{
  "code": "CV",
  "title": "Facilities Construction",
  "description": "This policy governs the planning, design, and construction of school district facilities. It covers the processes and standards that apply when building new structures or making major improvements to existing ones.",
  "policy_connect_url": "https://policyconnect.org/policy/conroe-isd/CV",
  "last_action_date": "2026-08-18",
  "last_action_result": "adopted",
  "timeline_local": [
    {
      "date": "2026-08-18",
      "school_year": "2026-2027",
      "action": "adopted",
      "result": "adopted",
      "summary": "This update to the CV (Facilities Construction) Local Policy significantly restructures the policy by reorganizing construction delivery methods and contracting authority into tiered thresholds (over/under $2,000,000 and over/under $500,000), introducing new Board approval form templates for delivery methods and contracts, revising change order approval requirements by contract size, splitting final payment provisions by contract tier, removing the standalone Project Administration section, and adding a new Implementation section with a December 31, 2026 deadline for required forms.",
      "changes_added": [
        "The Superintendent shall ensure that the Board receives timely, accurate, and ongoing information about construction contracts and is provided with information to make approvals required by Texas law.",
        "Construction Delivery Methods (section heading)",
        "Contracts Over $2,000,000 (subsection heading)",
        "a recommendation for the best value determination for the Board to consider, and approve, for all construction delivery methods for projects that are anticipated to exceed $2,000,000, prior to advertising the project delivery/contract award method.",
        "To assist the Board with approval of the construction delivery methods, the Superintendent shall prepare a standard approval form template for Board adoption that includes proposed key construction delivery method information, including an anticipated timeline of events.",
        "Once the construction delivery method template is adopted by the Board; the Superintendent shall provide the Board with the completed form for each construction project delivery method under this section.",
        "Contracts Under $2,000,000 (subsection heading)",
        "The Superintendent shall determine the construction delivery method in the best value determination of the District or in accordance with Texas law for contracts under $2,000,000.",
        "Contracting Authority Over $500,000 (revised subsection heading — 'Approval' removed)",
        "To assist the Board with approval of the construction contracts, the Superintendent shall prepare a standard approval form template for Board adoption that includes key construction contract information.",
        "Once the construction contract approval form template is adopted by the Board, the Superintendent shall provide the Board with the completed form for each construction contract under this section.",
        "Contracting Authority Under $500,000 (revised subsection heading — 'Approval' removed)",
        "Construction contracts and construction related materials or services under $500,000",
        "Board pPolicy",
        "CH(LOCAL) and CH(LEGAL)",
        "Board Approved Contracts Over $500,000 (subsection heading under Change Orders)",
        "Change orders on all Board-approved construction contracts over $100,000 shall require Board approval.",
        "The Superintendent shall prepare a change order recommendation form template for Board approval.",
        "Once the Board approves the change order form, the Superintendent shall provide the Board with the completed form, including accurate status, scope, cost, and schedule impacts of any Board approved construction contract change order under this section.",
        "District Approved Contracts Under $500,000 (subsection heading under Change Orders)",
        "On District approved construction contracts, change orders shall not require Board approval. The District shall inform the Board of all change orders, or combined change orders, over $100,000 using the template for Board Approved Contracts.",
        "Board Approved Contracts Over $500,000 (subsection heading under Final Payment)",
        "For Board approved construction contracts, the District shall not make final payments for construction until the work has been substantially completed and accepted by the Board.",
        "District Approved Contracts Under $500,000 (subsection heading under Final Payment)",
        "For District approved construction contracts, the District shall not make final payments for construction until the work has been substantially completed and accepted by the District the work.",
        "Implementation (section heading)",
        "The District shall adopt procedures to implement this Board Policy. The District shall present required forms for Board adoption no later than December 31, 2026."
      ],
      "changes_removed": [
        "The construction manager-at-risk project delivery method shall be deemed the project delivery/contract award method providing the best value to the District for construction projects valued at or above $100,000. If another method is deemed to provide the best value to the District for a particular construction project,",
        "or designee",
        "determine, and",
        "the contract the project delivery/contract award method",
        "For construction projects valued below $100,000, the Superintendent shall determine the project delivery/contract award method that provides the best value to the District.",
        "also",
        "resulting",
        "Lesser expenditures for construction",
        "Approval (from 'Approval Contracting Authority Over $500,000')",
        "Approval (from 'Approval Contracting Authority Under $500,000')",
        "Change orders permitted by law shall be approved prior to any changes being made in the approved plans or the actual construction of the facility.",
        "Changorders valued at or above $100,000",
        "However, if the Superintendent determines that such prior approval unreasonably delays construction, the Superintendent is authorized to approve the change orders, and the Board at the earliest opportunity shall ratify the change orders.",
        "Change orders permitted by law valued less than $100,000 shall be approved by the Superintendent prior to any changes being made in the approved plans or the actual construction of the facility.",
        "Project Administration (section heading)",
        "All construction projects shall be administered by the Superintendent or designee.",
        "The Superintendent shall keep the Board informed concerning construction projects and also shall provide information to the general public.",
        "or the supervision of construction for projects valued at $100,000 or more,",
        "the Board accepted",
        "the work. For all projects valued at less than $100,000, final payments for construction or the supervision of construction shall not be made until the work has been completed and the Superintendent or designee has accepted the work."
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-08-18_regular",
      "confidence": "medium",
      "source_redline": "CV_LOCAL.pdf",
      "notes": "The cover page does not contain a standard TASB action title (e.g., \"First Reading,\" \"Adopt Revisions\"), so the board action is marked as unknown. The redline uses red underline for additions and red strikethrough for removals consistently throughout. Some text (e.g., capitalization fixes like 'pPolicy', 'Cconstruction') appears to be minor typographical corrections included as tracked changes. The restructuring is extensive and some boundary lines between added/removed text required interpretive judgment where formatting overlapped.",
      "compliance_assessment": {
        "classification": "Mixed",
        "elements": [
          {
            "element": "Superintendent duty to ensure Board receives timely, accurate, and ongoing construction contract information",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District-initiated requirement placing affirmative information duty on Superintendent; no statute in the analysis mandates this specific information protocol or its framing"
          },
          {
            "element": "Construction Delivery Methods — Contracts Over $2,000,000: Board must approve best value delivery method recommendation prior to advertising",
            "classification": "Mixed",
            "statutory_basis": "TEC §44.031; 19 TAC §61.1040(d)",
            "supporting_quote": "TEC §44.031: 'all school district contracts for the purchase of goods and services...valued at $50,000 or more in the aggregate for each 12-month period shall be made by the method, of the following methods, that provides the best value for the district'; 19 TAC §61.1040(d): 'a board of trustees may not delegate the authority to act regarding an action authorized or required by TEC, Chapter 44, Subchapter B, to be taken by a board of trustees of a school district'",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "$2,000,000 threshold is locally chosen; requirement that Board approve prior to advertising is locally added; statute requires best-value method selection and prohibits delegation of Board-level procurement authority but does not specify this pre-advertising approval step or dollar threshold"
          },
          {
            "element": "Construction Delivery Methods — Contracts Over $2,000,000: Superintendent to prepare and present standard Board approval form template for delivery methods",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Form template requirement, template content specifications, and completed-form submission process are all locally designed; no statute in the analysis requires this specific mechanism"
          },
          {
            "element": "Construction Delivery Methods — Contracts Under $2,000,000: Superintendent determines delivery method by best value or in accordance with Texas law",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §44.031; 19 TAC §61.1040(d)",
            "supporting_quote": "19 TAC §61.1040(d): 'a board of trustees of a school district may, as appropriate, delegate its purchasing and contracting authority under TEC, Chapter 44, Subchapter B, regarding an action authorized or required to be taken by a school district or a designated person, representative, or committee'",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "$2,000,000 threshold for delegating delivery method selection to Superintendent is locally chosen; statute permits delegation but does not require it or specify this threshold"
          },
          {
            "element": "Removal of prior presumption that construction manager-at-risk is best value for projects at or above $100,000",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §44.031; TGC §2269.251",
            "supporting_quote": "TEC §44.031: 'all school district contracts...shall be made by the method, of the following methods, that provides the best value for the district'; TGC §2269.251: 'A governmental entity may use the construction manager-at-risk method in selecting a general contractor for the construction, rehabilitation, alteration, or repair of a facility only as provided by this subchapter'",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Prior policy presumed CM-at-risk was best value for projects $100,000+; statute permits but does not require CM-at-risk and requires case-by-case best-value determination; district's removal of the presumption is a local choice consistent with but not mandated by statute"
          },
          {
            "element": "Contracting Authority Over $500,000: Board approval of contracts; Superintendent to prepare Board approval form template and submit completed forms",
            "classification": "Mixed",
            "statutory_basis": "19 TAC §61.1040(d)",
            "supporting_quote": "19 TAC §61.1040(d): 'a board of trustees may not delegate the authority to act regarding an action authorized or required by TEC, Chapter 44, Subchapter B, to be taken by a board of trustees of a school district'; 'when procuring construction services for a capital improvement project, a school district board of trustees shall provide notice of the delegation and the limits of the delegation in the request for bids, proposals, or qualifications or in an addendum to the request'",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "$500,000 threshold is locally chosen; form template requirements, completed-form submission process, and template content specifications are locally designed; Board approval requirement has some statutory grounding in non-delegation rule, but threshold is local"
          },
          {
            "element": "Contracting Authority Under $500,000: Superintendent may approve construction contracts and related materials or services under $500,000",
            "classification": "Permitted by Law",
            "statutory_basis": "19 TAC §61.1040(d)",
            "supporting_quote": "19 TAC §61.1040(d): 'a board of trustees of a school district may, as appropriate, delegate its purchasing and contracting authority under TEC, Chapter 44, Subchapter B, regarding an action authorized or required to be taken by a school district or a designated person, representative, or committee'",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "$500,000 threshold is locally chosen; statute permits delegation but does not specify any dollar threshold or require delegation at this level"
          },
          {
            "element": "Change Orders — Board Approved Contracts Over $500,000: Board approval required for change orders on contracts over $100,000; Superintendent to prepare change order form template and submit completed forms",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Neither the $100,000 change order approval threshold nor the $500,000 contract-size trigger, nor the form template requirement, appears in the statute analysis; all are locally established"
          },
          {
            "element": "Change Orders — District Approved Contracts Under $500,000: No Board approval required; District must inform Board of change orders over $100,000",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Dual-track change order approval structure, $500,000 contract-size dividing line, and $100,000 informational notification threshold are all locally established; no statute in the analysis addresses change order approval authority or thresholds"
          },
          {
            "element": "Removal of prior language allowing Superintendent to approve change orders urgently and seek Board ratification",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Prior emergency ratification provision was locally adopted; its removal is also a local choice; no statute in the analysis addresses this mechanism"
          },
          {
            "element": "Final Payment — Board Approved Contracts Over $500,000: Board must substantially complete and accept work before final payment",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Tying final payment acceptance authority to Board for contracts over $500,000 is locally established; no statute in the analysis specifies who must accept work or sets a dollar threshold for final payment authority"
          },
          {
            "element": "Final Payment — District Approved Contracts Under $500,000: District (Superintendent-level) must substantially complete and accept work before final payment",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Delegation of final payment acceptance authority to Superintendent for contracts under $500,000 is locally established; no statute in the analysis requires or specifies this division"
          },
          {
            "element": "Implementation Section: District shall adopt procedures and present required forms for Board adoption no later than December 31, 2026",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "December 31, 2026 deadline, form adoption obligation, and implementation procedures requirement are entirely locally created; no statute in the analysis mandates any of these elements"
          }
        ]
      },
      "compliance_summary": [
        "Delivery Method Approval: For construction projects over $2,000,000, the updated policy requires the Board to approve the recommended construction delivery method before the district advertises the project. State law (TEC §44.031) requires school boards to use a best-value selection process and limits what can be delegated, but the $2,000,000 threshold and the pre-advertising approval step are decisions the district made on its own.",
        "Superintendent Delegation for Smaller Projects: For construction projects under $2,000,000, the Superintendent may choose the delivery method, and for contracts under $500,000, the Superintendent may approve the contract directly. State law (19 TAC §61.1040(d)) allows school districts to delegate these decisions, but the specific dollar amounts are thresholds the district set itself.",
        "Removal of CM-at-Risk Presumption: The previous policy assumed that a construction manager-at-risk arrangement was the best choice for projects at or above $100,000. The updated policy removes that assumption, which is consistent with state law (TEC §44.031 and TGC §2269.251) that requires districts to evaluate best value case by case rather than defaulting to any one method.",
        "Change Order Approval Structure: The updated policy creates two tracks for approving change orders based on the size of the original contract. For contracts over $500,000, Board approval is required for change orders over $100,000; for smaller contracts, the Superintendent handles change orders and informs the Board when they exceed $100,000. These thresholds and procedures are not required by state law — they are rules the district established on its own.",
        "Implementation Deadline: The policy includes a new section requiring the district to develop procedures and bring required approval forms to the Board for adoption no later than December 31, 2026. This deadline and the form adoption process are entirely district-created requirements with no corresponding state law mandate."
      ]
    },
    {
      "date": "2026-07-21",
      "school_year": "2025-2026",
      "action": "first_reading",
      "result": "first_reading",
      "summary": "This update to the CV (Facilities Construction) Local Policy significantly restructures construction contract and change order authority by introducing tiered approval thresholds, requiring the Superintendent to submit standardized form templates for Board adoption, clarifying Board vs. Superintendent approval roles for contracts over/under $500,000 and $2,000,000, and adding new sections on implementation deadlines and delegation of authority. The update also removes outdated language tying the construction manager-at-risk method to a $100,000 threshold, consolidates final payment provisions, and eliminates the prior emergency change order override provision for the Superintendent.",
      "changes_added": [
        "The Superintendent shall ensure that the Board receives timely, accurate, and ongoing information about construction contracts and is provided with information to make approvals required by Texas law.",
        "Contracts Over $2,000,000 (section heading)",
        "for all construction delivery methods for projects that are anticipated to exceed $2,000,000, prior to advertising the project delivery/contract award method.",
        "[See CH(LOCAL), CH(LEGAL), CV series generally and CBB(LEGAL) for requirements if federal funds are involved.]",
        "To assist the Board with approval of the construction delivery methods, the Superintendent shall prepare a standard approval form template for Board adoption that includes key construction delivery method information, including a proposed timeline of events. Once the construction delivery method template is adopted by the Board, the Superintendent shall provide the Board with the completed form for each construction delivery method under this section.",
        "Contracts Under $2,000,000 (section heading)",
        "The Superintendent shall determine the construction delivery method in the best value determination of the District or in accordance with Texas law for contracts under $2,000,000.",
        "Contracting Authority Over $500,000 (section heading revision — 'Contracting' added)",
        "To assist the Board with approval of the construction contracts, the Superintendent shall prepare a standard approval form template for Board adoption that includes key construction contract information. Once the construction contract template is adopted by the Board, the Superintendent shall provide the Board with the completed form for each construction contract under this section.",
        "Contracting Authority Under $500,000 (section heading revision — 'Contracting' added)",
        "Construction contracts and construction related materials or services under $500,000",
        "Board pPolicy. [See also CH(LOCAL) and CH(LEGAL) and CBB(LEGAL)]",
        "Change orders on all Board-approved construction contracts over $100,000 shall require Board approval.",
        "The Superintendent shall prepare a change order recommendation form template for Board approval. Once the Board approves the change order form, the Superintendent shall provide the Board with the completed form, including accurate status, scope, cost, and schedule impacts of any Board approved construction contract change order under this section.",
        "On District approved construction contracts, change orders shall not require Board approval. The District shall inform the Board of all change orders, or combined change orders, over $100,000.",
        "For Board approved construction contracts, the District shall not make final payments for construction until the work has been substantially completed and accepted by the Board.",
        "For District approved construction contracts,",
        "substantially",
        "by the District",
        "Implementation (section heading)",
        "The District shall adopt procedures to implement this Board Policy. The District shall present required forms for Board adoption no later than December 31, 2026."
      ],
      "changes_removed": [
        "The construction manager-at-risk project delivery method shall be deemed the project delivery/contract award method providing the best value to the District for construction projects valued at or above $100,000. If another method is deemed to provide the best value to the District for a particular construction project,",
        "or designee",
        "determine,",
        "prior to advertising the contract the project delivery/contract award method.",
        "Approval (section heading word — struck in 'Contracting Authority Over $500,000')",
        "also",
        "resulting",
        "Lesser expenditures for construction",
        "Approval (section heading word — struck in 'Contracting Authority Under $500,000')",
        "Change orders permitted by law shall be approved prior to any changes being made in the approved plans or the actual construction of the facility.",
        "Changorders valued at or above $100,000",
        "However, if the Superintendent determines that such prior approval unreasonably delays construction, the Superintendent is authorized to approve the change orders, and the Board at the earliest opportunity shall ratify the change orders.",
        "Change orders permitted by law valued less than $100,000 shall be approved by the Superintendent prior to any changes being made in the approved plans or the actual construction of the facility.",
        "Project Administration (entire section heading and body)",
        "All construction projects shall be administered by the Superintendent or designee.",
        "The Superintendent shall keep the Board informed concerning construction projects and also shall provide information to the general public.",
        "or the supervision of construction for projects valued at $100,000 or more,",
        "the Board",
        "the work. For all projects valued at less than $100,000, final payments for construction or the supervision of construction shall not be made until the work has been completed and the Superintendent or designee has accepted the work."
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-07-21_regular",
      "confidence": "medium",
      "source_redline": "CV_LOCAL.pdf",
      "notes": "The cover page does not contain a distinct action title (e.g., 'First Reading' or 'Adopt Revisions'); the document appears to be the redline policy text only without a separate cover/recommendation page, so action is marked 'unknown'. Some redline items (e.g., section heading word-level changes like 'Approval' struck and 'Contracting' added) required careful parsing. The 'C' capitalization change in 'Cconstruction' was treated as a minor formatting fix within a larger removal/addition. Confidence is medium due to complexity and density of changes across all three pages.",
      "compliance_assessment": {
        "classification": "Mixed",
        "elements": [
          {
            "element": "Construction delivery method determination for projects anticipated to exceed $2,000,000 — Board approval required prior to advertising",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §44.031; TGC §2269.056",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "TEC §44.031 requires best value determination but does not mandate Board approval of the delivery method selection, nor does the statute analysis contain any quote from TGC §2269.056 imposing such a requirement. The $2,000,000 threshold and Board approval requirement are locally chosen."
          },
          {
            "element": "Superintendent authority to determine construction delivery method for contracts under $2,000,000",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §44.0312",
            "supporting_quote": "The board of trustees of the district may, as appropriate, delegate its authority under this subchapter regarding an action authorized or required by this subchapter to be taken by a school district to a designated person, representative, or committee.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Statute permits delegation of board authority to a designated person. The specific $2,000,000 threshold and assignment to Superintendent are locally determined choices within that permission."
          },
          {
            "element": "Board approval required for construction contracts over $500,000",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The statute analysis contains no requirement or permission specifically mandating or authorizing Board approval at a $500,000 threshold. TEC §44.031 requires best value determination but does not assign Board approval authority at any dollar threshold. This threshold and approval structure are locally chosen."
          },
          {
            "element": "Superintendent contracting authority for construction contracts under $500,000",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §44.0312",
            "supporting_quote": "The board of trustees of the district may, as appropriate, delegate its authority under this subchapter regarding an action authorized or required by this subchapter to be taken by a school district to a designated person, representative, or committee.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Delegation to Superintendent is permitted by statute. The specific $500,000 threshold is a locally chosen boundary not specified in the statute."
          },
          {
            "element": "Standardized approval form templates for construction delivery method — Superintendent to prepare for Board adoption and complete per project",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No statute in the analysis requires or expressly authorizes the use of standardized form templates prepared by the Superintendent for Board adoption. This is an entirely locally chosen administrative procedure."
          },
          {
            "element": "Standardized approval form templates for construction contracts — Superintendent to prepare for Board adoption and complete per contract",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No statute in the analysis requires or expressly authorizes standardized contract form templates. This is a locally chosen administrative procedure."
          },
          {
            "element": "Change orders on Board-approved construction contracts over $100,000 require Board approval",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §44.0411",
            "supporting_quote": "the district may approve change orders making the changes...If a change order involves a decrease or an increase of $25,000 or less, the district may grant general authority to an administrative official to approve the change orders.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Statute permits the district to approve change orders and permits delegation of approval authority only for changes of $25,000 or less. The district chose a more restrictive local threshold of $100,000 for Board approval on Board-approved contracts, which is a local choice consistent with but beyond the statutory minimum delegation limit."
          },
          {
            "element": "Change orders on District-approved construction contracts do not require Board approval; Board to be informed of change orders over $100,000",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §44.0411; TEC §44.0312",
            "supporting_quote": "If a change order involves a decrease or an increase of $25,000 or less, the district may grant general authority to an administrative official to approve the change orders.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The statute permits administrative delegation for changes of $25,000 or less. The district extended Superintendent change order authority beyond $25,000 for District-approved contracts, which goes beyond the explicit statutory delegation permission. The Board notification requirement for change orders over $100,000 is a locally added reporting obligation with no statutory basis."
          },
          {
            "element": "Change order recommendation form template — Superintendent to prepare for Board approval and complete per change order",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No statute in the analysis requires or authorizes standardized change order form templates prepared by the Superintendent. This is entirely locally chosen."
          },
          {
            "element": "Removal of emergency change order override — Superintendent may no longer unilaterally approve change orders if prior approval would unreasonably delay construction",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The prior emergency override was a locally created exception. Its removal is also a local choice. No statute in the analysis requires or prohibits such an override provision."
          },
          {
            "element": "Final payment on Board-approved construction contracts withheld until work substantially completed and accepted by Board",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The statute analysis contains no requirement or permission addressing final payment timing or Board acceptance of completed work. This provision is entirely locally chosen."
          },
          {
            "element": "Final payment on District-approved construction contracts withheld until work substantially completed and accepted by District",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Same as above — no statutory basis identified in the analysis for this provision. Locally chosen."
          },
          {
            "element": "Superintendent obligation to ensure Board receives timely, accurate, ongoing information about construction contracts and approvals required by Texas law",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "While TEC §44.031 and §44.0411 impose substantive compliance requirements, the statute analysis contains no quote mandating or permitting this specific Superintendent reporting obligation. The provision is a locally chosen implementation mechanism to support compliance."
          },
          {
            "element": "Removal of automatic presumption that construction manager-at-risk is best value for projects $100,000 and above",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §44.031",
            "supporting_quote": "all school district contracts for the purchase of goods and services...valued at $50,000 or more in the aggregate for each 12-month period shall be made by the method...that provides the best value for the district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "Statute requires best value determination but does not mandate or prohibit any presumption favoring a particular delivery method. The prior presumption was locally created; its removal is also a local choice."
          },
          {
            "element": "Implementation deadline — District to present required forms for Board adoption no later than December 31, 2026",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No statute in the analysis imposes an implementation deadline. The December 31, 2026 date is an entirely locally chosen administrative deadline."
          }
        ]
      },
      "compliance_summary": [
        "Tiered Approval Thresholds: The updated policy sets dollar-based rules for who must approve construction contracts — the full Board for contracts over $500,000, and the Superintendent for contracts under that amount. Texas Education Code §44.0312 allows school boards to delegate contracting authority, and the specific dollar cutoffs were chosen locally.",
        "Delivery Method Decisions: For construction projects expected to cost more than $2,000,000, the Board must approve how the project will be built before it is advertised. For projects under that amount, the Superintendent may make that call — an arrangement permitted under TEC §44.0312, with the $2,000,000 dividing line set locally.",
        "Change Order Authority: Under TEC §44.0411, the district may delegate approval of change orders of $25,000 or less. This policy sets a stricter local rule requiring Board approval for change orders over $100,000 on Board-approved contracts, while allowing the Superintendent to approve change orders on District-approved contracts without returning to the Board.",
        "Emergency Override Removed: A previous provision allowed the Superintendent to approve change orders without prior Board approval if waiting would unreasonably delay construction. That exception was not required by state law, and the updated policy removes it — also a local choice with no state law requiring its removal.",
        "Standardized Forms Added: The policy requires the Superintendent to prepare standard forms for approving construction delivery methods, contracts, and change orders, which the Board will then formally adopt. No state statute requires this step — it is a locally chosen way to keep the approval process consistent and documented.",
        "Best Value Presumption Removed: An earlier version of the policy treated the construction manager-at-risk method as the assumed best option for projects of $100,000 or more. That presumption has been removed, bringing the policy closer to the case-by-case best value review that TEC §44.031 describes, without assuming any one method is preferred."
      ]
    }
  ],
  "timeline_legal": []
}