Internal Monitoring Report
Executive Limitation Policy EL –7, Asset Protection
GLOBAL POLICY PROHIBITION: The Superintendent shall not allow District assets to be unprotected, inadequately maintained or unnecessarily risked.
REPORT: This report is my assurance that, as reasonably interpreted, these conditions have not occurred and that the data submitted below are accurate as of this date, May 19, 2008.
1.POLICY PROHIBITION: It is unacceptable for the Superintendent to fail to insure against theft and casualty losses or property owned or used by the district, and against liability losses to Board members, staff and the organization itself. REPORT: We currently have an umbrella insurance policy covering against the above-mentioned occurrences through the Colorado School Districts Self Insurance Pool. (See the attached Statement of Property Values and Vehicle Schedule.) I am reporting compliance with this policy.
2.POLICY PROHIBITION: It is unacceptable for the Superintendent to subject plant and equipment to improper wear and tear or insufficient maintenance. REPORT: We do repairs to the plant and equipment both on as needed basis and as per a regular maintenance schedule. Each summer, for example, we strip and refinish the Moffat gymnasium floor – last summer we sanded as well as re-finished the floor (that was the last sanding possible before having to install a new floor in about ten years); we typically strip and wax the tile floors twice per year; each summer we patch and paint the interior walls, etc. District vehicles are maintained on an as needed basis. The Crestone Charter School arranges vehicle maintenance on their own or with the District Transportation Director. We were recently approved for a CDE Capital Construction Grant to remodel the office for improved security. We employ a Maintenance Director and three (2 FTE) building custodians. I am reporting compliance with this policy.
3.POLICY PROHIBITION: It is unacceptable for the Superintendent to make any purchase: (a) wherein normally prudent protection has not been given against conflict of interest; (b) of any material amount without having obtained comparative prices and quality; or without a stringent method of assuring the balance of long term quality and cost. REPORT: We operate our purchasing procedures as Administrative Policies DJA, DJB, DJD, and DJE. (a) Protection against conflict of interest is ensured by the safeguards we have built into our purchasing procedures: purchase orders are needed for most purchases, and these go through several stages of approval, including the Business Office and Superintendent, depending on who is making the purchase request. (b) Most state and federal grants require the bidding process. We do bids on many but not all major purchases or projects. [I interpret “major” as $1,000 for equipment, as per the Capital Reserve requirement.] We do not bid on those purchases/projects where we believe it would not be in the district’s best interest to take the additional time to do so. We regularly request bids from propane suppliers. We are getting three separate bids for the office remodel project. I am reporting compliance with this policy.
4.POLICY PROHIBITION: It is unacceptable for the Superintendent to fail to protect intellectual property, information and files from loss or significant damage. REPORT: We keep important documents in a safe; we keep cash in a combination locked, fireproof file cabinet; office files are kept in locked filing cabinets, including personnel and student records; computer files are backed-up daily and are protected through virus protection and firewalls. We follow an inventory administrative policy (DID) and use a bar code system of inventory. We have successfully made the transition to using the GASB 34 accounting/inventory procedure. The addition of a fireproof vault remains a long-term goal. Though we have not eliminated all risk of theft or damage, I believe I am in compliance with this policy.
5.POLICY PROHIBITION: It is unacceptable for the Superintendent to receive, process or disburse funds under controls that are insufficient to meet the Board-appointed auditor’s standards. REPORT: Our auditor’s reports consistently come back with overall positive comments. We follow our auditing administrative policy (DIE), and for a small school district have more internal controls and division of duties than most similarly sized districts. We are fortunate to have the front desk secretary, the Assistant Business Manager, the Business Manager and the Superintendent handling different financial accounting responsibilities. We continue to work closely with CCS in this area. I am reporting compliance with this policy.
6.POLICY PROHIBITION: It is unacceptable for the Superintendent to invest or hold operating capital without written investments procedures that, as a minimum identify investment objectives, designate an investment officer, identify eligible depositories and/or Securities broker/dealers, and provide for the allocation of assets. REPORT: We do have and follow an investment administrative policy (DFA/DFAA). We can, however, only invest in what the state allows us to invest in as public educational institution, which is definitely restricted. We do invest in Colotrust, which is a very low risk investment, currently yielding approximately 2.55% interest (down from 5.3% from the same time last year!). I will be attending a Colotrust presentation with our Business Managers on May 19, 2008 (the day of our BOE meeting). I am reporting compliance with this policy.
7.POLICY PROHIBITION: It is unacceptable for the Superintendent to endanger the district’s public image or credibility, particularly in ways that could hinder the accomplishment of its ends. REPORT: I interpret this policy as requiring the Superintendent to always exercise integrity and honesty when interacting with the community, with professional colleagues, with parents, students and staff, or in any setting where to do otherwise could cause harm to the district. I am reporting compliance with this policy.