Board Policies Vol. 7: 6000s

6100s

• 6100 Annual Budget
• 6110 Budget Planning
• 6110-R Budget Planning Regulations
• 6120 Budget Hearing

6200s

• 6240 Investments
• 6240-R Investments Regulation
• 6240- E Investments Exhibit
• 6245 Fund Balance and Governmental Fund Type Definitions

6400s

• 6410 Authorized Signatures
• 6415 Electronic or Wire Transfers
• 6415-R Electronic or Wire Transfers Procedures

6600s

• 6600 Fiscal Accounting and Reporting
• 6640 Capital Assets Accounting – GASB 34
• 6650 Claims Auditor
• 6660 Independent External Audit
• 6670 Petty Cash/Petty Cash Accounts
• 6670-R Petty Cash Accounts Regulation
• 6680 Internal Audit Function
• 6685 Medicaid Compliance
• 6685-R Medicaid Compliance
• 6685-E Procedures for Identifying, Claiming and Monitoring Medicaid Services Exhibit
• 6690 Audit Committee

6700s

• 6700 Purchasing
• 6700-R Purchasing Regulation
• 6700-E.1 Purchasing Exhibit 
• 6700-E.2 Explanations of “Other” Methods of Competition to Be Used For Non-Bid Procurements
• 6705 Apparel Purchasing Policy
• 6705-E Apparel Purchasing Policy Exhibit
• 6710 Purchasing Authority
• 6720 Bidding Requirements
• 6720-R Competitive Bidding Procedures Regulation
• 6730 Cooperative Purchasing
• 6731 State Contracts
• 6740 Purchasing Procedures
• 6741 Contracting for Professional Services

6800s

• 6830 Expense Reimbursement
• 6830-R Expense Reimbursement Regulation
• 6830.2 Meals and Refreshments
• 6830.2-R Meals and Refreshments Regulation
• 6840 Use of Credit Card
• 6840-R Use of Credit Card Regulation

6900s

• 6900 Disposal of District Property

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6100 Annual Budget

The school budget development is the legal basis for the establishment of the tax levy. It is the official document that describes the programs to be conducted during a given period of time. It is the operational plan, stated in financial terms, for the conduct of all programs in the school system.

The annual school budget process is important to school district operations and serves as a means to improve communications within the school organization and with the residents of the school community.

The budget will be presented to the public in three components (to be voted upon as one proposition):

1. a program component, which includes all program expenditures of the district, including the salaries and benefits of teachers and any school administrators or supervisors who spend a majority of their time performing teaching duties, and all transportation operating expenses;
2. a capital component, which includes all transportation capital, debt service and lease expenditures; costs resulting from court judgments, administrative orders or settled or compromised claims; and all facilities costs of the district, including facilities lease expenditures, annual debt service and total debt for all facilities financed by bonds and notes of the district, and costs of construction, acquisition, reconstruction, rehabilitation or improvement of school buildings, provided that the budget shall include a rental, operations and maintenance section that includes base rent costs, total rent costs, operation and maintenance charges, cost per square foot for each facility leased by the district, and all expenditures associated with custodial salaries and benefits, service contracts, supplies, utilities, and maintenance and repair of school facilities;
3. an administrative component, which includes office and central administrative expenses, traveling expenses, and all compensation, salaries and benefits of all school administrators and supervisors, all expenditures associated with the operation of the school board, the office of the Superintendent of Schools, general administration, the school business office, any consulting costs not directly related to direct student services and programs, planning, and all other administrative activities.

In addition, each component must be separately delineated in accordance with Regulations of the Commissioner. The budget will categorize revenues, property tax refunds, expenditures, budget transfers and fund balance information, and will be formatted to show changes in the data as compared with the previous year. Finally, the budget will be written in plain language and organized in a manner which best promotes the public’s understanding of its contents.

The budget will be completed at least seven days before the public hearing at which the Board will present the budget to the voters. Copies of the budget will be made available upon request to residents within the district (not just district taxpayers) during the 14 days preceding the date of the annual election and budget vote at each school building in the district, at the school district offices, and at any public library or free association library within the district, during normal business hours on each day other than Saturday, Sunday or holidays, as well as on the school district’s internet website, www.guilderlandschools.org. In addition, at least once during the school year, the Board will include in a district-wide mailing, notice of the availability of copies of the budget.

The following documents will be attached to the budget:

• a detailed statement of the total compensation to be paid to the  Superintendent  of  Schools, and any assistant or associate superintendent in the coming school year, including a delineation of the salary, annualized cost of benefits and any in-kind or other form of remuneration;
• a list of all other school administrators and supervisors, if any, whose annual salary will be at or above the amount designated by the State Education Department in the coming year, along with their title and annual salary;
• a school district report card detailing the academic and fiscal performance of the district; and
• a property tax report card prepared pursuant to the Education Law and the Regulations of the Commissioner of Education, including information on the tax levy limit.

If the proposed budget increases the property tax levy by more than either 2% or the rate of inflation as calculated by the formulas set forth in Education Law section 2023-a (whichever is less), it requires a supermajority of 60% in order to pass.

The Board may not submit the proposed budget or a related proposition to the voters more than twice. If the voters fail to approve the proposed budget or budget proposition after the second submission, or if the Board elects not to put the proposed budget to a public vote a second time, the Board must adopt a contingency budget with a tax levy of 0% increase (i.e., less than or equal to the tax levy of the previous year).

The Board may use district monies to present educational and informational material about the annual budget and related information to the voters. It shall not, however, use these funds to urge voters to cast their ballots in a particular fashion.

Ref:           Education Law §§1608; 1716; 1804(4); 1906(1); 2008(2); 2021; 2002(1); 2022(2); 2023;

2023-a; 2035(2); 2601-a

General Municipal Law §36

Phillips v. Maurer, 67 NY2d 672 (1986)

Fiscal Management (NYSSBA, 1997)

Hartman, William T., “Participatory Budgeting in High School”, Planning and Changing, Spring 1989, vol. 20, no. 1.

Adopted June 9, 1998 (Replaced January 24, 2012)

Adopted January 24, 2012

Reviewed and Adopted November 19, 2019

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6110 Budget Planning

The Superintendent of Schools, with the assistance of the Assistant Superintendent for Business, shall be responsible for preparation of the budget. This shall include developing a budget calendar in accordance with regulation 6110-R, and adhering to that calendar.  The budget calendar shall be approved by the Board of Education in advance of the preparation of the district’s annual budget.

The budget shall be designed to reflect the Board’s objectives for the education of the children of the district. In order to provide an adequate accounting for each program expenditure, an understanding of the financial needs of anticipated program developments, and be within the financial limitations of the district, the budget shall be carefully organized and planned. The budget shall take into consideration the statutory limits on the tax levy, and the possibility of voters overriding the limit if necessary. To assist in budget and long-range planning, ongoing studies of the district’s educational programs will include estimates of the fiscal implications of each program.

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

Cross-ref: 2260, Citizens Advisory Committees

Ref:     Education Law §§1608(2)-(4); 1716(2)-(4); 1804(4); 1906(1); 2002(1); 2003(1); 2004(1);

2022(2); 2023; 2023-a; 2601-a

Fiscal Management (NYSSBA, 1997)

Adopted June 23, 1998 (Replaced)

Adopted January 24, 2012

Reviewed and Adopted November 19, 2019

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6110-R Budget Planning Regulations

The budget calendar prepared by the Superintendent of Schools shall include:

• a schedule which sets forth all important meetings and dates, for budget proposals from within the district;
• commencement dates and deadlines for certain budgetary tasks such as the estimation of all revenues and income expected to be received by the district;
• events such as the preliminary dates for the Board of Education’s consideration of the tentative budget.

As part of the budget planning process, the Superintendent or Assistant Superintendent for Business will evaluate:

• the educational philosophy, goals and objectives of the district and their modification where required;
• the district education program and support systems such as transportation, building operation and maintenance, and business affairs;
• census and enrollment projections;
• debt service schedules;
• the tax levy limit for the upcoming year and the possibility of voters overriding the limit if necessary; and
• estimated revenue from sources other than the property tax, such as state and federal aid.

Reviewed October 20, 1998 (Replaced)

Reviewed January 10, 2012

Reviewed and Adopted November 19, 2019

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6120 Budget Hearing

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

The budget hearing will be held not less than seven nor more than 14 days prior to the annual district election, at which the district’s voters will vote on the budget. The proposed budget will be completed at least seven days before the budget hearing. A copy of the proposed budget may be obtained by any district resident (not just district taxpayers) at each school, the school district offices, and any public library or free association library within the district, during normal hours of operation or certain designated hours on each day (other than a Saturday, Sunday or holiday), as well as on the school district’s internet website, www.guilderlandschools.org during the 14 day period immediately preceding the annual district election.

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

Cross-ref:        1050, Annual District Election and Budget Vote 2120, School Board Elections

2120.1, Candidates and Campaigning

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

Adopted May 12, 1998 (replaced January 24, 2012)

Adopted January 24, 2012

Revised and Adopted November 19, 2019

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6240 Investments

The objectives of the district’s investment policy are to safeguard district funds and to minimize risk, to ensure that investments mature when cash is required to finance operations and to ensure a competitive rate of return. In accordance with this policy, the Treasurer or his/her designee is authorized to invest and/or deposit all funds, including proceeds of obligations and reserve funds, in time-deposit accounts, certificates of deposit, short-term government securities, repurchase agreements or other investment instruments permitted by law, subject to the investment regulations approved by the Board of Education.
To the extent feasible, investments and deposits shall be made in and through local or regional financial institutions. Concentration of investments in a single financial institution should be avoided. Diversification of investments and deposits is encouraged. Investments may be made either directly from an authorized trading partner, or by participation in a cooperative investment agreement with other authorized municipal corporations pursuant to General Municipal Law Article 5-G and in accordance with General Municipal Law Article 3-A.
This policy will be annually reviewed by the Board and may be amended from time to time in accordance with the provisions of section 39 of the General Municipal Law.

Adopted May 12, 1998
Revised and Adopted January 24, 2012
Adopted July 1, 2015
Revised and Adopted January 23, 2018

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6240-R Investments Regulation

Authorized Investments

A. The Treasurer is authorized to invest all available district funds, including proceeds of obligations and Reserve Funds, in the following types of investment instruments:

Savings Accounts or Money Market Accounts of designated banks;

Certificates of Deposit issued by a bank or trust company located in and authorized to do business in New York State;

Demand Deposit Accounts in a bank or trust company located in and authorized to do business in New York State; Obligations of New York State; Obligations of the United States Government (U.S. Treasury Bills and Notes);

Repurchase Agreements involving the purchase and sale of direct obligations of the United States;
B. All funds may be invested in Revenue Anticipation Notes or Tax Anticipation Notes of other school districts and municipalities, with the approval of the State Comptroller.
C. Only Reserve Funds established by section 6-d, 6-j, 6-l, 6-m and 6-n of the General Municipal Law may be invested in obligations of the school district.

Direct or Cooperative Investments

Investments may be made either directly from an authorized trading partner, or by participation in a cooperative investment agreement.

A. Cooperative investment agreements may be made with certain municipal corporations: any New York State county (outside New York City), city, town, village, BOCES, fire district, or school district, pursuant to General Municipal Law Article 5-G.
B. Cooperative investment agreements, pursuant to General Municipal Law Article 3-A, must address: the governing board of the cooperative, lead participant, proportional interest, the cooperative’s investment policy, contributions and distributions, apportionment of administrative expenses and costs, methodology to determine participants’ interest, determination of market value at least monthly, portfolio interest rate testing at least monthly, irrevocable letter of credit, professional services, contribution confirmations, monthly statements, notification of distribution deferrals or unanticipated losses or material adverse events, annual independent audit, annual information statements, annual investment reports, and governing board rating disclosure.

Conditions

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

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

2. The following written contracts are required:
a. Written agreements will be required for the purchase of all certificates of deposit.
b. A written contract will be required with the Custodial Bank(s).
c. Written contracts shall be required for all Repurchase Agreements. Only credit-worthy banks and primary reporting dealers shall be qualified to enter into a Repurchase Agreement with the school district.

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

D. Designation of Custodial Bank
1. The Board will designate a commercial bank or trust company authorized to do business in the State of New York to act as Custodial Bank of the school district’s investments. However, securities may not be purchased through a Repurchase Agreement with the Custodial Bank.
2. When purchasing eligible securities, the seller will be required to transfer the securities to the district’s Custodial Bank.
E. Selection of Financial Institutions
1. The Treasurer will periodically monitor, to the extent practical but not less than annually, the financial strength, credit-worthiness, experience, size and any other criteria of importance to the district, of all institutions and trading partners through which the district’s investments are made.
2. Investments in time deposits and certificates of deposit are to be made only with commercial banks or trust companies, as permitted by law.
F. Operations, Audit, and Reporting
1. The Treasurer or designee will authorize the purchase and sale of all securities and execute contracts for investments and deposits on behalf of the school district. Oral directions concerning the purchase or sale of securities will be confirmed in writing. The school district will pay for purchased securities upon the simultaneous delivery or book-entry thereof.
2. The school district will encourage the purchase and sale of securities through a competitive process involving telephone solicitation for at least three quotations.

3. The independent auditors will audit the investment proceeds of the school district for compliance with the provisions of this Investment Regulation.
4. Monthly investment reports will be furnished to the Board of Education.

Reviewed January 23, 2018

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6240- E Investments Exhibit

(I) Obligations issued, or fully insured or guaranteed as to the payment of principal and interest, by the United States of America, an agency thereof or a United States government sponsored corporation.

(ii) Obligations issued or fully guaranteed by the International Bank for Reconstruction and Development, the InterAmerican Development Bank, the Asian Development Bank, and the African Development Bank.
(iii) Obligations partially insured or guaranteed by any agency of the United States of America, at a proportion of the market value of the obligation that represents the amount of the insurance or guaranty.
(iv) Obligations issued or fully insured or guaranteed by the State of New York, obligations issued by a municipal corporation, school district or district corporation of such state or obligations of any public benefit corporation which under a specific state statute may be accepted as security for deposit of public moneys.

Reviewed April 28, 1998
Reviewed January 10, 2012

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6245 Fund Balance and Governmental Fund Type Definitions

The Board of Education recognizes that the maintenance of a fund balance is essential to the preservation of the financial integrity of the school district and is fiscally advantageous for both the District and the taxpayer. Unanticipated events may occur that could adversely affect the financial condition of the District and jeopardize the continuation of necessary public services. Accordingly, this policy is intended to guide the District regarding maintenance of adequate fund balances and reserves in order to:

A. Provide sufficient cash flow for daily financial needs

B. Secure and maintain investment grade bond ratings

C. Offset significant economic downturns or revenue shortfalls

D. Provide funds for unforeseen expenditures relating to emergencies

The Board of Education also recognizes the need to enhance the usefulness of fund balance information by providing clear fund balance classifications and clarifying governmental fund type definitions in accordance with Statement No. 54 of the Government Accounting Standards Board (GASB): Fund Balance Reporting and Governmental Fund Type Definitions.

Fund balance definition: Fund balance is a measurement of available financial resources calculated as the difference between total assets and total liabilities in each fund.

Fund type definitions: The following definitions will be used in reporting activity in governmental funds across the District. The District may or may not report in all fund types in any given reporting period, based on actual circumstances and activity.

The general fund is used to account for and report all financial resources not reported in other funds.

Special revenue funds are used to account for and report the proceeds of special revenue sources that are restricted or committed to expenditures for specific purposes other than debt service or capital projects.

Capital project funds are used to account for and report financial resources restricted, committed or assigned to expenditure for capital outlays, including the acquisition or construction of capital facilities and other capital assets.

Debt service funds are used to account for and report financial resources that are restricted, committed or assigned to expenditure for principal and interest.

Permanent funds are used to account for and report resources that are restricted to the extent that only earnings, and not principal, may be used for purposes that support programs for the benefit of the District.

Fund balance reporting in governmental funds: Fund balance will be reported in governmental funds under the following categories using the definitions provided by GASB Statement No. 54:

Nonspendable fund balance

Definition – consists of assets that are inherently nonspendable in the current period either because of their form or because they must be maintained intact, including prepaid items, inventories, long-term portions of loans receivable, financial assets for resale and principal endowments.

Classification – Nonspendable amounts will be determined before all other classifications and consist of the following items (as applicable in any given fiscal year):

• The District will maintain a fund balance equal to the value of inventory balances and prepaid items (to the extent that such balances are not offset with liabilities and actually result in fund balance)
• The District will maintain a fund balance equal to the value of long-term portions of loan receivables and financial assets for resale
• The District will maintain a fund balance equal to the corpus (principal) of any permanent funds that are legally or contractually required to be maintained intact

Restricted fund balance

Definition – consists of amounts that are subject to externally enforceable legal purpose restrictions imposed by creditors, grantors, contributors, or laws and regulations of other governments; or through constitutional provisions or enabling legislation.

Committed fund balance

Definition – consists of amounts that are subject to a purpose constraint imposed by a formal action of the government’s highest level of decision making authority (Board of Education) before the end of the fiscal year, and that require the same level of formal action to remove the constraint.

Authority to Commit – Commitments will only be used for specific purposes pursuant to a formal action of the Board of Education. A majority vote is required to approve a commitment or to remove a commitment.

Assigned fund balance

Definition – consists of amounts that are subject to a purpose constraint that represents an intended use established by the government’s highest level of decision-making authority (Board of Education), or by their designated body or official. The purpose of the assignment must be narrower than the purpose of the general fund; and in funds other than the general fund, assigned fund balance represents the residual amount of fund balance.

Authority to Assign – The Board of Education delegates to the Superintendent, School Business Official or designee the authority to assign amounts to be used for specific purposes. Such assignments cannot exceed the available (spendable, unrestricted, uncommitted) funds balance in any particular fund.

Unassigned fund balance

Definition – represents the residual classification for the government’s general fund, and could report a surplus or a deficit. In funds other than the general fund, the unassigned classification should be used only to report a deficit balance from overspending for specific purposes for which the amounts had been restricted, committed or assigned.

Operational guidelines: The following guidelines address the classification and use of fund balance in governmental funds:

Classifying fund balance amounts – Fund balance classifications depict the nature of the net resources that are reported in a governmental fund. An individual governmental fund may include nonspendable resources and amounts that are restricted, committed, or assigned, or any combination of those classifications. The general fund may also include an unassigned amount.

Encumbrance reporting – Encumbering amounts for specific purposes for which resources have already been restricted, committed or assigned should not result in separate display of encumbered amounts. Encumbered amounts for specific purposes for which amounts have not been previously restricted, committed or assigned, will be classified as committed or assigned, as appropriate, based on the definitions and criteria set forth in GASB Statement No. 54.

Prioritization of fund balance use – When an expenditure is incurred for purposes for which both restricted and unrestricted (committed, assigned, or unassigned) amounts are available, it shall be the policy of the District for the Superintendent, School Business Official or designee to determine the order of the expenditure of funds, on an annual basis.

Minimum unassigned fund balance – Real Property Tax Law Sec. 1318 limits the amount of unexpended surplus funds a school district can retain to no more than four percent of the next year’s budgetary appropriations. Funds properly retained under other sections of the law (i.e. reserves established pursuant to General Municipal Law or Education Law) are excluded from the four percent limitation. In the context of previous fund balance reporting, an unexpended surplus was interpreted to be synonymous with unappropriated, unreserved fund balance. Under GASB 54 fund balance classifications, the four percent limitation will be interpreted to be applied to unrestricted fund balance (i.e. the total of the committed, assigned and unassigned classifications) less appropriated fund balance, amounts reserved for insurance recovery, amounts reserved for tax reduction, and encumbrances included in committed and assigned fund balance. The District will strive to maintain a minimum unassigned fund balance as defined above in its general fund ranging from three percent to four percent (or the maximum level authorized by the State of New York) of the subsequent year’s budgeted expenditures. This minimum fund balance is to protect against cash flow shortfalls related to timing of projected revenue receipts and to maintain a strong bond rating:

Replenishing deficiencies – When minimum unassigned fund balance in the general fund falls below the minimum three percent range, the District will replenish shortages/deficiencies using the budget strategies and timeframes described below.

The District will utilize budgetary strategies such as reducing recurring expenditures to eliminate any structural deficit, increasing revenues or pursuing other funding sources, or applying a combination of both options. The District shall strive to replenish deficiencies within the following time periods:

• For a deficiency resulting in a minimum fund balance below 1 percent, the District shall strive to replenish such amount over a period not to exceed five years.
• For a deficiency resulting in a minimum fund balance between 1 and 2 percent, the District shall strive to replenish such amount over a period not to exceed three years.

Implementation and review: The Board of Education authorizes the Superintendent or designee to establish any standards and procedures which may be necessary for policy implementation. The policy and procedures promulgated under it shall supersede all previous regulations regarding the District’s fund balance. The policy shall be subject to periodic review and revision by the Board of Education.

Ref: GASB Statement No. 54: Fund Balance Reporting and Governmental Fund Type Definitions

Adopted June 16, 2015
Reviewed, Adopted March 7, 2023

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6410 Authorized Signatures

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

The Board hereby authorizes the use of electronic signature disks or flash drives that are password protected and which should be secured in a locked location under the control of the Treasurer and Deputy Treasurer.

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

Extra classroom activity fund checks shall be signed by both the Central Treasurer of the extracurricular activity fund and the Building Principal.

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

The Board authorizes the payment in advance of audit of claims for all public utility services, postage, freight and express charges, in accordance with law.

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

Adopted February 15, 2011
Revised, Adopted April 12, 2016
Revised, Adopted March 7, 2023

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6415 Electronic or Wire Transfers

The objectives of the District’s wire transfer policy is to safeguard district funds and to minimize the risk for any misappropriation of funds related to on-line banking wire transfers. The District shall establish internal controls and procedures aimed at segregating, recording and authorizing functions with the objective of minimizing risk. It shall also enter into written agreements with its banking institution for wire transfers that identifies authorized individuals and maintains separate permissions for initiating a wire transfer and for approving the wire. The District and the Bank shall implement a token system that only allows the release of a wire by an authorized initiator of the wire transfer who is separate from the individual who approves the wire.

The District will only initiate a wire through a stand-alone computer that is dedicated to on-line banking. Only authorized users will be granted access to the stand-alone computer. Electronic wire transfers must be authorized by Internal Claims Auditor before they are released by the Bank. However, the Superintendent or his or her designee must authorize any wires outside the United States or Canada. Also, any wire of $250,000 or greater requires the authorization of the

Assistant Superintendent for Business or his or her designee before the wire is released from the Bank. The Internal Claims Auditor, as part of the review of cash disbursements, will confirm that all wire transfers are accompanied by the proper supporting documentation and have the appropriate authorized signatures.

Ref: Education Law Section 2116-a
General Municipal Law Article 2 Section 5-a

Adopted June 19, 2012

Revised and Adopted December 18, 2018

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6415-R Electronic or Wire Transfers Procedures

Electronic Wire Transfers

• The Account Clerk(s) or Treasurer will prepare the supporting documentation for the wire transfer of funds and initiate the transfer.

• The Internal Claims Auditor or his or her designee will review the supporting documentation and authorize the wire transfer by signing the pending release wire statement.

• A second individual with authorization rights, apart from the initiator of the wire, will logon to the on-line banking system and review the transaction and supporting documentation. He or she, using an assigned token, will release the wire.

• The Internal Claims Auditor will review the wire disbursement after the release of the wire as part of the cash disbursement review.

Manual Wire Transfers

• For manual wires the Account Clerk(s) or Treasurer will complete a Wire Transfer  Request Form from the Bank and sign the form. The Internal Claims Auditor and Assistant Superintendent for Business or his or her designee must also sign the form before the transfer is executed.

• The form is then sent to the Bank for its review. The Bank will confirm by email to the Treasurer once the wire has been authorized and will be released.

• The Internal Claims Auditor will review the wire disbursement after the release of the wire as part of the cash disbursement review.

Reviewed June 19, 2012

Revised and Reviewed December 18, 2018

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6600 Fiscal Accounting and Reporting

The Board of Education insists on clear, complete, and detailed accounting of all financial transactions for which the Board is held accountable.

Accounting and Reporting Systems

The system of accounts will conform to the Uniform System of Accounts for School Districts, as defined by the State Comptroller’s Office. In addition, accounting and reporting will adhere to generally accepted governmental accounting standards. The accounting system will yield information necessary for the Board to make policy decisions and perform its oversight function.

The Board directs the Assistant Superintendent for Business to keep informed of changes in state and/or Government Accounting Standards Board (GASB) accounting requirements and implement changes, as appropriate. The Board expects that the Assistant Superintendent for Business will communicate new standards and/or requirements to the Board, as necessary, so that the Board can carry out its responsibilities.

Proposed expenditures will be budgeted under and the actual expenditures will be charged to categories that most accurately describe the purpose for which monies are to be spent.

The Board directs the Treasurer to keep it informed of the financial status of the district through monthly cash reconciliation and budget status reports and annual fiscal reports, including periodic projections of the end of year fund balance. The Treasurer should highlight any deviation in actual fiscal conditions from planned fiscal conditions and offer recommendations to the Board to remedy the situation. The Assistant Superintendent for Business will prepare and submit, through the Superintendent, to the Board and the Commissioner of Education, such reports as are prescribed by law. These shall be filed with appropriate governmental bodies as required under law or regulation. The district will cooperate with governmental agencies and research organizations as required by law for data concerning the fiscal operations of the district.

The district shall be audited annually by an independent certified public accountant or a public accountant. The auditor’s report shall be adopted by resolution and a copy shall be filed with the Commissioner of Education.

The Superintendent is hereby directed to respond to all audit findings and recommendations. Such response is to include a statement of the corrective actions taken or proposed to be taken, or if action is not taken or proposed, an explanation of reasons, as well as a statement on the status of corrective actions taken on findings or recommendations contained in any previous report of examination or external audit, or any management letter for which a response was required.

The Superintendent shall also ensure that the provisions contained in the General Municipal Law in regard to audit reports are followed.

Cross-ref: 1120, School District Records

Ref: Education Law §§1610; 1721; 2117; 2528; 2577; 2590-i

General Municipal Law §§33; 34

8 NYCRR §§155.1; 170.1; 170.2

Adopted June 6, 2011

Adopted March 6, 2012

Reviewed and Adopted December 10, 2019

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6640 Capital Assets Accounting – GASB 34

The District defines capital assets as non-consumables assets with a normal service life of more than two years. In order to provide for the proper control and conservation of district property, the Superintendent or designee shall maintain Inventory Records and account for Capital Expenditures in accordance with the following guidelines:

Inventory Records:

• All equipment items costing in excess of $1,000 shall be inventoried.
• All non-equipment capital assets costing in excess of $15,000 shall be inventoried.

Capital Expenditure Accounting:

• Fixed assets having an estimated useful life of at least two years following the date of acquisition will be capitalized.
• Capitalization thresholds will be applied to individual fixed assets rather than groups of fixed assets.

Note: Property inventory requirements and capitalization thresholds are different subjects that are commonly confused because of their overlapping terminology.

• An inventory is an itemized list for tracking and controlling property.
• Capitalization is an accounting treatment whereby an item is recorded as a long-term asset on the balance sheet rather than as a consumable expense of the current period.

The following information must be maintained on the equipment/fixed asset inventory:

• Name and description of property
• Location of equipment
• Serial number and other identification number
• Cost of the asset at acquisition
• Acquisition date

Capitalization of Assets:

• Equipment items that cost more than $5,000 will be capitalized and depreciated for GASB 34 reporting purposes.
• Equipment items costing less than $5,000 shall be expensed for GASB 34 reporting purposes.
• All non-equipment capital assets costing in excess of $15,000 shall be capitalized and depreciated for GASB 34 reporting purposes.
• All non-equipment capital assets costing less than $15,000 shall be expensed for GASB 34 reporting purposes.

Donated items will be capitalized at a fair-market value on the date of the donation.

Some assets individually may fall below the capitalization threshold but may be purchased in large quantities by the district. Examples include computers and electronic devices at their individual cost. The district may choose to capitalize these assets as groups.

All assets will be depreciated using the straight-line method. Residual value will be considered.

Useful lives will be determined in the year of purchase based on general guidelines obtained from professional organizations and asset’s present condition. Depreciation expense will be calculated beginning in the year of acquisition.

Adopted July 6, 2009

Revised and Adopted June 18, 2013

Reviewed and Adopted December 10, 2019

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6650 Claims Auditor

The Board of Education will designate and appoint a claims auditor for the district. The claims auditor shall serve at the pleasure of the Board. The claims auditor shall report directly to the Board. The claims auditor may not be a member of the Board of Education; the clerk or treasurer of the Board; the Superintendent of Schools or other official of the district responsible for business management; the person designated as purchasing agent; and/or clerical or professional personnel directly involved in accounting and purchasing functions of the district.

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

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

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

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

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

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

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

Cross-ref: 6680, Internal Audit Function

Ref: Education Law §§1604 (35); 1709(20-a); 1724; 2509; 2526; 2554(b)

8 NYCRR §170.2

Matter of Levy, 22 EDR 550 (1983)

Adopted April 29, 2008

Adopted November 19, 2013

Reviewed and Adopted December 10, 2019

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6660 Independent External Audit

As required by law, the school district shall obtain an annual audit of its records by an independent certified public accountant or an independent public accountant. The report of such annual audit shall be presented to the Board of Education by such accountant. The auditor’s report shall be adopted by resolution and a copy filed with the Commissioner of Education.

The district shall, within 90 days of the receipt of such report or letter, prepare a corrective action plan in response to any findings contained in the annual external audit report or management letter, or any final audit report issued by the state comptroller. This corrective action plan shall be presented to the Board for review. To the extent practicable, implementation of such corrective action plan shall begin no later than the end of the next fiscal year.

The district shall use a competitive request for proposals (RFP) process when contracting for such annual audit. In addition, pursuant to law, no audit engagement shall be for a term longer than five consecutive years; provided, however, that the district, in its discretion, may permit an independent certified public accountant or an independent public accountant engaged under an existing contract for such services to submit a proposal in response to an RFP or to be awarded a contract to provide such services under a RFP process. While no single contract for external auditing services may be for a period longer than five years, the law permits a District, in it discretion, to allow the auditor currently engaged to compete and be awarded a new contract for such services.

Cross-ref: 6600, Fiscal Accounting and Reporting

Ref: Education Law §2116-a(3) and (b)

[Note: Approved by the Guilderland C.S.D. Audit Committee December 2011.]

Adopted March 5, 2013

Reviewed and Adopted December 10, 2019

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6670 Petty Cash/Petty Cash Accounts

Petty cash funds are established for reimbursement of small out-of-pocket expenses incurred in the course of conducting school business. Petty cash funds promote efficiency and economy by eliminating the preparation of checks for small amounts.

Petty cash funds shall be established at the high school, the transportation department, and the business office for the purchase of materials, supplies or services.

The amount of each fund will not exceed $100.00. The Board of Education, upon the recommendation of the Superintendent of Schools, shall appoint a bursar for each petty cash fund who shall administer and be responsible for such fund.

To ensure that these funds are properly managed, the following guidelines shall be followed:

1. Receipts and cash-on-hand must always total the authorized fund amount. All disbursements from such funds are to be supported by receipted bills, paid out slips or other evidence documenting the expenditure.
2. Sales tax on purchases will not be paid by the school district from petty cash funds.

The district shall reimburse uses of petty cash funds up to the extent of expenditures, with appropriate documentary support.

Cross-ref: 6700, Purchasing

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

Adopted February 27, 2001
Adopted February 1, 2011
Revised, Adopted June 18, 2013
Revised, Adopted May 23, 2017
Revised, Adopted December 6, 2022

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6670-R Petty Cash Accounts Regulation

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

1. deposits to petty cash will be made in amounts which shall not exceed payments made in cash from the fund;

2. payments made from the funds will be indicated by receipts, receipted bills or other evidence of payments in form available for audit;

3. disbursements will be acknowledged by the signature of the individual receiving payment;

4. each disbursement will be properly budget coded prior to the disbursement of funds;

5. a request to replenish the petty cash fund will be accompanied by a summary sheet, signed by the Bursar of the fund, with all expenditures properly accounted; and

6. reconciling petty cash balance and receipts to authorize petty cash amount.

The Bursar will disburse petty cash only for payment for materials, supplies and services, and meal expenses for staff.

Reviewed February 13, 2001
Reviewed January 18, 2011
Revised, Reviewed May 23, 2017
Reviewed December 6, 2022

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6680 Internal Audit Function

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

• Development of an annual risk assessment of district fiscal operations which shall include but not be limited to:

a. a review of financial policies and procedures,
b. the testing and evaluation of district internal controls;

• An annual review and update of such risk assessment; and
• Preparation of reports, at least annually or more frequently as the Board may direct, which:

a. analyze significant risk assessment findings,
b. recommend changes for strengthening controls and reducing identified risks, and
c. specify timeframes for implementation of such recommendations.

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

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

Cross-ref:
6690, Audit Committee

Ref:
Education Law §2116-b
8 NYCRR §170.12(b)

Adopted April 29, 2008
Adopted January 6, 2015
Adopted July 5, 2022

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6685 Medicaid Compliance

6685-R Medicaid Compliance

I. Written Policies and Procedures

• The District shall submit claims for Medicaid eligible students only and for valid Medicaid services rendered.
• The District will not allow claiming practices that misrepresent the services that are actually rendered.
• Supporting documentation must be procured, prepared, and retained for all Medicaid eligible services rendered.
• The District will submit claims for Medicaid only services where the appropriate and required documentation has been procured, documented, and filed.
• An accurate and timely billing and documentation structure is critical to ensure that District staff can effectively implement and comply with required policies and Medicaid regulation.
• Demonstrated lapses in the documentation and claiming systems infrastructure will be remedied in a timely manner at the program level with input from the Director of Pupil Personnel Services, Compliance Officer, and Audit Committee whenever possible.
• The District staff and vendors are not to falsify documentation for any purposes, including Medicaid claiming.
• The District will reconcile any receipt of federal Medicaid monies to claims reports on the Central New York Regional Information Center website.

II. Compliance Plan Oversight and Management

Duties of the Medicaid Compliance include but are not limited to:

• Overseeing and monitoring the development of the Medicaid Compliance Plan;
• Establishing methods such as periodic reviews of the District’s compliance with the current Corrective Action Plans and the State Plan Amendment, developing effective lines of communication on compliance issues, and preparing written standards and procedures that reduce the District’s exposure to fraud and abuse;
• Revising periodically the Medicaid Compliance Plan to reflect changes in the needs of the organization, and the law or policies and procedures of the government;
• Providing guidance to management, program personnel, and appropriate departments relative to compliance matters;
• Conducting an annual assessment of the success and effectiveness of the Compliance Plan by reviewing internal and external audits, investigations, reports and other findings to the District Audit Committee;
• Consulting as necessary with the New York State Office of Medicaid Inspector General, the New York State Department of Health Medicaid Compliance Officer, and outside law enforcement agencies.

Duties of the Audit Committee includes but is no limited to:

• Working with the Medicaid Compliance Officer to develop any necessary changes for compliance;
• Recommending solutions to any barriers that may exist in the successful implementation of compliance activities;
• Addressing issues regarding Medicaid claiming that may impact the District’s ability to maximize revenue and make recommendations on how to improve them;
• Assessing the success of the Compliance Plan by reviewing compliance-related activities and recommending any needed updates to the Plan;

III. Training and Education

• The Director of Pupil Personnel Services, will have responsibility for training of new and existing employees, independent contractors, including administrators and Board of Education members, as it related to the Medicaid compliance program.
• As a result of the Compliance Agreement between New York State and the Centers for Medicare and Medicaid, New York State is required to conduct annual face-to-face training for “relevant employees” of the District. Relevant employees are the Compliance Officer, Director of Pupil Personnel Services, Business Official, and Billing Clerk(s).
• The Compliance Officer will work with the Director of Pupil Personnel Services, and the BOCES Regional Medicaid Program Director in assuring that all relevant employees attend mandated annual training.
• The BOCES Regional Medicaid Program Director will work with the Director of Pupil Personnel Services, and Compliance Officer to provide in-service training on an as-needed basis in order to address identified risk areas.
• Records of training and education will be maintained by the District and the BOCES Regional Information Center.

IV. Communication Lines

The prompt reporting of compliance concerns is critical to the success of the Medicaid Compliance Plan. The District encourages individuals to contact the District Medicaid Compliance Officer by any of the following means:

1) By phone at 518-456-6200 ext 3113;
2) By e-mail at rizzoj@guilderlandschools.net;
3) By fax at 518-456-1152;
4) In person at the District Administrative Offices at 8 School Rd., Guilderland Ctr., New York 12085;
5) By U.S. mail or express delivery at the above address.

Individual anonymity will be maintained and the District will ensure that no retaliatory actions by peers or supervisors will be taken against employees who report any non-compliance issues. Alternatively an individual may contact the New York State Medicaid Compliance Officer by:

1) By phone at 518-473-3234;
2) By e-mail at clk04@health.state.ny.us
3) By U.S. mail at New York State SSHSP Compliance Officer, Room 2482 Corning Tower, Albany, NY 12237.

Here are some examples of non-compliance issues:

• Claiming or verifying attendance for services that were not provided;
• Duplicate billing by both in-district employees and outside contractors;
• Claiming for services at a higher rate when a lower rate of service was actually provided (e.g. billing for one-to-one service when a group session was provided or intentionally using an incorrect service code on a claim);
• Submitting claims with knowledge of lack of adequate documentation:
• Certifying attendance for a complete session where a complete session was not provided.
• Evidence of intentional false or altered documents.

V. Disciplinary Consequences for School Employees

Employees and independent contractors found to have engaged in improper practices within the Medicaid Program shall be subject to the penalties that are set forth in provisions of law. An employee may also be subject to disciplinary procedures under Education or Civil Service Law, which may include, but may not be limited to, written reprimand, fine, suspension, and/or dismissal.
To the extent possible all employee reports will be handled in a manner that protects the confidentiality of the reporter if requested. However, there may be circumstances in which confidentiality cannot be maintained. In all cases, however, the District is determined that the reporting employee will not suffer from retaliation for his or her good-faith actions.
The District with the help of its 3rd Party Medicaid Administrator will conduct screening of key in-district providers, contractors, and vendors to ensure they have not been sanctioned by federal or state law enforcement, or regulatory and/or licensing Agency. The District with the help of its 3rd Party Claims Administrator will check the Medicaid or Medicare “exclusion” lists to ensure that all providers, contractors, and vendors are eligible to provide services.

VI. Identification of Compliance Risk

The District’s Audit Committee and Compliance Officer shall have the responsibility to review the internal auditor’s risk assessment with regard to any comments related to the Medicaid Program. Further, should the Medicaid Program be selected for internal audit, the Audit Committee and Compliance Officer will work to address and put in place procedures to mitigate risk associated with non-compliance issues related to the Medicaid Program.
The District Business Office will conduct its own audit of claims twice a year checking that paid Claims are supported by valid documentation that is kept on file in the District Office. This valid documentation consists of signed consents, physician’s scripts and professional referrals, identifiable related service(s) on the IEP, and a signed valid service log by a provider or supervisory personnel if applicable.

Communication of any non-compliance issues should be made to the Director of Pupil Personnel Services, providers, contractors, and billing clerks. They should be aware if policies and procedures are not being followed and report any non-compliance issues to the Medicaid Compliance Officer.

VII. Response to Compliance Issues

Upon notification of a suspected incident of a suspected non-compliance issue, the Medicaid Compliance Officer will:

• Notify the Superintendent of the allegation;
• Commence the investigation in a timely manner;
• Consult, as appropriate, with the external or external auditor;
• Notify the school attorney;
• Develop and implement corrective action(s) to address the cause of the non-compliance issue.

VIII. Non-Retaliation Policy

Employees, independent contractors, and vendors who make good-faith reports of suspected non-compliance Medicaid incidents shall not be subject to acts of reprisal. To the extent possible the confidentiality of all individuals reporting Medicaid non-compliance issues will be protected. Any individual who believes that he or she has been retaliated against for reporting any Medicaid non-compliance issue should contact the District’s Medicaid Compliance Officer. The Medicaid Compliance Officer will then follow the same procedures as mentioned above in the “Response to Compliance Issues” section.

Reviewed January 20, 2015

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6685-E Procedures for Identifying, Claiming and Monitoring Medicaid Services Exhibit

Special Education Office

Identification of Medicaid Students

CSE Director
The CSE department in their spring meetings will provide all parents with a one-time Medicaid consent form even if the student may not be Medicaid eligible. The CSE department must make sure that the IEP is complete and includes all related services. Also, if there is specialized transportation the reason must be specified on the IEP.
The CSE department obtains the updated Medicaid eligible student listings from using logging onto IEP Direct and printing out a listing of Medicaid eligible students who are receiving related services. CSE should review the list to make sure it is up to date. If it is not up to date, the district’s 3rd party billing administrator, the Management Advisory Group, should be contacted and have them download the latest listing from the Med Web Reports portal.
If transportation is to be claimed, the CSE department must also communicate with the Transportation Department Medicaid eligible students and to make sure that BUS logs are kept by each driver who transports these students. The IEP must be specific with regard to reason for special transportation.

Obtaining and inputting documents for claiming

CSE Account Clerk – Beginning in July
All providers of Medicaid services need to have assigned an NPI number. The CSE account clerk logs onto EdMedNY website and checks on the NPI number for all providers. All providers of services must have an NPI to claim. The CSE account clerk must also make sure that all ordering practitioners are enrolled in the Medicaid Program. For schools, this means that its speech pathologists, who can order services, must also be enrolled in the Medicaid program. The application and instructions can be obtained at the following website:
https://www.emedny.org/info/ProviderEnrollment/ProviderMaintForms/Core_OPRA_FAQs. pdf
The CSE account clerk inputs all the documentation in IEP Direct (consents, referrals, scripts) and scans the documentation using “Document Repository in IEP Direct. The clerk should file the original consents and scripts in separate binders by student name

CSE Director
For any service provider operating under the direction of a qualified licensed practitioner, documentation must be obtained demonstrating that there was an initial meeting with the practitioner, an ongoing consulting log with this practitioner (at least quarterly), and student contact log observing the provider and student (quarterly). The department has preset forms documenting this supervision that will be given to the licensed providers who give supervision or direction to the unlicensed providers.

CSE Account Clerk
The CSE account clerk should on a monthly basis log onto Medicaid Direct and run the upload claim function in order to view any qualified sessions (i.e. 30 minutes) that are “not claimable” due to missing documentation or unsigned session log notes. This is done by signing on to Medicaid Direct, selecting maintenance, importing/validating services, selecting month, selecting “non-claimable claims”, and then selecting continue. The CSE clerk should document any “unclaimable” claims by category (i.e. missing consents, missing scripts, unsigned session notes) and report these to the CSE Director.
The CSE account clerk on at least a biweekly basis should confer with the 3rd party claims administrator to get feedback on its analysis of “unclaimable” claims and to solicit its help in identifying any missing documentation and reclaiming any claims that were rejected by Medicaid (i.e. incorrect NPI, ICD-9 codes, other). This is important to identify any missing information early so as that the District does not continue to lose out on any future claims for these sessions.

Business Office

Review of Session Notes and Follow-up with Providers with Exceptions
Account Clerk
The account clerk on a biweekly basis starting in September will run a query in IEP Direct review that will show providers and session notes inputted and any missing “e –signatures”. The account clerk will review the providers with session notes to a listing of District providers providing Medicaid services to identify any providers that are not inputting any session notes at all.

The account clerk will also access the detail In-District session notes for providers who are acting under the supervision of to make sure that their supervisors are signing their session notes. The account clerk will also quickly review various session notes to determine that the correct ICD9 and CPT codes are entered correctly. The account clerk will then email the signature checklist query, a listing of providers with unsigned “under the supervision” signatures, a listing of providers not entering any session notes to the CSE Director, and any incorrect ICD9 or CPT codes to the CSE Director.

Reconciling Payments
Using the Medicaid Calendar Billing Cycle the Treasurer will log onto the CNYRIC MedWeb reports and reconcile actual claim dollars received from Medicaid to the Medicaid claims reports. Here are the key reports that the Treasurer should use in the reconciliation Billl Sum (gross claims uploaded), Remit (Any Net Claims), Srv Update (rejected claims by CNYRIC), PendRptPRV (Federal DOH errors) and PreAdj File (federal DOH errors).

Special Education Officer

Communicating Discrepancies and Updating IEP Direct
The CSE chair and CSE account clerk will take the biweekly report received from the business office and communicate with providers who are missing electronic signatures, who are not completing session notes, and are coding their session notes incorrectly. The CSE account clerk will also follows-up with providers on any claims that have been rejected once they have been uploaded to the CNYRIC MedWeb site from Medicaid Direct. Providers can then go into IEP Direct and correct ICD-9 codes. The CSE account clerk then communicates with the Third Party Claims Administrator (Special Ed Solutions) that the IEP files are ready to be uploaded into EdMedNY and then onto the Claiming Center (CNYRIC).
In the case of transportation the CSE account clerk obtains a copy of the transportation logs from the transportation department (January and July) and sends a copy to the Third Party Claims Administrator. The CSE department files copies of the transportation logs.

Reviewed January 20, 2015

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6690 Audit Committee

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

The Audit Committee shall:

1. Recommend internal and external audit plans to the Board, specifying the areas of District operations to be reviewed for compliance with legal and regulatory requirements, operating efficiency and effectiveness;

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

3. Receive and review the report of the external auditor on any findings commented on during the annual audit report, and the management response thereto, and propose recommendations to the Board for action as may be necessary and appropriate;

4. Oversee the selection of the internal auditor and the external auditor, pursuant to the relevant Board policies, and make recommendations to the Board for appointment to said positions; and

5. Perform any other responsibilities outlined by the Board and/or as listed in the District’s Audit Committee Charter.

The Board of Education does not expect the Audit Committee to participate in or be responsible for the day to day operations of the school district or in the decisions that are the responsibility of the Superintendent of Schools or Assistant Superintendent for Business, or the other district administrators.

Ref: Education Law §2116-c

8 NYCRR §170.12 (d)

[Note: Approved by the Guilderland C.S.D. Audit Committee – December 2011.]

Adopted March 5, 2013

Reviewed and Adopted December 10, 2019

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6700 Purchasing

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

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

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

1. to effectively supply all administrative units in the school system with needed materials, supplies, and contracted services;
2. to obtain materials, supplies and contracted services at the lowest prices possible consistent with the quality and standards needed as determined by the Purchasing Agent in conformance with state law and regulation and in cooperation with the requisitioning authority. The educational and physical welfare of the students is the foremost consideration in making any purchase;
3. to ensure that all purchases fall within the framework of budgetary limitations and that they are consistent with the educational goals and programs of the district;
4. to maintain an appropriate and comprehensive accounting and reporting system to record and document all purchasing transactions;
5. to ensure, through the use of proper internal controls, that loss and/or diversion of district property is prevented; and
6. to utilize the GreenNY purchasing specification set by New York State whenever feasible.

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

Special Circumstances

A. “Piggybacking”

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

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

1. 1. The contract must have been let by the United States, or any agency thereof, any state, or any other political subdivision or district therein;
   2. The contract must have been made available for use by other governmental entities; including New York State local governments;
   3. The contract must have been let to the lowest responsible bidder or on the basis of best value, in a manner consistent with General Municipal Law §103. Those main elements are: (a) public solicitation of bids or offers; (b) secure or confidential bids or offers: (c) use of a common standard for bidders or offers to compete fairly; and (d) awarded to the lowest responsible bidder, or responsible offeror of best value, which optimizes quality, cost and efficiency.

B. Instructional Material in Alternative Formats

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

C. Environmentally Conscious Purchasing

1. Environmentally Sensitive (“Green”) Cleaning Products

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

2. GreenNY Purchasing

Where the district is procuring a commodity, service, or technology, whether by competitive bid or other type of procurement, that is the subject of a GreenNY procurement specification that has received final approval of the NYS GreenNY Council pursuant to Executive Order No. 22 (2022), the Purchasing Agent will follow the GreenNY procurement specification to the maximum extent practicable, as long as the cost is reasonably competitive, as defined in General Municipal Law §104-a. GreenNY approved procurement specifications can be found online at:
https://ogs.ny.gov/greenny/approved-greenny-specifications.

However, the district will not follow the GreenNY specifications if the Purchasing Agent determines that:

a. The commodity, service or technology will not meet the district’s requirements for form, function, or utility; or
b. There is a compelling public health or safety reason not to purchase such commodity, service or technology.

3. Recycled Products

The district gives a preference to vendors of recycled products whenever they meet the district’s specifications and the price is reasonably competitive, defined in General Municipal Law §104-a.

D. E-Rate and other Federal Discounts

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

E. American Salt Preference

The district may give a preference to suppliers of American rock salt or sodium chloride, pursuant to the requirements of General Municipal Law §104-d.

Competitive Bidding

Exceptions to Competitive Bidding

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

1. emergencies where time is a crucial factor;
2. procurements for which there is no possibility of competition (sole source items);
3. professional services that require special skill or training (see policy 6741 for guidance on purchasing professional services);
4. purchases such as surplus or second-hand items from governmental entities, certain food and milk items, or goods and services from municipal hospitals; or
5. where the district is purchasing through (or is “piggybacking” onto) the contract of another governmental entity, where the original contract complies with the requirements of New York State law for competitive bidding.

Purchasing when Competitive Bidding Not Required

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

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

1. under a county contract;
2. under a state contract;
3. under a federal contract;
4. under a contract of another political subdivision;
5. of articles manufactured in state correctional institutions; or
6. from agencies for the blind and severely disabled.

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

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

General Purchasing Provisions

The Superintendent of Schools, with the assistance of the Purchasing Agent, is responsible for the establishment and implementation of the procedures and standard forms for use in all purchasing and related activities in the district. Such procedures shall comply with all applicable laws and regulations of the state and the Commissioner of Education.

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

Comments will be solicited from those administrators involved in the procurement process before enactment of the district’s policies regarding purchasing and from time to time thereafter. The policies must then be adopted by Board resolution. All district policies regarding the procurement processes will be reviewed by the Board annually.

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

Cross-ref: 6710, Purchasing Authority
6741, Contracting for Professional Services

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

Adopted April 28, 1998
Adopted June 20, 2006
Revised and Adopted May 3, 2011
Revised and Adopted July 2, 2013
Revised and Adopted January 20, 2015
Revised and Adopted December 8, 2020
Revised and Adopted January 30, 2024

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6700-R Purchasing Regulation

The following sets forth the procedures for the procurement of goods and services by the district:

I. Definitions

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

Purchase Contract: a contract involving the acquisition of commodities, materials, supplies or equipment

Public Work Contract: a contract involving labor or both materials and labor for a project such as construction.

Reasonable Competitive: the cost of a recycled product does not exceed (a) 10% above that of a comparable non-recycled product, or (b) 15% above that of a comparable non-recycled product, if at least 50% of the secondary materials used to make the product comes from New York State waste.

Recycled Product: any product manufactured from secondary materials (recovered from or otherwise destined for the waste stream), as defined in Economic Development Law §261(1), and which meets the requirements of Environmental Conservation Law §27-0717(2) and associated regulations 6 NYCRR §368.4.

II. General Municipal Law

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

III. Competitive Bidding Required

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

1. The district will first determine if the proposed procurement is a purchase contract or a contract for public work.
2. If the procurement is either a purchase contract or a contract for public work, the district will then determine whether the amount of the procurement is above the applicable monetary threshold as set forth above.
3. The district will also determine whether any exceptions to the competitive bidding requirements (as set forth below) exist.
4. All advertised bids must include the following statement required by General Municipal Law 103-g: “By submission of this bid, each bidder and each person signing on behalf of any bidder certifies, and in the case of a joint bid each party thereto certifies as to its own organization, under penalty of perjury, that to the best of its knowledge and belief that each bidder is not on the list created pursuant to paragraph (b) of subdivision 3 of section 165-a of the state finance law.”

B. Contract Combining Professional Services and Purchase

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

C. Opening and Recording Bids; Awarding Contracts

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

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

1. The entity’s investment activities in Iran were made before April 12, 2012; the investment activities in Iran have not been expanded or renewed after that date; and the entity has adopted, publicized, and is implementing a formal plan to cease the investment activities in Iran and to refrain from engaging in any new investments in Iran; or
2. The district makes a determination, in writing, that the goods or services are necessary for the district to perform its functions and that, absent such an exemption, the district would be unable to obtain the goods or services for which the contract is offered.

D. Documentation of Competitive Bids

The district will maintain proper written documentation which will set forth the method in which it determined whether the procurement is a purchase or a public work contract.

E. Leases of Personal Property

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

Documentation: The district will maintain written documentation such as quotes, cost-benefit analysis of leasing versus purchasing, etc.

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

IV. Exceptions to Competitive Bidding Requirements

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

1. emergency situations where:

a. the situation arises out of an accident or unforeseen occurrence or condition;
b. a district building, property, or the life, health, or safety of an individual on district property is affected; or
c. the situation requires immediate action which cannot await competitive bidding.

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

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

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

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

3. when the Board separately purchases eggs, livestock, fish and dairy products (other than milk), juice, grains and species of fresh fruits and vegetables grown, produced or harvested in New York State, each order not to exceed $150,000 unless granted permission by the Commissioner of Education, subject to the requirements of General Municipal Law §103(9) and Commissioner’s Regulations 114.3.

Documentation: The district will maintain documentation consistent with sections 114.3 of the Regulations of the Commissioner of Education;

4. when the Board separately purchases milk produced in New York State directly from licensed milk processors. The amount expended in any fiscal year by the district may not exceed an amount equal to twenty-five cents multiplied by the number of days in the school year multiplied by the total enrollment of the district or exceed the current market price.

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

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

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

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

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

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

Documentation: The district will keep proper documentation in accordance with policy 6741; or

8. when the district purchases through the contracts of (or “piggybacks” onto) other governmental entities, as authorized by law, for certain goods and services permitted by law. Factors relevant to the decision to “piggyback” may include cost, staff time, delivery arrangements, quality of goods and services, and suitability of such goods and services to the district’s needs.

Documentation: The district will keep documentation indicating why “piggybacking” is in the best interests of the district, copies of the original contract, and that the originating contract was let in a manner consistent with applicable competitive bidding requirements.

V. Quotes When Competitive Bidding Not Required

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

A. Methods of Documentation

1. Verbal Quotations: the telephone log or other record will set forth, at a minimum, the date, item or service desired, price quoted, name of vendor, name of vendor’s representative;
2. Written Quotations: vendors will provide, at a minimum, the date, description of the item or details of service to be provided, price quoted, name of contact. For example, with regard to insurance, the district will maintain documentation that will include bid advertisements, specifications and the awarding resolution. Alternatively, written or verbal quotation forms will serve as documentation if formal bidding is not required.
3. Requests for Proposals: the district will utilize RFP’s to engage professional services providers in accordance with policy 6741.

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

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

1. Purchase Contracts up to $20,000

a. Contracts from $1,500 to $5,000: Verbal quotes
Documentation will include notations of verbal quotes.
b. Contracts in excess of $5,000 up to $20,000: Written quotes

2. Public Work Contracts up to $35,000

a. Contracts from $5,000 to $10,000: Verbal quotes
Documentation will include notations of verbal quotes.
b. Contracts in excess of $10,000 up to $35,000: Written quotes

VI. Quotes Not Required When Competitive Bidding Not Required

The district will not be required to secure alternative proposals or quotations for those procurements as permitted by state law:

1. under a county contract;
2. under a state contract;
3. under a federal contract;
4. under a contract of another political subdivision;
5. of articles manufactured in state correctional institutions; or
6. from agencies for the blind and severely disabled.

“Piggybacking” onto the contract of other governmental agencies is permitted where the original contract is in conformance with the goals of the district’s policy and regulation for purchasing when competitive bidding is not required.

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

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

VIII. Preferential and Environmentally Conscious Purchasing

A. Instructional Materials in Alternative Formats

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

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

B. Environmentally-Sensitive Cleaning and Maintenance Products

In accordance with Education Law §409-I, the district will purchase and utilize environmentally sensitive cleaning and maintenance products whenever feasible. The purchasing agent will consult with the Green Guidelines provided by the Office of General Services.

C. GreenNY Purchasing

The district has opted to include the GreenNY procurement specifications in its purchasing, whenever feasible. The Purchasing Agent will determine whether a GreenNY specification exists for any potential purchase, including purchases subject to competitive bidding and those that are not, and whether to include the specification. Relevant factors include whether the cost is reasonable competitive, whether the product or service will meet the district’s needs, and if there is a health or safety reason to not purchase with the specification.

D. Recycled Products

The district has opted to give a preference to vendors of recycled products whenever the price is reasonably competitive, as these terms are defined in state law and reflected in this regulation. The Purchasing Agent is directed to seek out recycled materials whenever possible, and to include this information in its advertisements.

E. American Salt Preference

The district may award contracts for rock salt or sodium chloride (whether or not subject to competitive bidding) to a responsible and reliable supplier of rock salt or sodium chloride that is mined or hand harvested in the United States, as long as the offer if within ten percent of the lowest price or best value offer.

IX. Internal Control

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

Comments will be solicited from those administrators involved in the procurement process before enactment of the district’s regulations regarding purchasing and from time to time thereafter. The regulations must then be adopted by Board resolution. All district regulations regarding the procurement processes will be reviewed by the Board at least annually.

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

Reviewed June 18, 2013
Revised, Reviewed January 20, 2015
Revised, Reviewed January 30, 2024

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6700-E.1 Methods of Competition to Be Used for Non-Bid Procurements

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6700-E.2 Explanations of ‘Other’ Methods of Competition to Be Used For Non-Bid Procurements

Emergencies: Informal solicitation of quotes or otherwise, to the extent practicable under the circumstances
Leases of Personal Property: Section 1725 of the Education Law requires that a district will be subject to competitive bidding requirements for purchase contracts when it enters into a lease of personal property.
Second-Hand Equipment from Federal and State Governments: Section 103(6) of the General Municipal Law provides a statutory exception to the competitive bidding requirement by permitting the purchase of surplus and second-hand supplies, materials or equipment without competitive bidding from the federal or state governments or from any other political subdivision or public benefit corporation with the state.
Certain Food and Milk Purchases: Section 103(a) and (10) of the General Municipal Law provides a statutory exception to the competitive bidding requirement by permitting a Board of Education to separately purchase eggs, livestock, fish and dairy products (including milk), juice, grains and species of fresh fruits and vegetables directly from producers, growers or certain processors without bidding.
Certain Municipal Hospital Purchases: Section 103(8) of the General Municipal Law provides a statutory exception to the competitive bidding requirement by permitting the purchase of goods, supplies and services from municipal hospitals under joint contracts and arrangements entered into pursuant to section 2803-a of the Public Health Law.
Sole Source: Section 103 of the General Municipal Law provides a statutory exception to the competitive bidding requirement in limited situations where there is only one possible source from which to procure goods or services required in the public interest (such as in the case of certain patented goods or services or public utility services).
Note: Exhibit added

Reviewed April 7, 1998
Reviewed May 3, 2011
Reviewed June 18, 2013

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6705 Apparel Purchasing Policy

A goal of the Guilderland Central School District is to make informed choices when purchasing school apparel. The District will make a concerted effort to ensure that school funds are not perpetuating the operation of illegal garment sweatshops either in the United States or abroad. The Board of Education has the authority to refuse bids if a bidder/manufacturer does not meet certain employment standards. As with all bid documents, the Board identifies the District’s Purchasing Agent to be responsible for reviewing and evaluating the submission of bids and whether the criteria have been met.

The Board may determine that a bidder on a contract for the purchase of apparel is not a responsible bidder for purposes of Section 103 of the General Municipal Law of the State of New York, based upon either or both of the following conditions:

1. The labor standards applicable to the manufacture of the apparel, including but not limited to employee compensation, working conditions, employee rights to form unions, and the use of child labor.
2. The bidder’s failure to provide information sufficient for the Board of Education to determine the labor standards applicable to the vendor of the apparel.

Where procurement of apparel is not subject to the bidding requirements of Section 103 of the General Municipal Law, the Board may also prohibit the purchase of apparel from any vendor, based on either or both of the following conditions:

1. The labor standards applicable to the manufacture of the apparel, including but not limited to employee compensation, working conditions, employee rights to form unions, and the use of child labor.
2. The vendor’s failure to provide information sufficient for the Board to determine the labor standards applicable to the manufacturer of the apparel.

General Municipal Law Sections 103, 104-b
Legislative Memorandum in Support of Ch. 227 (September 4, 2001).

Adopted May 14, 2002
Adopted February 15, 2011
Adopted April 12, 2016
Reviewed March 7, 2023

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6705-E Apparel Purchasing Policy Exhibit

View/download document.

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6710 Purchasing Authority

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6720 Bidding Requirements

The Purchasing Agent has the authority to prepare, advertise and open bids for all purchase contracts and contracts for public work, if formal competitive bidding is required by Section 103 of the General Municipal Law.

The Purchasing Agent, subject to approval of the Superintendent of Schools, will be responsible for the development and administration of regulations for the competitive purchasing of goods and services by the school district in compliance with the requirements of the General Municipal Law.

Cross-ref: 6700, Purchasing
6731, State Contracts

Ref: Education Law §§1619; 1725; 1725-a; 2513; 2556
General Municipal Law §§100; 103, 103-d; 103-e; 104; 104-b; 105;
109-b
Correction Law §184
State Finance Law §§163; 175-a; 175-b
Local Finance Law §§20.00; 135.00
Abco Bux v. Macchiarola, 75 AD2d 831, dissenting opinion, reversed on dissent, 52NY2d 938 (1981)
Exley v. Village of Endicott, 51 NY2d 430 (1981)
Gerzof v. Sweeney, 22 NY2d 297 (1969)
Jered v. NYC Transit Authority, 22 NY2d 187 (1969)
Randolph McNutt v. Eckert, 257 NY 100 (1931)
Hauger v. Earl, 275 AD 437 (3rd Dept., 1949)
Hurd v. Erie County, 34 AD2d 289 (1971)
Orange Front Paint v. Scaramuccia, 59 AD2d 894 (1978)
Progressive Dietary v. Wyoming City, 90 AD2d 214 (1983)
Tufaro v. Board. of Education, 79 AD2d 376 (1981)
Varsity Transit v. NYC Board. of Ed., 130 AD2d 581 (1987)
Matter of Jester, 1 EDR 259 (1959)
Executive Order No. 170, Establishing Uniform Guidelines for Determining the Responsibility of Bidders, Executive Chamber, 1993
9 Op. St. Compt. 1953, p. 421
Op. St. Compt. 81-224
Op. St. Compt. 83-22
Op. St. Compt. 86-19; 86-25
Op. St. Compt. 87-46

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6720-R Competitive Bidding Procedures Regulation

The requirements for formal competitive bidding are as follows:

1. All items must be bid when the cost of any single item or group of similar items is in excess of twenty thousand dollars ($20,000).

2. All contracted pupil transportation services must be bid where the cost of any single transportation service is in excess of twenty thousand dollars ($20,000). However, the requirement for competitive bidding shall not apply to extensions of contracts involving transportation of school children not exceeding a period of five years.

3. All repair or contract obligations involving the use of personnel and goods in a single project must be bid when such a project’s costs exceed thirty-five thousand dollars ($35,000).

4. All items and/or groups of items whose total exceeds one thousand five hundred dollars ($1,500), but is not more than twenty thousand dollars ($20,000), will require informal quotations either by a request for quotation form mailed to bidders, or by telephone when time is of the essence.

5. A “Notice to Bidders” shall be published in the officially designated newspaper commencing not less than five (5) days prior to the bid opening date. Notices may also be mailed to potential bidders sufficiently in advance of the scheduled bid opening date to permit timely preparation and submission of bids.

6. Bids shall be received until the opening time designated in the official notice. All bids shall be date stamped upon receipt and shall be kept in a safe, locked location until the time for opening.

7. Bids shall be opened at the time and place set forth in the Notice to Bidders. There will be at least two (2) district employees present at each bid opening, including the purchasing agent or designee. All interested parties may also attend the opening of bids.

8. After being opened, all bids shall be recorded and analyzed. In this analysis, in order to determine whether the low bidder is “responsible,” the purchasing agent shall consider whether the record of the bidder demonstrates or includes:

a. lack of adequate expertise, lack of prior experience with comparable projects, or lack of financial resources necessary to perform the work outlined in the contract in a timely, competent and acceptable manner;
b. engagement in criminal conduct in connection with any other government contract or the conduct of business activity that involves such crimes as extortion, bribery, fraud, bid-rigging and embezzlement;
c. grave disregard for the safety of employees or members of the public. The purchasing agent should determine whether employees will be properly trained and whether the equipment to be used is safe and functioning properly;
d. willful noncompliance with the state labor laws regarding prevailing wage and supplement payment requirements. All contracts on public work projects are required to pay their employees not less than the prevailing wage;
e. disregard for other state labor laws, including child labor, proper and timely wage payments and unemployment insurance laws;
f. violations of the State Workers’ Compensation Law including failure to provide proof of proper workers’ compensation or disability coverage;
g. violations of any state or federal environmental statutes;
h. the failure to abide by state and federal statutes and regulations regarding efforts to solicit and use disadvantaged, minority and women-owned business enterprises as potential sub-contractors;
i. the submission of a bid which is mathematically or materially unbalanced;
j. the submission of a bid which is so much lower than the contracting agency’s confidential estimate that it appears unlikely that the contractor will be able to complete the project satisfactorily at the price bid; or
k. the presentation of false or misleading statements or any other issue that raises serious questions about the responsibility of the bidder.

9. The purchasing agent shall make a recommendation to the Board of Education as to the lowest responsible bidder who has met or complied with the bid specifications.

10. In the event there are two or more bona fide low responsible bidders, the Board may make an award to one of the low bidders or, in its discretion, it may reject all the bids and re-advertise the purchase. In making an award in the case of tied low bidders, the Board may give consideration to a local business or supplier.

11. Bid bonds or deposits of five percent (5%) of the bid price may be required, at the discretion of the purchasing agent, on purchase contracts and labor or service. Performance bonds may be required, at the discretion of the Purchasing Agent.

12. Every bid shall contain the certification, properly executed by the bidder, required by Section 103-d of the General Municipal Law.

13. Minor deviations from specifications or compliance with bidding requirements may be waived by the Board, upon the recommendation of the purchasing agent. The Board of Education shall determine all questions of comparability or equivalency.

Note: Regulation added

The General Municipal Law requires that all purchase contracts in excess of $20,000, and all contracts for public works in excess of $35,000 be awarded to the lowest responsible bidder, after advertising for bids (Ch. 56, Laws of 2010).

Reviewed April 7, 1998
Reviewed January 20, 2011
Revised, Reviewed December 6, 2016
Revised, Reviewed March 7, 2023

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6730 Cooperative Purchasing

The Board of Education endorses the concept of cooperative purchasing when such method is in the best interest of the school district. The Purchasing Agent designated by the Board is authorized to explore the possible participation by the school district in cooperative purchasing ventures with other school districts and municipalities. All proposals and contracts for cooperative purchasing ventures shall be submitted to the Board for consideration and approval.

Ref: Education Law §1950
General Municipal Law §119-o

Adopted April 28, 1998
Adopted February 15, 2011
Adopted December 6, 2016
Reviewed March 7, 2023

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6731 State Contracts

Whenever it is feasible and in the best interests of the district, purchases of materials, supplies or equipment (except printed material), in excess of one-thousand five-hundred dollars ($1,500), shall be made through New York State and County Government contracts. The district will adhere to the requirements of the State Finance Law in the purchase of any suitable products or services (as determined by the Commissioner of General Services) which are manufactured, assembled, produced or provided by the blind or other severely disabled persons from approved, qualified charitable or nonprofit-making agencies. The district must purchase any suitable products which are manufactured or prepared by prisoners in the state correctional institutions and penitentiaries, pursuant to Correction Law §184.

Ref: General Municipal Law §§103(30); 104; 109-a
State Finance Law §§175-a; 175-b
Correction Law §§184; 186

Adopted April 28, 1998
Adopted February 15, 2011
Revised, Adopted December 6, 2016
Reviewed and Adopted March 7, 2023

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6740 Purchasing Procedures

Only through the use of efficient purchasing procedures can the school district ensure that needed goods and services are acquired in the most economical manner. The Board of Education directs the Superintendent of Schools and the Assistant Superintendent for Business to develop administrative regulations on how purchasing is to be done in the district.

All purchasing is to be done by the Purchasing Agent on an official purchase order.

The Purchasing Agent is authorized to issue purchase orders without prior approval of the Board when formal bidding procedures are not required by law and budget appropriations are adequate to cover such obligations.

Cross-ref: 6700, Purchasing
6720, Bidding Requirements

Ref: Office of the State Comptroller-Financial Management Guide

Adopted April 28, 1998
Adopted October 19, 2010
Adopted February 15, 2011
Revised, Adopted December 6, 2016
Adopted March 7, 2023

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6741 Contracting for Professional Services

The Board of Education will make certain that professional services are secured in a manner that protects the integrity of the process, ensures the prudent use of taxpayer dollars and provides a high-quality standard of service, in accordance with law and regulation. Professional services are defined as services requiring special skill and/or training, such as legal services, medical services, auditing services, property appraisals or insurance.

Purchasing professional services does not require competitive bidding. The Board directs the Purchasing Agent to take measures to ensure that a highly qualified professional is secured through the prudent and economical use of public money, which may include:

1. reviewing trade journals;
2. checking professional listings; and/or
3. inquiring of other districts or other appropriate sources.

The designated district staff will prepare a comprehensive written request for proposals (RFP), which will contain critical details of the services sought. The RFP will specify that the proposal include the structure of the relationship between the district and the provider, including, if applicable, the terms of the retainer, the hourly fees and other associated costs.

In reviewing the submitted proposals, the district will consider, at a minimum, the following factors:

1. the suitability of the individual/firm for the district’s needs;
2. the special knowledge or expertise of the individual/firm;
3. the credentials and applicable certifications of the individual/firm;
4. the quality of the service provided by the individual/firm;
5. cost;
6. the staffing available from the firm or the time available from the individual;

The district will periodically issue professional service RFPs and may conduct interviews as part of the RFP process. The written proposals submitted by applicants shall be maintained for at least six years.

The Superintendent, after a thorough review of the proposals, in consultation with the Assistant Superintendent for Business will recommend the professional service provider best suited to the district to the Board of Education for its approval.

Regardless of when during the year the professional service provider was engaged by the Board, at the annual organizational meeting the Board will appoint the attorney, physician, external auditor, or other professional, as applicable. Professional service providers selected and appointed in this manner will not be considered employees of the district.

The Superintendent is charged with developing administrative procedures to implement this policy.

Cross-Ref: 

• 2210, Board Annual Organizational Meeting
• 9500, Compensation and Benefits

Adopted July 2, 2013
Reviewed and Adopted January 12, 2021

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6830 Expense Reimbursement

School district employees, officials and members of the Board of Education will be reimbursed for reasonable, actual and necessary out-of-pocket expenses which are legally authorized and incurred while traveling for school-related activities.

Only expenses necessary to the purpose of the travel are reimbursable. Transportation costs, such as tolls and taxicabs, are allowable only for essential transportation. Mileage will be paid at the rate fixed by the federal Internal Revenue Service for business travel. Tax exemption certificates will be issued and utilized as appropriate (sales tax for individual restaurant meals are considered a necessary expense incidental to the meal).

The Superintendent of Schools or designee determines in the first instance, whether attendance by district staff at any conference or professional meeting is in the best interest of the district and eligible for reimbursement of expenses under this policy.

To obtain reimbursement, the claimant must complete and sign an expense voucher, attach all receipts or other expense documentation, together with a copy of the approved conference attendance request form and evaluation report (if required), and submit the same to the appropriate administrator. Reimbursement will only be made after such claim has been audited and allowed. Failure to adhere to this policy will result in denial of reimbursement.

Regulations concerning expense reimbursement are attached to this policy and will be reviewed annually and revised as appropriate.

Ref: Education Law §§ 1604 (27); 1709(30);1804; 2118; 3023; 3028
General Municipal Law §77-b; 77-c
Internal Revenue Service, Office of Federal, State & Local Government, Publication
5137: “Fringe Benefit Guide,” https://www.irs.gov/pub/irs-pdf/p5137.pdf
Office of the NYS Comptroller, Local Government Management Guide, “Travel and Conference Expense Management” (Dec. 2020), https://www.osc.state.ny.us/files/local-government/publications/pdf/travel-and-conference-expense-management.pdf
Office of the NYS Comptroller, Local Government Management Guide, “Improving the Effectiveness of Your Claims Auditing Process” (Dec. 2020), https://www.osc.state.ny.us/files/local-government/publications/pdf/improving-the-effectiveness-of-claims-auditing-process.pdf

Adopted: June 20, 2006
Adopted: February 15, 2011
Adopted: December 8, 2015
Revised, Adopted March 28, 2023

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6830-R Expense Reimbursement Regulation

The district reimburses district employees, officials and members of the Board of Education for reasonable, actual and necessary out-of-pocket expenses incurred while traveling for school-related business upon receipt of a completed voucher with itemized receipts along with approved attendance form. The following rules guide the reimbursement of school-related travel expenses:

Transportation

• Travel must be by the most economical method, whether by private automobiles, school vehicle or common carrier such as bus, train or plane.
• If travel is by private automobile, mileage will be reimbursed at the level approved by the Internal Revenue Service for business travel. Parking and tolls will also be reimbursed but gasoline will not.
• When travel is from an employee’s home to an alternate work location, or from an alternate work location to home, at a minimum, transportation expenses must be reimbursed using the lesser of 1) mileage between the employee’s home and the alternate work location or 2) mileage between the employee’s official station and the alternate work location, multiplied by the IRS mileage reimbursement rate. This reimbursement method is called the “lesser of mileage rule.”
• Rental car expenses will be reimbursed only if authorized in advance. Receipts much be attached.
• Air travel is only allowed when determined by the Board President or the Superintendent to be in the district’s best interest. Air travel will be reimbursed at the lowest feasible fare available and must not exceed regular coach class fare. Travel arrangements should be made as soon as reasonably practicable to avoid payment of a higher fare due to a late booking.

Lodging

• Persons traveling on district-related business are expected to secure the most reasonable rate for necessary hotel accommodations. The district will reimburse for actual lodging fees up to the maximum lodging fee set by the federal government for that location (https://www.gsa.gov/travel/plan-book/per-diem-rates).
• When the rate is pre-determined by the organization sponsoring the event, the traveler must secure a room rate at no more than the pre-determined rate notwithstanding what the federal travel reimbursement rate is. Hotel accommodations at a rate other than the most reasonable rate or a pre-determined rate described above will be reimbursed only if approved by the Board President (for member of the board and the Superintendent) and
  the Superintendent (for all others) prior to the stay.

Meals

The district will pay for meals for individuals traveling on district business, where the travel is substantially longer than an ordinary day’s work, or requires an overnight stay or substantial sleep or rest. Where a meal is already paid for by the district (for example, included with the conference or hotel costs), the corresponding amount for that meal will be deducted from the daily total. The first and last day of travel is 75% of the federal allowance. Itemized
receipts are required to show that expenses are allowable under this policy.

Reimbursable meal charges, including taxes and gratuities, for persons traveling for district business shall be as follows:

•  Breakfast up to $7.50
• Lunch up to $12.50
• Dinner up to $25.00
  OR
• Daily Total up to $45.00

Personal Expenses

The district does not reimburse persons traveling on district-related business for personal expenses including, but not limited to, pay television, hotel health club facilities, alcoholic beverages, theater and show tickets, and telephone calls and transportation costs unrelated to district business.

Reviewed June 20, 2006
Reviewed January 18, 2011
Reviewed December 8, 2015
Revised and Reviewed March 28, 2023
Revised and Reviewed April 16, 2024

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6830.2 Meals and Refreshments

The Board of Education recognizes that from time to time, it may be appropriate to provide refreshments and/or meals at district meetings or events, which are being held for a district or educational purpose. As a general rule, meal requests may be approved when:

• officers and/or employees of the district will be prevented from taking time off for food consumption due to a pressing need to complete the business at hand;
• the district is faced with business of an immediate nature and meetings of district employees are essential at mealtime;
• the district wishes to recognize the services provided by volunteers or other unsalaried members of the district.

An example of an authorized expenditure would be refreshments and/or meals for staff assigned to participate in assessment day grading of standardized tests. Other examples of authorized categories of expenditures included but are not limited to refreshments for staff on teacher orientation day at the beginning of each year, refreshments for a Superintendent’s Conference Day, community / district meetings, receptions for volunteers, annual staff picnic and other meetings at which district business is conducted.
All expenses must be appropriately documented, including the date, purpose of the meeting and the group in attendance, and submitted to the district’s Business Office for the purposes of audit and possible reimbursement.

Adopted June 20, 2006
Revised January 8, 2008
Adopted January 6, 2015
Reviewed, Adopted December 8, 2015

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6830.2-R Meals and Refreshments Regulation

From time to time, meals and/or refreshments may be deemed appropriate for a particular meeting, event or situation. Whenever meals and/or refreshments are ordered, the person making the request shall indicate the date, purpose of the meeting and identify the group in attendance. It is acknowledged that meal and/or refreshment expenditures may be incurred as an extension of the responsibilities of employees or to continue to enhance a specific activity or event that is being held for a business purpose. In such instances, documentation as noted above shall be submitted to the business office for the purposes of audit and possible reimbursement. In an instance where a receipt has been lost or not obtained, at the discretion of the Claims Auditor, a signed statement may be submitted as a substitute document.
Examples of authorized categories include but are not limited to a meal with a consultant employed by the district, a meal provided to a committee or working group whose responsibilities require working through the meal hour, or other specific circumstances for which working through the meal hour is advantageous to the district.
Meal costs (excluding alcoholic beverages) included for travel-related approved conferences shall be regulated by the conference request/reimbursement forms available from the Office of the Assistant Superintendent for Instruction. Meal reimbursement for district-related non-travel activities shall be guided by the rate identified in the Expense Reimbursement Policy (#6830) and the supporting regulation.

Reviewed June 20, 2006
Reviewed December 11, 2007
Reviewed January 6, 2015
Revised, Reviewed December 8, 2015

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6840 Use of Credit Cards

The Board of Education permits the use of a district credit card to pay for actual and necessary expenses incurred in the performance of work-related duties and to purchase goods for the district. A list of those individuals that will be permitted to use credit card will be maintained in the Business Office and approved by the Board each year at its organizational meeting in July.

Upon separation of employment, the individuals’ credit card shall immediately be deactivated and destroyed.

The district shall establish a credit line not to exceed $5,000 for the issued card. The relationship between the district and the credit card company shall be such that the district preserves its right to refuse to pay any claim that is not expressly authorized. In addition, the Board through its Claims Auditor will ensure that no claim shall be paid unless an itemized voucher approved by the officer whose action gave rise or origin to the claim, and shall have been audited and allowed pursuant to standard district procedures.

The credit card can only be used for legitimate district-related business expenditures. The use of credit card is not intended to circumvent the district’s policy on purchasing. Personal use of the district credit card is strictly prohibited. The Assistant Superintendent for Business shall establish regulations governing the issuance and use of the credit card.

The Claims Auditor shall monthly monitor the use of the credit card and report any problems and/or discrepancies directly to the Superintendent and the Board.

Cross-ref: 6700, Purchasing 6830, Expense Reimbursement
Ref: Education Law §§1724(1); 2524(1), General Municipal Law §77-b,
Opns. St. Compt. No. 79-202, Opns. St. Compt. No. 79-494, Opns. St. Compt. No. 78-897

Adopted: August 14, 2018

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6840-R Use of Credit Cards Regulation

To facilitate the acquisition of certain goods and services by the district, the Superintendent authorizes the Assistant Superintendent for Business to apply for a credit card on behalf of the district.

The credit card must be signed out for use with each purchasing transaction. Before an individual employee may utilize the district credit card, the employee and the Assistant Superintendent for Business or his designee must sign for the release of the credit card and a valid purchase order must be executed. When not in use the credit card will be maintained in the business office in a secure location with limited access.

A credit card shall be issued for the Superintendent and Assistant Superintendent for Business and other Board authorized individuals, and be maintained under the physical custody of the

Assistant Superintendent for Business or his designee. When needed, the Assistant Superintendent for Business and/or his designee will approve of each transaction. Authorized users must take proper care of the credit card and take all reasonable precautions against damage, theft or loss. Any damage, theft or loss must be reported immediately to the Assistant

Superintendent for Business and to the appropriate financial institution. Purchases that are unauthorized, illegal, represent a conflict of interest, are personal in nature, or violate the intent of this policy may result in credit card revocation, criminal/civil action, and discipline of the employee.

Immediately upon separation from employment, the credit card for an authorized individual shall be cancelled with the financial institution and the credit card destroyed. A log shall be maintained documenting the actions taken.

The Claims Auditor shall monitor monthly the use of the credit card and report any findings to the audit committee on the monthly claims auditor reports.

Each authorized user shall sign a statement that they have been apprised of the procedures governing the use of the district credit card and they have read and are in agreement with policy

Reviewed: August 14, 2018

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6900 Disposal of District Property

Building administrators and support staff supervisors are responsible for identifying obsolete or surplus land, equipment, school buses, supplies and/or materials within their area(s) of responsibility. Each year, a determination shall be made of which land, equipment, school buses, supplies and/or materials are obsolete and cannot be salvaged or utilized effectively or economically by the school district. Such land, equipment, school buses, supplies, or materials shall be sold through bid procedures, if possible, for the highest possible price.

The Assistant Superintendent for Business shall be authorized to implement the provisions of this policy.

1. Lands: The Board of Education shall develop annually its intent regarding sale of real property.
2. Equipment:

   The School Business Administrator is authorized to put out for competitive bid or quote any item(s) of equipment such as typewriters, furniture, mowers, etc., which are no longer repairable or useful to the district, and to sell such items of equipment to the highest bidder.

   Computers, televisions, and computer monitors, which are no longer repairable or useful and represent a potential future liability to the district, will be recycled in accordance with The New York Electronic Recycling and Reuse Act. Any data storage will be removed or destroyed.

3. Materials: The Assistant Superintendent for Business is authorized to sell or donate to public schools and other public educational or public service institutions or agencies surplus and outdated textbooks and other forms of consumable materials which are no longer of use in the instructional program of the school district.
4. Buses:
   1. School buses or other school vehicles which have passed beyond the point of feasible repair or safe operating condition, and which are not needed by the district for parts replacement stripping or for other uses, may be offered for competitive bid and sold to the highest bidder after eradication of all markings referring to the Guilderland Central School District.
   2. The district reserves the right to reject all bids.
   3. If the district cannot or does not choose to sell an outworn bus or vehicle, it will be transported, under the supervision of the Transportation Supervisor, to a vehicular crusher and destroyed.

      Appropriate modifications shall be made in district inventory records to reflect property disposal.

5. Lease of Buildings:The district shall make available for lease under the provisions of section 403-a of the Education Law and section 155.8 of the Commissioner’s Regulations any school building it is not using or other real property not in use, with lease agreements subject to approval by the Board of Education. 

An annual report regarding the status of district property leases shall be made by the Assistant Superintendent for Business.

Ref: 

• General Municipal Law §§51; 800 et seq.
• The New York Electronic Recycling and Reuse Act

Adopted April 29, 2008
Revised and Adopted January 8, 2013
Revised and Adopted June 18, 2013
Reviewed and Adopted January 12, 2021

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