Code No.: 807.2
INTERNAL CONTROLS
Purpose: The Board expects all board members, employees, volunteers, consultants, vendors,
contractors, students and other parties maintaining any relationship with the school district to act with
integrity, due diligence, and in accordance with all laws in their duties involving the school district’s
resources. The board is entrusted with public dollars and no one connected with the school district
should do anything to erode that trust.
Policy: Internal control is the responsibility of all employees of the school district. The
Superintendent, business manager and board secretary shall be responsible for developing internal
controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the
school district subject to review and approval by the board. Administrators shall be alert for any
indication of fraud, financial impropriety, or irregularity within the administrator’s area of
responsibility.
Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions
immediately to his/her immediate supervisor and the Superintendent. The Superintendent shall have
primary responsibility for any necessary investigations and shall coordinate investigative efforts with
the board’s legal counsel, auditing firm, and other internal or external departments and agencies,
including law enforcement officials, as the Superintendent may deem appropriate.
Employees bringing forth a legitimate concern about a potential impropriety will not be retaliated
against and those who do retaliate against such an employee will be subject to disciplinary action up
to, and including, discharge.
In the event the concern or complaint involves the Superintendent, the concern shall be brought to the
attention of the board vice-president, who shall be empowered to contact the board’s legal counsel,
insurance agent, auditing firm, and any other agency to investigate the concern or complaint.
Upon approval of the board, the Superintendent, may contact the State Auditor or elect to employ the
school district’s auditing firm or State Auditor to conduct a complete or partial forensic/internal
control/SAS99 audit annually or otherwise as often as deemed necessary. The Superintendent is
authorized to order a complete forensic audit if, in the Superintendent’s judgment, such an audit
would be useful and beneficial to the school district. The Superintendent shall ensure the State
Auditor is notified of any suspected embezzlement or theft pursuant to Iowa law. In the event, there
is an investigation; records will be maintained for use in the investigation. Individuals found to have
altered or destroyed records will be subject to disciplinary action, up to, and including termination.
Legal References: American Competitiveness and Corporate Accountability Act of 2002,
Pub. L. No. 107-204.
Iowa Code ch. 11, 279.8 (2005).
Approved 3/19/07
Reviewed 6/20/11
Reviewed 5/2/16