adjusting to change: a legal and legislative update resa 7 – 2010 administrators forum august 9,...
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Adjusting to Change: A Adjusting to Change: A Legal and Legislative Legal and Legislative UpdateUpdate
RESA 7 – 2010 Administrators ForumRESA 7 – 2010 Administrators ForumAugust 9, 2010August 9, 2010
Howard Seufer, Jr. Howard Seufer, Jr. [email protected] 304-347-1776 304-347-1776
The Education Law GroupThe Education Law Group at Bowles at Bowles Rice McDavid Graff & LoveRice McDavid Graff & LovePrimary Attorneys
Greg Bailey - Morgantown
Rick Boothby - Parkersburg
Howard Seufer - Charleston
Rebecca Tinder - Charleston
Kim Croyle - Morgantown
Ashley Hardesty - Morgantown
Legal Assistants
Sarah Plantz - Charleston
Dianne Wolfe - Parkersburg
Adjunct Attorneys
Gene Bailey - Prevailing Wage
Bob Bays - Eminent Domain
Rick Brown - Employee Disability
Joe Caltrider - Personal Injury Defense
Pat Clark - Contracts
Mark D’Antoni - Real Estate
Carl Fletcher - Building Construction Disputes
Kit Francis - Creditors Rights
Jill Hall - Employee Benefits
Bob Kent - Personal Injury Defense
Ellen Maxwell-Hoffman – Ethics
Edd McDevitt – Bonds, QZABs & Levies
Marion Ray - Workers Compensation
Lesley Russo – Employee Benefits
Cam Siegrist – Finance
Beth Walker - Wage & Hour
Ken Webb - Construction Litigation
Our AgendaOur Agenda
Some school law resources to help you keep up-to-date all year long
An overview of new legislation affecting public education in West Virginia
Recent decisions of the courts impacting public education
Recent Significant Public Employees Grievance Board decisions
Some School Law Resources To Some School Law Resources To Help You Keep Up-to- Date All Help You Keep Up-to- Date All Year LongYear Long
““School Laws of West Virginia”School Laws of West Virginia” Beware! The latest edition and its CD-ROM are
already out of date! Current versions of the new statutes are typically
available at the West Virginia Legislature’s website shortly after they go into effect
Once the Governor signs bills enacted by the Legislature and we have carefully reviewed them, we post on the Bowles Rice website (www.bowlesrice.com),and send to people on our eNewsletter list, summaries of new education-related legislation with active links to the House and Senate bills
E-Newsletter Mailing ListE-Newsletter Mailing List E-Newsletter Mailing List Send an email to Sarah Plantz:
[email protected] Tell Sarah:
Who you are Your position in public education Your school board’s name That you want to receive the E-Newsletter
Is There a Doctor in the House? Serious Student Health Care Issues in the Public Schools September 15, 2010 – Charleston
By the Book: The Fundamentals of Professional and Service Employee RIFs, Transfers and Non-Renewals November 3, 2010 -- Charleston
Beyond the Basics: Sticky Issues Involving Professional and Service Employee RIFs, Transfers, and Non-Renewals November 4, 2010 -- Charleston
Signature Series E-Invitation ListSignature Series E-Invitation List Signature Series E-Invitation List Send an email to Sarah Plantz:
[email protected] Tell Sarah:
Who you are Your position in public education Your school board’s name That you want to receive Signature Series E-
Invitations
Caution!Caution! These materials are presented with the
understanding that the information provided is not legal advice
The law changes. Information contained in this presentation may become outdated
Before using this information, always research original sources of authority and update the information to ensure accuracy when dealing with a specific matter
No person should act or rely upon the information contained in this presentation without seeking the advice of an attorney
An Overview of New Legislation An Overview of New Legislation Affecting Public Education in Affecting Public Education in West VirginiaWest Virginia
Handout, pages 1-21
Despite What You May Have Heard, These Bills Did Not Pass in the Regular
Session or Were Vetoed Revising the professional vacancy-filling provisions
of W. Va. Code § 18A-4-7a Creating calendar committees in each county Authorizing a four-day school week Preventing a professional educator from taking a
coaching position away from a citizen coach Restoring the “old” personnel action deadlines Authorizing use of retirees as substitute teachers for
more than 140 days per year
Seven Categories of LegislationSeven Categories of Legislation
A. PersonnelB. Quality InstructionC. StudentsD. Public OfficialsE. FinanceF. BusinessG. InsuranceH. RetirementI. Miscellaneous
House Bill 3152
Can’t be an “athletic trainer” without registering with WV Board of Physical Therapy
Grandfather clause: Secondary school trainers practicing under State Board policy before July 1, 2011
Board of Physical Therapy regulates and polices registered athletic trainers
House Bill 3301
Misdemeanor: not keeping, at place of employment, proof of employee status. $100 per offense.
Labor Commissioner can order employer to produce records verifying workers legal employment status
Failure to produce records in 72 hours: citation “prominently presented” to magistrate or Circuit Court judge
House Bill 4512
Each service personnel posting Work site Starting and ending times
Each aide classification posting Program or primary assignment of position
“Director or Coordinator of Services” Can’t be “exclusively assigned to perform the
duties of any other class title” Can be multi-classified
House Bill 4512
School Bus Supervisor Must be or have been certified to operate a bus After July 1, 2010, a person first employed with
the class title must have five years experience working in a county board’s transportation department as a bus operator, or bus aide, or mechanic, assistant mechanic, or chief mechanic, or clerical employee
House Bill 4512 “Itinerant Status”
“A service person who does not have a fixed work site and may be involuntarily reassigned to another work site” Does not include a worker assigned to a beginning and
ending work site who, at county expense, travels during the daily schedule
Obtained only by bidding or agreeing to accept Only allowed
for aide and autism mentor classification categories, and if job duties involve exceptional students
House Bill 4512 (Itinerant status)
Itinerant status employee may be assigned to a different work site without posting or consent with 10 days prior notice Involuntarily, only 2 times per school year
At end of school year, must post positions that have been filled, without posting, by an itinerant
Bus operator certification test frequency Substitutes and probationary: annually Continuing contract, retiree subs with 10 years
regular experience: triennially
Senate Bill 183 Generally prohibits driver or owner from causing
engine to idle more than 15 minutes in any 60 minute period Diesel vehicles with GVW over 10,000 lbs.
18 exceptions Highway traffic or control Prevent safety/health emergency with defroster or air
conditioner (not a rest period) Installing equipment Manufacturer’s requirement or warranty Required for maintenance or federal/state inspection Maintain adequate temperature for passengers on board Queuing up off school grounds to pickup or discharge
students, and required by physical configuration
Senate Bill 183
Owner or operator of location where vehicles load or unload, or that provides more than 15 parking spaces for such vehicles: must post permanent sign
Violations of Act: misdemeanors with $150-300 fine
Senate Bill 396
Bus operator must have appropriate DMV license and comply with Uniform Commercial Driver’s License Act and State Board rules
Must surrender old license to renew or get duplicate with updated information from DMV
DMV must suspend license of CDL holder when another state or jurisdiction reports a failure to pay fines or appear for violation of state or local traffic laws
Senate Bill 396
Increased fine on employer that allows or requires driver of commercial vehicle to violate any RR highway grade crossing law Was $10,000 Now $25,000
Longer disqualification period for operating commercial vehicle after conviction for violating out-of-service order And greater fine and civil penalty
Senate Bill 2006School Committees & Teams
(In Effect July 21, 2010)
Enacted at the Special Session in July
Senate Bill 2006 State Board to study each school team and
committee created by state law or policy Assess time and paperwork requirements Consider alternatives
A school may apply to replace or augment its strategic planning committees, technology team, and/or school support team Application State Board to approve after faculty senate, LSIC,
county superintendent and county board approve Appeals process if county superintendent or
board disapprove
House Bill 4040 Eliminates August 26 and June 8 limits on
beginning and end of instructional term Each board must have an “icy conditions and
emergencies plan” to guarantee 180 days of instruction
HB 4040 does NOT change requirements that the instructional term fall within 200-day minimum
employment term, and the 10-month minimum employment term for
service personnel fall within 43 weeks
House Bill 4436 “Process for Teacher Collaboration to
Improve Instruction and Learning” Established by faculty senate, with principal’s
approval as either an alternative, or in addition to, the school curriculum team
Mission: Review student performance with multiple measures Identify strategies to improve it Make recommendations for improvement to be
implemented if principal approves Members: faculty senate selects
House Bill 4436
State Board-provided optional testing and assessment instruments School may use with approval of school
curriculum team or the teacher collaborative process
School cannot be cited, nor can principal in his/her evaluation, for exercising discretion in using them (or for implementing instructional strategies & programs the school determines best to promote student achievement)
House Bill 4436 School curriculum teams may apply for
waivers from: policies requiring that students be assessed using
a specific assessment except WESTEST2, Alternative Performance Task
Assessment, Online Writing Assessment, and NAEP policies requiring a specific instructional strategy
or program to achieve content standards for courses required by the State Board
approved and adopted instructional resources if the team judges that resources best suited to teach school’s curriculum aren’t available through the normal adoption process
House Bill 4436 Revised element of process for improving
education A “system of accountability for continuous
improvement” High quality standards to build capacity to meet
rigorous outcomes Additional trigger for low performing school
status When the most recent statewide assessment in
reading and math, or other multiple measures determined by the State Board, show that school was low performing at its programmatic level in 3 of the last 5 years
House Bill 4436 Team of consultants for low performing
school now comes from the “WV Department of Education State System of Support” No longer a 60-day deadline to make
recommendations for correction No longer must State Board approve team’s
recommendations County board has one year (not 6 months) to
make satisfactory progress Additional time possible A failure to make satisfactory progress = temporary
approval status
House Bill 4669Statutory Exceptions for
Certain Innovation Zones(In Effect June 9, 2010)
Handout, Page 10
House Bill 4669 The Legislature grants exemptions for State
Board-approved innovation plans Piedmont Elementary (Kanawha County)
Planning period statute, class size statute Putnam County Secondary Schools Consortium
School calendar statute Nellis Elementary (Boone County)
LSIC statute Cabell County Secondary Schools
Compulsory attendance statute; beginning teacher internship statute
House Bill 4669
An approved exemption automatically ends if purpose for exemption is changed by plan
modification or implementation, or State Board withdraws plan or revokes zone
Senate Bill 631
The textbook adoption process is altered “Textbooks” are now “instructional resources”
and include electronic resources and resources that are updated on an ongoing basis
Adoption cycle: a single 6-year limit within which State Board schedules periods of adoption
County “instructional resource adoption committees” may request waivers of the adoption cycle
Senate Bill 631 Without having to comply with adoption
procedures, counties may, to supplement items on the state multiple list, purchase software print and electronic magazines print and electronic newspapers other electronic periodicals licensed or subscription-based resources
Excess levies for “textbooks” now cover software electronic periodicals print and electronic magazines & newspapers
Senate Bill 631 With State Board approval, counties may,
before the end of a contract period, choose not to renew an electronic instructional resource and replace it with another from the official multiple listing
Vendors, with notice to the State Board, may change and update the navigational features and content of adopted electronic resources
Vendors must continue to support adopted versions & cannot require purchase of a new operating system
Senate Bill 631
State Board may create a standing committee for each subject and grade level to review new or revised instructional resources submitted after the initial approvals for adoption
With agreement of all RESA county superintendents, a RESA instructional resources team (with representatives of all the RESA counties) may review resources on the multiple list and make recommendations to each superintendent for
consideration and adoption by each county board
Senate Bill 631
Equity: If a county adopts electronic instructional resources, it must: ensure equity of access to all students have a plan to provide equity of access at home, if
necessary, through alternate avenues such as print software hardware support
Senate Bill 2009Pilot Programs to Increase
Academic Achievement(In Effect July 21, 2010)
Enacted at the Special Session in July
Senate Bill 2009 State Superintendent to establish one 5-year
“special community development” pilot program in one public school with significant enrollments of disadvantaged, minority, and underachieving students
Pilot school to collaborate with Higher education organizations State Board
Goal: Develop and implement strategies that could be replicated in other schools
House Bill 4223 Increased penalties for overtaking and passing a
stopped school bus 1st offense: $150-300 fine and/or up to 6 months in jail;
mandatory license suspension for 30 days 2nd offense: $300 fine and/or up to 6 months in jail;
license suspension for 90 days 3rd and additional offenses: $500 fine, at least 24
hours (and up to 6 months) in jail; license suspension for 180 days
Willful violations Serious injury: Felony. $500-2,000 fine; 1-3 years in
prison Death: Felony. $1000-3000 fine; 1-10 years in prison
House Bill 4223
Driver, not owner, may be charged Boards are authorized to mount a camera on
any school bus to help enforce the law State Police must publicize new provisions of
law But only to the extent of available funds
House Bill 4593 The “High School Graduation Improvement Act”
Shift in focus from compelled attendance to programs that engage and inspire students
Increased age for compulsory attendance Until the 17th birthday (rather than the 16th) Effective with the 2011-2012 high school freshman
class Exemption for high school graduation is
amended Now includes completion of an alternate secondary
program approved by State Board
House Bill 4593 Commits State of West Virginia to
Continue exploring instruction delivery strategies to accommodate different learning styles
Focus on statewide dropout intervention and prevention for students who have academic difficulty
Statewide credit recovery program, to include virtual schools
Establish up to 5 more juvenile drug courts Invest in programs to engage disconnected and
discouraged student
House Bill 4593 Directs State Superintendent and Board to:
Pursue GED Option designation for state, then implement program for students in high school to pursue
GED diploma offer the GED option at Mountaineer Challenge
Academy Expand Techademics (subjects and available
credit) and HSTA (to any school with any grades of eligible students
Provide dropout information to Mountaineer Challenge Academy
House Bill 4593 Requires each county board to:
Develop a plan for using available funds to implement the intent of the new Act
Include in its alternative ed. program a plan, to be approved by the State Board, with strategies to Increase the graduation rate Identify at the earliest possible age students at risk of
dropping out Provide more options for delivering academic credentials and
career-technical training to interested at-risk students (examples in statute)
Students at grade 9 and higher at risk of dropping out may be allowed in career and technical education programs that only accept students in certain upper grade levels
Senate Bill 533Revising Statutory Language
Related to Child Abuse(In Effect June 11, 2010)
Handout, Page 16
Senate Bill 533
Technical correction ensures that parents, guardians, custodians, and persons in positions of trust can be convicted of abuse not only for procuring a person to engage in sexual exploitation of a child, but also for allowing that to occur
Senate Bill 2010Pilot Programs for Alternative Schools in Elementary and
Middle Schools(In Effect July 21, 2010)
Enacted at the Special Session in July
Senate Bill 2010 Goal:
Remove disruptive students from the regular classroom
Make it possible for them to return without further disruptive behavior
State Board must amend alternative education policy to add uniform definitions of disruptive student behavior standards for placing students in alternative
settings or other intervention
Senate Bill 2010
State Board to establish five pilot projects elementary or middle schools or both employ alternative schools or other placements
for disruptive students to learn appropriate behaviors
reports to State board and Legislature will gauge effectiveness of projects in maintaining student discipline
Senate Bill 391 2009 legislation barred school board
candidates and members-elect from: also being employed by the board on which they
seek to serve running for or holding any other public office being a candidate for or serving as an elected
member of a political party executive committee being a candidate for or serving as a delegate or
alternate to a national political convention Soliciting or receiving political contributions to
support or retire campaign debt of a candidate for partisan office
Senate Bill 391
Senate Bill 391 repealed those rules as to candidates and members-elect
Note: However, sitting school board members are bound by all those restrictions
House Bill 4031
Keeps state aid formula RESA allowance at .63% of allowance for professional educators
Caps the RESA allowance at $3,990,000 instead of $4,200,000
Authorizes State Board to decide distribution to RESAs
House Bill 4037
Allows entities with bonding authority to issue federal subsidy bonds, including some Build America Bonds under the American Recovery and Reinvestment Act of 2009
Exempt from West Virginia tax Issuing agency may elect to receive periodic
credit payments from the U.S. Treasury to offset interest paid on bonds and pay future debt service
House Bill 4211Funding of Programs for Limited English Proficient
Students(In Effect June 9, 2010)
Handout, Page 3
House Bill 4211
Appropriations funneled through the State Department to supplement required programs for LEP students must be used by counties to supplement the cost of programs for which they have insufficient funds
State Department must consider the proficiency levels of student and a county’s capacity to deliver needed programs
Counties must apply for funding
Senate Bill 229
Allows the SBA to have $500 million in bonds outstanding at any one time
Excludes certain bonds from the $500 million calculation
Senate Bill 237 Certain county boards may issue revenue
bonds secured by and payable only from lottery revenue
To be eligible, a county board must be in a county that has adopted the Local Powers
Act, and in a county that has a racetrack that has
participated since January 2, 1991, in the W. Va. Thoroughbred Development Fund, and
receiving lottery revenues.
Senate Bill 401
Adjusts the calculation of available local funds under the state aid formula’s calculation of local share to account for any final decision of a Board of Assessment Appeals to refund or credit property taxes paid in prior years
Senate Bill 547
Corrects an inconsistency in the date when a county board must meet as a levying body if a levy is on the ballot for the primary election The March 7-28 meeting window and the
resumption of the levying meeting on the third Thursday of April, are postponed so that the board may lawfully meet before June 1
Senate Bill 548Boone County Board of Education Meeting as a
Levying Body(In Effect February 26, 2010)
Handout, Page 16
Senate Bill 548
Gave extra time (until May 28) to the Boone County Board, in 2010, to meet as a levying body, set the levying rate, and certify its actions
Purpose: To allow time for the Board to submit an excess levy renewal to the voters Unless renewed, the levy would expire on June
30, 2010
House Bill 4359Local Labor for Public Construction Contracts
(In Effect June 9, 2010)
Handout, Page 4
House Bill 4359
Old West Virginia Jobs Act: On public improvement construction projects of $1
million or more, 75% of the employees must come from any West Virginia county or from within 75 miles of the state boarder
Amended West Virginia Jobs Act: On public improvement construction projects of
$500,000 or more, 75% of the employees must come from any West Virginia county or from within 50 miles of the state border
House Bill 4615
Political subdivisions may establish risk pools to insure their workers compensation risk, but only in accordance with regulations to be enacted by the Insurance Commissioner
Senate Bill 573
A county board’s annual audit report will now be published electronically if it discloses misfeasance, malfeasance, or nonfeasance by a public officer or employee
Written notices of the electronic publication go to the school board’s legal authority, the prosecuting attorney, and the Attorney General
Senate Bill 633
School board funds may now deposited in accounts that are periodically swept into multiple federally fully insured deposit accounts through a deposit placement program with full federal insurance
Senate Bill 442Offsetting Certain PEIA
Retiree Premium Increases(In Effect March 13, 2010)
Handout, Page 15
Senate Bill 442
Allows for annual retiree PEIA premium increases to be offset with monies from the Retirement Health Benefit Trust Fund
Senate Bill 446Insurance for Deceased Public
Employees’ Survivors(In Effect June 11, 2010)
Handout, Page 15
Senate Bill 446
Clarifies that deceased public employee’s surviving spouse and dependents may participate only in PEIA comprehensive group health insurance coverage to which the deceased was entitled
Surviving spouse and dependents bear the premium cost
Senate Bill 449
Repeals prior rule prohibiting PEIA from paying for expenses incurred by participants in their first year in connection with a preexisting condition
PEIA enrollment and plan selections may be made only at the time of hire, or during the annual open enrollment period, or when a “qualifying event” occurs
Senate Bill 553Extended Time to Purchase
Full Service Credit(In Effect March 6, 2010)
Handout, Page 17
Senate Bill 553
Extended the time for certain members of the State Teachers Retirement System to purchase additional service credit for service in the Teachers’ Defined Contribution Retirement System
Senate Bill 648Repealing Outdated and
Obsolete Education Code Provisions
(In Effect June 11, 2010)
Handout, Page 19
Senate Bill 648
Repeals outdated and obsolete Code provisions: The West Virginia Share in Your Future Act Certain Teachers Retirement Board provisions
Resolutions
HCR 58: Labor History Week The week following Labor Day
HCR 102: Fostering Innovative Planning Strategies Matching grant program
SR 17: Encouraging a New Approach to Truancy Nicholas and Taylor County Circuit Courts
Recent Decisions of the Courts Recent Decisions of the Courts Impacting Public EducationImpacting Public Education
Handout, pages 22-23
United States Supreme Court
City of Ontario, Californiav.
Quon
(Searching Government Cell Phones)
Handout, Page 22
WV Supreme Court of Appeals
2. State ex rel Marshall County Commission
v.Carter
(Executive sessions aren’t sacrosanct)
Handout, Page 23
WV Supreme Court of Appeals
3. Risslerv.
Jefferson County Board of Zoning Appeals
(The appearance of partiality)
Handout, Page 23
Recent Significant Public Recent Significant Public Employees Grievance Board Employees Grievance Board DecisionsDecisions
Handout, pages 24-35
1. Lanham v. Putnam CountySecond grievance on same claimTime for grieving discrimination
2. Hatcher v. Raleigh CountyDidn’t apply? Can’t grieve selection process
3. Bennett v. Randolph CountyExcuses for untimely grievances
4. Stephens v. Wayne CountyBus operator’s primary employment
5. Jones v. Fayette CountyBus operator’s DUI charge has nexus
6. Midcap v. Fayette CountyDriving board-owned vehicles to & from work
7. Robertson v. Wayne CountyMisclassification; reclassification
8. Wimmer v. Braxton CountyRules re getting paid from two public jobs
9. Schifano v. Monongalia CountyPlanning period work not always teacher’s choice
10. Hoke v. Monroe CountyRetaking service personnel competency tests
11. Shroads v. Hancock CountyBoard member relying upon faulty information
12. Young v. Marshall CountyNo application? Can’t grieve posting or selection
13. Young v. Marshall CountyService personnel preference in consolidations
14. Conrad v. Grant CountyDisciplinary letter detail; off-work misconduct
15. Seeley v. Upshur CountyEvaluations & improvement plans aren’t discipline
16. Brockman v. Kanawha CountyDisciplinary labels; immorality
17. Walker v. Fayette CountyExpanded service personnel duties
18. McMann v. Jefferson CountyHarassment requires more than one incidentBad language toward supervisor = insubordination
19. McMann v. Jefferson CountyCorrectable incompetency?
20. Mullins v. Hancock CountyNo policy changes absent a legal mandate
21. Kirk v. Lincoln CountyEmployee Code of Conduct violationDeference to employer’s judgment on punishment
22. Kimble v. Kanawha CountyHostile or abusive work environment definedNexus misdemeanors may warrant dismissal
23. Clark v. Putnam CountyDiscrimination is a continuing practice
24. Guido v. Harrison CountyLate appointment doesn’t itself warrant reliefAssistant superintendent contract terms
25. Baker v. Pocahontas CountyWhen part-time teachers get planning periods
26. French v. Mercer CountyAdministrator hiring need not be mathematical
27. Prickett v. Monongalia CountyBus operator schedules need not be uniformSeniority needn’t control service transfers
28. Shanklin v. Kanawha CountyPartial RIF: multiclassified service personnel
29. Evans v. Marshall CountyArbitrary and capricious decisions
30. Layne v. Boone CountyBus operators taking insulin
31. Richards v. Kanawha CountyReminders and notices by email
32. Bishop v. Preston CountyProbationary nonrenewals are not disciplinary
Treasurer’s bond
33. Clark v. Wayne County
Policy changes and discrimination theory
34. Lucas and Tucker v. Raleigh County
Summer workers contracted by third party
35. Brewer v. Mercer County
New burden in service nonselection cases?
36. Redd v. McDowell County
Functional demotion
37. Webster v. Wood CountyEvaluations based on matters not observed
38. Ellison v. Fayette County
Extra-duty v. extracurricular service work
39. Hill v. Barbour County
Reclassifications & the non-relegation clause
40. Powell v. Hancock County
When substitute service seniority begins
41. Withrow v. Kanawha County
Put extra service qualifications in the posting
42. Samples v. Kanawha CountyFilling summer professional vacancies; Reprisal
43. Dunlap v. Marshall County
Secretary III v. executive secretary
44. Cottrill v. Gilmer County
Intemperance; cruelty; misdemeanor nexus
45. Eaves v. Wayne County
Two years experience to be autism mentor
46. Eisentrout v. Preston County
Summer school “same assignment” as last summer
47. Stephens v. Wayne CountyNo relief if not “next in line”
48. King v. Hancock County
Offering service substitute assignments in rotation
TSSI systems; calling times
49. Bennett v. Randolph County
Appeal disciplinary suspensions & expulsions one of two ways
Thanks for your input Thanks for your input today!today!
And genuine best wishes for a safe and And genuine best wishes for a safe and successful school year 2010-2011!successful school year 2010-2011!
Red Flag Legal Issues for 2010-11
1. Assignment and use of aides
2. Bullying and harassment
3. Unauthorized use of funds
4. Misconduct outside of school and work
5. Evaluations and improvement plans