Policy CAA: Fiscal Management Goals and Objectives: Financial Ethics

Policy CAA addresses financial ethics in the management of district funds, including the handling of federal grant money.

Local Changes (2)

2025-11-18adopted · Meeting notes

This update revises the Federal Awards Disclosure section of Policy CAA (Local) to align with federal grant requirements, clarifying that the District — as an applicant, recipient, or subrecipient of a Federal award — must promptly disclose credible evidence of fraud, conflict of interest, bribery, or gratuity violations (specifically those under Title 18 of the U.S. Code or the civil False Claims Act) to the federal awarding agency, pass-through entity, and the agency's Office of Inspector General, replacing the prior broader and less specific disclosure language.

Added

As an applicant, recipient, or subrecipient of a Federal award, t
promptly
and agency's Office of Inspector General any credible evidence of the commission of a
conflict of interest,
found in Title 18 of the United States Code or a violation of the civil False Claims Act. This applies to
award (including any activities or subawards thereunder)

Removed

in a timely manner
or
ll
potentially affecting

Legal Compliance Summary

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Federal Fraud Reporting Requirement: Federal regulations (2 CFR 200.113) require school districts that receive federal funding to report credible evidence of fraud, bribery, or similar offenses connected to that funding. This policy update reflects that requirement.
Civil False Claims Act Disclosures: Under 2 CFR 200.113, districts must also report credible evidence of violations of the civil False Claims Act, a federal law that addresses dishonest claims made to the government for money or property. This policy now specifically names that requirement.
Who Must Be Notified: Federal regulations specify that disclosures must be made in writing to three parties: the federal agency providing the funding, that agency's Office of Inspector General, and any pass-through entity that channeled the funds to the district. This policy update names all three recipients to match the regulatory requirement.
Faster Reporting Standard: The prior policy language required disclosure 'in a timely manner,' but 2 CFR 200.113 uses the word 'promptly.' This update brings the district's policy wording in line with the federal standard.
Clearer Scope of Coverage: The updated policy narrows the description of which situations trigger a reporting obligation, now specifying violations that occur 'in connection with the Federal award, including any activities or subawards thereunder.' This language comes directly from 2 CFR 200.113 and replaces a broader, less precise phrase used in the prior policy.

Legal Compliance Details Required by Law

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Mandatory disclosure of credible evidence of Federal criminal law violations (fraud, conflict of interest, bribery, gratuity violations under Title 18 U.S.C.) in connection with Federal award Required by Law

Statutory basis: 2 CFR 200.113