THE STATE
EDUCATION DEPARTMENT / THE UNIVERSITY
OF THE STATE OF |
TO: |
The Honorable the Members of the Board of Regents
|
FROM: |
Theresa E. Savo |
SUBJECT: |
Draft
pamphlet “Statement on the Governance Role of a Trustee or Board
Member” |
DATE: |
December 20, 2006 |
STRATEGIC
GOAL: |
Goal
5 |
AUTHORIZATION(S): |
|
Issue for Decision
Should the Board of Regents approve the revised pamphlet “Statement on
the Governance Role of a Trustee or Board Member”?
Requested by members of the Board of Regents
to reflect emerging issues in Board governance.
Proposed Handling
This
item will brought to the Subcommittee on Audits at its January 2007 meeting for
review and approval for forwarding for final action at the Full Board
meeting.
Procedural History
Not applicable
This pamphlet was initially released by the Board of Regents and the Commissioner in November 2001.
A team of SED staff represented by all
program areas have revised the pamphlet “The Statement of the Governance Role of
a Trustee or Board Member”. The
major changes to this document include the following:
·
An
enhanced section on Duty of Loyalty/Conflicts of Interest which references sample policy statements from
the New York State School Boards Association (NYSSBA) and the Internal Revenue
Service (IRS) websites;
·
Additional information for Board members or
Trustees who lack knowledge or experience in fiscal
governance;
·
Appendix B “Best Practices for Boards to
Follow” has been updated;
· Appendix F has been added which outlines how to report Fraud, Waste, and Abuse.
Recommendation
Staff recommend that the Board of Regents approve the revised pamphlet on
the “Statement on the Governance Role of a Trustee or Board Member” as
submitted.
Timetable for
Implementation
Not applicable
Board of
Regents
The University of the
State of
The University of the
State of
As a trustee or board
member, you have assumed an oversight role with your institution’s service to
the community, which includes protecting the public interest. This is a very
important role because, as a trustee or board member, you and your colleagues
are responsible for the overall direction, operation, assets, and fiscal
well-being of your institution. The assets of the institution are held in trust
for the people of the State with trustees/board members acting as fiduciaries.
As
an employee/volunteer, you must be willing to donate the time and
attention to ensure that senior managers are fulfilling the institution’s
charter and/or legislative mandate. Presented below are fundamental questions
that trustees/board members need to ask and revisit continuously to ensure they
are fulfilling their role in a responsible manner.
As a trustee/board
member, you should understand the purpose and mission of your institution, which
is defined by its charter, certificate of incorporation laws or by legislation.
USNY institutions encompass a wide array of education purposes. In the case of
organizations incorporated or chartered by the Board of Regents, you should
obtain a copy of the Regents-issued charter or certificate of incorporation and
by-laws. Institutions chartered or incorporated by the Board of Regents are
treated as not-for-profit entities. You should familiarize yourself with the
institution’s corporate status, powers, privileges, and duties, which are
defined by its charter or certificate of incorporation. Independent colleges and
universities derive their corporate powers from the Board of Regents as do
certain non-degree granting institutions. Libraries, museums, historical
societies, public television and/or radio stations also derive their corporate
powers from the Board of Regents. All of these institutions are governed by a
board of trustees which is legally responsible for assuring that the institution
fulfills the distinctive purposes for which it was
established.
On the other hand, the
State University of New York, its four university centers and various colleges
of arts and sciences, technical colleges, medical centers, and community
colleges derive their authorities from Education Law, as does the City
University of New York; all of which are part of the University of the State of
Proprietary (for profit)
colleges are incorporated under the provisions of the Business Corporation Law
with the Department of State and are authorized by the Board of Regents to award
degrees. Any amendment to the corporate purpose of these colleges requires the
consent of the Commissioner of Education.
USNY encompasses school
districts and Boards of Cooperative Educational Services (BOCES), which also
obtain their authority from the Education Law and other relevant statutes. As a
board member, you need to know whether the school district is considered a
common, union free, central, central high, or small or large city school
district. There are also “special act” school districts which have been established by the New York State
Legislature on the grounds of charitable institutions caring for children and
youth. BOCES are voluntary associations of school districts that agree to
provide education and business services in a cooperative manner for purposes of
economy and efficiency. The New York State School Boards Association publishes a
handbook for school board members that provide more detailed information on the
role of a school board member.
What is the financial
status of the institution?
One of the most important issues you need
to monitor is the financial status of your institution and whether its assets
are being used for the accomplishment of the institution’s mission. Scandals
involving financial mismanagement of USNY institutions have been identified in
the past and represent a serious violation of the public trust. As a Trustee or
Board member, you should be aware of the institution’s financial status. Among
the things you should request and examine are copies of periodic fiscal reports
including budget and actual revenue and expenses, year end financial statements,
and tax returns where applicable. Talk to executive staff and other board
members about the financial condition of the institution. Request to speak to
the external auditors if you have specific questions regarding the financial
statements.
For what am I
responsible?
You should meet with
other trustees/board members to discuss their expectations of you. Read the
by-laws; inquire about committees;
organizational structure; financial responsibility; and conflict of interest
policies. Keep in mind that being a trustee/board member requires a commitment
of personal time and effort generally with no fiscal remuneration.
Although varied in
purpose and mission, USNY institutions are, for the most part, government
entities and not-for-profit corporations subject to the Education Law, and other
laws governing not-for-profit corporations wherein trustees/board members must
fulfill certain duties to the institution and the community they serve. Such
duties involve care, loyalty, and obedience.
Duty of
Care
A trustee or board
member must act in good faith and exercise the degree of diligence, care, and
skill that an ordinary prudent individual would use under similar circumstances
in a like position. To conform with this standard, trustees and board members
should:
·
Regularly attend and
participate in board meetings and committee meetings where
applicable;
·
Read, review, and
inquire about materials that involve the institution, especially board
minutes, annual reports, other
reports, plans, policies, and any literature that involves the
institution;
·
Have a fiduciary
responsibility for the assets, finances, and investments of the institution and
exercise due diligence, care, and caution as if handling one’s own personal
finances; and
·
Use one’s own judgment
in analyzing matters that have an impact on the institution.
Duty of
Loyalty/Conflicts of Interest
Trustee/board members owe allegiance to the institution and must act in good faith with the best interest of the institution in mind. The conduct of a trustee/board member must, at all times, further the institution's goals and not the member's personal or business interests. Consequently, trustees/board members should not have any personal or business interest that may conflict with their responsibilities to the institution. A trustee/board member should avoid even the appearance of impropriety when conducting the institution's business. Acts of self-dealing constitute a breach of fiduciary responsibility that could result in personal liability and removal from the board.
The board of trustees/board of education should have a written conflict of interest policy that clearly sets forth the procedures to be followed in instances where a board member's personal or business interests may be advanced by an action of the board, including a provision that the trustee/board member may not participate in any decision to approve any transaction where such conflicting interests may be advanced. The policy should also include a requirement that each trustee/board member provide full, ongoing disclosure to the institution of any interest the trustee/board member and/or his or her family has in any entity that the board transacts business with. The policy should be reviewed and discussed with the institution's attorneys and auditors prior to its adoption.
In addition, there are specific provisions concerning conflicts of interest in Article 18 of the General Municipal Law (applicable to school districts, boards of cooperative educational services [BOCES], county vocational education and extension boards and public libraries), and section 715 of the Not-for-Profit Corporation Law (applicable to education corporations chartered by the Board of Regents). General Municipal Law §806 requires the governing body of each school district to adopt a code of ethics, including standards for officers and employees with respect to disclosure of interest in legislation before the governing body, holding of investments in conflict with official duties, private employment in conflict with official duties, future employment and such other standards relating to the conduct of officers and employees as may be deemed advisable.
A sample conflict of interest policy
is available on the Internal Revenue Service website (http://www.irs.gov/) under Appendix A of the
Instructions to IRS Form 1023.
School board members may contact the
New York State School Boards Association (NYSSBA) at (518) 783-0200 or go to
their website (http://www.nyssba.org/) to
access sample policies 2160, School Board Officer and Employee Ethics and
9120.1, Conflict of Interest for more guidance.
Duty of
Obedience
A trustee/board member
has a responsibility to insure that the institution’s resources are dedicated to
the fulfillment of its mission. The member also has a duty to ensure that the
institution complies with all applicable laws and does not engage in any
unauthorized activities.
The NYS Attorney General
publishes Right from the Start-Responsibilities of Directors and Officers of
Not-for-Profit Corporations, which may be obtained from the following web
site:http://www.oag.state.ny.us/charities/not_for_profit_booklet.pdf
The booklet contains more detailed
information on the duties of a trustee/board member of a not-for-profit
corporation.
What is the difference
between provisional and absolute charters?
Corporations formed for
the principal purpose of operating a college, university, school conducting some
or the entire grades nursery through twelve, library, museum, historical
society, or public television and/or radio station are created by the Board of
Regents by issuance of an instrument called a charter, which sets forth the
powers of the corporation. The document by which all other education
corporations are created is known as a certificate of
incorporation.
The initial
incorporation of the educational institution is executed by the issuance of a
provisional charter that is valid for a fixed term of one-to-five years. If the
Board of Regents is not satisfied that the corporation can qualify for an
absolute charter, it may extend the provisional charter for an additional term
of years.
The process for the
issuance of a certificate of incorporation is the same as that pertaining to a
provisional charter. The legal effect of a certificate of incorporation is the
same as that of an absolute charter.
If you are a trustee of
a chartered institution, you need to be aware of the
Following:
·
Whether your institution
has a provisional or absolute charter from the Board of
Regents;
·
The specific standards
that apply to your institution (see
Appendix C);
·
The specific powers of
the corporation contained in the charter; and
·
Whether the board has
the number of members stipulated in its charter.
How do I distinguish
between my governance role and that of a supporter or team player for my
institution?
There is a fine line
between governance and being a supporter of an institution. Members need to
avoid meddling in managing daily affairs. Trustees/board members must balance
their role as supporters for the institution’s success against their governance
role as overseers of the institution’s management to ensure that assets are used
properly, laws and regulations are followed, and the public interest is best
served. The board needs to support the institution’s management but must also
govern by holding the chief executive officer (CEO) accountable for the
institution’s operations and service to the public.
In the governance role,
trustees/board members should be concerned with protecting the public interest
which they serve. Members exercise this role by hiring a CEO to manage the
operation of the institution and evaluating his/her overall performance in
providing services to the public.
In a supportive role,
board members assist by fund-raising, liaison and networking with other
community leaders, and providing expertise in specialty areas such as law,
planning, accounting, and overall corporate management.
What if I lack knowledge
or experience in fiscal governance?
One of the most
important responsibilities of a trustee or board member is to ensure that
financial resources are being used efficiently and effectively toward meeting
the institution’s goals, in compliance with applicable law and regulation, and
that its assets are properly safeguarded. The area of fiscal governance is one
in which board members may feel the least qualified and rely entirely on the CEO
for guidance.
Trustees/board members
should be cautious about relying completely on the guidance and judgment of the
institution’s CEO and management. Members have ultimate responsibility for
governance of the institution’s resources and their primary role of protecting
the public interest. In monitoring the institution’s budget, board members
should ask questions about the assumptions made in preparing the budget. What
types of data are used to prepare the budget? How were
estimates developed for such expenditures as payroll, supplies and materials,
travel and conferences, capital outlays, etc.? Are accounting and/or management
processes adequate to ensure accurate and reliable data? What will be
accomplished by passing this budget? How will outcomes be measured, evaluated
and reported? How will the board hold the CEO accountable for budget outcomes?
How are variances from expectations handled?
Trustees/board members
should also ask questions about the institutional year end financial statements.
Inquire as to what they mean; what is the fiscal condition of the entity? If the
auditors’ issued a management letter, request to review the
letter.
Similar questions may be
raised about other areas, such as the institution’s system of financial
controls, processes employed to comply with applicable laws and regulations,
accountability with performance results, etc. Board members should be aware
of an institution’s internal control system. The existence of adequate systems
of internal controls is also critical for the protection and oversight of the
institutions assets. Internal controls are systems to protect the assets of an
organization, create reliable financial reporting, promote compliance with laws
and regulations, and achieve effective and efficient operations.
The NYS Attorney General
publishes Internal Controls and Financial Accountability for Not-for-Profit
Boards which may be obtained from the following web site address: The document contains
more detailed information on evaluating internal control systems.
What if the institution
needs more expertise with fiscal matters?
When matters of fiscal
governance become very technical and require greater expertise in assessing the
fiscal condition of the institution or its long-term well-being, a board should
seek the advice of experts. One mechanism for giving emphasis to the
responsibility of fiscal governance is to create an audit committee composed of
board members who have expertise in dealing with fiscal
affairs.
An audit committee is
organized pursuant to a charge or mission approved by the board. It should be
established in the institution’s charter, certificate of incorporation or
by-laws.
·
Helping set the fiscal
environment or “tone at the top,” which promotes a theme of fiscal
responsibility and ethical conduct among all institution staff and board
members;
·
Reviewing the certified
financial audit report of the institution and providing input on the results to
the full board;
·
Assessing the
effectiveness of the institution’s system of internal controls and reporting on
any weaknesses;
·
Assessing any risk
associated with the validity and reliability of financial data;
and
·
Monitoring compliance
with laws and regulations applicable to the institution’s operations.
These are just some of
the many activities that an audit committee can pursue to assist a board in its
role of fiscal governance. (Appendix
D) provides links to web sites that contain more information on audit
committees and other issues relevant to the duties and responsibilities of
trustees and board members.
Where can I get
additional help?
There are many sources
available to trustees and board members needing further information and guidance
on their role. Members are encouraged to seek additional guidance, evaluate the
need for additional training, and contact the NYS Education Department (SED) for
guidance. The offices and contact information for SED are illustrated in (Appendix E).
The procedures for the
creation of education corporations by the Regents, and other related matters,
are outlined in the pamphlet entitled “Education Corporations–Law Pamphlet 9.”
This pamphlet is available from the NYS Education Department Office of Counsel,
and is available on the SED web site: (www.counsel.nysed.gov).
Members are strongly
encouraged to seek the advice of an attorney in matters involving the
interpretation of laws and regulations pertaining to the institution’s
operations. The information contained in this document is not a substitute for
the guidance provided by legal counsel.
The appendices contain
additional information that may be helpful in fulfilling your role as a trustee
or board member. Their content is listed below.
Topic
Appendix
Top Ten Warning Signs
for Boards
A………………9
Best Practices for
Boards to Follow
B………………10-12
Select Regulations of
the Commissioner of Education Applicable
C………………13
to Chartered Institutions
Links to Web Sites
D………………14-15
Contact Offices in SED
by Type of Institution
E……................16-17
Report Waste, Fraud, and
Abuse
F………………18
Appendix
A
The University of the
State of
The State Education
Department
Top Ten Warning Signs
for Boards
1.
Lack of available
documentation on the organization’s by-laws,
charter, mission statement, organization chart, and prior year financial
statements.
2.
Lack of independent
attitude or excessive conflict among trustees/board
members.
3.
Infrequent board
meetings. Absence of board minutes.
4.
Poor board attendance at
meetings.
5.
Lack of access to key,
fiscal, budget, program, and operations
information.
6.
Lack of access to the
chief financial officer.
7.
Existence of conflict of
interest relationships or less than arm’s length transactions between the
institution’s board members and organizations that conduct business with the
institution.
8.
Lack of internal
financial controls and written policies and procedures to safeguard, promote,
and protect the organization’s funds and other assets. Lack
of fidelity bonds.
9.
Lack of involvement in
the hiring of key employees.
10.
Failure to file
documents with key control agencies such as the NYS Education
Department, Internal
Revenue Service, and NYS Department of Taxation and
Finance.
Appendix
B
The University of the
State of
The State Education
Department
Best Practices for
Boards to Follow
1. Be informed of the
institution’s activities by:
·
Discussing operations
with board members and officers.
·
Reviewing materials
provided by the institution.
·
Actively participating
in meetings of the board and the committees.
·
Asking questions and
obtaining an understanding of the issues facing the institution.
·
Attending fiscal
training for board members and Trustees.
2. Establish an audit
and finance committee with responsibility to periodically
meet with management and
the auditors to consider:
·
The adequacy of internal
controls and financial reporting processes, and the
reliability of fiscal
reports.
·
The independence and
performance of the internal and external auditors.
·
Steps taken by
management to address audit report findings.
·
Compliance with legal
and regulatory requirements.
·
Steps taken by
management to minimize significant risks to the
institution.
·
School districts and
BOCES are required to have an audit committee.
·
Museums, historical
societies and cultural agencies are required to have an audit
committee.
3. Ensure the
institution is carrying out its purpose without extravagance or
waste and is not
engaging in any questionable or illegal activities by:
·
Requiring management to
provide periodic reports on how well the institution
is fulfilling its
mission and the activities accomplished for the period.
·
Approving strategic
plans, budgets, policies, plans of operation, development
plans and goals,
contracts, implementing standards of operation,
key financial and program reports, and other items.
·
Holding the chief
executive officer accountable for results.
·
Being involved in the
selection and compensation of the chief executive officer.
·
Using good judgment in
analyzing matters that may impact the institution.
·
School districts are
required to have an internal committee to review internal
controls.
·
Reviewing all
claims.
4. Monitor the financial
condition and management practices of the institution by:
·
Reviewing periodic
fiscal reports, financial statements,
audit reports, management letter; including managerial letters, and tax returns.
·
Ensuring reserve funds
are used for their intended purposes.
·
Verifying fund raising
expenses are reasonable in relation to the amount of fund raising revenue
generated.
·
Ensuring net assets are
positive, but not excessive.
·
Verifying that deficits
are being addressed with remedial action.
·
Ensuring records are
complete and accurate, and required reports are filed
with federal and state
agencies.
·
Issuing a Request for
Proposal (RFP) for an external auditor at least once every five years.
5. To help ensure
effectiveness, trustees/board members need to
ensure boards address the
Following; consistent with
statute:
·
Consist of a minimum of
five voting members who are independent.
·
Meet at least twice a
year, and more often as needed or required by statute.
·
Keep complete and
accurate minutes of all meetings.
·
Convene an annual
meeting and elections as required by law.
·
Not compensate their
members for services in their role as trustee or board member (see note below).
·
Develop a training program for both
new and experienced board members.
·
Seek expert advice when needed.
·
Avoid any conflict of interests or even
the appearance of a conflict and maintain
a conflict of interest policy for board members and employees.
·
Require each member to
file an annual written disclosure of any business
involvement with the
institution or related parties.
·
Assess the need for
liability insurance to protect board members and officers
from legal liability.
·
Ensure processes for
selecting new members result in diversity of viewpoints and seek out individuals
with commitment, skills, life experience, background, and other characteristics
that will serve the institution and its needs.
·
Be aware of the
requirement to petition the Regents to amend the charter or certificate of
incorporation to change the name, address or purposes of the corporation.
· Be aware of the laws and regulations relating to dissolution of the corporation, and not distribute, disperse or spend down any assets without going through the proper dissolution procedure.
Note: Reimbursement for
expenses in the ordinary course of business does not constitute compensation.
Trustees/board members who also serve as officers may receive compensation in
their role as an officer (e.g., treasurer, secretary). In addition, some school districts are
allowed under the law to compensate their Board Members.
Appendix
C
The University of the
State of
The State Education
Department
Select Rules of the
Board of Regents and Regulations of the Commissioner of
Education
Applicable to Chartered
Institutions
………………………………………………………………………………………………………
Elementary and Secondary Schools
Part 100 and Sections 170.2, 170.3, and
170.12 of the
Commissioner’s Regulations
……………………………………………………………………………………………………….
Nursery Schools and Kindergartens Part
125 of the Commissioner's Regulations
………………………………………………………………………………………………………
Libraries and Library Systems
Part 90 of the
Commissioner's Regulations
………………………………………………………………………………………………………..
Historical Societies
Without Collections
Section 3.30 of the Rules of the Board
and Cultural Agencies
of
Regents and Section 52.22 of the
Commissioner's Regulations
……………………………………………………………………………………………………….
Museums and Historical
Societies
Section 3.27 of the
with Collections Rules
of the Board of Regents and Section
52.22 of the Commissioner's
Regulations
……………………………………………………………………………………………………….
Public Television and/or
Radio Stations
Part 26 of the Rules of the Board of Regents and Part 179 of the
Commissioner's Regulations
……………………………………………………………………………………………………….
Colleges and
Universities
Parts 50 through 54 of the Commissioner's Regulations
Note: This list is not
exhaustive. Moreover, it does not include relevant provisions of the Education
law or other laws affecting these institutions.
Appendix
D
The University of the
State of
The State Education
Department
Links to Web
Sites
Government Agencies
Internal Revenue
Service
http://www.irs.ustreas.gov/
NYS Attorney
General
http://www.oag.state.ny.us/
NYS Education
Department
http://www.nysed.gov/
Office of General
Services
http://www.ogs.state.ny.us/
Department of State
http://www.dos.state.ny.us/
Civil Service
http://www.cs.state.ny.us/
Taxation &
Finance
http://www.tax.state.ny.us/
NYS Office of the State
Comptroller
http://www.osc.state.ny.us/
Education Associations
American Association of
School Administrators
http://www.aasa.org/
Education Commission of
the States
http://www.ecs.org/
Educational Research
Service
http://www.ers.org/
National Association of
State Boards of Education
http://www.nasbe.org/
National School Boards
Association
http://www.nsba.org/
New England School
Development Council
http://www.nesdec.org/
New York State School
Boards Association
www.nyssba.org
Not-for-Profit
Associations
Center for Non-Profit
Corporations
http://www.njnonprofits.org/
Guidestar (IRS Form 990
database)
http://www.guidestar.org/
Law about Nonprofit
Organizations
www.law.cornell.edu/topics/nonprofits
Nonprofit Evaluation
Tools
http://www.innonet.org/
Urban Institute – Center
on Nonprofits
http://www.urban.org/
Museums/Art
Associations
American Association for
State and Local History
http://www.aaslh.org/
(AASLH)
American Association of
Museums (AAM)
http://www.aam-us.org/
Museum Association of
New York (MANY)
http://www.manyonline.org/
New York State Council
on the Arts,
http://www.nysca.org/
Museum Program (NYSCA)
The International
Council of
http://www.icom.org/
Museums (ICOM)
Library
Associations
American Library
Association’s Association for
www.ala.org/alta
Library Trustees and
Advocates
New York Library
Association
http://www.nyla.org/
New York State
Association of Library Boards
http://www.nysalb.org/
New York State
Library
www.nysl.nysed.gov/libdev
DISCLAIMER: These sites
are provided for the user’s convenience. The State Education Department (SED)
does not control or guarantee the accuracy, relevance, timeliness or
completeness of web sites not maintained by SED. Further, the inclusion of such
sites on this list is not intended to reflect their importance, nor is it
intended to endorse views expressed, or products or services offered, on these
outside sites, or the organizations sponsoring the sites.
Appendix
E
The University of the
State of
The State Education
Department
Contact Offices in SED
by Type of Institution
To obtain further
guidance about the governance role of a trustee or board member, you may contact
the following addresses, telephone numbers, and web sites for your respective
institution.
Institution
Contact
Office
Public schools,
School Operations and Management Services
Boards of
Cooperative
Office of Elementary,
Middle, Secondary, and
Educational Services
Continuing Education
Room 874 EBA
518-474-2238
Nonpublic schools
Office for Nonpublic
School Services
Room 481 EBA
www.emsc.nysed.gov/rscs/nonpub.htm
518-474-3879
Charter Schools
Room 462 EBA
518-474-1762
Museums, historical
societies,
and other Cultural
agencies
Room
3097 CEC
518-473-3131
Libraries and library
systems
Division of Library Development
NYS Library
NYS Education Department
Room 10C50 CEC
www.nysl.nysed.gov/libdev/libs/index.
htmal#trustee
518-474-7196
Public, independent, and
propriety
Office of Higher
Education
colleges and
universities, licensed
NYS Education
Department
private and registered
business schools
2 M West Wing
http://www.highered.nysed.gov/
518-474-3862
Independent living
centers
Office of Vocational and
Educational Services
for Individuals with
Disabilities
One
www.nysed.gov/vesid
518-474-3946
Psychotherapy Institutes Executive Secretary to the State Board for Psychology
Office of the Professions
http://www.psychbd@mail.nysed.gov/
518-474-3817
ext. 150
Appendix
F
The University of the
State of
The State Education
Department
Report Fraud, Waste, and
Abuse
The New York State
Education Department is interested in information pertaining to fraud, waste,
abuse, or mismanagement of local, state, or federal education funds (including
information on vendors who receive education funds). Both the Board of Regents
and the Commissioner of Education take these concerns very
seriously.
Individuals who make an
allegation are not required to identify themselves; they may remain anonymous.
In such cases, the State Education Department will assess the information
provided, given the constraints of an anonymous contact. Therefore, persons
making a complaint may wish to provide contact information in the event
additional questions arise.
Preferred
Method:
Fill out electronic
complaint form the following address:
Other
Methods:
·
Email: www.OAS@mail.nysed.gov
·
Phone:
518-473-4516
·
Fax:
518-473-0259
·
Mail:
New York State Education
Department
The Office of Audit Services
(OAS)