{ "code": "DGBA", "title": "Personnel-Management Relations: Employee Complaints/Grievances", "description": "This policy governs the process by which district employees can formally raise workplace grievances with district administration. It outlines the steps, timelines, and procedures for submitting and resolving grievances at multiple levels up to and including the school board, and addresses recordkeeping, recusal, and appeal options.", "policy_connect_url": "https://policyconnect.org/policy/conroe-isd/DGBA", "last_action_date": "2025-10-21", "last_action_result": "adopted", "timeline_local": [ { "date": "2025-10-21", "school_year": "2025-2026", "action": "second_reading", "result": "adopted", "summary": "This update to Conroe ISD's DGBA (Local) policy replaces the term \"complaint\" with \"grievance\" throughout, extends and restructures filing deadlines at Level One, removes references to \"hearing officer\" and \"legal office\" in favor of named administrators, and adds several new provisions including Recusal, Grievance Record, Remand, Decisions Made on the Merits, Report to TEA, Availability of Policy, and Appeal to Commissioner sections.", "changes_added": [ "grievance (replacing 'complaint' throughout the entire policy, including all headings and body text)", "Other Complaint Grievance Process (section heading update)", "Whistleblower Grievances (section heading update)", "Complaints Grievances Against Supervisors (section heading update)", "Complaint Grievance And Appeal Forms (section heading update)", "Consolidating Grievances (section heading update)", "Complaint Grievance And Appeal Forms (section heading update)", "Recusal: A District employee or Board member involved in reviewing a grievance must recuse himself or herself from the review process if that employee or Board member is the subject of the grievance. If a Board member files a grievance, he or she shall be prohibited from voting on matters related to that grievance. If the designated administrator at any level of the review process is required to recuse himself or herself, the grievance shall be subject to a higher level of review.", "Grievance Record: At each level of the grievance review process, a record shall be created and retained by the District. This record shall include: 1. Documents submitted by the person who filed the grievance or determined relevant by school district personnel; and 2. A written record of the decision, including an explanation of the basis for the decision and an indication of each document that supports the decision. The person who filed the grievance may supplement the record with additional documents or add additional claims.", "Remand: At any time, a grievance may be remanded to a lower level of review to develop a record, including when a grievance is pending before the Board of Trustees.", "Decisions Made on the Merits: At each level in the grievance review process, the District shall issue a decision on the merits of the concern raised in the grievance, notwithstanding procedural errors or the type of relief requested.", "Level One filing deadline changed to: Within 60 calendar days of the date the employee first knew or had reason to know of the facts giving rise to the grievance, or the later of: A. 90 calendar days of the date the employee first knew or had reason to know of the facts giving rise to the grievance if the employee engaged in informal attempts to resolve the grievance, or B. 30 calendar days from the date on which the District provided information to the grievant regarding how to file the grievance", "Level One item 2: With the principal's or principal's designee's office at the school campus at which the student attends or at which the facts giving rise to the grievance occurred, or, for a grievance that arises from a subject matter unrelated to a campus, with an administrator at the District's central office.", "In most circumstances, employees on a school campus shall file Level One grievances with the campus principal; other District employees shall file Level One grievances with their immediate supervisor.", "If the only administrator who has authority to remedy the alleged problem is the Superintendent or designee or the grievance arises from subject matter unrelated to a specific campus, the grievance may begin at Level Two following the procedure, including deadlines, for filing the grievance form at Level One.", "the principal, designee, or other appropriate administrator (replacing 'hearing officer' in Level One investigation and conference scheduling language)", "The written response shall set forth the basis of the decision, any relief or redress to be provided and information regarding filing an appeal, including the timeline for filing such appeal under this policy and under Texas Education Code \u00a7 7.057, as applicable. (added to Level One written response requirement)", "Level One written response deadline changed to 20 calendar days following the conference", "The designated Level Two administrator shall be the Superintendent or the Superintendent's designee at the District's central office.", "Level Two appeal notice deadline changed to 20 calendar days", "Level Two written response requirement: The written response shall set forth the basis of the decision, any relief or redress to be provided and information regarding filing an appeal, including the timeline for filing such appeal under this policy and under Texas Education Code \u00a7 7.057, as applicable.", "Superintendent or designee (replacing 'Level Two hearing officer' throughout Level Two provisions)", "appropriate administrator (replacing references to 'legal office' and 'hearing officer and the legal office' in Level Two forwarding provisions)", "Level Three appeal notice deadline changed to 20 calendar days", "The Board may delegate the authority to hear and decide a grievance to a committee of at least three members composed only of members of the Board. For purposes of an appeal to the Commissioner of Education under Texas Education Code \u00a7 7.057, a decision by this committee constitutes a decision of the Board.", "Superintendent or designee (replacing 'legal office' in Level Three notification and record-forwarding provisions)", "The Board or its committee must hold a meeting to discuss the grievance not later than the 60th day after the date on which the previous decision on the grievance was made.", "The Board shall make and give notice of its decision not later than the 30th day after the date on which the Board or its committee considers the grievance.", "The employee may request that the hearing or meeting at which the meeting will be discussed be open or closed, unless otherwise required by law. If the employee does not make this request, the Board shall determine whether the grievance will be presented in open or closed meeting in accordance with the Texas Open Meetings Act and other applicable law.", "Report to TEA: The District shall annually submit to TEA a report on grievances filed in the District during the preceding year. For each grievance included on the report, the District shall include the resolution of the grievance and any corrective action taken.", "Availability of Policy: The following shall be made available in a prominent location on the District's website and included in the Student Handbook: This policy; The grievance and appeal forms referenced in this policy; The method by which a grievance may be filed electronically.", "Appeal To Commissioner: Except as may be provided to the contrary by state or federal law or other District policies, Level Three decisions by the Board may be appealed to the Commissioner of Education.", "administration (replacing 'Board of Trustees' in Level Three evidence notice provision)", "Superintendent or designee (replacing 'administration' in Level Three evidence notice provision)", "description notice of the nature of the evidence or other information the Board intends to rely on at least five days before the hearing (replacing 'three' days)", "Level Three document restriction notice period changed to five days (from three)" ], "changes_removed": [ "In this policy, the terms \"complaint\" and \"grievance\" shall have the same meaning. (deleted opening Complaints definition section)", "complaint (replaced by 'grievance' throughout entire policy)", "Complaints (section heading)", "Whistleblower Complaints (section heading)", "Complaints Grievances Against Supervisors \u2014 'Complaints' heading portion", "Complaint And Appeal Forms \u2014 'Complaint' heading portion", "Consolidating Complaints \u2014 'Complaints' heading portion", "Within 15 calendar days of the date the employee first knew, or with reasonable diligence should have known, of the decision or action or had reason to know of the facts giving rise to the complaint or grievance; and (former Level One deadline language)", "District's legal office (replaced by 'appropriate administrator' in Level One filing location)", "hearing officer (replaced by 'principal, designee, or other appropriate administrator' throughout Level One)", "receipt of the written complaint (replaced by 'the date the grievance was initially filed' in Level One conference scheduling)", "Absent extenuating circumstances, t (deleted from Level One response provision)", "ten (days) (replaced by '20 calendar days' for Level One written response deadline)", "District's legal office (replaced by form filed with the District's website-designated individual in Level Two appeal notice)", "ten (days) (replaced by '20 calendar days' for Level Two appeal notice deadline)", "Level Two hearing officer (replaced by 'Superintendent or designee' throughout Level Two provisions)", "hearing officer and the legal office (replaced by 'administrator' in Level Two forwarding provision)", "legal office (replaced by 'Superintendent or designee' in Level Three notification provisions)", "ten (days) (replaced by '20 calendar days' for Level Three appeal notice deadline)", "at any time up to and including the next regularly scheduled Board meeting (removed from Board decision timing language)", "If the Board does not make a decision regarding the complaint by the end of the next regularly scheduled meeting, the lack of a response by the Board upholds the administrative decision at Level Two. (deleted)", "After the Level One conference, no new documents may be submitted by the employee unless the employee did not know the documents existed before the Level One conference. (deleted from Complaint/Grievance and Appeal Forms section)", "three (days notice period for Level Three evidence, replaced by 'five')" ], "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2025-10-21_regular", "confidence": "medium", "source_redline": "DGBA_LOCAL.pdf", "notes": "The document is a comprehensive redline of Conroe ISD DGBA (Local). The predominant change is a global replacement of \"complaint\" with \"grievance\" throughout; this was captured as a single overarching item as well as in specific contextual instances. Several entirely new sections were added (Recusal, Grievance Record, Remand, Decisions Made on the Merits, Report to TEA, Availability of Policy, Appeal to Commissioner). Timelines were significantly extended (15\u219260 days at Level One; 10\u219220 days at Levels Two and Three). References to \"hearing officer\" and \"legal office\" were replaced with specific named administrators. Board decision deadline language was restructured.", "compliance_assessment": { "classification": "Mixed", "elements": [ { "element": "Terminology Change from 'Complaint' to 'Grievance' Throughout Policy", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The board of trustees of a school district shall adopt a grievance policy to address grievances received by the district.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None. Statute uses 'grievance' throughout; district aligned terminology accordingly." }, { "element": "First-Level Review by Campus Principal or Designee; Central Office Administrator for Non-Campus Grievances", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "a review by either (A) the principal of the school district campus at which the grievance is filed or the principal's designee; or (B) for a grievance that arises from subject matter unrelated to a campus, an administrator at the school district's central office", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Policy adds: 'In most circumstances, employees on a school campus shall file Level One grievances with the campus principal; other District employees shall file Level One grievances with their immediate supervisor.' Also adds provision allowing certain grievances to begin at Level Two if only the Superintendent or designee has authority to remedy the problem." }, { "element": "Superintendent or Superintendent's Designee as Level Two Reviewer", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "an appeal to the superintendent of the school district or the superintendent's designee", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Policy specifies 'The designated Level Two administrator shall be the Superintendent or the Superintendent's designee at the District's central office.' \u2014 consistent with statute." }, { "element": "Board of Trustees as Level Three Reviewer", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "an appeal to the board of trustees of the school district", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Policy adds delegation to committee of at least three Board members (see separate element)." }, { "element": "Recusal Requirement \u2014 Person Reviewing Grievance is Subject of Grievance", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "require a person involved in reviewing a grievance under the policy to recuse himself or herself from reviewing the grievance if the person is the subject of the grievance", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Higher Level of Review When Recusal Required", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "provide for a higher level of review if the person who would otherwise review the grievance is required to recuse himself or herself", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Board Member Filing Grievance Prohibited from Voting on Related Matters", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "allow for a member of the board of trustees of the school district to file a grievance with the district, but prohibit the member from voting on matters related to that grievance", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Grievance Record \u2014 Creation and Retention", "classification": "Mixed", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "provide for the creation and retention of a record of each hearing on the grievance, including documents submitted by the person who filed the grievance or determined relevant by school district personnel", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Statute requires creation and retention of record including documents submitted by grievant or determined relevant. Policy adds: 'A written record of the decision, including an explanation of the basis for the decision and an indication of each document that supports the decision. The person who filed the grievance may supplement the record with additional documents or add additional claims.' \u2014 these additional requirements are locally chosen." }, { "element": "Remand to Lower Level of Review", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "allow for a remand to a lower level of review to develop a record at any time, including at the board of trustees level of review", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None. Though the statute analysis categorizes this under 'permissions,' the quoted text is phrased as a mandatory policy element ('allow for a remand') that the policy must include, making it required. Policy language mirrors statute." }, { "element": "Decision on Merits Notwithstanding Procedural Errors or Type of Relief Requested", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "require the school district to issue a decision on the merits of the concern raised in the grievance, notwithstanding procedural errors or the type of relief requested", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Misdirected Grievance \u2014 Redirection to Correct Administrator and Filing Date Preservation", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "require the school district to direct a grievance that is filed with the incorrect administrator to the appropriate administrator and consider the grievance filed on the date on which the grievance was initially filed", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Open or Closed Hearing at Request of Person Who Filed Grievance", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "unless otherwise required by law, allow for a hearing or meeting at which the grievance will be discussed to be open or closed at the request of the person who filed the grievance", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Policy adds a default rule when no request is made: 'If the employee does not make this request, the Board shall determine whether the grievance will be presented in open or closed meeting in accordance with the Texas Open Meetings Act and other applicable law.' This default rule is locally chosen." }, { "element": "Employee Reporting Grievance Against Supervisor to a Different Supervisor", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 11.171", "supporting_quote": "A school district grievance policy must permit a school district employee to report a grievance against a supervisor that alleges the supervisor's violation of the law in the workplace or the supervisor's unlawful harassment of the employee to a supervisor other than the supervisor against whom the employee intends to report the grievance.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None identified in the change summary beyond implementing the statutory requirement." }, { "element": "Employee Permitted to Make Audio Recording of Grievance Meeting or Proceeding", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 11.171", "supporting_quote": "A school district grievance policy must permit an employee who reports a grievance to make an audio recording of any meeting or proceeding at which the substance of a grievance that complies with the policy is investigated or discussed.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None identified in the change summary." }, { "element": "Grievance Filing and Appeal Timelines Generally", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.002 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The policy adopted under Section 26A.001 must provide for timelines that allow for filing and appeal of grievances.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Statute requires timelines exist but does not prescribe specific day counts. All specific deadlines (60/90/30-day Level One filing window; 20-day appeal notice deadlines; 20-day response deadlines) are locally chosen numbers within the statutory framework." }, { "element": "Level One Filing Deadline \u2014 60-Day Base / 90-Day if Informal Resolution Attempted / 30-Day from District-Provided Filing Information", "classification": "Locally Discretionary", "statutory_basis": "TEC \u00a7 26A.002 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The policy adopted under Section 26A.001 must provide for timelines that allow for filing and appeal of grievances.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Statute requires timelines exist but specifies no day counts. The 60-day base, 90-day extension for informal resolution, and 30-day extension from district-provided information are all locally chosen. Prior policy had a 15-calendar-day deadline." }, { "element": "Level One Written Response Deadline \u2014 20 Calendar Days Following Conference", "classification": "Locally Discretionary", "statutory_basis": "TEC \u00a7 26A.002 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The policy adopted under Section 26A.001 must provide for timelines that allow for filing and appeal of grievances.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "20-day deadline is a local choice; previously 10 days." }, { "element": "Level Two Appeal Notice Deadline \u2014 20 Calendar Days", "classification": "Locally Discretionary", "statutory_basis": "TEC \u00a7 26A.002 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The policy adopted under Section 26A.001 must provide for timelines that allow for filing and appeal of grievances.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "20-day deadline is a local choice; previously 10 days." }, { "element": "Level Three Appeal Notice Deadline \u2014 20 Calendar Days", "classification": "Locally Discretionary", "statutory_basis": "TEC \u00a7 26A.002 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The policy adopted under Section 26A.001 must provide for timelines that allow for filing and appeal of grievances.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "20-day deadline is a local choice; previously 10 days." }, { "element": "Board/Committee Must Hold Meeting Within 60 Days of Previous Decision", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text \u2014 no matching provision found in statute analysis", "litigation_status": "None identified", "local_additions": "Policy adds: 'The Board or its committee must hold a meeting to discuss the grievance not later than the 60th day after the date on which the previous decision on the grievance was made.' No statute in the analysis requires or authorizes this specific deadline." }, { "element": "Board Decision Timeline \u2014 30 Days After Board or Committee Considers Grievance", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text \u2014 no matching provision found in statute analysis", "litigation_status": "None identified", "local_additions": "Policy adds: 'The Board shall make and give notice of its decision not later than the 30th day after the date on which the Board or its committee considers the grievance.' No statute in the analysis mandates this specific deadline." }, { "element": "Public Availability of Policy on District Website in Prominent Location", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.003 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "The board of trustees of a school district shall develop, make publicly available in a prominent location on the district's Internet website, and include in the district's student handbook: (1) the policy adopted under Section 26A.001", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Inclusion of Grievance Policy in Student Handbook", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.003 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "include in the district's student handbook: (1) the policy adopted under Section 26A.001", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Standardized Grievance and Appeal Forms Made Publicly Available", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.003 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "standardized forms for filing a grievance, a notice of appeal, or a request for a hearing under this chapter", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Method for Filing Grievance Electronically Made Publicly Available", "classification": "Required by Law", "statutory_basis": "TEC \u00a7 26A.003 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "the method by which a grievance may be filed electronically", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None." }, { "element": "Annual Report to TEA on Grievances", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text \u2014 TEC \u00a7 26A.004 in the statute analysis addresses superintendent appearance before SBOE when commissioner finds against a district five or more times; it does not contain a verbatim requirement for the district to adopt a policy mandating annual TEA reporting", "litigation_status": "None identified", "local_additions": "Policy adds: 'The District shall annually submit to TEA a report on grievances filed in the District during the preceding year. For each grievance included on the report, the District shall include the resolution of the grievance and any corrective action taken.' No statute in the provided analysis contains a verbatim requirement for a district policy element mandating this annual submission; classified as locally discretionary per the grounding rule." }, { "element": "Board Committee Delegation \u2014 Authority to Hear and Decide Grievance", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text \u2014 statute requires Board of Trustees as a level of review but does not mention or authorize delegation to a committee", "litigation_status": "None identified", "local_additions": "Policy adds: 'The Board may delegate the authority to hear and decide a grievance to a committee of at least three members composed only of members of the Board. For purposes of an appeal to the Commissioner of Education under Texas Education Code \u00a7 7.057, a decision by this committee constitutes a decision of the Board.' This is a local procedural choice not grounded in the statute analysis." }, { "element": "Level One and Level Two Written Response \u2014 Must Set Forth Basis, Relief, and Appeal Information Including TEC \u00a7 7.057", "classification": "Mixed", "statutory_basis": "TEC \u00a7 26A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025) (decision on merits); TEC \u00a7 7.057 (appeal to Commissioner reference)", "supporting_quote": "require the school district to issue a decision on the merits of the concern raised in the grievance, notwithstanding procedural errors or the type of relief requested", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "Statute requires a decision on the merits; it does not specify that the written response must set forth the basis, relief to be provided, and appeal timeline information including TEC \u00a7 7.057. These content requirements for the written response are locally chosen additions." }, { "element": "Five-Day Advance Notice of Board Evidence (Increased from Three Days)", "classification": "Required by Law", "statutory_basis": "TEC \u00a726A.001 as enacted by S.B. 12 (89th Leg., R.S., 2025)", "supporting_quote": "at least five business days before the grievance hearing, the district must provide the grievant with a description of any information the board intends to rely on that is not contained in the record", "verification_method": "verbatim statute text \u2014 confirmed by TEA official guidance post-SB 12 (tea.texas.gov/raising-concerns-with-your-school) and Leon Alcala law firm analysis of enrolled S.B. 12; enrolled bill text not directly accessible", "litigation_status": "None identified", "local_additions": "COMPLIANCE GAP IN ADOPTED POLICY TEXT: S.B. 12 requires at least five 'business days' notice. The adopted policy text says 'five days' without the 'business' qualifier. This is a material deviation \u2014 calendar days and business days are different standards. The policy should be corrected before final adoption to specify 'five business days' to match the statutory requirement." }, { "element": "Appeal to Commissioner of Education (TEC \u00a7 7.057 Reference)", "classification": "Permitted by Law", "statutory_basis": "TEC \u00a7 7.057", "supporting_quote": "None \u2014 TEC \u00a7 7.057 is cited in the statute analysis only as a citation with no requirements, permissions, or prohibitions quoted", "verification_method": "verbatim statute text \u2014 statute analysis contains no verbatim quotes for TEC \u00a7 7.057", "litigation_status": "None identified", "local_additions": "Policy adds: 'Except as may be provided to the contrary by state or federal law or other District policies, Level Three decisions by the Board may be appealed to the Commissioner of Education.' While TEC \u00a7 7.057 provides for Commissioner appeal as a matter of law, the statute analysis contains no verbatim text grounding this element; the district's choice to reference it expressly in the local policy is locally discretionary as a policy element, though the underlying right exists in law." }, { "element": "Deletion of Provision That Unanswered Board Grievance Upholds Level Two Decision", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text \u2014 no provision in statute analysis addresses consequences of Board inaction", "litigation_status": "None identified", "local_additions": "District removed: 'If the Board does not make a decision regarding the complaint by the end of the next regularly scheduled meeting, the lack of a response by the Board upholds the administrative decision at Level Two.' This removal is a local procedural choice." }, { "element": "Deletion of Post-Level-One-Conference Document Restriction", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text \u2014 no provision in statute analysis addresses post-conference document submission restrictions", "litigation_status": "None identified", "local_additions": "District removed: 'After the Level One conference, no new documents may be submitted by the employee unless the employee did not know the documents existed before the Level One conference.' This deletion is a local procedural choice consistent with the statutory requirement for record supplementation." } ] }, "compliance_summary": [ "Terminology Update: S.B. 12 (2025) added a new section to Texas Education Code requiring school districts to use the word 'grievance' instead of 'complaint' in their employee dispute policies. Conroe ISD updated its policy language to match that requirement.", "Three-Level Review Process: State law S.B. 12 (2025) requires districts to have a structured review process where grievances move from a campus principal or supervisor, to a central office administrator, and then to the Board of Trustees if unresolved. Conroe ISD's updated policy follows that required structure.", "Recusal and Conflict Rules: S.B. 12 (2025) requires that if the person responsible for reviewing a grievance is the subject of that grievance, they must step aside and the matter must move to the next level of review. The policy also prohibits a Board member who filed a grievance from voting on related decisions, as the law requires.", "Filing Deadlines Extended: State law requires districts to set timelines for filing grievances but does not specify exact deadlines. Conroe ISD chose to expand the filing window from 15 calendar days to 60 days \u2014 or up to 90 days if the employee first tried to resolve the issue informally \u2014 and increased several appeal and response deadlines from 10 to 20 calendar days.", "Grievance Record Requirements: S.B. 12 (2025) requires districts to create and keep a record of each grievance, including documents submitted by the employee or found to be relevant. The district added its own requirement that the record also include a written explanation of the basis for the decision and a list of supporting documents.", "Public Access Requirements: S.B. 12 (2025) requires districts to post their grievance policy in a prominent place on the district website, include it in the student handbook, make standardized forms publicly available, and provide a way for employees to file grievances electronically. The updated policy reflects all of these requirements." ] } ], "timeline_legal": [] }