3100 Financial Management
3110 Preparation of Budget
3140 Banking Services
3155 Payments from Federal Awards/Cash Management
3160 Investment of District Funds
3165 Code of Standards
3166 Federal Awards – Allowable Costs
3230 Expenditures for Certificated Staff
3320 Taxing Authority/Tax Rate Hearing
3330 Bonded Indebtedness
3370 Fundraising
3380 Sale/Lease of Real Property
3440 Travel and Reimbursement
3450 Sales Tax
3480 Bond Proceeds Reporting
FINANCIAL OPERATION Regulation 3100
Financial Management
The following procedures or actions shall be taken:
FINANCIAL OPERATION Regulation 3110
Financial Management
Preparation of Budget
On or before the second Tuesday in June of each year, the Superintendent shall prepare and submit to the Board for its consideration a preliminary draft of the annual budget covering salaries of the teachers, principals, and other employees, and an estimate of other current expenses for the next fiscal year together with an estimate of the income or revenue available and necessary for the purpose of fixing the annual levy to be submitted to the voters according to the law.
After the beginning of the fiscal year in July, the Superintendent shall prepare and present to the Board for its consideration a detailed annual budget covering all estimated expenditures for the ensuing fiscal year in accordance with the levy authorized by the voters. The aggregate estimated expenditures shall not exceed ninety-eight percent (98%) of the estimated income plus any fund balances carried forward from the previous fiscal year. This annual budget, with such changes or additions as the Board may desire to make, shall be adopted by the Board on or before the second Tuesday of August of each year.
Income
Estimates of income are based on previous receipts, information such as new legislation, new programs and phasing out of present programs; interest rates; tax rate (less 3% uncollectible). Unencumbered balance is defined as the end-of-fiscal year balance minus anticipated expenditures between July 1st and November 1st.
Expenditures
Budget expenditures are to reflect the needs and priorities of the District’s programs. By law, the expenditures cannot exceed the estimated revenue to be received plus any unencumbered balance. Building Modifications Building modification plans for major changes must be in the Associate Superintendent’s office by April 1st to be given serious consideration for the next fiscal year. The Maintenance personnel should be included in the early planning stages. A general guideline for budgeting is that the District must be able to demonstrate equal per pupil allocation of funds available. This will vary from year to year; however, except in unusual cases, this should not vary more than 5%.
FINANCIAL OPERATION Regulation 3140
Financial Management
Banking Services
For purposes of letting bids, the Board will divide District funds into no less than two nor more than ten equal parts. Each eligible bidder may bid for any number of the parts. However, the bid for each part must be separate. Notice that bids for depositary of District funds will be received will be published in a newspaper within the county which publishes at least five times per week or, if no such publication exists, then notice will be published in a newspaper of general circulation within the county. Notice that bids will be received will be published at least twenty days prior to the date designated for acceptance of bids.
Each eligible bidder is required to deliver to the secretary of the Board a sealed bid stating the rate of interest or the method by which the interest will be determined for the term of up to five years as specified in the notice to bidders. Each bid must be accompanied by a certified check drawn upon a county bank or a bank in an adjoining county made out to the District in an amount of no less than two thousand five hundred dollars. The bidder's certified check is required as a guaranty of good faith that if selected as depositary, it will deposit the required security. Bids will not be disclosed prior to opening at a public meeting.
On the date designated for acceptance of bids, the Board/designee will publicly open each bid and will verbally read and document each such bid. After discussion and after any clarification of bids, the board will select the successful bidder(s) for each fund part let for bid. Upon award of the depositary bid(s), the security checks will be returned to all bidders. The Board reserves the right to reject any and all bids. Depositary contracts may be terminated at any time by the mutual agreement of the Board and the depositary.
Interest on funds deposited will be computed on the daily balance and will be payable on the first day of each month to the treasurer of the District for credit of the District. No later than the fifth day of each month, the District's depositary(s) will provide to the secretary of the Board a written accounting of the interest paid by the depositary on District funds.
District funds will be deposited in the name of the District. No funds may be withdrawn except by a legally drawn check bearing the signatures of the president and the treasurer of the Board or by wire transfers executed by a person designated by the Board to execute such transfers.
FINANCIAL OPERATION Regulation 3155
Financial Management
Payments from Federal Awards/Cash Management
Cash Management Procedure
In order to ensure compliance with Cash Management Improvement Act (CMIA), the following procedures have been implemented:
Updated: 03/14/17
FINANCIAL OPERATION Regulation 3160
Financial Management
Investment of District Funds
In achieving the District’s investment objectives, District officials will be guided by the following criteria:
Permissible Investments
The following categories of investments are authorized for investment of District funds:
1. United States Treasury Securities – The District may invest in obligations of
the United States government for which the full faith and credit of the United
States are pledged for the payment of principal and interest.
2. United States Agency Securities – The District may invest in obligations issued
or guaranteed by any agency/instrumentalities or any wholly owned
corporation of the United States Government.
3. Repurchase Agreements – Such agreements must be purchased through
approved broker/dealers and may not be entered into for periods in excess of ninety (90) days. Approved broker/dealers must have a signed Public Securities Association Master Repurchase Agreement on file with the State Treasurer’s Office. The purchaser in a repurchase agreement (repo) enters into a contractual agreement to purchase Treasury and government agency securities while simultaneously agreeing to resell the securities at predetermined dates and prices. Overnight and open repurchase agreements must be collateralized at 100% with approved securities. Term repurchase agreements must be collateralized at 100%. The market value of all repurchase agreement collateral will be reviewed at least weekly to determine collateral adequacy.
4. Collateralized Public Deposits (Certificates of Deposit) – Instruments issued by financial institutions which state that specified sums have been deposited for specified periods of time and at specified rates of interest. The certificates of deposit are required to be backed by acceptable collateral securities as described in §§ 110.010 - .020, RSMo.
5. Commercial Paper – Investments are limited to paper which has received the highest letter and numerical ranking (A-l/P-1) as provided by Standard & Poor’s and Moody’s. Issues are limited to corporations that are organized and operating in the United States and have a total commercial paper program in excess of $500,000,000 and have long term debt ratings, if any, of “A” or better from Standard & Poor’s and Moody’s. Such purchases may not exceed 180 days to maturity.
6. Banker’s Acceptances - Issuing banks for such bills of exchange or time drafts must have the highest letter and numerical rating by Standard and Poor’s and Moody’s. Such banks must be organized and operating in the United States. Banker’s acceptance agreements may not have maturity dates exceeding 180 days.
Prohibited Transactions
1. Leveraged Borrowing for Investment Purposes – Leveraging is prohibited whether through a reverse repurchase agreement or otherwise.
2. Use of “Structured Note” – (e.g., inverse floaters, leveraged floaters, and equity-linked securities) is not permitted. Investment in any instrument, which is commonly considered a “derivative” instrument (e.g., options, futures, swaps, caps, floors, and collars), is prohibited.
3. Contracting to sell securities not yet acquired in order to purchase other securities for purposes of speculation on developments or trends in the market is prohibited.
Collateralization
Collateralization will be required on two (2) types of investment: certificates of deposit and repurchase agreements. In order to anticipate market changes and provide a level of security for all funds, the market value (including accrued interest) of the collateral should be at least 100%. For certificates of deposit, the market value of collateral must be at least 100% or greater of the amount of certificates of deposit plus demand deposits with the depository, less the amount, if any, which is insured by the Federal Deposit Corporation.
All securities, which serve as collateral against the deposits of a depository institution, must be safekept at a non-affiliated custodial facility. Depository institutions pledging collateral against deposits must, in conjunction with the custodial agent, furnish the necessary custodial receipts within five (5) business days from the settlement date.
Repurchase Agreements
The securities for which repurchase agreements will be transacted will be limited to Treasury and government agency securities that are eligible to be delivered via the Federal Reserve’s Fedwire book entry system. Securities will be delivered to the District’s designated Custodial Agent. Funds and securities will be transferred on a delivery vs. payment basis.
All deposits placed in financial institutions must be at least 100% collateralized with approved securities. All securities, which serve as collateral against the deposits of a depository institution must be safekept at a nonaffiliated custodial facility. Depository institutions pledging collateral against deposits must, in conjunction with the custodial agent, furnish the necessary custodial receipts.
Asset Allocation
District investment will be diversified to minimize the risk of loss resulting from over concentration of assets in specific maturity, specific issuer, or specific classes of securities. At a minimum District investment will fall within the following minimum and maximum allocations.
INVESTMENT TYPE |
MINIMUM ALLOCATION |
MAXIMUM ALLOCATION |
U.S. Treasuries/Securities having principal and interest guaranteed with the U.S. Government |
0% |
100% |
U.S. Government Agencies and Government-sponsored Enterprises |
0% |
100% |
U.S. Government Agency Callable Securities |
0% |
30% |
Repurchase Agreements |
0% |
50% |
Collateralized CDs/Time and Demand Deposits |
0% |
100% |
Commercial Paper and Banker’s Acceptances |
0% |
50% |
Maximum Maturity
To the extent possible, the District will attempt to match its investments with anticipated cash flow requirements. Investment in bankers’ acceptances and commercial paper will mature and become payable not more than 180 days from the date of purchases. All other investments will mature and become payable not more than five (5) years from the date of purchase.
Internal Controls
In keeping with the emphasis, the Board has placed in ensuring the safety of public funds, the District will maintain and enhance its internal controls of funds. Every reasonable effort will be made to minimize the potential for loss of funds from fraud, employee error, misrepresentations by third parties, unanticipated changes in financial markets or imprudent actions by employees. Investments that are downgraded below the minimum acceptable rating levels will be reviewed for possible sale within a reasonable time period. At least quarterly, the District’s investments will be revalued to reflect prevailing market prices.
Internal controls to achieve investment safety include, but are not limited to:
1. Separation of duties;
2. Separation of transaction authority from accounting and record keeping;
3. 3rd Party Custodial safekeeping;
4. Clear delegation of authority;
5. Written confirmation of telephone transactions;
6. Documentation of transaction strategies;
7. Monitoring of ethics and conflict of interest provisions provided in this policy/regulation.
Reporting
The Superintendent/designee will direct preparation of a report at least quarterly to the Board concerning the current status and performance of the District’s investments. The quarterly investment report will include but not be limited to:
The quarterly investment report will be delivered at an open session of a regular meeting of the Board. A copy of the District investment policy/regulation will be provided to each outside manager of District investment funds. Commitment to compliance with this policy/regulation will be a precondition for initial placement of District funds. Adherence to District policies/regulations will be condition for continued retention as a manager of District funds.
Updated: 12/08/15
FINANCIAL OPERATION Regulation 3165
Procurement Standards-Federal Contracts
Code of Standards
Conflict of Interest
The District maintains a written code of standards of conduct which governs the performance of District employees who may be engaged in the award and administration of contracts. These standards will include a prohibition against employees who are involved in the selection, award or administration of a contract supported by federal funds, if a conflict of interest, real or apparent, would be involved.
A conflict of interest would arise if a District board member or employee, any member of their family, their partner, or an organization which employs or is about to employ any of the parties named in this paragraph, has a financial or other interest in the firm selected for the award. Neither District board members, nor employees will accept gratuities, favors, or anything of monetary value from contractors, potential contractors or parties to sub-agreements. This rule will not apply to gifts of less than ten dollars ($10.00), or is an unsolicited item of nominal intrinsic value. Violations of these conflict of interest provisions will result in disciplinary action up to and including termination for employees, and up to and including public sanction of a violating Board member.
Avoidance of Unnecessary/Duplicate Purchase
The District will review proposed procurements to avoid purchases of unnecessary or duplicative items. Consideration will be given to consolidating or breaking out procurements to obtain a more economical purchase. Where appropriate, an analysis will be made of lease versus purchase alternatives, and any other appropriate analysis to determine the most economical approach. Where appropriate to foster great economy and efficiency, the District will consider entering into state and local intergovernmental agreements for procurement, or lease of common goods and services. Moreover where appropriate, the District will use federal excess and surplus property in lieu of purchasing new equipment and property.
The District will, when appropriate, consider and utilize value engineering classes in contracts for construction projects for cost reductions. In making awards, the District will select contractors to successfully perform under the terms of the procurement. In analyzing the suitability of contractors, consideration will be given to contractor integrity, compliance with public policy, past performances, as well as, financial and technical services.
Recordkeeping
The District will maintain records sufficient to detail the significant history of a procurement. These records will include, but not be limited to, the following:
Time and Material Type Contracts
The District will use time and material contracts only after a determination has been made that no other contract is suitable and, if the contract includes a ceiling price, which the contractor may exceed only at its own risk.
Contractor Compliance Resolution
The District is responsible for resolution and settlement of all contractual and administrative issues arising out of federal related procurements including, but not limited to, source evaluation, protests, disputes and claims. Violations of law will be referred to the local, state or federal authority having jurisdiction.
The District will maintain procedures to handle and resolve procurement disputes, including provisions to share information regarding the protest to the awarding agency.
Competition for Contract Awards
The District will conduct all procurement transactions in a manner providing full and open competition. In doing so, the District will avoid:
The District will avoid in such federal procurements administratively imposed in-state or local geographical preferences in the evaluation of bids or proposals, except where federal law expressly mandates or encourages such preferences. However, when contracting for architectural and engineering services, geographic locations may be a selection criterion provided that the use of such criteria leaves a sufficient number of qualified firms to compete for the contract.
Procedures for Procurement Transactions
The District will ensure a clear and accurate description of the technical requirements for the material, product or service to be provided under federally related procurements. The description may include a statement of the qualitative nature of the material, product or service to be procured and when appropriate will set forth those minimum essential characteristics and standards to which it need conform in order to satisfy the intended use. Where appropriate, a "brand name or equal" description may be used to define the performance or other requirements of a procurement.
The District will ensure that all prequalified lists of persons, firms, or products are current and include enough qualified sources to ensure maximum open and free competition. Potential bidders will not be precluded from qualifying during the solicitations process.
Methods of Procurement Affecting
Where small purchases under One Hundred Thousand ($100,000), or rate quotation will be obtained from an adequate number of qualified sources, the following procedures will be utilized.
When procurement is by sealed bid (formal advertising), bids are publically solicited and a firm-fixed price contract is awarded, the award will be made to the responsible bidder whose bid, conforming with all material terms and conditions of the invitation to bid, is the lowest in price. The sealed bid method is preferred for construction if the following conditions apply:
If sealed bids are used, the following requirements apply:
The District will utilize a competitive proposal method when conditions are not appropriate for the use of sealed bids. When this method is used, the following requirements will apply:
Where appropriate, procurement may be made by competitive proposals through a proposal from any one source or after solicitation, competition is deemed inadequate. This method will be used when small purchase procedures, sealed bid, or competitive proposals are infeasible and one of the following applies:
Contract Cost and Price
The District will perform a cost or price analysis in connection with every procurement action. At a minimum, the District will make independent estimates before receiving bids or proposals. A cost analysis will be required when adequate price competition is lacking and for sole source procurements, unless price reasonableness can be established on the basis of catalog or mailed price. The District will negotiate profit as a separate element of the process for each contract.
Contracting with Small and Minority Firms, Women's Business Enterprise and Labor Surplus Area Firms
The District will take all necessary steps to assure participation of such firms. Affirmative steps will include:
Costs or prices on estimated costs will be allowable only to the extent that costs incurred or cost estimates are consistent with federal cost principals. The District will not use a cost plus a percentage of cost and a percentage of construction cost method.
Agency Review
The District will make available, upon request of the federal agency, all documents, including but not limited to, procurement specifications; invitations to bid; procurement procedures; pre-award documents.
Biding Requirements
The District will require bonding for all construction or facility improvements ensuring that the awarding federal agency's interests are adequately protected as provided in federal regulations.
Contract Provisions
The District's contracts under the Regulation will include:
Faith Based Organizations
Faith based organizations are eligible to contract with those Districts on federally related contracts on the same basis as any other private organization. In such contracting, the District will not discriminate for or against an organization based on the organization's religious character or affiliation. However, private organizations that engage in inherently religious activities, such as religious workshops, instruction or proselytization must offer these services separately in a time or location separate from any programs or services supported by a federally related District contract.
A faith-based organization that contracts with the District on a federally related contract may retain its independence, autonomy, right of expression, religious character and authority over its governance.
Updated: 04/13/21
FINANCIAL OPERATION Regulation 3166
Financial Management
Federal Awards – Allowable Costs
Allowable, Reasonable, Allocable Cost Principles
Allowable
To be allowable under a Federal award, costs will meet the following criteria:
Reasonable
A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a reasonable person under the prevailing circumstances. In determining reasonableness of a specific cost, consideration must be given to:
Allocable
A cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to the Federal award in accordance with the benefits received. This standard is met if the cost:
Allowability Procedures
At the time of budgeting for a Federal award, all costs, direct and indirect, will be reviewed by the District’s Federal Grant administrator to assure compliance with Federal allowability principles.
Documentation of Personnel Costs
Semi-Annual Certification – Where employees are expected to work solely on a single Federal award or cost objection, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the certification period.
Monthly Personnel Reports
Where District employees work on multiple activities or cost objectives, a distribution of their salary and wages will be supported by personnel activity reports. Similar procedure will be used for District employees working on cost sharing or matching activities.
If the District elects to work under a substitute system for time and effort, the District will seek approval by DESE.
Stipends and Extra Duty Pay
Where the District pays for extra work beyond an employee’s regular contract, the District will have developed written documentation that demonstrates the extra work to be performed; the dates of performance; and the amount or rate to be paid to such employee. A contract will also be signed by the District and the employee to show acceptance of the terms. In addition, the employee must complete time and effort documentation that supports the extra work beyond the employee’s regular contract. This documentation may be a semi-annual time certification or monthly personnel activity report.
Updated: 03/14/17
FINANCIAL OPERATION Regulation 3230
Payroll
Expenditures for Certificated Staff
The District will expend for tuition, teacher retirement and compensation of certificated staff a percentage of current operating costs that is no less than two (2) percentage points less than the base school year certificated salary percentage.
Or Have an unrestricted fund balance in the combined incidental and teachers' fund on June 30, which is equal to or less than ten percent (10%) of the combined expenditures for the year from those funds.
Or Maintain or increase its fiscal instructional ratio of efficiency (FIRE) compared to the District's FIRE for the 1997-98 base year.
The District's FIRE is the quotient of the sum of the District's current operating costs plus the cost of improvement of instruction and the cost of purchased services and supplies for operation of the facilities housing those programs, and excluding student activities divided by the sum of the District's current operating cost for kindergarten through grade twelve, plus all tuition revenue received from other districts minus all noncapital transportation and school safety and security costs.
Exceptions
The above provisions do not apply to qualifying districts when the state distributes ninety-six percent (96%) or less for the formula than it did in fiscal year 2002. A qualifying district:
Or
Or
Or
FINANCIAL OPERATION Regulation 3320
Revenue
Tax Rate Hearing
The Board of Education will annually conduct tax rate hearing(s) prior to September 1. The purpose of the tax rate hearing process is to provide administrative recommendations, obtain community input and adoption of a tax rate. Notice of all tax rate hearings will be provided by posting in at least three District sites or publication in a local newspaper at least seven (7) days prior to the hearing. Written notice will include the District's assessed valuation, proposed tax rate, date, time and place of hearing and will advise where copies of the proposed tax rate may be obtained.
FINANCIAL OPERATION Regulation 3330
Revenue
Bonded Indebtedness
The Missouri State law guidelines shall serve to direct the Board's bonds issue. Guidelines currently include the following provisions:
FINANCIAL OPERATION Regulation 3370
Revenue
Fundraising
In order to implement this policy, the following guidelines shall be applied:
1. No selling or vending of items for fund raising purposes, with the exception of the operation of concession stands, shall be allowed at any school activity.
2. Elementary school fund raising activities shall be limited to one per year and shall be limited to carnivals, chili suppers, ice cream socials, and other similar activities that promote the school, community and family relationships.
3. No students shall be singled out and recognized either individually or in groups for their success in raising funds.
4. Students are not permitted to participate in door to door solicitation of funds, or selling of goods or items as fund raising activities, relating to PTO organizations or High School booster groups, etc.
5. All athletic teams are required to wear only those uniforms that are provided by the District.
An admission price may be charged for student activities as may be set by the activities conference or the Board.
The District or, with administrative approval, an organization within the school system may establish reasonable dues, or charges for co-curricular activities, services, or merchandise provided so long as such payments are not made a condition of school attendance or membership and participation is at the option of the student. The Board endorses the student activity ticket as a means of encouraging participation and partially financing school activities.
Student activity funds shall be deposited though the principal’s offices and handled through the regular accounting system of the District.
FINANCIAL OPERATION Regulation 3380
Revenue
Sale/Lease of Real Property
If the Board of Education affirmatively votes to sell or lease unneeded real property, the sale will be conducted as follows:
Listing with Real Estate Broker
At its option, the Board may list the property with one or more real estate brokers licensed by the State of Missouri. In such cases, the Board is authorized to pay a commission upon successful completion of such sale or lease.
Sales/Lease to Highest Bidder
If the Board chooses not to list the unneeded real property with a real estate broker, the notice of the sale or lease will be published in a newspaper of general circulation in the community in which the District is located in whole or in part. Notice of the sale or lease will be published at least once a week for two consecutive weeks with the last publication to be at least seven (7) days prior to the sale or lease. Property will then be sold/leased to the highest bidder. The Board reserves the right, in its sole discretion, to set a minimum bid.
Sale/Lease to City, State, or Governmental Subdivision
The Board may also elect to sell or lease such real property to a city, state agency, municipal corporation, or other governmental subdivision located within the District for public use or purpose. In such case, the notice will be given by publication in a newspaper of general circulation as set out in the preceding section. The price for sale or lease of the property will be as agreed upon by the District and the governmental entity.
Regardless of how sold/leased, the lease or deed of conveyance will be signed by the Board President and attested to by the Board Secretary. The proceeds from such sale/lease, except for districts identified as financially distressed, will be placed in the capital projects fund.
Disposal of Previously Donated Property
If after ten years following the donation of real property, the District may sell the donated property after first offering to return the property to the previous owner. If the previous owner declines, the District may sell the property as surplus.
Updated: 09/14/10
FINANCIAL OPERATION Regulation 3440
Accounting and Reporting
Travel and Reimbursement
Travel Expense Allowance
Upon approval of the Superintendent, employees may be authorized to attend conferences, meetings, conventions, etc. When full expenses are allowed, they shall be deemed to include registration, transportation fees, lodging and meals.
Each employee allowed travel expenses shall file with the Superintendent/designee an itemized account of expenses; he/she may request an advance of estimated expenses subject to adjustment upon filing of the itemized account. Each employee shall submit to the Superintendent/designee such other reports as may be required.
The Superintendent may authorize attendance at professional meetings by staff members, Board members and others working on District matters, and may approve reasonable expenditures that include an amount set annually by the Board for lodging, travel expenses and applicable registration fees.
The Superintendent shall notify the Board of the date and purpose of the event for which such approval is granted, name(s) of person(s) attending, and cost to the District.
The Superintendent shall have the power to excuse any employee from duty for the above purposes for a period not to exceed one (1) day without allowance for expenses.
Reimbursement Policies
Updated: 03/14/17
FINANCIAL OPERATION Regulation 3450
Accounting and Reporting
Sales Tax
Suppliers or retailers selling rings, pictures, sweaters, jackets, school annuals, musical instruments, shoes and similar items, or renting of gowns, caps and other items which are for personal, individual benefit and use of a student, should include and collect the sales or use tax on such sales or rentals.
Purchase orders will designate if purchases are for school purposes and not for students' individual and personal ownership. If the purchases are for the school's purposes as part of its regular educational activities, no tax should be collected by the sellers. (Examples of nontaxable purchases: books, desks, school supplies and equipment; diplomas, medals, awards or cups; athletic, musical or other equipment and supplies purchased for the athletic and other departments; and items for the general use by or benefit of all students entered or engaged in regularly sponsored school athletic or other educational programs, classes, events or activities.)
Operators of vending machines or commissaries located in schools, but not operated by the schools or any school group, are required to report the tax on the gross receipts from these vending machines or commissaries operated by them (retailers).
Tax will not be collected on admissions charged to school plays or entertainment sponsored as a part of the regular school program, as such activities are considered occasional in nature. However, when entertainment or programs are put on by individuals, entertainers or groups who make this a business and receive as compensation a portion of the net receipts, then the sales tax must be collected on the admission charge even though sponsored by the school, and the profits, if any, are intended to be used for school purposes.
FINANCIAL OPERATION Regulation 3480
Financial Management
Bond Proceeds Reporting
In order to ensure compliance with the Security Exchange Act of 1954, the District hereby adopts the following policies and procedures:
Updated: 04/14/15