300. FINANCIAL MANAGEMENT

Transcription

1 300. FINANCIAL MANAGEMENT

2 FINANCIAL MANAGEMENT 301. THE BUDGETING PROCESS 310. CONFLICT OF INTEREST 311. PURCHASING PROCEDURES 312. PROCUREMENT PLAN - CHILD NUTRITION DEPARTMENT 320. INVESTMENT OF SCHOOL FUNDS 321. TAX EXEMPT BOND TAX COMPLIANCE GUIDELINES ACTIVITY ACCOUNT PROCEDURES 340. PAYROLL 341. PAYROLL DEDUCTIONS 342.* INSURANCE CLAIMS 350. MANAGEMENT PROCEDURES FOR ACTIVITY FUNDS 360. PURCHASING CARDS * Negotiated Item

3 FINANCIAL MANAGEMENT 301. THE BUDGETING PROCESS The Board of Education shall annually employ a public accountant approved by the State Department of Education to prepare the annual Estimate of Needs and Financial Statement and to audit the financial records of the school district.

4 310. CONFLICT OF INTEREST ( ) It is the policy of the Sapulpa Board of Education to not enter into, or cause, or allow to be entered into any contract for the sale of goods or services to the District with any District employee, individually or through any business enterprise, in which a District employee holds a financial interest, if such employee is responsible for managing or supervising the business or financial affairs of the District, whether directly or indirectly, including the determination of vendors for individual departments within the District. Additionally, members of the Board of Education will use district property solely for the benefit of the district; will accept or give only such gifts, privileges, or favors that clearly have no relation to the performance of their district responsibilities or influence on their decision; will disclose any actual or potential conflict of interest involving them or known to them; and will participate in deliberations and decision making only when free from actual conflict of interest. CONFLICTS OF INTEREST A. If, as a result of receiving any affidavit required by this policy, the Board of Education believes that a conflict or potential conflict of interest exists between the affiant or any representative of the affiant, any member of the Board of Education or employee of the district, including the district s architects and attorneys, then the Board of Education shall determine: (1) whether such conflict or potential conflict will materially and substantially interfere with, impede, or delay the contract in question; or (2) whether a benefit from a monetary or financial standpoint will result to any member of the Board of Education or their immediate family members or the employees of the district, including the district s architects and attorneys or their immediate family members, as a result of the contract in question. If the Board of Education determines that either of the above two conditions exist, then the Board shall take all such action as is necessary to eliminate or avoid the conflict or potential conflict of interest. B. This policy is supplemental to any statutes, regulations, or case law governing conflicts of interest involving school districts and the agents, Board of Education members, employees, and representatives of school districts. C. The term immediate family under this policy shall mean spouse, child, child s spouse, parent, parent s spouse, grandchild, grandchild s spouse, grandparent, grandparent s spouse, brother, brother s spouse, sister, sister s spouse, niece, nephew, uncle, and aunt.

5 311. PURCHASING PROCEDURES (Revised )(Revised )(Revised )(see procedure page) A. All supplies, equipment and construction shall be purchased under a purchase order system following established procedures and regulations and complying with applicable state and federal laws and the regulations of the Oklahoma State Department of Education. B. Supplies and Equipment - Purchases under $7500 may be authorized by the Superintendent. For expenditures over $7500, quoted prices from three different vendors should be obtained, if possible, with the quotes listed on the requisition for a purchase order, and shall be approved by the Board of Education. C. Expenditures for Construction Under the Competitive Bidding Act will follow Oklahoma state law. D. Construction Under Force Account will follow Oklahoma state law. E. On construction projects of less than $40,000, substantial completion authorization may be delegated to the Superintendent. F. All vendors providing services on school property will be required to sign a Hold Harmless Agreement and provide a Certificate of Insurance with Sapulpa Public Schools listed as an additional insured, and limits of no less than $1,000,000 per occurrence. The Insurance Certificate and the Hold Harmless Agreement are required to be attached to the purchase requisition by the requestor in order to receive a valid Purchase Order.

6 312. PROCUREMENT PLAN CHILD NUTRITION DEPARTMENT (Approved )(Revised ) (see procedure page)

7 320. INVESTMENT OF SCHOOL FUNDS (Revised ) A. The school district treasurer is authorized by the Board of Education to invest surplus funds in Certificates of Deposit or repurchase agreements as authorized by state law at the highest possible rate of interest in bids from banks in the city of Sapulpa as far as is feasible. Deposits not to exceed $100,000 secured by FSLIC or the FDIC may be made in demand passbook savings accounts at any bank or federal savings and loan association in the city of Sapulpa as far as is feasible. B. The Superintendent and/or Assistant Superintendent are authorized to direct the investment of all surplus activity funds according to the provisions of Oklahoma State Law. (Approved )

8 321. TAX EXEMPT BOND TAX COMPLIANCE GUIDELINES (Approved ) I. Use of Tax Exempt Bond Financing The Independent School District No. 33 of Creek County, OK (Sapulpa Public Schools) (the Issuer ) will evaluate opportunities to utilize tax exempt bond financing for major capital projects, primarily for building construction, acquisition and renovation and may also include the acquisition or equipment or other capital expenditures. Capital costs relating to equipment and furnishings will likely be included in financings for major capital projects. Financing with tax exempt bonds is determined through the Business Manager or Superintendent and the Board of Education. The Board of Education will adopt a resolution as a declaration of intent to use tax exempt financing to reimburse for project capital expenditures incurred prior to the borrowing. The Business Manager or Superintendent will consult with legal counsel and bond advisors throughout the bond financing process, including during the post-issuance term of the bonds. II. Tax-Exempt Bond Tax Law Compliance Requirements Documentation The federal tax law requirements affecting tax exempt financing are set forth in the No-Arbitrage Certificate, which is included as a document in the closing transcript for the bonds. After the delivery of a tax-exempt financing, the bond advisors shall provide the completed IRS Form 8038-G in a timely manner to the Issuer, in order for a timely filing with the IRS. A copy of the executed form and return mail receipt will be retained by the Issuer with the other tax exempt financing documents. External Counsel/Advisors Issuer maintains an ongoing relationship with outside legal counsel and bond advisors to serve as a resource for advice regarding tax exempt bond compliance. Counsel will review all contracts or arrangements involving the use of the bond financed facilities by private parties or that may be an activity that is unrelated to the exempt purpose of the organization. Issuer maintains a relationship with a firm to serve as bond advisor in connection with tax exempt bond financing to advise with respect to outstanding tax exempt bonds and for future capital projects.

9 Investments/Role of Issuer or Outside Advisor The investment of bond proceeds is managed by the Treasurer or a Trustee Bank. Unexpended bond proceeds are held by the Treasurer or Trustee Bank who is responsible for recording all investments and transactions relating to the proceeds. The Treasurer or Trustee Bank will provide regular, periodic (monthly) statements regarding the investments and transactions involving bond proceeds. Arbitrage Rebate and Yield Restriction The services of an expert advisor have been engaged by the Issuer to assist in the calculation of arbitrage rebate attributable to the investment of bond proceeds. Investment and checking (interest bearing account) statements and other requested documents and information will be provided to the rebate service provider upon request in a timely manner. Arbitrage rebate services will be monitored to assure compliance with required rebate payments, if any, no later than each 5 year period over the term of the tax exempt bonds and upon the final maturity date of each bond issue. X Alternatively, arbitrage rebate and/or yield restriction determinations will be made annually, and upon the final maturity date of each bond issue, with aforementioned data being submitted annually to the arbitrage provider. During the construction period of the capital project, the investment and expenditure of bond proceeds will be monitored and the arbitrage rebate service provider will be consulted to determine compliance with exceptions from the arbitrage rebate requirement upon the expenditure of proceeds during each 6 month spending period up to 6 months, 18 months or 24 months, as applicable, following the issuance of the bonds. Copies of all arbitrage reports, related return filings with the Internal Revenue Service, copies of cancelled checks with respect to any rebate payments and investment and checking (interest bearing account) statements will be retained as described below. Private Use of Bond Proceeds The Director of Support Services will monitor the use of bond financed assets (e.g., facilities, furnishings or equipment) throughout the term of the bonds (or the expected useful life of the assets, if shorter) to identify any use by a private person, including any use that is unrelated to the tax exempt purpose of the organization.

10 Monitoring of such private use must assure that no more than 5% of the bond proceeds are privately used. Bond proceeds applied to pay costs of issuing the bonds are treated as a private use. Records will be maintained identifying the assets or portion of assets that are financed with tax exempt bond proceeds. Outside legal counsel and bond advisers have been engaged and will be consulted to review any contracts or arrangements involving private or unrelated use of the bond financed facility and to assist in monitoring the use of bond financed assets to assure compliance with the 5% limitation on the use of bond proceeds for private use. Records will be maintained for any contracts or arrangements involving private or unrelated use of the bond financed facility. Representatives of the Issuer will meet at least annually with facilities personnel to identify and discuss any existing or planned private or unrelated use of bond financed facilities. The Director of Support Services will maintain a record of private and unrelated use of bond financed facilities to assure ongoing compliance with the 5% private use limitation throughout the term of the bonds. All relevant records and contracts will be maintained as described below. III. Record Keeping Requirements** A copy of all relevant documents and records sufficient to support that the requirements relating to the tax-exempt status of the bonds have been satisfied will be maintained by the Business Manager or Superintendent for the term of the bonds (including refunding bonds, if any) plus three years, including the following documents and records: Bond closing transcript and other relevant documentation. All documents relating to capital expenditures financed by bond proceeds. Such documents will include construction contracts, purchase orders, invoices, trustee requisitions (if applicable) and payment records. Such documents will include documents relating to costs reimbursed with bond proceeds. Records will be maintained identifying the assets or portion of assets that are financed with tax exempt bond proceeds. All contracts and arrangements involving private or unrelated use of the bond financed assets. All reports relating to the allocation of bond proceeds and private or unrelated use of bond financed assets.

11 All records of investments, investment agreements, arbitrage reports, return filings with the IRS and underlying documents, including investment and checking (interest bearing account) statements. **To support these tax positions, material records should generally be kept for as long as the bonds are outstanding, plus 3 years after the final redemption date of the bonds. This rule is consistent with the specific record retention requirements under section (d)(6)(iii)(E) of the arbitrage regulations. Certain federal, state, or local record retention requirements may also apply.** IV. Tax Compliance Training The Business Manager or Superintendent responsible for monitoring post-issuance compliance matters, will attend training or educational forums to stay up to date with tax exempt bond tax requirements. V. Annual Review The Issuer and an Independent Auditor will coordinate an annual review process, to investigate, monitor, assure and document compliance with tax exempt bond tax requirements. Adopted this 11th day of June By:

12 330.1 ACTIVITY ACCOUNT PROCEDURES (see procedure page)

13 340. PAYROLL (Revised 8-97) Teachers will be paid on a twelve months basis, the first check to be paid on the 12th of September and thereafter on the 12th of each month.

14 341. PAYROLL DEDUCTIONS Payroll deductions will be made upon request by the school employee for only those categories approved by the Board of Education.

15 342.* INSURANCE CLAIMS (Negotiated 1981) The payroll clerk will assist any employee with his/her insurance claims.

16 350. MANAGEMENT PROCEDURES FOR ACTIVITY FUNDS (Approved ) (Revised 10-07) (Revised ) The Board of Education shall exercise complete control over all activity funds and shall adopt appropriate rules and regulations for handling, expending, and accounting for all such funds. The Superintendent shall cause the activity account to be audited annually by a certified public accountant who will be selected by the Board. The audit shall be furnished to the Board. No expenditures shall be made from activity funds except by check and on the authorization of the sponsor of the groups to whom the funds belong. All such checks are to be issued and signed by the custodian of the activity fund and countersigned by the authorized administrator. The only allowable exception to this payment procedure is the payment to the Purchasing Card (P-card) vendor. The Board of Education will allow the monthly payment to the purchasing card to be auto-drafted on the due date to insure interest charges do not accrue. All activity monies shall be deposited with the activity account custodian, or with the appropriate bank with the deposit slip furnished to the activity account custodian. Complete and accurate accounts will be kept of all activity funds, and monthly reports will be made to the proper parties. The Activity Fund Custodian will be appointed by the Board of Education. The Custodian will be covered by a surety bond in an amount determined by the Board, but not less than $1,000, the premium to be paid from the general fund. All fundraising activities, to include all sources of income and the purpose for which the monies may be spent, will be approved in advance by the Board and included as an addendum to this policy, in accordance with HB 1935, effective July 1, The Superintendent is authorized to establish regulations governing the operation of the activity account.

17 360. Purchasing Cards (Approved ) The Sapulpa School District has implemented a Purchasing Card Program (P-Card) to facilitate the purchase and payment of goods and services. The main purpose of this program is to establish a more efficient, costeffective method of purchasing items for District programs and activities. Purchasing Cards are a privilege and facilitate acquisition of goods for the organization. Purchasing Cards must only be issued to employees who have the recurrent need to make purchases, and have a history of complying with all purchasing and financial policies. Check out cards are available for employees and volunteers who do not have the need to make recurrent purchases. The approvals of the site administrator and/or program director, and the P-card administrator are required for the issue of any card. All prospective cardholders must sign the Purchasing Card Agreement annually prior to a card being issued. The Sapulpa School District Director of Finance is responsible for administering the program for the District. The P-card administrator will report all P-Card issuances on a regular basis to the Superintendent. The Purchasing Card is similar to any other credit card, except that all statements must be paid off monthly. It includes controls to make it functional for large organizations. These controls ensure that the card can be used only for specific commodity purchases and vendor types within specific dollar limits. Improper card use may result in card cancellation and disciplinary action, which may result in termination of employment and/or criminal prosecution. Each site administrator and/or program director using the program will be responsible for its implementation and procedures used to control the use of the Purchasing Cards. They must ensure that all District purchasing and financial procedures are adhered to. Using the Purchasing Card does not supplant any of the policies required to make purchases with District Funds. Oklahoma State Law and the Sapulpa Board of Education require that a requisition (RQ) must be prepared and a purchase order (PO) issued to encumber funds before goods/services are ordered or purchased

18 using a P-Card. The Districts Director of Finance or his/her designee shall conduct independent regular reviews of each cardholder's activity to verify that the purchasing card is being used in accordance with this policy and administrative procedures. Cardholders must use common sense and good judgment when using school resources. This policy and related administrative procedures cannot cover every issue, exception, or contingency that may arise during the cardholders' use of the purchasing card.