Update: It has been pointed out to me that the Financial Procedures document that McCaulley shared as justification below was published in June 2010. It has therefore taken the district 5 years to “comply” with state directive? And just in case the district might argue that no one looked at this, remember that in 2012 the district received its first district wide accreditation. If PTAs had been required at that time to submit this information to the district, the district would have received a finding from AdvancedEd the accrediting agency. At the very least, one would assume that the state would have called them on it before now. This is, in other words, yet more evidence that McCaulley’s “justification” for this request is flawed.
As has been definitively confirmed by nearly every PTA in the district at this point, Dr. Wardynski is ordering principals to require the PTAs at their schools to submit monthly financial reports to Mr. Jason Taylor. As I wrote on Wednesday, PTAs need to respectfully and firmly decline this request.
Yesterday Ms. Laurie McCaulley took to Facebook to share with with her friends and the “Uplifting Huntsville City Schools” group members the following justification for the district’s request.
The Justification for Requesting PTAs Financial Records
In case the screen capture isn’t clear enough, here’s the justification she shared:
Huntsville City Schools is aligning its procedures to comply with the Alabama State Department of Education guidelines for boosters and PTAs/PTOs. Here is the link to the document on the ALSDE website outlining financial guidelines for boosters and PTAs/PTOs. The section that concerns school systems is Section 7 page 2. Please note that the pagination restarts in each section, making it a little tedious to find.
Here is the excerpt for your convenience from the Local School Financial Procedures:
Special Requirements:[sic: “Specific Requirements.”] Parent organizations and booster organizations that maintain financial operations outside the control of the school could create a negative image for the school by failing to maintain proper accounting controls. Accountability for the funds these organizations control includes an agreement that:
a) The organization has obtained an employer identification number from the IRS.
b) The organization provides a report of the annual audit of the organization to the school.
c) The organization makes its financial records available to the school’s auditors and authorized school employees upon request.
d) The organization provides required financial reports.
e) The organization provides proof of a fidelity bond for the treasurer.
f) The organization will not provide any payment or benefit to a school employee (or family member of a school employee) in violation of the State Ethics Law.
This request from HCS was not meant to be intrusive or invasive but one of compliance and transparency.
Please inbox me your concerns, thanks
In other words, Ms. McCaulley is arguing that the district is requesting the PTAs’ financial information because she believes the state is requiring them to request it.
First, I’d like to say thank you to Ms. McCaulley for offering a justification. She appears to be the only board member or central office employee who has done so. For that, she is to be commended, and the rest should be embarrassed. To McGinnis, Wilder, Culbreath and Ferrell, just a friendly reminder: I know that talking to the public is beneath you, but you do actually work for us.
Second, I’d also like to thank Ms. McCaulley for actually linking to the state department document. It is astonishing how often the people leading our schools claim their policies, procedures, and recommendations are based on other requirements or best practices, and yet they then completely fail to ever link to those actual documents. It’s almost as though the leaders of our education system believe reading is bad. (Well, it is dangerous, especially to those in power.)
Since Ms. McCaulley asked us to inbox her with our concerns, and since she said, “please,” I did. Here’s what I wrote.
First, based on the limited reading that McCaulley has quoted from the ALSDE Financial Procedures for Local Schools, I would actually agree with her. It does appear that the ALSDE is requesting districts to financially monitor PTAs’ finances.
I don’t agree that the state has the right to make monitor PTAs’ finances (they don’t), but it does appear this is what the document is saying.
Thankfully, however, my teachers in school taught me how to read a complete document and not just pull out keywords from the document as proof text.
What ALSDE is Actually Requesting
As I beg my students every semester, please, if someone tells you that a document says something, go read that document for yourself. Far too often people will tell you that a document says something, but once you read it for yourself, you’ll see it doesn’t say that at all.
I’ve pulled out the relevant sections of the document below, but please, go read the document for yourself. You should not trust my reading any more than you should trust Ms. McCaulley’s reading.
I have highlighted to two sections that I shared with Ms. McCaulley. Those sections point out that first, it is particularly important to determine if an organization should be considered a “school activity.” If it is a “school activity,” then the six requirements that Ms. McCaulley listed in her post yesterday morning probably apply.
However, if the organization is not a “school activity” then neither the school nor the school district has any jurisdiction over the organization. Here the first relevant section on identifying if an organization is or is not a school activity:
The determination that a particular club or organization is a school activity must be made on a case-by-case basis according to the actual facts and circumstances of the club or organization’s operations at a school. The fact that an organization would not exist without the school it supports has no bearing on determining that the organization is a school activity (Sec. 7, Pg. 1 or Pg. 20 of the PDF).
So just because the PTA would not exist without the school it is affiliated with does not mean that the PTA is a “school activity” according to the ALSDE document.
The Guidelines go on to offer some specific situations under which a PTA may be considered a school activity.
Those guideline for a PTA read:
Parent and parent/teacher organizations provide a vital role in the education of students. In Alabama public schools, the PTA and the PTO are the most common parent organizations. Many parent organizations join a national organization that serves the individual school organizations. Each of the national organizations publishes guidance for the financial operations of the individual school organizations. These organizations must have a separate employer identification number (EIN) and a separate mailing address in order to maintain their own records and accounts outside the control of the school. However, these organizations will become school activities if:
a) Both parties mutually assent to the fiduciary control of the principal,
b) A school employee leads fundraising or maintains the accounting records for the organization.
PTAs Are Not “School Activities”
So, unless the PTA relinquished fiduciary control to the principal, and unless the PTA’s fundraising activities are led by a school employee, the PTA is not considered to be a “school activity” by the Alabama State Department of Education.
Thus if, the PTA is not a “school activity,” the district has no reason to require the PTA to submit its financial records.
If a PTA does submit its financial records, that could be interpreted to mean that the PTA is relinquishing fiduciary control of its funds.
In other words, following the district’s request to review a PTA’s financial records could mean that the district is then responsible for the actions of the PTA.
The justification that Ms. McCaulley has offered for why they are requesting PTAs to submit their financial records does not withstand even a cursory reading of the state’s recommendations.
Per her request, I contacted Ms. McCaulley about this via her inbox.
This was her response:
I find myself wondering if Ms. McCaulley actually read the same document that I read? I believe the state department’s financial procedures are quite clear that unless a PTA has voluntarily given over fiduciary control to the principal of the school, and unless the PTA is using school employees to organize its fund-raisers, the PTA is not a school activity. I don’t see this as an “interpretation” nor as simply my “perspective.” I think the ALSDE is quite clear in what they believe to be the responsibility of the district to oversee.
So, Why? Control of PTAs
Since the justification for the district’s request doesn’t withstand even a cursory reading, why are they asking for these reports? Here are a few possibilities.
- Since the recommendations from the state lay out two specific guidelines for how a PTA can become a “School Activity,” I think that part of the district’s motivation here is to make sure that all of the PTAs actually do become a “School Activity.” Sharing a financial report and surrendering fiduciary control are not the same, but it is certainly a step in that direction. Having fiduciary control of all of the PTAs in the district would certainly benefit the district.
- A significant part of the consent decree calls for a leveling of services across the district. For example, the dance program at Grissom has to be limited so that the dance program at Lee will be “the best.” The Huntsville High Theatre program was likewise limited. While the consent decree does not explicitly call for a leveling of parental funding (because it really can’t call for that), a “leveling” of services is clearly a goal of the decree. The only way this is possible with the PTAs is if the district controls the PTAs.
- I’m convinced that establishing district control over the PTAs and the PTA funding is the primary reason for this “request” to review the PTAs’ finances. While the PTAs have been almost overwhelmingly supportive of Dr. Wardynski (this is particularly true of the Huntsville Council of PTAs and former President and current board member Elisa Ferrell), I believe that to a large extent this support is beginning to waver. Thus, Wardynski has little to lose by attacking the PTAs at this time. If they comply, he gains control of their funds. If they don’t, he can benefit by having the one main voice of Parents and Teachers in this district that is not entirely under his thumb disbanded. (I have heard this possibility discussed among PTA leadership across the district.)
- I think that part of McCaulley’s motivation for supporting this is in the hope that she can discredit the new Johnson PTA president Michelle Lanier-Watkins. Ms. Lanier-Watkins is planning to run against Ms. McCaulley in the upcoming board election, and the district this year lost control of the leadership of the Johnson PTA after seemingly hand picking them a year ago. McCaulley has taken a similar approach to opposition before.
The PTA Response
Honestly, the best response that PTAs can make to this is simply to respectfully decline the request.
The school district has not been ordered by the state department of education to review the PTAs books. (And even if they had been, the response here should still be no.)
There is absolutely nothing to be gained by the PTAs turning over the financial reports, and potentially there is everything to lose. The PTA is a completely separate organization from the school district. Allowing Wardynski to marry their fortunes together will harm both organizations.
So, yes, Ms. McCaulley, this is both intrusive and invasive. And it is not required for compliance nor transparency. The ALSDE Financial Procedures document makes that abundantly clear once we read it.
I would highly suggest and advise that the district do just that and then leave the PTAs alone to do the work they’ve been doing so well for years.