{ "code": "FOFF", "title": "Special Education Parent Advisory Council (SEPAC)", "description": "This policy establishes the structure and operation of the Special Education Parent Advisory Council (SEPAC) for Conroe ISD. It covers the council's purpose, how it is governed, who can be a member, how often it meets, and what it must report. The policy also addresses confidentiality requirements, what district support the council can access, and how complaints or grievances are handled.", "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 revises the FOFF(LOCAL) Special Education Parent Advisory Council policy by removing a clause that permitted a SEPAC-affiliated 501(c)(3) to operate independently of Conroe ISD, replacing broad facility-access language with a specific designation as a \"Campus-Affiliated Facility User\" under Board Policy GKD(LOCAL), removing the \"Superintendent or\" from the submission trigger language for reports, and removing the phrase \"current Conroe ISD students and\" from the voting membership composition requirements. Several other clarifying edits are made throughout, including to the Recommendations and District Support sections.", "changes_added": [ "district-affiliated school-support organization under Board Policy CDC(LOCAL) and GE(LOCAL).", "For District facilities use, the SEPAC is a Campus-Affiliated Facility User under Board Policy GKD(LOCAL). SEPAC is a district-affiliated school-support organization under Board Policy GE(LOCAL), as appropriate.", "consistent with the SEPAC Bylaws", "Before a written report or other recommendation may be submitted to the Board of Trustees, the majority of SEPAC must vote for the written report or recommendation to be submitted.", "individual student matters must be addressed through the District's established grievance and complaint procedures." ], "changes_removed": [ "provided such organization operates independently of Conroe ISD.", "The SEPAC shall have access to District facilities and supports on the same basis as comparable parent organizations (e.g., the Parent-Teacher Association) and under Board Policy GKD(LOCAL).", "current Conroe ISD students and", "Before a written report or other recommendation may be submitted to the Superintendent or Board of Trustees, the majority of SEPAC must vote for the written report or recommendation to be submitted." ], "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-08-18_regular", "confidence": "high", "source_redline": "FOFF_LOCAL.pdf", "notes": "The document is labeled \"DRAFT FOR SECOND READ AUGUST 2026\" with a final meeting date of August 18, 2026, so action is recorded as second_reading. All red underlined text was captured as additions and red strikethrough text as removals. The majority of the document text appears in red underline (indicating this is largely new/revised language), but only the portions with explicit strikethrough vs. underline contrast within the same sections were treated as tracked changes relative to the first-read draft. Some redline distinctions between first-read additions and second-read modifications were subtle; extraction focused on visible strikethrough vs. clean underline differences.", "compliance_assessment": { "classification": "Locally Discretionary", "elements": [ { "element": "Reclassification of SEPAC as district-affiliated organization under Board Policies CDC(LOCAL), GE(LOCAL), and GKD(LOCAL), removing independent-operation language", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "statute analysis incomplete — no verbatim text retrieved; web search confirmed no statutory mandate for this specific structural change", "litigation_status": "None identified", "local_additions": "District chose to reclassify SEPAC from an independently operating 501(c)(3) to a Campus-Affiliated Facility User and district-affiliated school-support organization. This is a local governance and structural decision with no identified statutory basis." }, { "element": "Designation of SEPAC as Campus-Affiliated Facility User under Board Policy GKD(LOCAL), replacing broad facility-access language modeled on PTA parity", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "statute analysis incomplete — no verbatim text retrieved; web search confirmed no statutory mandate for this specific facility-access framework", "litigation_status": "None identified", "local_additions": "District narrowed and specified facility-use protocols by replacing a broad parity standard with a specific policy classification. No statute requires or expressly authorizes this particular designation." }, { "element": "Removal of 'Superintendent or' from the submission trigger — reports now go only to the Board of Trustees after majority SEPAC vote", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "statute analysis incomplete — no verbatim text retrieved", "litigation_status": "None identified", "local_additions": "District removed the Superintendent as an alternate submission path for written SEPAC reports and recommendations. This is a local administrative choice about internal reporting structure." }, { "element": "Removal of 'current Conroe ISD students and' from voting membership composition, expanding eligible voters beyond parents of currently enrolled students", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "statute analysis incomplete — no verbatim text retrieved; web search found no statutory mandate or prohibition on this membership definition", "litigation_status": "None identified", "local_additions": "District broadened SEPAC voting membership eligibility. No statute identified that compels or expressly authorizes this specific membership composition change." }, { "element": "Addition of 'consistent with the SEPAC Bylaws' cross-reference and clarification that individual student matters must be addressed through established grievance and complaint procedures", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "statute analysis incomplete — no verbatim text retrieved", "litigation_status": "None identified", "local_additions": "District added a bylaws cross-reference for operational consistency and redirected individual student disputes to established grievance channels. These are local structural and operational clarifications with no identified statutory compulsion." } ], "statute_retrieval": "low_confidence" }, "compliance_summary": [ "SEPAC Organizational Status: The district updated its policy to classify the Special Education Parent Advisory Council (SEPAC) as a district-affiliated organization rather than an independently operating nonprofit. This is a local governance decision not required or specifically authorized by any state law.", "Facility Access Rules: The policy now designates SEPAC as a 'Campus-Affiliated Facility User' under Board Policy GKD(LOCAL), replacing broader language that had compared SEPAC's facility access to that of a PTA. No state law required or directed this specific change.", "Report Submission Process: Under the revised policy, written SEPAC reports and recommendations go directly to the Board of Trustees after a majority vote, and the Superintendent is no longer listed as an alternate recipient. This is an internal administrative choice made by the district with no identified state law behind it.", "Voting Membership Eligibility: The policy removes a requirement that voting members be parents of currently enrolled Conroe ISD students, which broadens who may vote in SEPAC. This change was made at the district's discretion and is not tied to a specific state law.", "Grievance Process Clarification: The updated policy states that concerns about individual students must be handled through the district's established grievance and complaint procedures rather than through SEPAC. This is a local operational clarification with no identified state law as its basis." ] }, { "date": "2026-07-21", "school_year": "2025-2026", "action": "first_reading", "result": "first_reading", "summary": "This update establishes the full text of the Special Education Parent Advisory Council (SEPAC) policy FOFF(LOCAL) for Conroe ISD, covering the council's purpose, governance, membership composition, meeting requirements, reporting obligations, confidentiality requirements, district support access, and complaints/grievances procedures. All text in this draft is presented as new red-underlined language, indicating this is the initial introduction of this policy at first reading.", "changes_added": [ "The Board of Trustees authorizes the establishment of a Special Education Parent Advisory Council (SEPAC) to serve as an advisory body to the Superintendent and the Board of Trustees on matters relating to special education programs and services. The SEPAC is purely advisory in nature and does not have decision-making authority over the Board of Trustees or District.", "The SEPAC may: 1. Advise on Board Policies, District procedures, programs and services that support students receiving special education services; 2. Support training, events, and education on topics relevant to special education; and 3. Promote community awareness and engagement on matters relating to special education.", "The SEPAC shall not: Address, investigate, render findings, interfere with, or intervene in any individual parent, guardian, or student issue, including but not limited to a student's Admission, Review, and Dismissal (ARD) committee decisions, Section 504 plans, individualized education programs (IEPs), behavioral intervention plans, placements, disciplinary matters, grades, special education eligibility determinations, or grievances; Direct, supervise, or otherwise instruct District employees; or Exercise any authority over District operations, resources, or decisions.", "The SEPAC shall adopt bylaws. The bylaws shall include, but are not limited to, provisions related to SEPAC council eligibility, council application, appointment and terms, meeting procedures, quorum and voting, agendas and executive session, executive Council composition and officer duties, standing council (if any), decision-making authority, conflicts of interest, confidentiality, and dissolution of the organization.", "Nothing in this Board Policy prohibits SEPAC from organizing a separate 501(c)(3) nonprofit organization to support SEPAC, provided such organization operates independently of Conroe ISD.", "The District shall maintain a dedicated SEPAC webpage that serves as the primary public resource for information about SEPAC. The webpage shall include meeting dates, times, agendas, minutes, reports, bylaws, and upcoming events along with other information.", "The webpage shall clearly state that SEPAC is advisory in nature and does not have decision-making authority over Conroe ISD or its Board of Trustees.", "The webpage shall include a Council Membership Application for individuals wishing to serve on the SEPAC.", "The webpage shall also include a Suggestion Submission Form through which students, parents or guardians, staff, and community members may submit feedback, suggestions, questions, concerns, and recommendations to SEPAC. The SEPAC shall regularly review all Suggestion Submission Forms and consider them for recommendations to the Board of Trustees or Superintendent.", "The SEPAC shall consist of no fewer than five (5) and no more than fifteen (15) voting members. The SEPAC Council Membership shall be composed of parents and guardians of current Conroe ISD students and represent a variety of campuses, parents or guardians, and students. Members shall not be required to pay dues or other fees.", "One District staff representative may serve as an Ex-Officio member on the SEPAC in an advisory capacity, as determined by the Superintendent. The Ex-Officio staff member shall not vote on SEPAC matters and may serve in a liaison capacity between SEPAC and the District.", "One member of the Board of Trustees may serve as an Ex-Officio member of the SEPAC. The Ex-Officio Board Member shall not vote on SEPAC matters and may serve in a liaison capacity between SEPAC and the Board.", "Individuals serving on an existing Conroe ISD SEPAC as of the date of adoption of this Board Policy may remain on the SEPAC for a term consistent with the SEPAC bylaws for terms.", "SEPAC shall submit membership recommendations to the Board of Trustees for approval as appropriate or needed.", "The SEPAC shall meet on a regular basis, at a minimum quarterly, or as otherwise determined by the SEPAC.", "A quorum shall consist of a majority of the current voting membership. No official vote or formal recommendation shall be taken in the absence of a quorum. For purposes of determining a quorum, vacant seats shall not be counted.", "All SEPAC meetings will be open to the public, unless an executive or closed session is appropriate and permitted by law.", "The SEPAC shall seek to submit at least one (1) written report to the Superintendent and the Board of Trustees annually. This report shall include: Any SEPAC recommendations regarding special education programs, services, curriculum, education, or related matters; Any suggested modifications to prior SEPAC recommendations; and A summary of SEPAC activities during the reporting period.", "Before a written report or other recommendation may be submitted to the Superintendent or Board of Trustees, the majority of SEPAC must vote for the written report or recommendation to be submitted.", "The Superintendent or Board of Trustees may, but is not required to, take action on SEPAC recommendations.", "SEPAC shall develop, and all SEPAC Council Members shall sign a confidentiality agreement. All members of the SEPAC shall maintain strict confidentiality regarding individual students and staff-specific information. No discussion, identification, or disclosure of personally identifiable student or staff information shall occur in any SEPAC meeting, communication, or report. A Council Member's obligation of confidentiality survives the conclusion of their service on the SEPAC.", "SEPAC Council Members shall comply with all applicable federal and state privacy laws, School Board Policies, and District procedures, including the Family Educational Rights and Privacy Act (FERPA).", "The SEPAC shall have access to District facilities and supports on the same basis as comparable parent organizations (e.g., the Parent-Teacher Association) and under Board Policy GKD(LOCAL).", "The SEPAC shall not serve as a grievance body or forum for the resolution of grievances or complaints. Any concerns relating to Board of Trustees or District decisions, staff conduct, or individual student matters must be addressed through the District's established grievance and complaint procedures." ], "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-07-21_regular", "confidence": "high", "source_redline": "FOFF_LOCAL.pdf", "notes": "All policy text appears in red underlined format throughout all pages, indicating this entire policy is being introduced as new language at first reading. There are no red strikethrough (removal) markings anywhere in the document. Two small portions of text on page 4 appear to be cut off in the PDF (\"A Council M[ember's obligation of confidentiality survives the conclusion of their service on the] SEPAC.\" and \"individual student matters must be addressed through the District's [established grievance and] complaint procedures.\") — the complete text was inferred from context and the visible portions. The document is clearly marked \"DRAFT FOR FIRST READ JULY 21, 2026.\"", "compliance_assessment": { "classification": "Locally Discretionary", "elements": [ { "element": "Establishment of Special Education Parent Advisory Council (SEPAC) as advisory body to Superintendent and Board", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District chose to create SEPAC; no Texas statute or federal regulation in the statute analysis requires or expressly authorizes a local SEPAC" }, { "element": "SEPAC advisory scope — advise on policies/programs/services, support training, promote community awareness", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District defined specific advisory functions; no statute in the analysis mandates or authorizes this advisory scope" }, { "element": "SEPAC prohibitions — no interference with ARD decisions, IEPs, Section 504 plans, placements, discipline, eligibility, or grievances; no authority over district employees or operations", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District-imposed guardrails to prevent SEPAC from encroaching on individualized decision-making processes; reflects district practice, not a statutory mandate" }, { "element": "SEPAC bylaws requirement (including eligibility, application, appointment, terms, quorum, voting, officer duties, conflicts of interest, confidentiality, dissolution)", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District required SEPAC to adopt bylaws with specified content; entirely a local governance choice" }, { "element": "SEPAC membership composition — 5 to 15 voting members; parents/guardians of current students; no dues required", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District specified membership size range, composition criteria, and fee waiver; no statute in the analysis addresses local SEPAC membership" }, { "element": "Ex-officio non-voting District staff representative and Board member liaison positions", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District created optional non-voting liaison roles; no statutory basis in the analysis" }, { "element": "SEPAC meeting frequency (minimum quarterly) and open-to-the-public requirement with limited executive session exception", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District established minimum quarterly frequency and public access policy; no statute in the analysis requires this for a local advisory council" }, { "element": "Quorum requirement — majority of current voting membership; no vote or formal recommendation without quorum; vacant seats excluded from quorum count", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District defined quorum rules for SEPAC; entirely local governance choice" }, { "element": "Annual written report to Superintendent and Board of Trustees on recommendations and activities", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District required at least one annual written report; no statute in the analysis mandates this" }, { "element": "Majority vote required before SEPAC may submit written report or recommendation; Superintendent and Board not required to act on recommendations", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District established internal decision-making threshold and preserved Board/Superintendent discretion; entirely local choice" }, { "element": "Confidentiality agreement signed by all SEPAC members; prohibition on discussing or disclosing personally identifiable student or staff information; obligation survives service", "classification": "Mixed", "statutory_basis": "20 U.S.C. § 1232g (FERPA) for underlying privacy obligation; local discretion for the signed confidentiality agreement mechanism and surviving-service provision", "supporting_quote": "No funds shall be made available under any applicable program to any educational agency or institution which has a policy of denying, or which effectively prevents, the parents of students who are or have been in attendance at a school of such agency or at such institution, as the case may be, the right to inspect and review the education records of their children.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District added a mandatory signed confidentiality agreement, surviving-service obligation, and explicit prohibition on discussing personally identifiable information in SEPAC meetings — all beyond what FERPA's text in the statute analysis requires" }, { "element": "SEPAC compliance with FERPA and applicable federal and state privacy laws and District policies", "classification": "Required by Law", "statutory_basis": "20 U.S.C. § 1232g (FERPA)", "supporting_quote": "No funds shall be made available under any applicable program to any educational agency or institution which has a policy of denying, or which effectively prevents, the parents of students who are or have been in attendance at a school of such agency or at such institution, as the case may be, the right to inspect and review the education records of their children.", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "None — FERPA compliance is federally required; the policy simply extends that obligation to SEPAC members" }, { "element": "District-maintained SEPAC webpage with meeting dates, agendas, minutes, reports, bylaws, events, advisory-nature disclaimer, membership application, and Suggestion Submission Form", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District chose to create a dedicated public webpage with specified content; no statute in the analysis requires this" }, { "element": "SEPAC access to District facilities and supports on same basis as comparable parent organizations (e.g., PTA) and under Board Policy GKD(LOCAL)", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District chose to grant SEPAC access parity with comparable parent organizations by reference to GKD(LOCAL); no statute in the analysis requires this" }, { "element": "SEPAC shall not serve as grievance body; individual concerns must go through established District grievance and complaint procedures", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District explicitly limited SEPAC's role and redirected complaints to formal channels; entirely a local governance decision" }, { "element": "Authorization for SEPAC to organize a separate 501(c)(3) nonprofit that operates independently of the District", "classification": "Locally Discretionary", "statutory_basis": "None", "supporting_quote": "None", "verification_method": "verbatim statute text", "litigation_status": "None identified", "local_additions": "District expressly permitted (but did not require) formation of an independent nonprofit to support SEPAC, conditioned on independent operation; no statute in the analysis addresses this" } ] }, "compliance_summary": [ "New Advisory Council Created: Conroe ISD is establishing a Special Education Parent Advisory Council (SEPAC) to advise the Superintendent and Board of Trustees on special education policies, programs, and services. No state or federal law required the district to create this council — it is entirely the district's own decision.", "Council Membership Rules: The policy sets membership at between 5 and 15 voting members, all of whom must be parents or guardians of current Conroe ISD students receiving special education services, with no dues required to participate. These rules were set by the district and are not required by any state or federal law.", "Limits on Council Authority: The policy makes clear that the SEPAC cannot get involved in individual student decisions, such as IEP meetings, Section 504 plans, eligibility determinations, or discipline matters. The district chose to include these boundaries to keep the council focused on broad advisory topics rather than individual cases.", "Privacy Requirements: All SEPAC members must sign a confidentiality agreement and are prohibited from sharing or discussing personally identifiable information about students or staff, even after their time on the council ends. Federal law known as FERPA (20 U.S.C. § 1232g) requires the district to protect student privacy, and the district added the signed agreement and the surviving-service rule on top of that baseline federal requirement.", "Public Transparency Measures: The district will maintain a dedicated webpage for the SEPAC that includes meeting dates, agendas, minutes, reports, bylaws, and a membership application. This website requirement is not mandated by law — it is a choice the district made to keep the public informed about the council's work.", "Nonprofit Option: The policy allows SEPAC members to form a separate, independent nonprofit organization under IRS rules for 501(c)(3) groups to support the council's work. No law requires or specifically authorizes this — it is a local decision, and the policy specifies that any such nonprofit must operate independently from the district." ] } ], "timeline_legal": [] }