions prevent it.  In that case, students will be kept at or returned to school until they are picked up by the parents.

When, in the judgment of the driver, weather conditions are so poor as to present a hazard when loading or unloading students, the driver will radio the Superintendent for instructions.  If radio contact is not possible, the driver will proceed to the next stop which does not present a hazard and make telephone contact personally.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

The Board supports the District’s use of video recording on District premises and District transportation as a means to monitor and maintain a safe environment for students and employees.  Video recording may be done on school premises, including inside and/or outside school buildings; may be operated during school hours and/or during non-school hours; and may be operated on District vehicles used for transportation to and from school and District activities.  Video recordings of student and/or employee activity on District premises and/or while using District transportation may be used as evidence in a student and/or employee disciplinary proceeding.

Student Records

A video recording of student activity on District premises and/or while using District transportation may be a student record subject to Board policy and administrative regulations regarding confidential student records.  Only those persons with a legitimate educational purpose may view a video recording of a student on District premises and/or using District transportation.  In most instances, those individuals with a legitimate educational purpose may be the Superintendent, building principal, activities director, facilities director, transportation director, bus driver, and special education staffing team.  A video recording made during a District activity and/or in a classroom during a class may also be accessible to the sponsor of the activity and/or the teacher of the class.  A video recording made during a District-sponsored trip, such as an athletic event, may also be accessible to the sponsor or coach of the activity.  If the content of the video recording becomes the subject of a student disciplinary proceeding, it will be treated like other evidence in the proceeding.

Employee Records

A video recording of an employee’s activity on District premises and/or while using District transportation may be an employee record subject to Board policy and administrative regulations regarding confidential employee records.  Only those persons with a legitimate disciplinary and/or investigatory purpose may view a video recording of an employee on District premises and/or using District transportation.  In most instances, those individuals with a legitimate disciplinary and/or investigatory purpose may be the Superintendent and any other person who supervises the employee and/or is involved in investigating and/or evaluating the employee’s performance and/or conduct.

Notice

The District will annually provide the following notice to students and parents:

The Eddyville-Blakesburg-Fremont Community School District Board of Directors has authorized the use of video recording on District premises and video recording and audio recording on District transportation.  The video recording and audio recording will be used to monitor and record student behavior to maintain order on District premises and District transportation and to promote and maintain a safe environment.  Students and parents are hereby notified that the content of the video and audio recordings may be used in a student disciplinary investigation and/or proceeding.  The content of the video and audio recordings may be confidential student records and may be retained with other student records.  Video and audio recordings may be retained if necessary for use in a student disciplinary investigation and/or proceeding or other matter as deemed necessary by the administration.  Parents may request to review video and audio recordings of their child only if the video and audio recordings are used in a disciplinary proceeding involving their child.

The District will annually provide the following notice to employees:

The Eddyville-Blakesburg-Fremont Community School District Board of Directors has authorized the use of video recording on District premises and video recording and audio recording on District transportation.  The video recording and audio recording will be used to monitor and record employee behavior to maintain order on District premises and District transportation and to promote and maintain a safe environment.  Employees are hereby notified that the content of the video and audio recordings may be used in an employee disciplinary investigation and/or proceeding.  The content of the video and audio recordings may be confidential employee records and may be retained with other employment records.  Video and audio recordings may be retained if necessary for use in an employee disciplinary investigation and/or proceeding or other matter as deemed necessary by the administration.  Employees may request to view video and audio recordings involving them if the video and audio recordings are used in an employee disciplinary investigation and/or proceeding involving them.

The following notice will be placed on all District premises and/or District buildings equipped with video recording capability:

            This area and/or building is equipped with a video monitoring system.

The following notice will be placed on all District transportation equipped with video and audio recording capabilities:

            This vehicle and/or bus is equipped with a video monitoring system and      audio   recording equipment.

Review of Video and Audio Recordings

The District will review video and audio recordings randomly or when necessary as a result of an incident reported by a District employee or student.  Video and audio recordings may be recirculated for erasure after approximately thirty (15) days.

The review of video and audio recordings is limited to the individuals having a legitimate educational purpose and/or a disciplinary and/or investigatory purpose.  A written log will be kept of those individuals reviewing video and audio recordings stating the time, name of individual viewing, and the date the video and/or audio recording was viewed.

Video and Audio Monitoring Systems

Video recording may be used as follows: used on some District premises; used at all District buildings, at a select number of locations within each District building; used on all District buses; and/or used on other District vehicles, not including District buses.  Audio recording may be used as follows: used on all District buses and/or used on other District vehicles, not including school buses.

The determination of how video recording and audio recording will be used and the location of the video recording equipment will be made by the Superintendent in consultation with the building principals and transportation director.

Student and Employee Conduct

Students and employees are prohibited from tampering with the video recording and/or audio recording equipment at any location.  Students and employees found in violation of this policy will be disciplined in accordance with all applicable District disciplinary policies and rules, and will reimburse the District for the cost of any repairs or replacement necessary as a result of the tampering.

REVIEWED: 11/18/2019 - APPROVED 12/03/2019

REVIEWED: 03/24/2025

730

FUNDRAISING

Purpose of Fundraising

It is recognized that revenues, beyond that which the District can provide, may be necessary to operate some activity programs at a level desired by students, staff, and the community. In such cases it may be appropriate to allow students who participate in that activity to engage in fundraising efforts. School organizations may sponsor fundraising activities in which products and services are sold to benefit the District programs. Products may also be sold in relation to production by students as part of the educational program. All funds raised by student groups must be accounted for in accordance with District procedures. The District values the participation and support of certain fundraising activities organized and administered through organizations such as parent-teacher organizations and booster organizations. Parent-teacher organizations and booster organizations must follow Board policy on the use of the District’s name/logo and/or other likeness when fundraising.

Definitions

Fundraising is the selling of a product, providing a service or activity or requesting donations. District fundraising directly funds District programs.

Student organizations are groups that are sponsored by the District and approved by the Board. They are designed to provide opportunities for students to participate, on an individual or group basis, in District and public events. Student organizations are directed or supervised by District staff. Student organizations include athletics, extra-curricular activities, clubs, and classrooms or grade levels.

Charitable/Service Project fundraising shall be limited to unusual or compelling circumstances, shall be for a public purpose and not for an individual student or family, shall be of educational value to students, and must have prior Board approval.

Outside organizations are non-District funded groups such as parent-teacher organizations and booster organizations that provide supplementary support to existing District programs and activities.

Online fundraising and crowdfunding is the use of small amounts of capital from a large number of individuals to finance a project, business venture or to fundraise for a specific cause or charity where individuals donate online to a cause through a second party online service.

Public purpose is addressed in Article III, Section 31 of the Iowa Constitution which states no public money or property shall be appropriated for local or private purposes.  Public money may be spent only for the public benefit.

School activities are Board approved activities such as co-curricular and extracurricular student activities.

Approval of Fundraising Activities

The Activities Director or Superintendent by authority of the Board of Directors must approve all fundraising requests prior to the start of the fundraising activity. Application forms for fundraisers must be submitted to the Activities Director, Superintendent or Board Secretary.

Fundraising Guidelines

All fundraisers should be for a public purpose and benefit all members of a school program or activity.  Funds raised should complement, not replace, public funding for education.

The District name, school or organization that is conducting the fundraising shall be accurately and appropriately included on all information that is used as part of the fundraising activity.

All funds accepted by the Board from fundraising activities are considered to public funds and must be used for the public purpose of supporting the educational mission of the District.

It is the responsibility of individuals working with students on fundraising to adhere to all applicable District policies. All students who participate in approved fundraising activities are expected to represent the District, District organizations, and the community in a responsible manner. There should be no door to door sales/solicitations by students for safety reasons.

Fundraising by students for events other than District-sponsored events is not allowed during the District operational hours and District-sponsored events.  Students will not be excused from class to participate in fundraising.

Student participation in fundraising is voluntary. No student will be excluded from an event or program because of non-participation by the student. No student grades will be affected by a student’s participation or lack of participation in fundraising.

No quotas will be imposed upon students involved in fundraising.  Group (class or grade) incentives are the preferred means to motivate and reward students. Incentives purchased for qualifying groups of students from public funds as part of an initiative, program or recognition (e.g., rewards, honor roll) shall be of nominal value and authorized by the school administrator.  Students will not be given gift card, gift certificates or cash as an award for fundraising.

The District discourages fundraisers that sell food. The District will allow those fundraisers that sell food and beverages if it meets state and federal guidelines as determined by the Food Service Director.

The Board strongly suggests that the option to donate, as opposed to participating in a fundraiser, be considered as an option. This option should be considered based on the nature of the fundraiser and timing of the fundraiser.

Collection boxes for District fundraising must have prior approval from the building administrator before being placed on District property. Collection boxes should only be used for non-monetary items.

Student handling of cash should be kept to a minimum. Fundraising activities should discourage giving cash to students.

Checks should be made out payable to the District or outside organization. Checks should never be made out to a District employee or individuals.

REVIEWED: 11/18/2019 – APPROVED 12/03/2019

REVISED: 10/21/2024 – APPROVED: 11/18/2024

REVIEWED: 03/24/2025

To improve the District's oversight of fixed assets by assigning and recording them to specific facilities and programs and to provide for proof loss of fixed assets for insurance purposes, the District will establish and maintain a fixed assets management system for reporting capitalized fixed assets owned or under the jurisdiction of the District in its financial reports in accordance with generally accepted accounting principles (GAAP) as required or modified by law.

A separate fixed assets listing is prepared for fixed assets in the general fixed assets account group (GFAAG) and for the fixed assets of each proprietary and fiduciary fund. 

"Fixed assets" in the GFAAG will include school district buildings and sites, construction in progress, improvements other than buildings and sites, land and machinery and equipment.  "Fixed assets" in the proprietary funds will include school district buildings and sites, construction in progress, improvements other than buildings and sites, capitalized interest, infrastructure, land and machinery and equipment.  Fixed assets reported in the financial reports will include individual fixed assets with an historical cost equal to or greater than $2,500.00.  Fixed assets accounted for and reported in the proprietary funds are depreciated over the useful life of each fixed asset. 

The fixed assets management system is updated monthly to account for the addition/acquisition, disposal, relocation/transfers of fixed assets.  It is the responsibility of the Superintendent to count and reconcile the fixed assets listing for the general fixed assets account group and for each proprietary and fiduciary fund with the fixed assets management system on June 30 each year.

It is the responsibility of the Superintendent to develop administrative regulations implementing this policy.  It will also be the responsibility of the Superintendent to educate employees about this policy and its supporting administrative regulations.  

REVIEWED: 09/14/2020 - APPROVED 10/19/2020

REVISED: 03/24/2025 – APPROVED: 04/21/2025

732

DEBT MANAGEMENT

DEBT LIMITS
Credit Ratings
The school district seeks to maintain the highest possible credit ratings for all categories of short- and long-term debt that can be achieved without compromising the delivery of services and the achievement of adopted objectives.  The school district recognizes that external economic, natural, or other events may from time to time affect the creditworthiness of its debt. Nevertheless, the school district is committed to ensuring that actions within their control are prudent.

Debt Limits
For general obligation debt, the school district’s outstanding debt limit shall be no more than five percent (5%) of the actual value of property within the school district’s boundaries, as prescribed the Iowa constitution and statutory restrictions.

For revenue debt, the school district’s goal is to provide adequate debt service coverage of at least 1.20 times the annual debt service costs.

In accordance with Iowa law, the school district may not act as a conduit issuer or issue municipal securities to raise capital for revenue-generating projects where the funds generated are used by a third party (“conduit borrower”) to make payments to investors.

PURPOSES AND USES OF DEBT 
Capital Planning
To enhance creditworthiness and prudent financial management, the school district is committed to systematic capital planning, intergovernmental cooperation and coordination and long-term financial planning.

Capital Financing
The school district may issue long-term debt for capital projects as authorized by Iowa law, which include, but are not limited to, the costs of planning, design, land acquisition, buildings, permanent structures, attached fixtures or equipment, and movable pieces of equipment. Capitalized interest may be included in sizing any capital project debt issue.  The types of debt instruments to be used by the school district include:

• General Obligation Bonds
• General Obligation Capital Loan Notes
• Bond Anticipation Notes
• Revenue Anticipation Notes
• School Infrastructure Sales, Services and Use Tax Revenue Bonds
• Lease Purchase Agreements, including Certificates of Participation

Working Capital Financing
The school district may issue debt for working capital for operations after cash flow analysis has determined that there is a mismatch between available cash and cash outflows.  The school district shall strive to repay working capital debt by the end of the fiscal year in which the debt was incurred.  A Working Capital Reserve may be included in sizing any working capital debt issue.
 

Refundings
Periodic reviews of all outstanding debt will be undertaken to determine if refunding opportunities exist. Refunding will be considered (within federal tax law restraints) if and when there is a net economic benefit of the refunding or if the refunding is otherwise in the best interests of the school district, such as to release restrictive bond covenants which affect the operations and management of the school district.

In general, advance refundings for economic savings will be undertaken when a net present value savings exceeds three percent of the refunded debt can be achieved.  Current refundings, which produce a new present value savings of less than three percent will be considered on a case by case basis taking into consideration bond covenants and general conditions.  Refundings with negative savings will not be considered unless there is a compelling public policy objective for doing so.

DEBT STANDARDS AND STRUCTURE
Length of Debt
Debt will be structured for the shortest period consistent with a fair allocation of costs to current and future beneficiaries or users.  Long-term debt will not be issued for periods exceeding the useful life or average useful lives of the project or projects to be financed.  All debt issued will adhere to state and federal law regarding the length of time the debt may be outstanding.

Debt Structure
Debt will be structured to achieve the lowest possible net cost to the school district given market conditions, the urgency of the capital project, the type of debt being issued, and the nature and type of repayment source.  To the extent possible, the school district will design the repayment of its overall debt to rapidly recapture its credit capacity for future use.

Generally, the school district will only issue fixed-rate debt.  In very limited circumstances, the school district may issue variable rate debt, consistent with the limitations of Iowa law and upon a finding of the board that the use of fixed rate debt is not in the best interest of the school district and a statement of the reasons for the use of variable rate debt.

All debt may be structured using discount, par or premium coupons, and as serial or term bonds or notes, or any combination thereof, consistent with Iowa law.  The school district should utilize the coupon structure that produces the lowest True Interest Cost (TIC) taking into consideration the call option value of any callable maturities.

The school district will strive to structure their debt in sinking fund installments for each debt issue that achieves, as nearly as practicable, level debt service within an issue or overall debt service within a particular classification of debt.

Derivatives (including, but not limited to, interest rate swaps, caps, collars, corridors, ceiling and floor agreements, forward agreements, float agreements, or other similar financing arrangements), zero-coupon or capital appreciation bonds are not allowed to be issued consistent with State law.

Decision Analysis to Issue Debt
Whenever the school district is contemplating the issuance of debt, information will be developed concerning the following four categories commonly used by rating agencies assessing the school district’s credit worthiness, listed below.

Debt Analysis – Debt capacity analysis; purpose for which debt is proposed to be issued; debt structure; debt burden; debt history and trends; and adequacy of debt and capital planning. 

Financial Analysis – Stability, diversity, and growth rates of tax or other revenue sources; trend in assessed valuation and collections; current budget trends; appraisal of past revenue and expenditure trends; history and long-term trends of revenues and expenditures; evidences of financial planning; adherence to GAAP; audit results; fund balance status and trends in operating and debt funds; financial monitoring systems and capabilities; and cash flow projections.

Governmental and Administrative Analysis – Government organization structure; location of financial responsibilities and degree of control; adequacy of basic service provision; intergovernmental cooperation/conflict and extent of duplication; and overall planning efforts.

Economic Analysis – Geographic and location advantages; population and demographic characteristics; wealth indicators; types of employment, industry and occupation; housing characteristics; new construction; evidences of industrial decline; and trend of the economy.

DEBT ISSUANCE 
Credit Enhancement
Credit enhancements (.i.e., bond insurance, etc.) may be used but only when the net debt service on the debt is reduced by more than the costs of the credit enhancement.

Costs and Fees
All costs and fees related to issuing the debt will be paid out of debt proceeds and allocated across all projects receiving proceeds of the debt issue.

Method of Sale
Generally, all school district debt will be sold through a competitive bidding process.  Bids will be awarded on a TIC basis providing other bidding requirements are satisfied.

The school district may sell debt using a negotiated process in extraordinary circumstances when the complexity of the issue requires specialized expertise, when the negotiated sale would result in substantial savings in time or money, or when market conditions of school district credit are unusually volatile or uncertain.

Professional Service Providers
The school district will retain external bond counsel for all debt issues.  All debt issued by the school district will include a written opinion by bond counsel affirming that the school district is authorized to issue the debt, stating that the school district has met all Iowa constitutional and statutory requirements necessary for issuance and determining the debt’s federal income tax status.  The bond counsel retained must have comprehensive municipal debt experience and a thorough understanding of Iowa law as it relates to the issuance of the particular debt.

The school district will retain an independent financial advisor.  The financial advisor will be responsible for structuring and preparing all offering documents for each debt issue.  The financial advisor retained will have comprehensive municipal debt experience, experience with diverse financial structuring and pricing of municipal securities.

The treasurer shall have the authority to periodically select other service providers (e.g., escrow agents, verification agents, trustees, arbitrage consultants, rebate specialist, etc.) as necessary to meet legal requirements and minimize net debt costs.  These services can include debt restructuring services and security or escrow purchases. 

Compensation for bond counsel, financial advisor and other service providers will be as economical as possible and consistent with industry standards for the desired qualification levels.

DEBT MANAGEMENT
Investment of Debt Proceeds
The school district shall invest all proceeds received from the issuance of debt separate from the school district’s consolidated cash pool unless otherwise specified by the authorizing bond resolution or trust indenture.  Investments will be consistent with those authorized by Iowa law and the school district’s Investment Policy to maintain safety of principal and liquidity of the funds.

Arbitrage and Record Keeping Compliance
The treasurer shall maintain a system of record-keeping, reporting and compliance procedures with respect to all federal tax requirements which are currently, or may become applicable through the lifetime of all tax-exempt or tax credit bonds.

Federal tax compliance, record-keeping, reporting and compliance procedures shall include but not be limited to: 

1. post-issuance compliance procedures (including proper use of proceeds, timely expenditure of proceeds, proper use of bond financed property, yield restriction and rebate, and timely return filing);
2. proper maintenance of records to support federal tax compliance;
3. investments and arbitrage compliance; 
4. expenditures and assets; 
5. private business use; and
6. designation of primary responsibilities for federal tax compliance of all bond financings.

Financial Disclosure
The school district is committed to full and complete financial disclosure, and to cooperating fully with rating agencies, institutional and individual investors, other levels of government, and the general public to share comprehensible and accurate financial information.  The school district is dedicated to meeting secondary disclosure requirements on a timely and comprehensive basis, as promulgated by the Securities and Exchange Commission.

The Official Statements accompanying debt issues, Annual Audits, and Continuing Disclosure statements will meet the standards articulated  by the Municipal Securities Rulemaking Board (MSRB), the Government Accounting Standards Board (GASB), the Securities and Exchange Commission (SEC), Generally Accepted Accounting Principles (GAAP) and the Internal Revenue Service (IRS).  The treasurer shall be responsible for ongoing debt disclosure as required by any Continuing Disclosure Certificate for any debt issue and for maintaining compliance with disclosure standards promulgated by state and federal regulatory bodies
 

REVIEWED: 09/03/2025 – APPROVED 09/15/2025