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PURPOSE AND MISSION

Internal audit serves agency administrators and the governing board by furnishing independent analyses, appraisals, and recommendations about the adequacy and effectiveness of TSBVI’s systems of internal control and the quality of performance in carrying out assigned responsibilities.  Texas Government Code 2102.002

The purpose of the Texas School for the Blind and Visually Impaired’s (TSBVI) Internal Audit activity is to provide independent, objective assurance and consulting services designed to add value and improve TSBVI’s operations.  The mission of internal audit is to enhance and protect organizational value by providing risk-based and objective assurance, advice, and insight. The internal audit activity helps TSBVI to accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of governance, risk management, and control processes.  Institute of Internal Auditors (IIA) Model Charter

The purpose, authority, and responsibility of the internal audit activity must be formally defined in an internal audit charter, consistent with the Mission of Internal Audit and the mandatory elements of the International Professional Practices Framework (the Core Principles, the Code of Ethics, the Standards, and the Definition of Internal Auditing).  The Internal Audit Director must periodically review the internal audit charter and present it to senior management and the board for approval. IIA Standard 1000

STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING

The internal audit program shall comply with the Texas Internal Audit Act, the Standards for the Professional Practice of Internal Auditing, the Code of Ethics contained in the Professional Practices Framework as promulgated by the Institute of Internal Auditors, and generally accepted governmental auditing standards. Texas Government Code 2102.011

The internal audit activity will govern itself by adherence to the mandatory elements of The Institute of Internal Auditors' International Professional Practices Framework, including the core Principles for the Professional Practice of Internal Auditing, the Code of Ethics, the International Standards for the Professional Practice of Internal Auditing, and the Definition of Internal Auditing. The Internal Audit Director will report periodically to senior management and the Board regarding the internal audit activity’s conformance to the Code of Ethics and the Standards.

Ten Core Principles articulate what effective internal auditing looks like in practice:

  1. Demonstrates integrity
  2. Demonstrates competence and due professional care
  3. Is objective and free from undue influence (independent)
  4. Aligns with the strategies, objectives and risks of the organization
  5. Is appropriately positioned and adequately resourced
  6. Demonstrates quality and continuous improvement
  7. Communicates effectively
  8. Provides risk-based assurance
  9. Is insightful, proactive, and future-focused
  10. Promotes organizational improvement

The professional standards and guidance contained in Government Auditing Standards, commonly referred to as generally accepted government auditing standards (GAGAS), provide a framework for conducting high quality audits with competence, integrity, objectivity, and independence. These standards are for use by auditors of government entities and entities that receive government awards and audit organizations performing GAGAS audits. GAGAS contains requirements and guidance dealing with ethics, independence, auditors’ professional judgment and competence, quality control, performance of the audit, and reporting. GAGAS 1.04

AUTHORITY

The program of internal auditing conducted by a state agency must provide for the auditor to have access to the administrator; and be free of all operational and management responsibilities that would impair the auditor's ability to review independently all aspects of the state agency's operation. TGC 2102.007

The Internal Audit Director shall report functionally to the board of trustees on internal auditing matters and administratively to the School Superintendent.  The Internal Audit Director must be a certified public accountant (CPA) or a certified internal auditor (CIA) and have at least three years of auditing experience.  The board of trustees shall periodically review the resources dedicated to the internal audit program and determine if adequate resources exist to ensure that risks identified in the annual risk assessment are adequately covered within a reasonable time frame.  Texas Government Code 2102.006The Internal Audit Director will report functionally to the Board and administratively (i.e., day-to-day operations) to the Superintendent. To establish, maintain, and assure that TSBVI’s internal audit activity has sufficient authority to fulfill its duties, the Board will:

  • Approve the internal audit activity’s charter.
  • Approve the risk-based internal audit plan.
  • Approve the internal audit activity’s budget and resource plan.
  • Receive communications from the Internal Audit Director on the internal audit activity’s performance relative to its plan and other matters.
  • Approve decisions regarding the appointment and removal of the Internal Audit Director.
  • Approve the remuneration of the Internal Audit Director.
  • Make appropriate inquiries of management and the Internal Audit Director to determine whether there is inappropriate scope or resource limitations.

The Internal Audit Director will have unrestricted access to, and communicate and interact directly with, the Board and Audit Committee, including in private meetings without management present.

The Board authorizes the internal audit activity to:

  • Have full, free, and unrestricted access to all functions, records, property, and personnel pertinent to carrying out any engagement, subject to accountability for confidentiality and safeguarding of records and information.
  • Allocate resources, set frequencies, select subjects, determine scopes of work, apply techniques required to accomplish audit objectives, and issue reports.
  • Obtain assistance from the necessary personnel of TSBVI, as well as other specialized services from within or outside TSBVI, in order to complete the engagement.

The Director of Internal Audit will have unrestricted access to, and communicate and interact directly with, the Board of Trustees, including in private meetings without management present.

Administrative reporting is the reporting relationship within the organization’s management structure that facilitates the day-to-day operations of the internal audit activity. Administrative reporting typically includes:

  • Budgeting and management accounting
  • Human resource administration, including personnel evaluations and compensation
  • Internal communications and information flows
  • Administration of the internal audit activity’s policies and procedures. IIA PA 1110-1

ORGANIZATION

The Director of Internal Auditing (or Chief Audit Executive) shall report functionally to the board of trustees on internal auditing matters and administratively to the School superintendent.  The Director of Internal Auditing must be a certified public accountant (CPA) or a certified internal auditor (CIA) and have at least three years of auditing experience. The board of trustees shall periodically review the resources dedicated to the internal audit program and determine if adequate resources exist to ensure that risks identified in the annual risk assessment are adequately covered within a reasonable time frame. Texas Government Code 2102.006

Functional reporting to the Board typically involves the Board:

  • Approving the internal audit charter.
  • Approving the risk based internal audit plan.
  • Approving the internal audit budget and resource plan.
  • Receiving communications from the Director of Internal Auditing on the internal audit activity’s performance relative to its plan and other matters.
  • Approving decisions regarding the appointment and removal of the Director of Internal Auditing.
  • Approving the remuneration of the Director of Internal Auditing.
  • Making appropriate inquiries of management and the Director of Internal Auditing to determine whether there are inappropriate scope or resource limitations.

Administrative reporting is the reporting relationship within the organization’s management structure that facilitates the day-to-day operations of the internal audit activity. Administrative reporting typically includes:

  • Budgeting and management accounting
  • Human resource administration, including personnel evaluations and compensation
  • Internal communications and information flows
  • Administration of the internal audit activity’s policies and procedures. IIA PA 1110-1

INDEPENDENCE AND OBJECTIVITY

The program of internal auditing conducted by a state agency must provide for the auditor to:

  • Have access to the administrator; and
  • Be free of all operational and management responsibilities that would impair the auditor’s ability to review independently all aspects of the state agency’s operations. TGC 2102.007(b)

The Internal Auditor Director will ensure that the internal audit activity remains free from all conditions that threaten the ability of internal auditors to carry out their responsibilities in an unbiased manner, including matters of audit selection, scope, procedures, frequency, timing, and report content. If the

Internal auditors will maintain an unbiased mental attitude that allows them to perform engagements objectively and in such a manner that they believe in their work product, that no quality compromises are made, and that they do not subordinate their judgment on audit matters to others.

Internal auditors will have no direct operational responsibility or authority over any of the activities audited. Accordingly, internal auditors will not implement internal controls, develop procedures, install systems, prepare records, or engage in any other activity that may impair their judgment, including:

  • Assessing specific operations for which they had responsibility within the previous year.
  • Performing any operational duties for TSBVI or its affiliates.
  • Initiating or approving transactions external to the internal audit activity.
  • Directing the activities of any TSBVI employee not employed by the internal audit activity, except to the extent that such employees have been appropriately assigned to auditing teams or to otherwise assist internal auditors.

Where the Internal Audit Director has or is expected to have roles and/or responsibilities that fall outside of internal auditing, safeguards will be established to limit impairments to independence or objectivity.Many different circumstances, or combinations of circumstances, are relevant in evaluating threats to independence. Therefore, GAGAS establishes a conceptual framework that auditors use to identify, evaluate, and apply safeguards to address threats to independence. The conceptual framework assists auditors in maintaining both independence of mind and independence in appearance. It can be applied to any variations in circumstances that create threats to independence and allows auditors to address threats to independence that result from activities that are not specifically prohibited. GAGAS 3.07

Internal auditors will:

  • Disclose any impairment of independence or objectivity, in fact or appearance, to appropriate parties.
  • Exhibit professional objectivity in gathering, evaluating, and communicating information about the activity or process being examined.
  • Make balanced assessment of all available and relevant facts and circumstances.
  • Take necessary precautions to avoid being unduly influenced by their own interests or by others in forming judgments

The Director of Internal Audit will confirm to the Board, at least annually, the organizational independence of the internal audit activity. The organizational independence of the internal audit activity at TSBVI is affirmed through the annual review and update of the Internal Audit Charter.

The Director of Internal Audit will disclose to the Board any interference and related implications in determining the scope of internal auditing, performing work, and/or communicating results.  IIA Model Charter

Many different circumstances, or combinations of circumstances, are relevant in evaluating threats to independence. Therefore, GAGAS establishes a conceptual framework that auditors use to identify, evaluate, and apply safeguards to address threats to independence. The conceptual framework assists auditors in maintaining both independence of mind and independence in appearance. It can be applied to any variations in circumstances that create threats to independence and allows auditors to address threats to independence that result from activities that are not specifically prohibited. GAGAS 3.07

SCOPE OF INTERNAL AUDIT ACTIVITIES

The scope of internal audit activities encompasses, but is not limited to, objective examinations of evidence for the purpose of providing independent assessment to the Board, management, and outside parties on the adequacy and effectiveness of governance, risk management, and control processes for TSBVI. Internal audit assessments include evaluating whether:

  • Risks relating to the achievement of the TSBVI’s strategic objectives are appropriately identified and managed.
  • The actions of TSBVI’s officers, directors, employees, and contractors are in compliance with TSBVI’s policies, procedures, and applicable laws, regulations, and governance standards.
  • The results of operations or programs are consistent with established goals and objectives.
  • Operations or programs are being carried out effectively and efficiently.
  • Established processes and systems enable compliance with the policies, procedures, laws, and regulations that could significantly impact TSBVI.
  • Information and the means used to identify, measure, analyze, classify, and report such information are reliable and have integrity.
  • Resources and assets are acquired economically, used efficiently, and protected adequately.

The Internal Audit Director will report periodically to senior management and the Board regarding:

  • The internal audit activity’s purpose, authority, and responsibility.
  • The internal audit activity’s plan and performance relative to its plan.
  • The internal audit activity’s conformance with the IIA’s Code of Ethics and Standards, and action plans to address any significant conformance issues.
  • Significant risk exposures and control issues, including fraud risks, governance issues, and other matters requiring the attention of, or requested by, the Board.
  • Results of audit engagement or other activities.
  • Resource requirements.
  • Any response to risk by management that may be unacceptable to TSBVI.

The Internal Audit Director also coordinates activities, where possible, and considers relying upon the work of other internal and external assurance and consulting service providers as needed. The internal audit activity may perform advisory and related client service activities, the nature and scope of which will be agreed with the client, provided the internal audit activity does not assume management responsibility.

Opportunities for improving the efficiency of governance, risk management, and control processes may be identified during engagements. These opportunities will be communicated to the appropriate level of management. IIA Model Charter

Using professional judgment is important to auditors in carrying out all aspects of their professional responsibilities, including following the independence standards and related conceptual framework; maintaining objectivity and credibility; assigning competent staff to the audit; defining the scope of work; evaluating, documenting, and reporting the results of the work; and maintaining appropriate quality control over the audit process. GAGAS 3.64

RESPONSIBILITY

The Internal Audit Director has the responsibility to:

  • Submit, at least annually, to senior management and the Board a risk-based internal audit plan for review and approval.
  • Communicate to senior management and the Board the impact of resource limitations on the internal audit plan.
  • Review and adjust the internal audit plan, as necessary, in response to changes in TSBVI’s business, risks, operations, programs, systems, and controls.
  • Communicate to senior management and the Board any significant interim changes to the internal audit plan.
  • Ensure each engagement of the internal audit plan is executed, including the establishment of objectives and scope, the assignment of appropriate and adequate resources, the documentation of work programs and testing results, and the communication of engagement results with applicable conclusions and recommendations to appropriate parties.
  • Follow up on engagement findings and corrective actions, and report periodically to senior management and the Board any corrective actions not effectively implemented.
  • Ensure the principles of integrity, objectivity, confidentiality, and competency are applied and upheld.
  • Ensure the internal audit activity possesses or obtains the knowledge, skills, and other competencies needed to meet the requirements of the internal audit charter.
  • Ensure trends and emerging issues that could impact TSBVI are considered and communicated to senior management and the Board as appropriate.
  • Ensure emerging trends and successful practices in internal auditing are considered.
  • Establish and ensure adherence to policies and procedures designed to guide the internal audit activity.
  • Ensure adherence to TSBVI’s relevant policies and procedures, unless such policies and procedures conflict with the internal audit charter. Any such conflicts will be resolved or otherwise communicated to senior management and the Board.
  • Ensure conformance of the internal audit activity with the Standards, with the following qualifications:
    • If the internal audit activity is prohibited by law or regulation from conformance with certain parts of the Standards, the Internal Audit Director will ensure appropriate disclosures and will ensure conformance with all other parts of the
    • If the Standards are used in conjunction with requirements issued by the GAO, the Internal Audit Director will ensure that the internal audit activity conforms with the Standards, even if the internal audit activity also conforms with the more restrictive requirements of GAO.

DEFINITION OF ASSURANCE SERVICES

Assurance services involve the internal auditor’s objective assessment of evidence to provide an independent opinion or conclusions regarding an entity, operation, function, process, system, or other subject matter.  The nature and scope of the assurance engagement are determined by the internal auditor.  There are generally three parties involved in assurance services: (1) the person or group directly involved with the entity, operation, function, process, system, or other subject matter – the process owner, (2) the person or group making the assessment – the internal auditor, and (3) the person or group using the assessment – the user. IIA Standard 1000.A1

“Assurance services” means an examination of evidence for the purpose of providing an independent assessment of risk management, control, or governance processes.  Assurance services include audits as defined in this section.  Texas Government Code 2102.003(2)

TGC 2102.003 Definitions “Audit” means:

  1. a financial audit described by Section 321.0131;
  2. a compliance audit described by Section 321.0132;
  3. an economy and efficiency audit described by Section 321.0133;
  4. an effectiveness audit described by Section 321.0134; or
  5. an investigation described by Section 321.0136. GAGAS establishes requirements and provides guidance for audits that includes financial audits, attestation engagements, and performance audits. GAGAS 2.01

DEFINITION OF CONSULTING SERVICES

Consulting services are advisory in nature, and are generally performed at the specific request of an engagement client.  The nature and scope of the consulting engagement are subject to agreement with the engagement client.  Consulting services generally involve two parties: (1) the person or group offering the advice – the internal auditor, and (2) the person or group seeking and receiving the advice – the engagement client.  When performing consulting services, the internal auditor should maintain objectivity and not assume management responsibility. IIA Standard 1000.C1

“Consulting services” means advisory and related service activities, the nature and scope of which are agreed upon with the client and are intended to add value and improve an organization’s operations.  Consulting services include counsel, advice, facilitation, and training.   Texas Government Code 2102.003(4)

 

GAGAS does not cover nonaudit services, which are defined as professional services other than audits or attestation engagements. GAGAS 2.12

REPORTING AND MONITORING

A state agency shall file with the Sunset Advisory Commission, the budget division of the governor's office, the state auditor, and the Legislative Budget Board a copy of each report submitted to the state agency's governing board or the administrator of the state agency if the state agency does not have a governing board by the agency's internal auditor. Each report shall be filed not later than the 30th day after the date the report is submitted to the state agency's governing board or the administrator of the state agency if the state agency does not have a governing board.  In addition, a state agency shall file with the budget division of the governor's office, the state auditor, and the Legislative Budget Board any action plan or other response issued by the state agency's governing board or the administrator of the state agency if the state agency does not have a governing board in response to the report of the state agency's internal auditor. Texas Government Code 2102.0091

The Superintendent is responsible for ensuring that actions on recommendations are reported back to the Internal Audit Director on a timely basis. The report will indicate what actions were taken in regard to the specific findings and recommendations in the internal audit reports. If appropriate, a timetable for the anticipated completion of these actions will be included.

The Internal Audit Director must establish and maintain a system to monitor the disposition of results communicated to management. The Internal Audit Director must establish a follow-up process to monitor and ensure that management actions have been effectively implemented or that senior management has accepted the risk of not taking action. IIA Standard 2500

QUALITY ASSURANCE AND IMPROVEMENT PROGRAM

The internal audit activity will maintain a quality assurance and improvement program that covers all aspects of the internal audit activity. The program will include an evaluation of the internal audit activity’s conformance with the Standards and an evaluation of whether internal auditors apply the IIA’s Code of Ethics. The program will also assess the efficiency and effectiveness of the internal audit activity and identify opportunities for improvement.

The Director of Internal Audit will communicate to senior management and the Board on the internal audit activity’s quality assurance and improvement program, including results of internal assessments (both ongoing and periodic) and external assessments conducted at least once every three years by a qualified, independent assessor or assessment team from outside TSBVI. IIA Model Charter

Adopted:        5/30/91

Amended:      11/15/96, 9/22/00, 11/21/03, 11/21/08, 11/9/12, 11/20/15, 9/30/16, 9/29/17

Reviewed:      9/24/93, 11/19/10, 11/18/11, 1/31/14

AUDIT

The Internal Audit Director shall prepare an annual report and submit it before November 1 of each year to the Governor, the LBB, the Sunset Advisory Commission, the state auditor, TSBVI Board and Superintendent.  Gov’t. Code 2102.009

The State Auditor's Office, in accordance with the state audit plan approved by the Legislative Audit Committee, may conduct financial audits, compliance audits and investigations, economy and efficiency audits, effectiveness audits, special audits, and investigations as defined by Government Code Chapter 321 and specified in the audit plan.  Gov’t. Code 321.013(f)

Other governmental entities with oversight responsibility may conduct audits as allowed by law or rule. 

TSBVI may employ a qualified private auditor only if the state auditor first delegates that authority and grants permission to contract after reviewing the scope of the proposed audit and selection of the private auditor is procured through a competitive selection process.  Gov’t. Code 321020

COOPERATING WITH HHSC AUDITORS AND FEDERAL REGULATORS

TSBVI staff will promptly cooperate with TSBVI’s Internal Auditor and coordinate efforts to respond and comply with outside auditors, inspectors and/or investigators from the Texas Health and Human Services Commission (HHSC) or federal regulatory agencies with oversight responsibilities.  [See Medicaid Administrative Claims Contract requirements.]

CONTRACTING FOR AUDITS

TSVBI may not use appropriated money to contract with a person to audit the financial records or accounts of the School except:

  1. for the appointment of an internal auditor under Government Code 2102.005 or to contract with the state auditor; or
  2. to finance a supplemental audit of payments received from the government of the United States if the audit is required as a condition of receipt of the money and an amount for the audit is provided by the federal grant, allocation, aid, or other payment.

Gov’t.t Code 2113.102

Adopted:         5/8/81

Amended:       1/14/83, 3/25/94, 9/29/95, 9/26/97, 3/21/03, 11/19/04, 4/6/18, 11/15/19

Reviewed:      

PROPERTY ACCOUNTING SYSTEM

The Superintendent shall be responsible for establishing a property accounting system that complies with the provisions for property accounting under the Texas Gov't Code, Chapter 403.271 et.seq. and the federal Education Department General Administrative Regulations (EDGAR) for property obtained through federal grants. All real and personal property must be accounted for by the School. The School’s inventory accounting system shall include procedures for the disposition of equipment and supplies purchased with federal grants, including funds received from the Individuals with Disabilities Education Act (IDEA) and No Child Left Behind (NCLB) Act. The School shall implement administrative procedures regarding the use and disposition of any such equipment with an original per unit acquisition cost of $5,000 or more, or an aggregate amount of supplies of $5,000 or more.

PERSONAL PROPERTY DEFINED

Personal property is defined by the Comptroller of Public Accounts to include equipment, machines, vehicles and furniture. The Comptroller of Public Accounts is responsible for administering the personal property accounting system for the State of Texas and for setting the dollar value amount for capitalizing assets. Texas Gov't Code, Chapter 403.271 et.seq

The Superintendent:

  1. Is responsible for the custody and care of state property in the School’s possession.
  2. Is responsible for ensuring that state personal property is used for state purposes only.
  3. Must designate a property manager and inform the Comptroller of Public Accounts.
  4. Must approve all loans of property to another state agency.
  5. May transfer any personal property in the School’s possession to another state agency with or without reimbursement.
  6. Will ensure that a physical inventory of all personal property in the School’s possession shall be completed on the date prescribed by the Comptroller of Public Accounts.
  7. Shall report immediately to the State Auditor and the Attorney General if reasonable cause exists to believe that personal property in the School’s possession has been lost, destroyed, or damaged, through negligence of a state official, or employee. A monetary liability for property lost, destroyed, or damaged through the negligence, or fault, of any state official, or employee, may attach, on a joint and several basis to more than one person in a particular instance.

The School’s property manager:

  1. Is the custodian of all personal property possessed by the School and is responsible for maintaining the required records.
  2. Must mark and identify state personal property in accordance with the Comptroller of Public Accounts’ rules.
  3. Must require a written receipt from a person entrusted with custody of personal property.
  4. Must ensure that personal property records accurately reflect the property currently possessed by the School.
  5. Must furnish a certification of personal property inventory at the time, and in the form, directed by the Comptroller of Public Accounts.
  6. Must dispose of surplus, or obsolete, personal property in the manner authorized by the Comptroller of Public Accounts.

REAL PROPERTY DEFINED

Real property is defined by the General Land Office to include land and buildings and associated capital improvements. Texas Natural Resources Code ß31.51, et seq.

REAL PROPERTY RECORDS

Records will be maintained in accordance with rules and regulations of the General Land Office as stated in Texas Natural Resources Code. Texas Natural Resources Code ß31.51, et seq.

Adopted:         11/7/80

Amended:       3/25/94, 11/14/97, 3/26/02, 7/15/15, 8/7/15

Reviewed:

STANDARD ACCOUNTING AND REPORTING

The Superintendent shall ensure that the School maintains a standard state governmental financial accounting system that conforms with generally accepted accounting principles.  The uniform system for budgeting, accounting, and financial reporting shall reflect full implementation of modified and full accrual accounting, as appropriate.  This system shall meet the minimum reporting standards prescribed by the Comptroller of Public Accounts.  Gov’t Code 2101.011(d), .012(b)

REPORT OF REVENUES AND EXPENDITURES

An annual report of the revenues and expenditures for the preceding fiscal year shall be provided to the Board by the Superintendent and the Chief Financial Officer.  The report shall include financial information that will enable the TSBVI Board to review and monitor the budgetary process and determine educational and operational costs by program and division.

ANNUAL FINANCIAL REPORT

The Superintendent shall ensure that, not later than November 20 of each year, an annual financial report regarding the School’s use of appropriated money during the preceding fiscal year is submitted to:

  1. the governor;
  2. the comptroller;
  3. the Legislative Reference Library;
  4. the state auditor; and
  5. the Legislative Budget Board

Gov’t Code 2101.011(b)

The annual financial report shall include all provisions as set forth by the Legislature and prepared in accordance with the reporting requirements established by the Comptroller of Public Accounts.

TSBVI’s annual financial report must include a detailed statement of all assets, liabilities, and fund balances, including:

  1. cash on hand and on deposit in banks and accounts in the state treasury;
  2. the value of consumable supplies and postage;
  3. the value of the agency’s inventory of movable equipment and other fixed assets;
  4. all other assets;
  5. an itemization of the investments, bonds, notes, and other securities owned by any special funds under the agency’s jurisdiction, including the amount and value of the securities;
  6. all money due the agency from any source;
  7. all outstanding commitments of agency, including amounts due for services of goods received by the agency;
  8. a summary by source of all revenue collected or accruing through the agency;
  9. a summary of all appropriations, expenditures, bona fide encumbrances, and other disbursements by the agency; and
  10. any other financial information requested by the comptroller.

Gov’t Code 2101.011(c)

Adopted:         11/7/80

Amended:       11/13/81, 3/25/94, 8/26/94, 11/15/96, 9/26/97, 1/24/02, 6/3/15, 6/1/18, 5/31/19

Reviewed:       3/21/03

The Superintendent shall ensure that the School maintains a standard state governmental financial accounting system that conforms with generally accepted accounting principles. The uniform system for budgeting, accounting, and financial reporting shall reflect full implementation of modified and full accrual accounting, as appropriate. This system shall meet the minimum reporting standards prescribed by the Comptroller of Public Accounts.

Government Code 2101.011(b)

Adopted: 11/7/80

Amended: 5/27/93, 3/25/94, 11/15/96, 9/26/97, 1/24/02. 3/21/03

Reviewed:

AUTHORIZED EXPENDITURES

The School shall not lend its credit or gratuitously grant public money or thing of value in aid of any individual, association, or corporation. Tx. Constit. Art. III, Sec. 52; Brazoria County v. Perry, 537 S.W. 2d 89 (Civ. App. 1976)

The School shall not grant any extra compensation, fee, or allowance to a public officer, agent, servant, or contractor after service has been rendered or a contract entered into and performed in whole or in part. Nor shall the School pay or authorize the payment of any claim against the School under any agreement or contract made without authority of law. Tx. Const. Art. III, Sec. 53; Harlingen ISD v. C.H. Page and Bro., 48 S.W. 2d 983 (Comm. App. 1932)

No public funds of the School may be spent in any manner other than as provided for in the budget adopted by the Board.

Education Code 30.022(d)

BUDGET PREPARATION

The Superintendent shall prepare, or cause to be prepared, a proposed budget covering all estimated revenue and proposed expenditures of the School for the following year.

Education Code 30.022(d)

DEADLINES

On or before December 1st of each fiscal year, an itemized budget covering the operation of that fiscal year shall be filed with the Governor's Office of Budget and Planning, the Legislative Budget Board, the Comptroller, and the Legislative Reference Library in the format prescribed jointly by both budget offices.

General Appropriations Act, Art. IX, Sec. 7.01

BOARD APPROVAL

The Board shall review and approve the annual operating budget at the next regularly scheduled Board meeting subsequent to its preparation.

AMENDMENT OF APPROVED BUDGET

The Board may amend the approved budget. All subsequent amendments to the original budget shall be filed with the Governor's Office of Budget and Planning and the Legislative Budget Board within thirty (30) days of approval of such amendments, unless such reporting requirement is waived.

General Appropriations Act, Art. IX, Sec. 7.01

The Board shall annually determine a percentage, not to exceed 20%, that the Superintendent may transfer, at his/her discretion, from one appropriation item to another appropriation item without the prior approval of the Board.

General Appropriations Act, Article IX, Sec. 14.01

BUDGET MONITORING

The Superintendent shall prepare at least semi-annually, for Board review, budget reports which show budget expenditures and account balances.

Adopted: 11/7/80

Amended: 11/13/81, 11/11/83, 5/27/93, 5/26/94, 11/15/96, 9/26/97, 1/24/02, 11/22/02, 11/18/05, 11/16/07

Reviewed:

AUTHORITY AND PURPOSE

The board may accept and retain control of gifts, devises, bequests, donations, or non-governmental grants, to the School (hereinafter, "gift"), either absolutely or in trust, of money, securities, personal property, and real property from any individual, estate, group, association, or corporation. The funds, or other property donated, or the income from the property may be spent by the board for:

  1. Any purpose designated by the donor that is in keeping with the lawful purpose of the School; or
  2. Any legal purpose, if a specific purpose is not designated by the donor.

Tx. Educ. Code 30.022

The School may accept a gift that has a value of $500 or more only if a majority of the Board, in an open meeting, acknowledges the acceptance of the gift not later than the 90th day after the date the gift is accepted.

Tx. Govt. Code 575.003

The School shall maintain monetary gifts to the School in its Expendable Trust Fund account, commonly referred to as the "School Legacy Fund", the title which will be used throughout this policy.  Legacy funds received by the School are appropriated to the School by the Texas Legislature.  No appropriated funds, including Legacy funds, may be used for a private purpose.  The Superintendent shall establish guidelines or procedures in accord with applicable state laws and rules to guide School staff in making decisions about the allowable use of appropriated funds.

ETHICAL CONSIDERATIONS

The School shall follow the opinions of the Texas Ethics Commission regarding the acceptance and use of gifts by a state agency.  The School may accept gifts only if the gifts can be used in carrying out the School’s powers and duties.  A gift to a state agency becomes state property, and neither the agency nor any officer or employee of the agency is permitted to use it for personal or private purposes.  Consequently, the School as a state agency, cannot accept gifts for the personal use or enjoyment of individual state officers or employees nor may it expend gifts for a private purpose, that is any purpose not directly related to the School’s purpose and mission.

Texas Ethics Commission: Ethics Advisory Opinion No. 62 (1992); Ethics Advisory Opinion No. 130 (1993); A Guide to the Ethics Laws for State Officers and Employees, p.5 (2008)

BOARD NOTIFICATION AND ACCEPTANCE

At the next regularly scheduled board meeting following the School’s receipt of a gift with a value of $500 or more from a donor, or the notification by the donor, or the donor's representative, of the donor's intent to make a gift to the School, the Superintendent shall include an item on the Board agenda to inform the Board of the gift and to allow the Board to acknowledge the acceptance of the gift.  The Superintendent will also inform the Board of gifts with a value of less than $500 so that the Board in an open meeting may acknowledge the acceptance of the gift or direct the Superintendent otherwise.

The Board reserves the right to determine the designated expenditure of monetary gifts of any value when the purpose for that gift is not designated by the donor.

When the Board acknowledges the acceptance of a gift with a value of $500 or more, the board meeting minutes must include the name of the donor, a description of the gift, and a statement of the purpose of the gift.

Government Code Chapter 575.004

ACCEPTANCE BY SUPERINTENDENT

The Superintendent is authorized to receive all legal and ethical gifts pending the next regularly scheduled meeting of the Board, at which time the Board will acknowledge the acceptance of a gift with a value of $500 or more or direct the Superintendent otherwise.  The Board acknowledges that some donated goods or services, valued at $500 or more, may be time sensitive, and hereby authorizes the Superintendent to accept and utilize such gifts as necessary.

MANAGEMENT

All monetary gifts, including income from real property or from financial vehicles donated to the School shall be maintained and accounted for in a separate fund designated as the School "Legacy Fund."

No other funds shall be maintained, commingled, or accounted for with the funds in the Legacy Fund.

INVESTMENT

The property and funds in the Legacy Fund shall be managed in accordance with the Public Funds Investment Act and TSBVI Board Policy CDA.

FINANCIAL REPORT

All gifts shall be included among the total receipts of the School which are reported in the annual financial report.

General Appropriations Act (current)

ANNUAL LEGACY FUND BUDGET

Preparation and Approval

The Superintendent, or designee, shall annually present to the Board for approval at a regularly scheduled meeting of the Board, prior to the beginning of the fiscal year, a budget for the expenditure of funds from the Legacy Fund for the next fiscal year.

Budget Amount

Unless otherwise directed by a quorum majority of the Board to exceed 100% of annual projected revenues, the amount to be budgeted annually from the Legacy Fund shall not exceed 100% of all revenues projected to be received during the next fiscal year from the following sources:

  1. Income received from gifts accepted prior to the approval of the current year's Legacy Budget; and
  2. Interest earned on investments.

Additional Budget Approval

When the School receives gifts during a fiscal year after the Legacy Budget has been approved by the Board, the Board may authorize the expenditure of those additional gifts either in accordance with the expressed purpose of the donor or for a specific purpose approved by the Board.   The Superintendent may propose specific uses of these additional gifts to the Board. 

Budget Amendments

The Superintendent is authorized to prepare an amended budget for any revenues that are greater than the amounts originally projected.  Any amendment to the annual Legacy Fund Budget is subject to the approval of the Board.

LEGACY FUND REPORT

The Superintendent, or designee, shall present to the Finance and Audit Committee of the Board, at each regularly scheduled meeting, a report of all funds deposited into and expended from the Legacy Fund.

Adopted:         9/26/97
Amended:       11/14/97, 3/31/98, 4/10/15
Reviewed:       3/26/02

AUTHORIZED EXPENDITURES

The School shall not lend its credit or gratuitously grant public money or thing of value in aid of any individual, association, or corporation.  Tx. Constitution Art. III, Sec. 52; Brazoria County v. Perry, 537 S.W. 2d 89 (Civ. App. 1976)

The School shall not grant any extra compensation, fee, or allowance to a public officer, agent, servant, or contractor after service has been rendered or a contract entered into and performed in whole or in part. Nor shall the School pay or authorize the payment of any claim against the School under any agreement or contract made without authority of law.  Tx. Constitution Art. III, Sec. 44; Harlingen ISD v. C.H. Page and Bro., 48 S.W. 2d 983 (Comm. App. 1932)

No public funds of the School may be spent in any manner other than as provided for in the budget adopted by the Board.

Education Code 30.022(d); General Appropriations Act, Art. IX, Sec. 1.01

BUDGET PREPARATION

The Superintendent shall prepare, or cause to be prepared, a proposed budget covering all estimated revenue and proposed expenditures of the School for the following biennium, with an annual operating budget for each fiscal year.

Education Code 30.022(e)

DEADLINES

On or before December 1st of each fiscal year, an itemized budget covering the operation of that fiscal year shall be filed with the Governor's Office of Budget and Planning, the Legislative Budget Board, the Comptroller, and the Legislative Reference Library in the format prescribed jointly by both budget offices.

General Appropriations Act, Art. IX, Sec. 7.01(a)(1)

BOARD APPROVAL

The Board shall review and approve the annual operating budget at the next regularly scheduled Board meeting subsequent to its preparation.

AMENDMENT OF APPROVED BUDGET

The Board may amend the approved budget. All subsequent amendments to the original budget shall be filed with the Governor's Office of Budget and Planning and the Legislative Budget Board within thirty (30) days of approval of such amendments, unless such reporting requirement is waived.

General Appropriations Act, Art. IX, Sec. 7.01(a)(2)

The Board shall annually determine a percentage, not to exceed 12.5 %, that the Superintendent may transfer, at his/her discretion, from one appropriation item to another appropriation item without the prior approval of the Board.

General Appropriations Act, Article IX, Sec. 14.01(a)

BUDGET MONITORING

The Superintendent shall prepare at least semi-annually, for Board review, budget reports which show budget expenditures and account balances.

Adopted:         11/7/80

Amended:       11/13/81, 11/11/83, 5/27/93, 5/26/94, 11/15/96, 9/26/97, 1/24/02, 11/22/02, 11/18/05, 11/16/07, 6/1/18

Reviewed:

 

SALE, LEASE OR EXCHANGE OF REAL PROPERTY AND INTERESTS IN REAL PROPERTY

The sale, lease, or exchange, of the School's real property shall be authorized by the legislature and administered by the Asset Division of the General Land Office. Texas Natural Resources Code 31.158.

LEASE OF OIL AND NATURAL GAS PRODUCTION

Lease of oil and natural gas in land belonging to the School can be initiated by a resolution adopted by a majority of the Board. The lease and terms thereof shall be submitted to the Board for Lease for the TSBVI for approval and disposition of any such transaction. Tx. Nat. Res. Code 52.011

OTHER LEASE OF PROPERTY BEQUEATHED TO THE SCHOOL

The Board of Trustees may enter into arrangements, such as agricultural leases, to obtain revenue from the use of real property bequeathed to the School. Tx. Educ. Code 30.022(i)

Adopted: 5/26/94
Amended: 11/14/97
Reviewed: 9/24/99, 1/24/02, 11/19/04, 4/3/09, 6/3/15

INVESTMENT AUTHORITY

The Superintendent, or other person designated by Board resolution, shall serve as the investment officer of the School, shall recommend appropriate legally authorized and adequately secured investments, and shall invest School funds as directed by the Board, and in accordance with the School's written investment policy and generally accepted accounting procedures.

All investments made by the School shall comply with the Public Funds Investment Act (Texas Government Code Chapter 2256, Subchapter A) and all federal, state, and local statutes, rules or regulations.   Gov’t Code 2256.026

INVESTMENT OFFICER

The investment officer is responsible for investment of TSBVI’s funds consistent with the Board’s investment policy. In the administration of the duties of an investment officer, the person designated as investment officer shall exercise the judgment and care, under prevailing circumstances, that a person of prudence, discretion, and intelligence would exercise in the management of the person's own affairs, but the Board retains the ultimate responsibility as fiduciaries of the assets for TSBVI. Unless authorized by law, a person may not deposit, withdraw, transfer, or manage in any other manner the funds of the investing entity. Authority granted to a person to deposit, withdraw, invest, transfer, or manage an entity's funds is effective until rescinded by the Board, or until termination of the person's employment by the School. Gov't Code 2256.005(f)

The School's investment officer may use School employees or the services of a contractor of the School to aid the investment officer in the execution of the officer's duties under Government Code 2256. If the Board contracts with another investing entity to invest its funds, that entity’s investment officer becomes the investment officer for TSBVI until the expiration of the contract.  Gov’t Code 2256.005(f)

Gov't Code 2256.003(c)

AUTHORIZED  INVESTMENTs

The Board may purchase, sell, and invest its funds and funds under its control in investments described below, in compliance with its adopted investment policies and according to the standard of care set out in this policy. Investments may be made directly by the Board or by a nonprofit corporation acting on behalf of the Board or an investment pool acting on behalf of two or more local governments, state agencies, or a combination of the two. Gov't Code 2256.003(a)

In the exercise of these powers, the Board may contract with an investment management firm registered under the Investment Advisers Act of 1940 (15 U.S.C. Section 80b-1 et seq.) or with the State Securities Board to provide for the investment and management of its public funds or other funds under its control. A contract made for such purpose may not be for a term longer than two years. A renewal or extension of the contract must be made by the Board by order, ordinance, or resolution. Gov't Code 2256.003(b)

The Board shall permit investment of School funds in only the following investment types, consistent with the strategies and maturities defined in this policy.

  1. Obligations, including letters of credit, of the United States or its agencies and instrumentalities; direct obligations of the state of Texas or its agencies and instrumentalities; collateralized mortgage obligations directly issued by a federal agency or instrumentality of the United States, the underlying security for which is guaranteed by an agency or instrumentality of the United States; other obligations, the principal and interest of which are unconditionally guaranteed or insured by, or backed by the full faith and credit of, the state of Texas, the United States, or their respective agencies and instrumentalities including obligations that are fully guaranteed or insured by the Federal Deposit Insurance Corporation or by the explicit full faith and credit of the United States; obligations of states, agencies, counties, cities, and other political subdivisions of any state rated as to investment quality by a nationally recognized investment rating firm not less than A or its equivalent; and bonds issued, assumed, or guaranteed by the state of Israel. Gov't Code 2256.009(a)
  2. Certificates of deposit as permitted by Gov't Code 2256.010.
  3. Fully collateralized repurchase agreements permitted by Gov't Code 2256.011.
  4. Banker's acceptances as permitted by Gov't Code 2256.012.
  5. Commercial paper as permitted by Gov't Code 2256.013.
  6. Two types of mutual funds as permitted by Gov't Code 2256.014: Money market mutual funds and no-load mutual funds.
  7. Public funds investment pools as permitted by Gov't Code 2256.016-2256.017, 2256.019.

The School is not required to liquidate investments that were authorized investments at the time of purchase.

Gov't Code 2256.017

SAFETY AND INVESTMENT MANAGEMENT

The investment officer shall observe financial market indicators, study financial trends, and utilize available educational tools in order to maintain appropriate managerial expertise. Investments shall be made in a manner that ensures the preservation of capital in the overall portfolio and offsets, during a 12-month period, any market price losses resulting from interest-rate fluctuations by income received from the balance of the portfolio. No individual investment transaction shall be undertaken that jeopardizes the total capital position of the overall portfolio.

LIQUIDITY AND MATURITY

Assets of the School shall be invested in instruments whose maturities do not exceed one year from the time of purchase, subject to the following exceptions:

  1. A shorter maturity is required by law.
  2. A longer maturity may be specifically authorized by the Board for a given investment, provided legal limits are not exceeded.

The School's investment portfolio shall have sufficient liquidity to meet anticipated cash flow requirements, projected on a weekly, monthly, and annual basis. The School shall have procedures to determine cash flow requirements according to generally accepted financial and accounting procedures.

DIVERSITY

The investment portfolio shall be diversified in terms of investment instruments, maturity scheduling, and financial institutions to reduce risk of loss resulting from over concentration of assets in a specific class of investments, specific maturity, or specific issuer.

MONITORING MARKET PRICES

Monitoring shall be done monthly and more often as economic conditions warrant by using appropriate reports, indices, or benchmarks for the type of investment. The investment officer shall keep the Board informed of significant declines in the market value of the School's investment portfolio. Information sources may include financial/investment publications and electronic media, available software for tracking investments, depository banks, commercial or investment banks, financial advisers, and representatives/advisors of investment pools, or money market funds.

FUNDS/STRATEGIES

Investments of the expendable trust fund shall be consistent with this policy and shall have as their primary objectives safety, investment liquidity, and maturity sufficient to meet anticipated cash flow requirements. [See CDC] The investment strategy of the expendable trust fund shall include the

following priorities in order of importance:

  1. understanding of the suitability of the investment to the financial requirements of TSBVI;
  2. preservation and safety of principal;
  3. liquidity;
  4. marketability of the investment if the need arises to liquidate the investment before maturity;
  5. diversification of the investment portfolio;
  6. yield; and
  7. procedures to monitor rating changes in investments acquired with public funds and the liquidation of such investments consistent with the provisions of Section 2256.021.

All investment transactions, except mutual funds, shall be executed on a delivery versus payment basis.  Gov’t Code 2256.005(b)

SAFEKEEPING AND CUSTODY

The cash, collateral, and investments of the School shall be held by an independent third party with whom the School has a current custodial agreement. The School shall retain clearly marked receipts providing proof of the School's ownership, or the School may delegate to an investment pool the authority to hold legal title, as custodian, of investments purchased with School funds.

BROKERS/DEALERS

Selection of Broker

Prior to engaging in any investment transactions with a broker, the Board shall adopt a list of qualified brokers that are authorized to engage in investment transactions with the School.

At least annually thereafter, the Board shall review, revise, and adopt a list of qualified brokers that are authorized to engage in investment transactions with the School.

Gov't Code 2256.025

Prior to handling investments on behalf of the School, broker/dealers must submit required written documents and annual audited financial statements to the School, and be in good standing with the National Association of Securities Dealers. Representatives of brokers/dealers shall be registered with the Texas State Securities Board and must have membership in the Securities Investor Protection Corporation (SIPC).

SOLICITING BIDS

In order to get the best return on its investments, the School may solicit bids in writing, by telephone, or electronically.

INTERNAL CONTROLS

A system of internal controls shall be established and documented, in writing, and must designate who has authority to withdraw funds. Also, they shall be designed to protect against losses of public funds arising from fraud, employee error, misrepresentation by third parties, unanticipated changes in financial markets, or imprudent actions by employees and officers of the School. Controls deemed most important shall include:

  1. Separation of transaction authority from accounting and record keeping.
  2. Avoidance of collusion.
  3. Custodial safekeeping.
  4. Clear delegation of authority.
  5. Written confirmation of telephone transactions.
  6. Documentation of dealer questionnaires, quotations and bids, evaluations, transactions and rationale.
  7. Avoidance of bearer-form securities.

These controls shall be reviewed by the School's internal auditor.

QUARTERLY REPORTS

Not less than quarterly, the School's investment officer shall prepare and submit to the Board, a written report of investment transactions for all funds covered by the Public Funds Investment Act for the preceding reporting period. This report shall be presented to the Board not less than quarterly, and within a reasonable time after the end of the period. The report must:

  1. Contain a detailed description of the investment position of the School on the date of the report.
  2. Be prepared jointly and signed by all School investment officers.
  3. Contain a summary statement of each pooled fund that states:
    1. Beginning market value for the reporting period.
    2. Ending market value for the period; and
    3. Fully accrued interest for the reporting period.
  4. State the book value and market value of each separately invested asset at the beginning and end of the reporting period by the type of asset and fund type invested.
  5. State the maturity date of each separately invested asset that has a maturity date.
  6. State the account, or fund, or pooled group fund, in the School for which each individual investment was acquired.
  7. State the compliance of the investment portfolio of the School as it relates to the School's investment strategy expressed in the School's investment policy and relevant provisions of law.

If the School invests in other than money market mutual funds, investment pools, or accounts, offered by its depository bank in the form of certificates of deposit, or money market accounts, or similar accounts, the reports shall be formally reviewed at least annually by an independent auditor, and the result of the review shall be reported to the Board by that auditor.

Gov't Code 2256.023

ANNUAL REVIEW

The investment policy and the investment strategy shall be reviewed by the Board not less than annually.

The Board shall adopt a written instrument stating that it has reviewed the investment policy and investment strategies and that the written instrument so adopted shall record any changes made to either the investment policy or investment strategies.  Gov’t Code 2256.005(e)

AUDIT

At least once every two years, the Board shall require the School's internal auditor to perform a compliance audit of management controls on investments and adherence to the Board's established investment policies.  The School shall report the results of this audit to the State auditor.  Gov’t Code 2256.005(n)

INVESTMENT TRAINING

Each member of the TSBVI governing Board and its investment officer shall attend at least one training session relating to the person's responsibilities under the Public Funds Investment Act (PFIA) within six months after taking office, or assuming duties.

Training must include education in investment controls, security risks, strategy risks, market risks, diversification of investment portfolio, and compliance with the Public Funds Investment Act.

An investment officer shall attend a training session not less than once each state fiscal biennium and may receive training from any independent source approved by the TSBVI governing body.

The investment officer shall prepare a report on this training and deliver the report to the TSBVI governing body not later than the 180th day after the last day of each regular session of the legislature.

Gov't Code 2256.007(a),(c),(d)

STANDARD OF CARE

Investments shall be made with judgment and care, under prevailing circumstances that a person of prudence, discretion, and intelligence would exercise in the management of his, or her, own affairs, not for speculation, but for investment, considering the probably safety of capital and the probable income to be derived. Investments shall be governed by the following objectives in order of priority:

  1. Preservation and safety of principal;
  2. Liquidity; and
  3. Yield.

In determining whether an investment officer has exercised prudence with respect to an investment decision, the following shall be taken into consideration:

  1. The investment of all funds, rather than the prudence of a single investment, over which the officer had responsibility.
  2. Whether the investment decision was consistent with a board’s written investment policy.

Gov’t Code 2256.006

PERSONAL INTEREST

A School investment officer who has a personal business relationship with an entity seeking to sell an investment to the School shall file a statement disclosing that personal business interest. An investment officer who is related within the second degree by affinity, or consanguinity, as determined by Government Code Chapter 573 (regarding nepotism prohibition), to an individual seeking to sell an investment to the School shall file a statement disclosing that relationship with the Board and with the Texas Ethics Commission. Gov't Code 2256.005

For purposes of this policy, an investment officer has a personal business relationship with a business organization if:

  1. The investment officer owns ten percent, or more, of the voting stock, or shares, of the business organization or owns $5,000, or more, of the fair market value of the business organization;
  2. Funds received by the investment officer from the business organization exceed ten percent of the investment officer's gross income for the previous year; or
  3. The investment officer has acquired from the business organization during the previous year investments with a book value of $2,500, or more, for the personal account of the investment officer.

SELLERS OF INVESTMENTS

This policy shall be presented to any person seeking to sell an authorized investment to the School. For purposes of this policy, a business organization includes investment pools. The registered principal of the business organization seeking to sell an authorized investment shall execute a written instrument stating:

  1. The registered principal has received and thoroughly reviewed this policy; and
  2. The registered principal acknowledges that the business organization has implemented reasonable procedures and controls in an effort to preclude imprudent investment activities arising out of investment transactions conducted between the School and the organization.

The investment officer of the School may not buy any securities from a person who has not delivered to the School an instrument in substantially this form.

Business Organizations

For the purposes of the provisions at Sellers of Investments above, “business organization” means an investment pool or investment management firm under contract with a district to invest or manage the district’s investment portfolio that has accepted authority granted by the district under the contract to exercise investment discretion in regard to the district’s funds.

Gov't Code 2256.005(k),(l)

DONATIONS

A gift, devise, or bequest made to provide college scholarships for TSBVI graduates may be invested or retained by the Board as provided in Property Code 117.004 (Uniform Prudent Investor Act), unless otherwise specifically provided by the terms of the gift, devise, or bequest.  Education Code 45.107

Investments donated to the School for a particular purpose or under terms of use specified by the donor are not subject to the requirements of the Public Funds Investment Act.  Gov't Code 2256.004(b)

ELECTRONIC FUNDS TRANSFER

The School may use electronic means to transfer, or invest, all funds collected, or controlled by the School.

Gov't Code 2256.051

Adopted:         11/7/80

Amended:       5/31/90, 3/25/94, 5/26/94, 9/29/95, 1/24/97, 11/14/97, 3/30/99, 11/22/02, 1/30/04, 11/18/05, 11/18/11, 11/21/14, 11/20/15, 11/18/16, 11/17/17, 11/16/18

Reviewed:       1/24/02, 11/19/04, 1/26/07, 11/16/07, 11/21/08, 11/20/09, 11/19/10, 11/9/12, 11/8/13, 11/15/19