Meeting Overview and Adoption of Minutes
Facilitator Dick Withycombe reviewed the objectives of this meeting: to complete the committee’s review of the draft donations procedure and to plan stakeholder engagement strategies. The committee also adopted as submitted the minutes of their November 14 meeting.
Review of Draft Donations Procedure
The committee continued its review of the first draft of a revised procedure for implementing the donations policy, prepared by District Director of Athletics and Activities Jeff Lowell and Director of Finance and Budget Marie Telecky and based on the committee’s earlier discussions. The portion reviewed today is attached, as further revised to reflect committee input and with excerpts from that discussion.
Application of Donations Procedure to BSF and PTSAs
Executive Director of Schools John Harrison told the group that Policy 6115 Bellevue Schools Foundation is under review, to make sure it serves both BSF and the district well. The people involved are considering adding specifics to the policy or creating an accompanying procedure, and they have decided that, until that process is complete, BSF should follow the donations policy. John therefore suggested deleting a sentence added November 14 to the last paragraph of the first section of the donations procedure: “Additionally, receipts for Bellevue Schools Foundation funded programs (grants) are not considered donations.”
Currently, the district does not have a policy that specifically addresses grants. John said the board policy committee is considering adding a section to Policy 6110 Sources of Revenue to cover them. The board is aware of the issues, and John’s expectation is that the new provision will both clarify the distinction between donations and grants and provide direction with respect to BSF and PTSAs. Until something changes, he suggested both BSF and PTSAs follow the donations procedure.
The group discussed a variety of related issues, including:
- the distinction between optional grants to schools or the district (e.g., from the National Science Foundation) and the grants PTSAs give to individual teachers;
- the fact that BSF and PTSAs are “partner organizations” and the district has an interest in not imposing an onerous process on them;
- the importance of following our own procedures, of doing what we say we’re doing;
- being careful about naming organizations in the procedure because there are differences among schools;
- whether there are significant differences among schools and, if so, whether school-based organizations should be encouraged to adopt a common model for raising funds to support school programs and activities; and
- a preference for simply saying the rules apply to all groups and working to support full implementation, which would include consequences for not following the rules, as well as training.
Jeff reminded committee members that the board has invited them to identify additional issues and suggested that this may be one area the committee wishes to bring to the board’s attention. However, for now the discussion has been set aside pending the work underway on these two related policies.
Next Phase of Work
The next step in the revision of the donations policy and procedure is to review them in their entirety to make sure they respond fully to the board’s charge to the committee, including the questions added in the “Donation Policy Committee Charge Clarification.”
Dick summarized the discussion about this next phase of the committee’s work, saying that the conversation suggested a disconnect between the work already done and the questions the board posed in September, when asked for clarification. If so, the solution is to evaluate the policy and procedure revisions in light of those board questions and to formulate recommendations that address any remaining issues, taking into account concerns about placing constraints on partner organizations that are not directly related to the district’s donation policy interests. He said he can envision two report components: the revised policy and procedure and also a set of recommendations that respond to the board questions but, in the opinion of the committee, fall outside the donations policy framework.
To support the next conversation, at the January 3 meeting, Jeff and Marie will provide information and documents from other school districts that address anticipated topics, based on today’s discussion.
The Donations Policy Committee will meet Wednesday, January 3 (3:00 p.m. to 5:00 p.m.) in the district office. In addition to reviewing work to date in the framework of the clarified board charge, the committee will prepare to provide a progress report at the January 8 districtwide PTSA meeting and discuss what additional stakeholder engagement would be appropriate.
Draft Procedure 6114P
Tangible Personal Property (Equipment and Materials)
For donations of tangible personal property (equipment and materials) to a particular school or to the District as a whole, the Donation Acknowledgment Form for Tangible Personal Property (Procedure 6114P – Exhibit B) must be completed and sent to the office of the Deputy Superintendent of Finance and Operations with the appropriate departmental and/or school approval included.
“Appropriate approval” refers to the level of approval required based on the value of the property.
These forms will be filed and stored in the office of the Deputy Superintendent of Finance and Operations.
For example, the Technology Department reviews and approves/denies donations of computers and computer-related equipment; the Facilities Department reviews and approves/denies donations of playground equipment; and the Curriculum Department reviews and approves/denies donations of books and teaching-related material. In all cases, where a particular school is directly impacted, the Donation Acknowledgment Form for Tangible Personal Property (Procedure 6114P – Exhibit B) will also be sent to the principal for review and approval/denial.
In approving the donation of equipment and material, reviewers will take note of the donation’s suitability and durability and any possible health or safety hazards. If the equipment and/or materials are found to be unsuitable, the principal or department representative will indicate the reason(s) in writing. If found to be acceptable, and if the item(s) need to be installed, the benefiting department or school will submit a work order for appropriate installation.
Donations of tangible personal property must satisfy the following criteria:
- The purpose or use is consistent with philosophy and programs of the
- The district will assume only a minimum financial obligation for installation, maintenance, and
- The equipment will be free from health and/or safety
- The equipment will be free from a direct or implied commercial endorsement except as outlined in Procedure 6102P – District Fundraising Activities: Contests, Advertising, and Promotions.
- Pass-through donations of tickets or other similar items (such as school supplies, reading aids, baseball tickets, etc.) must be appropriate for students and enhance the District’s mission and programs. (Note: nominal classroom supplies provided by parents are considered to be outside the scope of this )
- Administrative Procedure 3515P: Student Incentives provides guidance regarding student awards, prize values, donations and defines de Minimis values for such items.
Note: donations of tangible personal property are considered valid only when all appropriate approvals have been received.
Note: the Donation Acknowledgment Form for Tangible Personal Property (Procedure 6114P – Exhibit B) states that the District shall not make any attestations as to the fair market value of a donation of tangible personal property. Establishing a deductible value for tax purposes is solely the responsibility of the donor and his/her tax advisor.
All donations become the property of the District. The District will make reasonable efforts to accommodate the intended purpose and use of the donation but reserves the right to utilize, relocate, and/or dispose of the donation, as it deems appropriate.
Notification of donations of tangible personal property valued at or above $10,000 will be provided to the Board in the consent agenda.
- If the district accepts a donation of tangible property, it is responsible for all associated costs (e.g., installation, insurance, fuel, repairs).
- The district would prefer to solicit cash donations and use those funds to purchase exactly what schools need.
- Replacing “substantial” with the specific notification threshold aligns this section with the previous one pertaining to cash donations; in both cases, notification will be in the consent agenda.
Donations to Benefit Students Individually
Any donation intended to benefit students individually must be recorded in the Private-Purpose Trust Fund of the District, and the Board must formally agree to honor the intent of the donor. Often such donations become a scholarship or student support fund for the purchase of services or goods that would be donations of public funds if purchased with General Fund money.
The Business Office will work with the donor to draft the appropriate Private-Purpose Trust Fund documents to send to the School Board for approval. Any accounts or funds set up within the Private-Purpose Trust Fund must address:
- Whether the fund is expendable, (principal and interest can be disbursed) or non-expendable (only the interest can be disbursed).
- The configuration of any decision-making group involved in deciding how the funds are to be spent (e.g., a scholarship committee).
- In no case may a donor designate the recipient of the donation except as a member of the decision-making group involved in deciding how to spend the funds.
- The criteria upon which to base the disbursement decision.
- The types of items that are allowable purchases.
- Provision for any changes in scope over time (e.g., increase in scholarship award amounts).
- How to close out the account (e.g., when the account reaches a specific threshold) and what is to be done with any remaining
On an annual basis, the Business Office shall review each Private-Purpose Trust Fund agreement with the school or department engaged in fund management to ensure each school or department maintains the terms of each agreement.
- A new fund, new donor, or new purpose requires approval by board resolution, rather than inclusion in the consent agenda.
- This part of the procedure was revised last year, in the process of cleaning up old funds.
- How many private-purpose funds are there? There are about 15 such funds.
Rejection of Donations
- Any rejected donation of cash, cash equivalents, or tangible personal property valued at less than $1000 will be documented by the Principal of the school or District department supervisor through a written statement to the prospective donor. The statement must include the amount of the donation, the reason for the rejection, and if applicable any remedy that would allow the school or District department to accept the prospective donation. The statement must be forwarded to the Deputy Superintendent of Finance and Operations’ Office for copying and retention.
- If the prospective donation or donation is $1,000 or above, the rejection must be reflected on the appropriate form (either the Donation Agreement Form for Cash and Cash Equivalents (Procedure 6114P – Exhibit A) or the Donation Acknowledgment Form for Tangible Personal Property (Procedure 6114P – Exhibit B)). In addition, the Principal of the school or District department supervisor will attach a written statement to the form. The statement must include the reason for the rejection, and if applicable, any remedy that would allow the school or District department to accept the prospective donation. The form and statement must be forwarded to the Deputy Superintendent of Finance and Operations’ Office for copying and retention.
Disposition of Donation Agreement Forms
The Deputy Superintendent of Finance and Operations’ Office produces copies of the Donation Agreement Form for Cash and Cash Equivalents (Procedure 6114P – Exhibit A) and the Donation Acknowledgment Form for Tangible Personal Property (Procedure 6114P – Exhibit B) after receipt of all required approvals or denials. Copies are provided to the donor, the Business Office, and the school or district department receiving the donation within 30 business days of the final determination. The Deputy Superintendent of Finance and Operations’ Office retains the original copy of each form.
This revision specifies the timeframe for final notification.