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Sudbury Public Schools (SPS) Acting Director of Business and Human Resources Buck Creel told the School Committee’s Budget Subcommittee on Oct. 23 that the district should have its next permanent business director conduct an audit of all student activity accounts, noting he could find no evidence that an audit has been performed on any of the accounts in the past three years. Creel explained “I can’t find where Don [Sawyer] did an audit in the past three years.”
The recommendation touches on accounts governed by both Massachusetts General Law (M.G.L. c. 71, § 47) and Sudbury School Committee Policy JJF, which establishes protocols for managing, expending, and auditing monies raised for student organizations, field trips, and school programs. Creel explained they are mostly used for field trips.
According to Policy JJF, student activity checking accounts operated by building principals are required to be audited annually in accordance with Massachusetts Department of Elementary and Secondary Education (DESE) guidelines. In addition, for student activity accounts that maintain maximum balance limits exceeding $25,000, district policy specifies that the School Committee shall consider having an audit conducted by an independent outside audit firm every three years.
Sudbury’s Assistant Town Manager and Finance Director Victor Garofalo clarified the division of fiscal responsibility between the town administration and the school district regarding the accounts.
“The Town Finance Department does not administer SPS’s collection of payments from parents or maintain the School Department’s records identifying which families have paid for field trips, student activities, or other school programs,” Garofalo said in a statement. “SPS is responsible for collecting and tracking those payments, and the school principal oversees the applicable student activity accounts and expenditures.”
Garofalo emphasized that State law keeps the operational control of those funds within the schools rather than municipal finance offices.
“Under M.G.L. c. 71, § 47, student activity funds are maintained separately, and the school principal operates and controls the Student Activity Checking Account for activities authorized by the School Committee,” Garofalo said. “The Town’s role is limited to receiving funds turned over to it and processing approved vouchers through the established municipal process. The Town Finance Department does not maintain the underlying parent payment records or determine how student activity funds are spent. Those responsibilities remain with the School Department and the respective school principals.”
Creel made it clear to the Budget Subcommittee that an audit would be good practice, but he didn’t have major concerns. “If I thought it was a real risk then I would say we would conduct an audit this year. But then, again, a new school business official is going to want to conduct that audit as one of the turnover things.”
Subcommittee Member Betsy Sues asked during the October 23 meeting “Is someone reconciling to bank statements at least?” Creel responded “I don’t know. I assume so.” He added that he would, if he were a permanent director in the district, get staff to stop using checkbooks and begin using the procurement system.
Creel concluded “In the context of a 52, 53 million dollar budget, you’re absolutely right, it’s a relatively small exposure.”
The budget subcommittee opted to authorize Member Karyn Jones to work with Creel on a memo to update the full committee. The gist of the discussion was to hold off on an audit and policy update until a a later date, or potentially until a new Business Director was onboarded. The district hasn’t disclosed if its existing Director of Business and Human Resources, Don Sawyer, will be returning to his post or not.
Jump to 2:26 below for the discussion.

