{
  "code": "CAA",
  "title": "Fiscal Management Goals and Objectives: Financial Ethics",
  "description": "Policy CAA addresses financial ethics in the management of district funds, including the handling of federal grant money. It covers the district's obligations related to disclosing evidence of fraud, conflicts of interest, bribery, and other violations of federal law when the district receives or applies for federal awards. The policy applies to the district's role as an applicant, recipient, or subrecipient of federal funding.",
  "last_action_date": "2025-11-18",
  "last_action_result": "adopted",
  "policy_connect_url": "https://policyconnect.org/policy/conroe-isd/CAA",
  "timeline_local": [
    {
      "date": "2025-11-18",
      "school_year": "2025-2026",
      "action": "adopted",
      "result": "adopted",
      "summary": "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.",
      "changes_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)"
      ],
      "changes_removed": [
        "in a timely manner",
        "or",
        "ll",
        "potentially affecting"
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2025-11-18_regular",
      "confidence": "medium",
      "source_redline": "CAA_LOCAL.pdf",
      "notes": "The redline on page 4 contains several interleaved additions and deletions within a single paragraph, making precise boundary identification of each change somewhat challenging. The additions and removals have been parsed as faithfully as possible from the red underlined and red strikethrough text visible in the document. The word \"t\" at the start of \"the District\" appears to be part of a sentence restructuring where \"As an applicant, recipient, or subrecipient of a Federal award, t\" was added and the original \"T\" was effectively lowercased/replaced. The fragments \"ll\" (completing \"all\") and \"or\" reflect small in-line substitutions. Color rendering in the PDF scan may have caused some ambiguity.",
      "compliance_assessment": {
        "classification": "Required by Law",
        "elements": [
          {
            "element": "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",
            "classification": "Required by Law",
            "statutory_basis": "2 CFR 200.113",
            "supporting_quote": "An applicant, recipient, or subrecipient of a Federal award must promptly disclose whenever, in connection with the Federal award (including any activities or subawards thereunder), it has credible evidence of the commission of a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 of the United States Code",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Mandatory disclosure of credible evidence of civil False Claims Act violations in connection with Federal award",
            "classification": "Required by Law",
            "statutory_basis": "2 CFR 200.113",
            "supporting_quote": "must promptly disclose whenever, in connection with the Federal award (including any activities or subawards thereunder), it has credible evidence of the commission of a violation of the civil False Claims Act (31 U.S.C. 3729-3733)",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Written disclosure to the Federal agency, the agency's Office of Inspector General, and pass-through entity",
            "classification": "Required by Law",
            "statutory_basis": "2 CFR 200.113",
            "supporting_quote": "The disclosure must be made in writing to the Federal agency, the agency's Office of Inspector General, and pass-through entity (if applicable).",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Timing standard for disclosure changed from 'in a timely manner' to 'promptly'",
            "classification": "Required by Law",
            "statutory_basis": "2 CFR 200.113",
            "supporting_quote": "An applicant, recipient, or subrecipient of a Federal award must promptly disclose",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Nexus standard refined to 'in connection with the Federal award (including any activities or subawards thereunder)' replacing broader 'potentially affecting' language",
            "classification": "Required by Law",
            "statutory_basis": "2 CFR 200.113",
            "supporting_quote": "in connection with the Federal award (including any activities or subawards thereunder)",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          }
        ]
      },
      "compliance_summary": [
        "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."
      ]
    },
    {
      "date": "2025-10-21",
      "school_year": "2025-2026",
      "action": "first_reading",
      "result": "first_reading",
      "summary": "This update revises the Federal Awards Disclosure section of Policy CAA (Local) to align with updated federal regulatory language, specifying that the District, as an applicant, recipient, or subrecipient of a Federal award, must promptly disclose credible evidence of all violations of federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 of the U.S. Code or a violation of the civil False Claims Act, including any activities or subawards thereunder. The revision replaces vague legacy phrasing with more precise federal compliance terminology.",
      "changes_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 all",
        "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)"
      ],
      "changes_removed": [
        "in a timely manner",
        "or",
        "violations",
        "potentially affecting"
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2025-10-21_regular",
      "confidence": "medium",
      "source_redline": "CAA_LOCAL.pdf",
      "notes": "The redline on page 4 is rendered in red underline and red strikethrough within a single paragraph under \"Federal Awards Disclosure.\" Some of the added and removed text is interleaved within the same sentence, making precise boundary identification challenging. The additions and removals have been separated to the best extent possible based on the visible color-coding. The cover page title heading reads \"Discuss Revisions to Board Policy CAA (Local),\" indicating a first reading. The body text recommends adoption but per instructions, the title heading takes precedence."
    }
  ],
  "timeline_legal": []
}