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Series 6000

Fiscal Management Goals 6000
Fiscal Controls 6010
Fund Balance and Reserve Funds
Annual Budget 6100
Budget Planning 6110
Budget Deadlines and Schedules 6111
Determination of Budget Priorities 6112
Budget Hearing 6120
Budget Adoption 6130
Contingency Budget 6135
Budget Implementation 6140
Budget Transfers 6150
Revenue 6200
Local Tax Levy 6210
Senior Citizens’ Exemption 6215
Federal Funds 6230
Title I/PSEN Programs and Services 6231
Investments 6240
Non-Resident Tuition 6254
Depositories of Funds 6400
Authorized Signatures 6410
Wire Transfers 6415
Online Banking Resources 6420
Bonded Employees and Officers 6500
Fiscal Accounting and Reporting 6600
Financial Reports and Statements 6630
Fixed Asset Accounting Policy
Claims Auditor 6650
Independent/External Auditor 6660
Petty Cash/Petty Cash Account 6670
Extraclassroom Activity Fund 6675
Internal Audit Function 6680
Medicaid False Claims, Fraud Prevention and Detection 6685
Audit Committee 6690
Purchasing 6700
Purchasing Authority 6710
Bidding Requirements 6720
Cooperative Purchasing 6730
State Contracts 6731
Purchasing Procedures 6740
Use of Credit Cards 6745
Payment Procedures 6760
Payroll Procedures 6800
Travel Reimbursement 6830
Disposal of Broken, Surplus, Obsolete District Property





                                    FISCAL MANAGEMENT GOALS


The Board of Education recognizes excellent fiscal planning as a key factor in attaining the district's educational goals and priorities.  The Board seeks to engage in thorough advance planning of budgets and to devise expenditures which achieve the greatest educational returns given the district's available resources. 


The annual budget will be prepared in accordance with the Education Law of the State of New York.


Adoption date: February 10, 1998




                                                ANNUAL BUDGET


The school budget is the legal basis for the establishment of the tax levy. It is the official document that describes the programs to be conducted during a given period of time. It is the operational plan, stated in financial terms, for the conduct of all programs in the school system.

The annual school budget process is important to school district operations and serves as a means to improve communications within the school organization and with the residents of the school community.

The budget will be presented to the public in three components (to be voted upon as one proposition):


  1. a program component, which includes all program expenditures of the district, including the salaries and benefits of teachers and any school administrators or supervisors who spend a majority of their time performing teaching duties, and all transportation operating expenses;
    2. a capital component, which includes all transportation capital, debt service and lease expenditures; costs resulting from court judgments, administrative orders or settled or compromised claims; and all facilities costs of the district, including facilities lease expenditures, annual debt service and total debt for all facilities financed by bonds and notes of the district, and costs of construction, acquisition, reconstruction, rehabilitation or improvement of school buildings, provided that the budget shall include a rental, operations and maintenance section that includes base rent costs, total rent costs, operation and maintenance charges, cost per square foot for each facility leased by the district, and all expenditures associated with custodial salaries and benefits, service contracts, supplies, utilities, and maintenance and repair of school facilities;
    3. an administrative component, which includes office and central administrative expenses, traveling expenses, and all compensation, salaries and benefits of all school administrators and supervisors, all expenditures associated with the operation of the school board, the office of the Superintendent of Schools, general administration, the school business office, any consulting costs not directly related to direct student services and programs, planning, and all other administrative activities.

In addition, each component must be separately delineated in accordance with Regulations of the Commissioner. The budget will categorize revenues, property tax refunds, expenditures, budget transfers and fund balance information, and will be formatted to show changes in the data as compared with the previous year. Finally, the budget will be written in plain language and organized in a manner which best promotes the public’s understanding of its contents.

The budget will be completed at least seven days before the public hearing at which the Board will present the budget to the voters. Copies of the budget will be made available upon request to residents within the district (not just district taxpayers) during the 14 days preceding the date of the annual election and budget vote at each school building in the district, at the school district offices, and at any public library or free association library within the district, between the hours of 9:00 am and 5:00 p.m. on each day other than Saturday, Sunday or holidays, as well as on the school district’s internet website In addition, at least once during the school year, the Board will include in a district-wide mailing, notice of the availability of copies of the budget.


The following documents will be attached to the budget:


  • a detailed statement of the total compensation to be paid to the Superintendent of Schools, and any assistant or associate superintendent in the coming school year, including a delineation of the salary, annualized cost of benefits and any in-kind or other form of remuneration;
    · a list of all other school administrators and supervisors, if any, whose annual salary will be at or above the amount designated by the State Education Department in the coming year, along with their title and annual salary;
    · a school district report card detailing the academic and fiscal performance of the district; and
    · a property tax report card prepared pursuant to the Regulations of the Commissioner of Education.


The Board may not submit the proposed budget or a related proposition to the voters more than twice. If the voters fail to approve the proposed budget or budget proposition after the second submission, or if the Board elects not to put the proposed budget to a public vote a second time, the Board must adopt a contingency budget.


The Board may use district monies to present educational and informational material about the annual budget and related information to the voters. It shall not, however, use these funds to urge voters to cast their ballots in a particular fashion.


Ref: Education Law §§1608; 1716; 1804(4); 1906(1); 2008(2); 2021; 2002(1); 2022(2); 2035(2); 2601-a
General Municipal Law §36
Phillips v. Maurer, 67 NY2d 672 (1986)
Fiscal Management (NYSSBA, 1997)
Hartman, William T., “Participatory Budgeting in High School”, Planning and Changing, Spring 1989, vol. 20, no. 1.


Adoption date: February 10, 1998
Revision date: September 21, 1999
Revision date: November 18, 2009





                                              BUDGET PLANNING


The Superintendent of Schools, with the assistance of the Assistant Superintendent for Business, shall be responsible for preparation of the budget. This shall include developing  and adhering to  a budget calendar.  The budget calendar shall be approved by the Board of Education in advance of the preparation of the district’s annual budget. 


The budget shall be designed to reflect the Board’s objectives for the education of the children of the district. It shall be carefully organized and planned to provide adequate accounting for each program expenditure, understanding of the financial needs of anticipated program developments, and be within the financial limitations of the district. To assist in budget and long-range planning, ongoing studies of the district’s educational programs will include estimates of the fiscal implications of each program.


The budget for the ensuing school year shall be thoroughly reviewed by the Board before its presentation to the voters for final adoption.


Cross-ref:        2260, Citizens Advisory Committees

                        6130, Budget Adoption


Ref:     Education Law §§ 1608(2)-(4); 1716(2)-(4); §1804(4); 1906(1); 2002(1); 2003(1); 2004(1); 2022(2); 2601-a

            Fiscal Management (NYSSBA, 1997)


Adoption date: February 10, 1998

Revision date: September 21, 1999




                             BUDGET DEADLINES AND SCHEDULES


The Superintendent of Schools, with the assistance of the Assistant Superintendent for Business and School Finance Manager, shall have responsibility for developing and adhering to a budget calendar.  The Board will consider and adopt such a calendar in advance of the preparation of the district's annual budget.  The calendar shall present a plan of action for the estimation and completion of the proposed annual budget during the ensuing school year.  The calendar is to identify necessary budgetary activities and the schedule, with deadlines, for the completion of each activity.  It will also indicate to whom the responsibility for completion of each budget activity has been delegated.  The calendar shall contain preliminary dates for the Board of Education's consideration of the tentative budget and the dates for public hearings on the final budget, including those required by statute.


Adoption date: February 10, 1998






After receiving direction from the Board of Education, and with the assistance of the Assistant Superintendent for Business, the Superintendent of Schools shall prepare proposed budget priorities for the school district which strike a balance between an ideal educational program and the district's fiscal resources.  In setting budget priorities, the following factors shall be considered:


  1. the health and safety of pupils and employees;
  2. items directly related to the educational needs and goals of the district. All segments of the district's programs are to be treated equitably within the available resources;
  3. adequate staffing of programs and the salaries of employees;
  4. maintenance of capital investment, equipment and facilities;
  5. improvements in noninstructional items;
  6. state and/or federal legal requirements for the funding of programs;
  7. requirements and regulations of the State Education Department and the Commissioner of Education as well as other state agencies; and
  8. fiscal and nonfiscal resources available.


Adoption date: February 10, 1998




                                                BUDGET HEARING


The Board of Education will hold an annual budget hearing at which it will present a detailed proposed budget for the following school year. The purpose of the budget hearing is to inform the public of the contents of the budget and to provide an explanation and justification for the decisions the proposed budget reflects.


The budget hearing will be held not less than seven nor more than 14 days prior to the annual district election, at which the district’s voters will vote on the budget. The proposed budget will be completed at least seven days before the budget hearing. A copy of the proposed budget may be obtained by any district resident (not just district taxpayers) at each school, the school district offices, and any public library or free association library within the district, during certain designated hours on each day (other than a Saturday, Sunday or holiday), as well as on the school district’s internet website during the 14 day period immediately preceding the annual district election.


Notice of the date, time and place of the annual budget hearing will be contained in the notice of the annual district election and budget vote.

Cross-ref: 1050, Annual District Election and Budget Vote
2120, School Board Elections
2120.1, Candidates and Campaigning

Ref: Education Law §§1608; 1716; 1804(4); 1906(1); 2002(1); 2003(1); 2004(1); 2002(1); 2601-a(2)


Adoption date: February 10, 1998
Revision date: September 21, 1999
Revision date: November 18, 2009



                                              BUDGET ADOPTION


Final approval of the tentative budget rests with the Board of Education.  The Superintendent of Schools and such members of his/her staff as he/she shall deem necessary, shall be prepared to explain and justify the budget to the Board.  Final authorization of the budget rests with the voters of the district.


The proposed budget shall be presented to the voters of the district for adoption on the third Tuesday in May, unless this date conflicts with religious observances on that day, in which case the budget vote (as well as the election of members of the Board of Education and the annual meeting) will be held on the second Tuesday in May.


Individuals desiring to submit questions, propositions, or amendments to be placed on the ballot shall conform to the following requirements:


  1. petitions must be filed with the District Clerk at least 30 days prior to the annual meeting and election, except for petitions relating to a proposition which must be included in the notice of the annual meeting (e.g., changing the number of board members). Such petitions must be submitted 60 days in advance of the annual meeting and election to facilitate the preparation and printing of the ballots;


  1. unless otherwise required by the Education Law, said propositions shall be supported by petitions containing signatures of 25 voters or 5 percent of the number of eligible voters who voted in the previous annual election of members of the Board of Education, whichever is greater;


  1. the proposition shall be stated clearly and concisely and is subject to revision as to length and form by the Board, while considering same for placement on the voting machine; and


  1. any propositions which require the expenditures of monies must include the necessary specific dollar appropriation. Any proposition may be rejected by the Board if it fails to include the necessary specific appropriation and/or is not within the power of the voters.


Cross-ref:        1050, Annual District Meeting and Election

                        6100, Annual Budget

                        6110, Budget Planning

                        6120, Budget Hearing

                        6135, Contingency Budget

Ref:     Education Law §§1804(4); 1906(1); 2002; 2003(1); 2004(1); 2013; 2017; 2022(1); 2023; 2601-a 


Adoption date: February 10, 1998

Revision date: September 21, 1999




                                          CONTINGENCY BUDGET


The annual district budget and any related propositions related thereto may be submitted to the voters only twice.  If the original budget is not approved by the voters, the Board of Education may either resubmit the original or a revised budget to the voters for approval or adopt a contingency budget.  If the Board decides to submit the budget to the voters a second time and the voters do not approve it, the Board will adopt a contingency budget and levy a tax for its implementation.


The contingency budget will fund only teachers’ salaries and those items the Board determines constitute “ordinary contingent expenses.”  Ordinary contingent expenses include pre-existing legal obligations of the district, those expenditures specifically authorized by statute, and other items necessary to maintain the education program, preserve property and assure the health and safety of students and staff.  A list of expenditures which have been determined to constitute ordinary contingent expenses is attached.


The contingency budget will be prepared in accordance with the statutory spending limits on the administrative component of the contingency budget and on overall district spending. Specifically, the monies in the administrative component of the contingency budget will not exceed either the percentage of the administrative component of the district’s prior year’s budget, or the percentage the administrative component comprised in the last proposed defeated budget. In addition, the percentage increase in the district’s total spending under the contingency budget in comparison to the district’s total spending under the budget for the prior year will be limited to 120 percent of the consumer price index (CPI) or 4 percent, whichever is less.  In determining total district spending, the Board will disregard the following types of expenditures:


  • expenditures resulting from a tax certiorari proceeding;
  • expenditures resulting from a court order or judgment against the district;
  • emergency expenditures that are certified by the Commissioner of Education as necessary as a result of damage to, or destruction of, a school building or school equipment;
  • capital expenditures resulting from the construction, acquisition, reconstruction, rehabilitation or improvement of school facilities, including debt services and lease expenditures, subject to voter approval;
  • expenditures attributable to projected increases in public school enrollment; and
  • non-recurring expenditures in the prior year’s budget.


In the event the Board elects or is required to adopt a contingency budget, it will pass a resolution officially doing so. That resolution will contain or refer to a statement which specifies the projected percentage increase or decrease in total spending for the school year and which explains the reasons why the Board disregarded any portion of the increase in spending in determining together the contingency budget.





Before adopting the contingency budget, the Board shall refer it to the school attorney for review.


Cross-ref:        6130, Budget Adoption


Ref:     Education Law §§2002; 2023; 2601-a

            Education Law § 2024

            Formal Opinion of Counsel No. 213, 7 EDR 153 (1967)

            Onteora CSD at Boiceville, 79 AD2d 415, aff’d 56 NY2d 769 (1982)

            Brown v. Whitesboro Central School District, 88 AD2d 184 (1982)

            Matter of Gouverneur CSD, 15 EDR 468 (1976)


Adoption date: February 10, 1998

Revision date: September 21, 1999




                                      BUDGET IMPLEMENTATION


The administration of the annual budget is an executive function which is the responsibility of the Superintendent of Schools and the administrative staff.  Under the direction and control of the Superintendent, funds may be expended within budgetary appropriations without prior approval from the Board of Education.


The Superintendent shall acquaint district employees, through the administrative staff, with the full provisions of the budget and guide them in planning to operate effectively and economically.  Under the direction of the Superintendent, the Assistant  Superintendent for Business shall maintain such accounting records as are or may be required by the New York State Uniform System of Accounts for School Districts or the Board, or as otherwise deemed necessary.  The Assistant  Superintendent for Business shall keep all of the various operational units in the school district informed of the status of their budgets through periodic reports.


Heads of administrative units are responsible to the Superintendent for operation of their units within budgetary amounts.  The Board shall require periodic status reports on the budget.


Ref:     Education Law §§1609; 1709(16); 1718; 1720; 2021; 2022; 2023; 2024


Adoption date: February 10, 1998






The Superintendent of Schools is responsible for providing the Board of Education with information about available sources of revenue and the possible benefits to the district of each such source. To provide the best education possible to students within the limits of the resources available, the Board shall:


  1. request adequate local funds for the district operations. The amount of the local financial support requested, when added to state and federal aid and revenue from all other sources, shall yield sufficient revenue to meet the total expenses of the school district;
  2. accept all available state funds to which the district is entitled by law or through state regulations to support the programs that the district seeks to offer;
  3. accept all federal funds that are available providing there is a specific need for them and the local funds that are required to support the particular programs of the district are available; and
  4. upon the recommendation of the Superintendent, and after careful consideration and review, accept all appropriate special grants or aid.


When in need to borrow money for the district's general financial operations, until such time as tax monies and state aid payments are received, the President and Clerk of the Board, jointly, are authorized to borrow money by revenue or tax anticipation notes as authorized by the Local Finance Law.


Ref:     Education Law §3602

            Local Finance Law §§24.00; 25.00


Adoption date: February 10, 1998




                                                LOCAL TAX LEVY


Sufficient local tax revenue shall be raised to meet the requirements of the total school district budget, less an amount equal to all other income sources available to the school district.


After August 1, and following receipt of the final equalization rate and as­sessment rolls, a tax levy shall be set which will generate that portion of the school district budget requirement to be provided at the local level.  The Board of Education shall approve the tax levy and shall issue a warrant for the collection of taxes.


Ref:     Education Law §§2021-2023; 2130

            Real Property Tax Law Article #13


Adoption date: February 10, 1998




                                   SENIOR CITIZENS' EXEMPTION


The Board of Education grants an exemption from taxation to the extent of fifty percentum (50%) of assessed valuation of real property located in the district and owned by persons sixty-five (65) years of age or over, or by a husband and wife, one of whom is 65 or over, whose income meets the statutory requirements set forth in Section 467 of the Real Property Tax Law of the State of New York in effect for the income tax year of application.


Ref:     Real Property Tax Law §467


Adoption date: February 10, 1998




                                                 FEDERAL FUNDS


The Board of Education shall consider whether to apply for any federal aid for which it is eligible.  The administrative staff has the responsibility to evaluate federally funded programs, including their possible benefits to the children and youth in the school district, apprise the Board of the value of each, and make recommendations accordingly.  A separate federal aid fund shall be maintained to record all financial transactions in federally aided programs and projects. A separate checking account, distinct from all other district accounts, shall be maintained for federal funds.


Ref:     8 NYCRR Parts 114; 167; 200


Adoption date: February 10, 1998




                          TITLE I/PSEN PROGRAMS AND SERVICES


Title I


The Board of Education may apply for Title I of the Elementary and Secondary Education Act (ESEA) funding for projects designed to meet the special educational needs of educationally deprived children.  Such funding shall be used to provide appropriate programs and services to participating students in basic and more advanced skills.  In particular, funds may be used for the following:


  1. year-round services and activities, including intensive summer school programs;
  2. purchasing appropriate equipment and/or instructional materials;
  3. employment of special instructional personnel, school counselors, and/or other pupil services personnel;
  4. employment and training for NYS teaching assistants;
  5. teacher bonuses in excess of regular salary schedules for service in such programs;
  6. training of teachers, librarians, other instructional and pupil services personnel, and early childhood education professionals when appropriate;
  7. construction, if necessary, of school facilities;
  8. parental involvement activities;
  9. planning for and evaluation of Title I programs; and
  10. other activities permitted under federal regulations.


With the approval of the State Education Department, the district may use up to and including five percent (5%) of such funds for "innovation projects to promote quality" in the district's Title I program.  Such projects may include the following:


  1. continuation of services to those students who participated in the program in any previous year;
  2. continuation of services for a period not to exceed two additional years to participating students who are transferred to areas/schools which are ineligible for such funding, as part of a desegregation plan;
  3. incentive payments to schools that have demonstrated significant progress and success in attaining Title I goals;
  4. training of teachers and librarians in the special educational needs of eligible students, and in the integration of Title I programs into regular classroom programs;
  5. programs which encourage innovative approaches to parental involvement, or rewards to or expansion of exemplary parental involvement programs; and
  6. encouraging community and business involvement in meeting the needs of eligible children.








The Board must submit for approval a plan for the expenditure of its Pupils with Special Educational Needs (PSEN) funds, which are state funds which must be expended only for project activities for eligible pupils in the school year for which funds are appropriated.  PSEN serves as a funding source for all school districts based upon the number of educationally deficient students in each district.


The Board directs the administration to follow all applicable State Education Department guidelines for completing budget forms for the operation of Title I/PSEN projects.



Cross-ref:        1900, Parental Involvement

                        4010, Equivalence in Instructional Staff and Materials

                        4325, Compensatory Education


Ref:     8 NYCRR Part 149

            34 CFR Part 75; §200.34(c)(1)(i)  (ESEA Title 1 Program in Local  Educational Agencies)

            Applicant's Guide and Instructions for Consolidated Application and the Program Information Report, The University of the State of New York (1989)

            Pupils With Compensatory Educational Needs:  Questions and Answers July 1987, The University of the State of New York (1987)

            Chapter 1 Policy Manual, The University of the State of New York (1990)


Adoption date: February 10, 1998





                                          NONRESIDENT TUITION


The Board of Education will establish a tuition rate for nonresident pupils each year, using the formulae provided by the State Education Department in calculating the tuition rates.  For school attendance by a nonresident child for a period longer than 90 calendar days, tuition is payable in advance for each succeeding 30 calendar days, or on a prorated basis.


Cross-ref:        5152, Admission of Nonresident Students


Ref:     Education Law §3203

            8 NYCRR §174.2

            Matter of Richards, 25 EDR 38 (1986)

            Matter of Hill, 23 EDR 338 (1984)

            Matter of Bunk, 22 EDR 38 (1983)

            Matter of Schumer, 21 EDR 640 (1982)

            Matter of Wadas, 21 EDR 577 (1982)

            Letter to Counsel, NYS Education Department from the U.S. Dept. of Education, Office of Civil Rights, August 10, 1994


Adoption date: February 10, 1998




                                         DEPOSITORIES OF FUNDS


All money belonging to the district shall be turned over to the District Treasurer without delay.  The Treasurer shall deposit district funds only in depositories duly designated by the Board of Education.  The designated depositories are required to collateralize all deposits fully.


Ref:     Education Law §§2129; 2130(4)

            8 NYCRR §§170.1; 170.2

            General Municipal Law §§10; 11; 800 et seq.


Adoption date: February 10, 1998




6415 WIRE TRANSFERS        Click the link to the left to view Policy 6415




                             BONDED EMPLOYEES AND OFFICERS


No money other than petty cash shall be kept in any school building overnight.  The Superintendent of Schools shall inform all employees of this require­ment and enforce this policy.


School employees may be held personally responsible for funds which they collect during the course of their assigned duties and responsibilities.  Monies should be deposited in the bank as soon as possible.


All school employees, officials and members of the Board of Education authorized to sign checks or required to handle school funds will be covered by a blanket bond furnished by the school district in such amounts as recommended by the Superintendent.


The District Treasurer shall be covered by a bond in an amount fixed and approved by the Board.  The bond must be received by the Board within 10 days after notification of appointment and before assumption of duties.


Ref:     Education Law §§1709(20-a); 1720; 2130(5); 2526


Adoption date: February 10, 1998




                          FINANCIAL REPORTS AND STATEMENTS


The Board of Education requires the District Treasurer to make a written report at regular Board meetings each month covering the previous month.  The Board must accept the report by resolution.  The report shall be permanently filed in the minute book.


Bank statements of the financial accounts of the district shall be included in the records of the Treasurer.  Bank statements shall be obtained on the last day of each month.  These bank statements shall be filed and become part of the permanent records of the district.


The Treasurer shall be responsible for filing, keeping and protecting all financial records.


Cross-ref:        1120, School District Records


Adoption date: February 10, 1998





The Board of Education recognizes its responsibility to ensure sound fiscal management of the district. To this end, The Board establishes an internal audit function to carry out the following tasks:

  • Develop risk assessment of district fiscal operations which shall include but not be limited to:
  1. a review of financial policies and procedures
    b. the testing and evaluation of district internal controls;
  • An annual review and update of such risk assessment;
  • Periodic testing and evaluation of one or more areas of the district's internal controls, which take into account risk, control weaknesses, size, and complexity of operations; and
  • Prepare reports, at least annually or more frequently as the Board may direct, which:

a.analyze significant risk assessment findings,
b.recommend changes for strengthening controls and reducing identified risks, and
c.specify timeframes for implementation of such recommendations.

To fulfill this function, the district may use inter-municipal cooperative agreements, BOCES shared services, or independent contractors as long as such personnel or entities performing the internal audit function comply with the Regulations of the Commissioner and meet professional auditing standards for independence between the auditor and the district. The district may also use existing personnel to fulfill this function but only if such persons shall not have any responsibilities for other business operations of the district while performing such function.

Personnel or entities performing this function shall report directly to the Board and shall follow generally accepted auditing standards. The district's audit committee shall assist in the oversight of this internal audit function.

The results of the work of the internal audit function shall be reported directly to the Board.

Cross-Ref: 6690, Audit Committee
Ref: Education Law §2116-b
8 NYCRR § 170.12

Adoption Date:




The Board of Education recognizes the importance of detecting and preventing Medicaid fraud, waste, and abuse. The purpose of this policy is to set forth the procedures that will be used by the Sachem Central School District (hereinafter referred to as the “School District”) to respond to reports by employees and others of activity which might violate applicable Medicaid laws or regulations, which includes, but is not limited to, submitting and/or receiving claims in a manner which does not meet the Medicaid program requirements, as applicable.


Each employee must act in an ethical manner and adhere to applicable legal requirements in the course of performing their duties on behalf of the School District.

Any employee of the School District who has knowledge of activities that he or she believes may violate a law, rule, or regulation has an obligation to promptly report this matter to the designated Compliance Officer and/or his or her immediate supervisor. Reports may be made anonymously and employees will not be penalized for reports made in good faith. Failure to report known violations, failure to detect violations due to negligence or reckless conduct and intentionally making false reports shall be grounds for disciplinary action, including termination. The appropriate form of discipline will be case-specific and in accordance with applicable law and/or existing collective bargaining agreements.

Necessary steps will be taken to communicate appropriate standards and procedures to all employees by disseminating information that explains what is required. This shall include the posting of this policy.

In order to detect and prevent fraud, the Board of Education authorizes the utilization of monitoring and auditing systems that are reasonably designed to detect misconduct by its employees, contractors, and/or agents.

Once a suspected violation has been reported, the Board of Education acting upon the recommendation of the Superintendent of Schools and the Compliance Officer, will take reasonable steps to respond appropriately and to prevent further violations, which shall include, any necessary modifications to its program designed to prevent and detect violations of applicable law.

All contractors and agents who furnish or authorize the furnishing of Medicaid services on behalf of the School District, or perform billing or coding functions are required to communicate these policies and procedures to their employees and are responsible for ensuring that such communication occurs.

Appointment of Compliance Officer

The Superintendent of Schools shall appoint a Compliance Officer, subject to the approval of the Board of Education, who shall have the authority to:

  1. Oversee and monitor the implementation of the School
    District’s compliance policy;
    2. Consult outside counsel as legally necessary;
    3. Conduct internal investigations and audits relating to
    compliance issues;
    4. Review all documents and other information relevant
    to Medicaid compliance activities; and
    5. Maintain direct access to the Superintendent of Schools,
    and when appropriate, the Board of Education.

Training and Education

The Compliance Officer shall implement a training program to help employees identify, prevent, and report noncompliance with applicable law. The Board of Education expects all employees to participate in general compliance training upon initial hire or periodically thereafter and must acknowledge attendance at each session. Documentation of attendance will be maintained by the Compliance Officer. Conversely, specialized training will be provided to employees, whose actions directly affect submission and reimbursement of claims, including those involved in dispensing, billing, and reimbursement of Medicaid claims.


Through the Compliance Officer, the School District shall promptly respond to and take appropriate action for detected offenses.

  1. Internal Investigation

The Compliance Officer will conduct a timely and reasonable investigation of all credible reports of suspected noncompliance. A reasonable inquiry includes a preliminary investigation by the Compliance Officer or other compliance personnel.

If an internal investigation results in the discovery of misconduct that may violate applicable laws or regulations, the Compliance Officer must notify the Superintendent of Schools and Board of Education.

  1. Government Investigation

If a government investigation arises, the School District aims to be forthright and cooperative with the investigation.


This policy will be made available on the School District’s website. In addition, hard copies will be made available to new employees during the orientation process and current employees in those departments submitting and/or receiving claims.

Cross-ref: Code of Ethics, Policy No. 2160

Ref: False Claims Act, 31 U.S.C. §3729, et seq.
N.Y. State Finance Law §187, et seq.
N.Y. Social Services Law §145-b
N.Y. Social Services Law §145-c
N.Y. Social Services Law §363-d
N.Y. Labor Law §740
18 NYCRR S 521.1, et seq.

Adoption Date: June 16, 2010





The Board of Education will designate and appoint an Audit Committee for purposes of overseeing and carrying out the Board's audit policies and the performance of related duties and responsibilities.

The District's Audit Committee shall be comprised of at least three members. At least three members shall be appointed to serve on the committee on an annual basis. Members of the Audit Committee who serve on the advisory committee, shall be independent and shall not: (1) be employees of the District; (2) be an individual who has provided services or goods to the District in the last two years or currently provides goods or services to the District; (3) be the owner of or have a direct and material interest in a company providing goods or services to the District; (4) be a close or immediate family member of an employee, officer, or contractor providing services to the District. The members of the Audit Committee should collectively possess knowledge in accounting, auditing, financial reporting and school district finances. Residency in the District or BOCES supervisory district shall not be a requirement for membership on the Audit Committee.

Members of the Audit Committee shall be deemed school district officers for purposes of Education Law §3811 and §3813 and serve without compensation; however, the District shall reimburse members for any actual and necessary expenditures incurred in relation to attendance at meetings.

The Audit Committee shall:

1.Recommend internal and external audit plans to the Board, specifying the areas of District operations to be reviewed for compliance with legal and regulatory requirements, operating efficiency and effectiveness;
2.Oversee the selection of the internal auditor and the external auditor, pursuant to the relevant Board policies, and make recommendations to the Board for appointment to said positions; and
3.Meet with the external auditor prior to commencement of the audit;
4.Review and discuss with the external auditor any risk assessment of the District's fiscal operations developed as part of the auditor's responsibilities under governmental auditing standards for a financial statement audit and federal single audit standards if applicable;
5.Receive and review the resulting audit reports; and propose recommendations to the Board for action as may be necessary and appropriate;
6.Receive and review the report of the external auditor on any findings commented on during the annual audit report, and the management response thereto, and propose recommendations to the Board for acceptance and action as may be necessary and appropriate;
7.Review every corrective plan to be developed by the District as required by under the Education Law and assist the Board with implementation of the corrective plan;
8.Develop and submit to the Board for approval a formal written charter which shall include, but not be limited to, provisions regarding the committee's purpose, mission, duties, responsibilities and membership requirements;
9.Perform any other responsibilities outlined by the Board and/or as listed in the District' Audit Committee Charter;
10.Hold regularly scheduled meetings and report to the Board on the activities of the Audit Committee on an as-needed basis but not less than once per year. The report shall include, at a minimum: (1) the activities of the Audit Committee; (2) summary of the minutes of the public meetings; (3) significant findings brought to the attention of the Audit Committee; any indications of suspected fraud or waste, or abuse; significant internal control findings; and activities of the internal function;
11.As a public body, the Audit Committee is subject to the requirements of the Open Meetings Law. However, the Audit Committee is authorized to conduct an executive session for the reasons delineated in Public Officer's Law §105, as well as for the following purposes, as described in Education Law § 2116-c: (1) meeting with the external auditor prior to commencement of the audit; (2) receiving and reviewing the draft annual audit report and accompanying draft management letter; or (3) working with the external auditor to assist the Board on accepting the annual audit report; By accepting appointment to the Audit Committee, Audit Committee members shall be subject to the confidentiality requirements of General Municipal Law §801-a(1)(b) and shall execute a confidentiality agreement with the district.

It is not the intent of the Board of Education that the Audit Committee participate in or be responsible for the day to day operations of the school district or in the decisions that are the responsibility of the Superintendent of Schools or Assistant Superintendent for Business, or the other district administrators.

Ref: Education Law §2116-c
8 NYCRR §170.12

Adoption Date: August 24, 2006
Revised Date: December 19, 2006




Pursuant to Board resolution dated August 24, 2006, the Board of Education of the Sachem Central School District has established an audit committee to assist the Board of Education in the oversight of both the internal and external audit functions. The requirement to create an audit committee was established by Education Law §2116-c. According to §2116-c(4), the role of an audit committee shall be advisory and any recommendations it provides to the Board shall not be substituted for any required review and acceptance by the Board of Education.


The Board of Education has established an audit committee to provide independent assistance to the Board in the oversight of the following matters:

  • Assist the Board in providing oversight of the internal and external audit functions, including the appointment of the internal and external auditors.
    • Oversee the competitive Request for Proposal Process (RFP) used to solicit quotations for the District’s annual external audit and the internal auditor.
    • Review the scope, plan and coordination of the external audit.
    • Review corrective action plans and necessary improvement based on audit findings and recommendations received from external and internal auditors.
    • Provide a communications link between the external and internal auditors and the Board.

The District’s Audit Committee is comprised of at least five (5) members, who will serve without compensation. The committee shall include:

  • Two Board of Education Members
    • Three Community Members

The Committee members collectively should possess the expertise and experience in accounting, auditing, financial reporting and school district finances needed to understand and evaluate the school district’s financial statements, the external audit of those statements and the district’s internal audit activities. Accordingly, the Audit Committee’s members should:

• Possess the requisite skills and experience necessary to understand technical and complex financial reporting issues.
• Have the ability to communicate with, and offer advice and assistance to, the School Board, public finance officers and auditors.
• Be knowledgeable about internal controls, financial statement audits and management/operational audits.

The duties and responsibilities of the District’s Audit Committee include the following:

External Audit Focus

o Recommend selection of the external auditor to the Board of Education
o Meet with the external auditor prior to commencement of the audit to review the engagement letter.
o Review and discuss with the external auditor any risk assessment of the district’s fiscal operations developed as part of the auditor’s responsibilities under governmental auditing standards for a financial statement audit and federal single audit standards.
o Review the external auditor’s assessment of the district’s system of internal controls.
o Receive and review the draft annual audit report and accompanying draft management letter and, working directly with the external auditor, assist the Board of Education in interpreting such documents.
o Make a recommendation to the Board of Education on accepting the annual audit report.
o Review any corrective action plan developed by the school district and assist the Board of Education in the implementation of such plans.
o Monitor implementation of the external auditor’s recommendations by management.

  • Internal Audit Focus

    Assist in the oversight of the internal audit function, including but not limited to:
    o Make recommendations to the Board of Education regarding the appointment of the internal auditor.
    o Review the annual internal audit plan to ensure that high risk areas and key control activities are periodically evaluated and tested.
    o Review the results of internal audit activities and significant recommendations and findings of the internal auditor.
    o Review the results of claims audit activities and significant recommendations and findings of the claims auditor.
    o Monitor implementation of the internal auditor’s recommendations by management.
    o Provide input on the performance evaluation of the internal auditor.
  • Administrative Matters

o Hold regularly scheduled meetings.
o Administer other related duties as prescribed by the Board of Education.
o Review and revise the Audit Committee Charter.

The membership duties of the Sachem Audit Committee include the following:

  • Good Faith – Members of the Committee shall perform their duties in good faith, in a manner they reasonably believe to be in the best interests of the Committee and the District with such care as a generally prudent person in a similar position would use under similar circumstances.
  • Independence – Persons other than Board Members who serve on an advisory committee shall be independent and shall not be::

o Someone currently employed by the District
o Someone who, within the last two years, provided or currently provides goods or services to the District.
o Someone in the immediate family (spouse, spouse equivalent or dependent, whether or not related) or close family member (parent, sibling or nondependent child) of an individual who is an employee of the District in the past two years, officer or contractor providing goods or services to the district.
o Someone who is the owner of or has a direct and material interest in a company providing goods or services to the district.

  • Confidentiality – During the exercise of duties and responsibilities, the Committee members may have access to confidential information. The Committee shall have an obligation to the district to maintain the confidentiality of such information. By accepting appointment to the Audit Committee, the Audit Committee members shall be subject to confidentiality requirements of General Municipal Laws §801-a(1)(b) and shall execute a confidentiality agreement with the school district.
  • Oath of Office - All non-board members, who are members of the Audit Committee, should be administered the district’s oath of office by the District Clerk.


The Sachem Audit Committee shall meet a minimum of four times each year. An agenda of each meeting should be clearly determined in advance and the Audit Committee should receive supporting documents in advance, for reasonable review and consideration. The Audit Committee may conduct an executive session in accordance with law and Commissioner’s regulation. Any member of the Board of Education who is not a member of the Audit Committee may be allowed to attend an executive session if authorized by a resolution of the Board of Education.

The Audit Committee shall prepare minutes of each meeting. At a minimum, the minutes will include the following:
• Copies of the meeting agenda
• Date, attendance and location of the meeting
• As appropriate, brief summary of the topics discussed
• Except as otherwise provided by law in connection with executive session, copies of materials discussed or presented at the meeting
• A record of all actions or recommendations agreed to by the committee

All decisions shall be reached by consensus of those members present at the meeting. Consensus is defined as an acceptable solution that all can agree to support. If consensus cannot be reached, polling of the voting membership will take place and simple majority will rule. A quorum constitutes a simple majority of the total membership and meetings will not be conducted unless a quorum is present. All decisions shall be reached by vote of a simple majority of the total membership.

The Sachem Audit Committee has the duty and responsibility to report its activities to the Board of Education. Periodic written reports of Audit Committee activities are an important communication link between the Audit Committee and the Board on key decisions and responsibilities. The Audit Committee’s reporting requirements are to:

  • Report on the scope and breadth of committee activities so that the Board of Education is kept informed of its work.
    • Provide minutes of meetings which clearly record the actions and recommendations of the Committee.
    • Report on their review of the District’s draft annual audit report and accompanying management letter and their review of significant findings and recommendations of the internal auditor.
    • Report on suspected fraud or abuse or material defects in the internal control systems.
    • Report on indication of material or significant non-compliances with laws or District policies and regulations.
    • Report on any other matters that should be disclosed to the Board of Education.


The Sachem Audit Committee shall assess and report to the Board of Education on the adequacy of this Charter no less than an annual basis or as necessary. Charter modifications, as recommended by the Audit Committee, should be presented to the Board of Education in writing for their review and action.

Adoption date: January 20, 2010



6700 PURCHASING: Click the link to the left to view revised policy 6700




                                         PURCHASING AUTHORITY

The Board of Education shall designate an individual as Purchasing Agent for the school district. Under the general supervision of the Superintendent of Schools or his/her designee, the Purchasing Agent will be responsible for administering all purchasing activities and ensuring the quality and quantity of purchases made by the district. Only the Purchasing Agent may commit the district to a purchase. In the absence of the Purchasing Agent, the Purchasing Technician may sign purchase orders acting as alternate Purchasing Agent

Upon the recommendation of the Superintendent of Schools, the Board of Education has approved the following: Catherine Nocco has been appointed School Purchasing Agent, and is authorized to purchase supplies and equipment and services as provided for in the budget. In the event Ms. Nocco is absent, Nancy Merkle, Purchasing Technician, act as an alternate Purchasing Agent. (Comm’s. Reg. 170.2)

All purchases shall be made through the Business Office by the Purchasing Agent or his/her designee, subject to the approval of the Superintendent or his/her designee.

The Purchasing Agent is authorized to issue purchase orders without prior approval of the Board when formal bidding procedures are not required by law and budget appropriations are adequate to cover such obligations.

The Purchasing Agent shall select, along with the requisitioner, quality materials, equipment, supplies, and/or services which shall be sufficient to complete the function for which the requisitioned items will be purchased.

The Purchasing Agent shall be responsible for preparing all bid specifications and a statement of general bidding conditions to be included in every notice or invitation to bid. The requisitioner shall be responsible to provide an adequate description of the item(s) as required by the Purchasing Agent in order that the Purchasing Agent may be able to prepare the specifications and make procurement in the most expeditious and economical manner. If there are questions concerning specifications, the Purchasing Agent will consult with the requisitioner to clarify the matter so as to ensure that the appropriate goods or services are obtained. The Purchasing Agent shall make alternate suggestions to the requisitioner if, in the judgment of the Purchasing Agent, the specifications are inadequate for the intended task or the procurement of the desired commodity and/or service could be provided more expeditiously or economically.

The Purchasing Agent shall be responsible for determining whether a proposed substitution by a low bidder as an equal product or service is, in fact, equal. Such decision shall be based on his/her evaluation and that of the requisitioner. In the case of disagreement between the requisitioner and the Purchasing Agent, either party may refer the matter in accordance with established procedure.

Ref: Education Law §1709(20-a)

Adoption date: February 10, 1998
Revision date: September 21, 1999
Revision date: February 24, 2010




                                        BIDDING REQUIREMENTS


The Purchasing Agent has the authority to prepare, advertise and openbids for all purchase contracts and contracts for public work, if formalcompetitive bidding is required by Section 103 of the General MunicipalLaw.

The Purchasing Agent, subject to approval of the Superintendent ofSchools, will be responsible for the development and administration ofregulations for the competitive purchasing of goods and services by theschool district in compliance with the requirements of the GeneralMunicipal Law.

The purpose of such procedures shall be to ensure that the districtreceives the specific goods and/or services required at the lowest costavailable. The Board of Education believes that the acceptance of bidsfor goods or services from non-responsible vendors or suppliers is aquestionable use of district resources, even when such inferiorgoods orservices are offered at the lowest cost.

Bid specifications shall be specific enough to permit as precise anevaluation and comparison of various products and/or services aspossible. Contracts for products and/or services shall be awarded to thelowest responsible bidder whose product and/or service meets or exceedsthe specifications of the district.

Cross-ref 6700, Purchasing
6731, State Contracts
6740, Purchasing Procedures
7360, Construction Contracts, Bidding and Awards

Ref: Education Law §§1619; 1725; 1725-a; 2513; 2556
General Municipal Law §§100; 103, 103-d; 103-e; 104; 104-b; 105;
Correction Law §184
State Finance Law §§163; 175-a; 175-b
Local Finance Law §§20.00; 135.00
Abco Bux v. Macchiarola, 75 AD2d 831, dissenting opinion, reversed on dissent, 52NY2d 938 (1981)
Exley v. Village of Endicott, 51 NY2d 430 (1981)
Gerzof v. Sweeney, 22 NY2d 297 (1969)
Jered v. NYC Transit Authority, 22 NY2d 187 (1969)
Randolph McNutt v. Eckert, 257 NY 100 (1931)
Hauger v. Earl, 275 AD 437 (3rd Dept., 1949)
Hurd v. Erie County, 34 AD2d 289 (1971)
Orange Front Paint v. Scaramuccia, 59 AD2d 894 (1978)
Progressive Dietary v. Wyoming County, 90 AD2d 214 (1983)
Tufaro v. Bd. of Education, 79 AD2d 376 (1981)
Varsity Transit v. NYC Bd. of Ed., 130 AD2d 581 (1987)
Matter of Jester, 1 EDR 259 (1959)
Executive Order No. 170, Establishing Uniform Guidelines for Determining the Responsibility of Bidders, Executive Chamber, 1993
9 Op. St. Compt. 1953, p. 421
Op. St. Compt. 81-224
Op. St. Compt. 83-22
Op. St. Compt. 86-19; 86-25
Op. St. Compt. 87-46

Adoption date: February 10, 1998  



                                      COOPERATIVE PURCHASING


The Board of Education endorses the concept of cooperative purchasing when such method is in the best interest of the school district. The Purchasing Agent designated by the Board is authorized to explore the possible participation by the school district in cooperative purchasing ventures with other school districts and municipalities. All proposals and contracts for cooperative purchasing ventures shall be submitted to the Board for consideration and approval.

Ref: Education Law §1950
General Municipal Law §119-o

Adoption date: February 10, 1998



                                               STATE CONTRACTS

Whenever it is feasible and in the best interests of the district, purchases of materials, supplies or equipment (except printed material), in excess of five hundred dollars ($500), shall be made through New York State and County Government contracts. The district will adhere to the requirements of the State Finance Law in the purchase of any suitable products or services (as determined by the Commissioner of General Services) which are manufactured, assembled, produced or provided by the blind or other severely disabled persons from approved, qualified charitable or nonprofit-making agencies. The district must purchase any suitable products which are manufactured or prepared by prisoners in the state correctional institutions and penitentiaries, pursuant to Correction Law §184.

Cross-ref: 6720, Bidding Requirements

Ref: General Municipal Law §§103(30); 104; 109-a
State Finance Law §§175-a; 175-b
Correction Law §§184; 186

Adoption date: February 10, 1998



                                       PURCHASING PROCEDURES


6740 Purchaing Procedures: Please View the Link on the Left for the Revised Purchasing Procedures






                                          PAYMENT PROCEDURES


The Associate Superintendent for Business shall prepare a schedule of bills which have been properly documented for payment. This schedule shall be presented to the Board of Education and the Internal Auditor for review and approval on a weekly basis.

Payment of any claims against the district shall be made only upon verification of the following:

1. the claim is the result of an authorized purchase;
2. the receipt of goods and services, for which the claim has been submitted, is verified by an authorized district employee;
3. the claim is calculated properly and complies with all applicable contractual agreements and conditions; and
4. proper accounting procedures have been followed.

The Associate Superintendent for Business shall establish the necessary procedures and forms for the prompt, efficient and responsible processing of claims for payment.

Ref: Education Law §§1709(20-a); 1718; 1719; 1720; 1804; 1950; 2122; 2523; 2524; 2526; 2554(2-a); 2562; 2580
Office of the State Comptroller--Fiscal Management Guide

Adoption date: February 10, 1998
Revision date: September 21, 1999
Revision date: February 24, 2010