Ohio School Boards Association

OSBA assisting with guidance on nutrition-focused student wellness Submitting school safety plans Conducting emergency drills The role of the security officer/ school resource officer in your schools School district contract settlements Working well with your board of education: A workshop for administrative assistants and professionals

September 2012

Third-grade reading guarantee by Renee L. Fambro deputy director of labor relations One hotly debated provision of Senate Bill (SB) 316 was the third-grade reading guarantee. In the end, there were changes made to student retention criteria, diagnostic assessments, and intervention and reporting requirements. Below is a review of the changes made to the Ohio Revised Code (RC). Because there are different implementation dates throughout the legislation, it’s important to pay careful attention to what your district must do now and what must be done in school year 2013-14. Due to the complexity of the law, the Ohio Department of Education (ODE) has created a guidance document to help districts navigate the new third-grade reading requirements. The document can be found at http://links. ohioschoolboards.org/23286.

Assessment and intervention

Beginning with school year 2012-13, districts and community schools are required to annually assess the reading skills of each student in grades K-three by Sept. 30, and identify students reading below grade level. Districts and community schools must administer to all students the state-developed diagnostic assessment in English language arts or a comparable tool approved by ODE. According to ODE’s guidance document, because these changes were made during the summer after many districts had already ordered their diagnostic tools, districts may use the state’s reading diagnostic assessment or any diagnostic assessment they had planned to use in school year 2012-13.

Districts and community schools have two immediate responsibilities when a student is identified by the diagnostic assessment as having reading skills below grade level. First, they must provide written notification to the parent or guardian, which: l states that the student has been identified as having a substantial reading deficiency; l describes the current services provided to the student; l describes the proposed supplemental services and supports to be provided; l explains that the student may be retained in third grade if the student scores below the “cut” score as established by the State Board of Education in the “limited” range on the third-grade reading assessment, unless the student falls into one of the exceptions; l specifies that the assessment is not the sole determinant of promotion and that additional evaluation and assessments are available to the student to help parents and the district know when a student is reading at or above grade level and is ready for promotion. Secondly, districts and community schools must provide intensive reading instruction that includes “research-based reading strategies that have been shown to be successful in improving reading among low-performing readers and instruction targeted at the student’s identified reading deficiencies.” School districts and community schools must develop a reading improvement and monitoring plan for each student identified as reading below grade level within 60 days of receiving the diagnostic assessment results. The district shall involve the student’s parent or guardian in developing the plan. The plan

must: l identify the student’s specific reading deficiencies; l describe the additional instructional services and support that will be provided to remediate the student’s deficiencies; l include opportunities for parental involvement in those services and support; l specify a process for monitoring the student’s receipt of the services and support; l provide a reading curriculum during regular school hours that helps the student read at grade level, provides scientifically based and reliable assessment and provides initial and ongoing analysis of the student’s reading progress; l state that the student may be retained in third grade for failure to pass the third-grade reading achievement assessment. According to RC 3313.608(C)(6), beginning with students entering the third grade in school year 2013-14 or later, districts and community schools must assign each student who has a reading improvement and monitoring plan to a teacher who either has

received a passing score on a rigorous test of principles of scientifically based reading instruction or has a reading endorsement on the teacher’s license. For each student retained in the third grade, districts and community schools must: l Provide intense remediation services until the student is able to read at grade level. These services must include intensive interventions in reading that address the areas of deficiencies, including, but not limited to, no less than 90 minutes of daily reading. Other services are optional. l Establish a policy for mid-year promotion if the student demonstrates that he or she is reading at or above grade level and is reading proficiently in accordance with standards developed by ODE. l Provide a high-performing teacher as determined by the teacher’s student performance data and performance reviews, when such data is available. l Offer the option to receive services from other service providers, but they must be screened and approved by the district or ODE. SB 316 includes summer reading camps as an option for services offered

SMN Ohio School Boards Association 8050 N. High St., Suite 100 Columbus, OH 43235-6481 (614) 540-4000 or (800) 589-OSBA fax: (614) 540-4100 l www.ohioschoolboards.org OSBA President: Sharon E. Manson, Waverly City and Pike County Career Technology Center OSBA Executive Director: Richard Lewis, CAE Editor: Renee L. Fambro, deputy director of labor relations Layout and design: Angela Penquite, communication design manager A one-year subscription to School Management News is $185 for paper subscriptions; $150 for electronic subscriptions. For more information, contact Ann Herritt at the address or fax number above or email [email protected]. SMN is published monthly by the Ohio School Boards Association. Postage paid at Westerville, Ohio. Postmaster: Send address changes to: SMN, Attn.: Mailroom, Ohio School Boards Association, 8050 N. High St., Suite 100, Columbus, OH 43235-6481. © 2012 Ohio School Boards Association OSBA leads the way to educational excellence by serving Ohio’s public school board members and the diverse districts they represent through superior service and creative solutions.

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to retained third-graders, but it does not mandate summer service. It also eliminates the requirement under current law that summer remediation must be provided in a school or community center and not on an at-home basis.

Retention

First, changes were made that impact the State Board’s duties related to the third-grade reading guarantee. SB 316 requires the State Board to determine and designate a “cut” score on the third-grade English language arts assessment, not lower than “limited,” for students to be promoted to fourth grade. The State Board will progressively increase this level of achievement until the retention requirements apply to students who do not receive at least a “proficient” score under RC 3301.0710(A)(2). No later than Dec. 31, 2013, the State Board must submit to the General Assembly recommended changes to scoring ranges on achievement assessments necessary for the successful completion of the Common Core curriculum and assessments in school year 2014-15. Next, several changes were made regarding which students can be retained beginning with students entering the third grade on or after July 1, 2013. After this date, districts and community schools are generally prohibited from promoting a student to fourth grade who scores in the “limited” range on the third-grade reading achievement assessment, with the following exceptions: l Limited English proficient students who have been enrolled in U.S. schools for less than two full school years and had less than two years of instruction in an English as a second language program. l Special education students whose individualized education programs (IEPs) exempt them from retention under the third-grade guarantee, and special education students whose IEPs or 504 plans show they have received intensive remediation in reading for two school years and were retained in any grade, K-three, but still

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demonstrate a deficiency in reading. l Students who demonstrate an acceptable level of performance on an alternative standardized reading assessment as determined by ODE. l Students who received intensive remediation in reading for two school years, but still demonstrate a deficiency in reading, and were retained in any grade, K-three, as long as the student continues to receive intensive reading instruction in fourth grade. This instruction must include an altered instructional day that includes specialized diagnostic information and specific research-based reading strategies that have been successful in improving reading among low-performing readers. Districts and community schools are required to provide all retained third-graders with instruction in a specific academic field that is commensurate with student achievement levels. In other words, retained students who demonstrate

proficiency in subjects other than reading should receive fourth grade instruction in those subjects.

required to comply with the terms of the third-grade reading guarantee.

Reporting requirements

Unfortunately, districts were not given a lot of time to incorporate these changes into the upcoming school year. One area that needs immediate attention is board policy. Language changes in RC 3313.608 and 3313.609 require changes to board policy, including a new policy and regulation which needs to be adopted by Sept. 30, 2012. Boards that subscribe to OSBA’s policy services received information about the required policy updates in the August 2012 issue of Policy Development Quarterly. As your district moves forward with the required changes, it’s important to note that there are places where the law differs from what appears in the ODE guidance document. In those cases, we suggest districts with clarification or implementation questions contact ODE directly for further guidance.

Districts and community schools are explicitly required to submit the results of the K-three diagnostic assessments in English language arts and math to ODE. Also, they are required annually to report to ODE on district implementation and compliance with the third-grade guarantee requirements. In addition, the districts and community schools are required to report any information requested by ODE about the reading improvement and monitoring plans. ODE will then issue a report on collected data. 

Community schools

SB 316 requires community schools to comply with the existing law requiring each school district to adopt a promotion and retention policy. In addition, community schools are now

Implications for schools

OSBA assisting with guidance on nutrition-focused student wellness by Megan Greulich policy consultant Student wellness has been a hot topic for some time. Although district resources are stretched thin, student wellness remains an important part of the education environment. The Ohio Department of Education (ODE) and Ohio Department of Health (ODH) recently received a grant from the National Association of State Boards of Education (NASBE) to promote student wellness through nutrition, physical activity and general health guidance. OSBA is part of a stakeholder group that ODE and ODH have assembled to begin this important work. Policy language dealing with student wellness and nutrition is required by state and federal law. At the state level, the requirements stem from the

September 2012

Healthy Choices for Healthy Children Act (Senate Bill 210). At the federal level, the requirements come from the Healthy Hunger Free Kids Act, which extended the requirements set forth by the Child Nutrition and WIC Reauthorization Act of 2004. While requirements are in place at the state level, ongoing federal legislation will likely affect how student wellness is dealt with in school districts. Whether the guidance and requirements come from state or federal law, determining how to implement them is a local decision as long as the implementation complies with legal standards. While the stakeholder group is working on three topics dealing with student wellness, OSBA is assisting with the nutrition-based wellness guidance. The goal is to help districts prepare for the requirements set forth by state and federal law by providing policy samples

that can be implemented, depending upon available resources. The guidance will help districts develop local board and district policies and procedures to carry out the legal requirements. The guidance will provide several levels of options for districts to implement as they see fit, culminating with a “gold standard” for districts that have the available resources. The basic form of guidance will provide districts with a minimum standard. The mid-level will build on the basic level by providing guidance for districts wishing to exceed the minimum requirements and the highest level of guidance, the “gold standard,” will provide districts with guidance that represents a best-case scenario approach to student nutrition-based wellness. All three levels of guidance will be legally compliant, but will provide different options for implementing the legal

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standards to suit individual district needs. The stakeholder group is aware that not all districts have the resources to go above and beyond the legal requirements. With that in mind, the group endeavors to provide legally compliant guidance and options for all districts. The goal is not to single out districts that can’t implement the gold standard, but to provide guidance to all types of districts that can be used to develop the best possible policies and procedures for their specific needs and available resources. School districts cannot, nor should they endeavor to, fix the problems associated with student wellness alone. But by providing districts with appropriate guidance, the work group hopes to help districts become part of the solution. Apart from the policy guidance, it is important for school boards, administrators and teachers to

understand the importance of student wellness and proper nutrition and their roles in educating students on these topics. Student wellness is tied to student performance. As a result, all members of the educational community should work together to improve student wellness. At the end of the day, everyone in the district is working toward the shared goal of student success, and although the topics aren’t always considered together, student wellness and student success go hand in hand. Providing student wellness guidance gives districts the resources to educate themselves and implement wise standards within their means. Board policies on these topics should reflect the legal requirements, and district-level policies and procedures should include additional details about district practices. While school boards must adopt policy on these topics,

district nutrition and wellness experts should have the flexibility to implement board policy. As always, school boards should set standards and allow district experts to implement board policies by developing district-level policies and procedures. When it is complete, the work group’s guidance will help develop both board and district-level policies and procedures. Districts should watch for more information on student wellness. In the meantime, OSBA welcomes your input. If you have infomration to share, please contact Kenna Haycox at khaycox@ ohioschoolboards.org or (614) 540-4000. We would be happy to pass along your insights to the current stakeholder group during the development process. Districts can’t solve every problem, but when it comes to student wellness, they can be part of the solution.

Submitting school safety plans by Van D. Keating director of management services The other day I found myself in a meeting with the Ohio attorney general’s staff (OAG), discussing school security plans. More specifically, the conversation focused on proposed legislation in which districts could be subject to fines for failing to submit building floor plans and related security details. Currently, nearly 150 school buildings around the state are not in compliance. I was a little surprised that even though there are 4,000-plus school buildings in Ohio, 150 have not submitted anything to OAG. Without getting technical or legal, the purpose of sending floor and security plans to OAG is to allow the office to place them online so any emergency responders can access them if needed. As we have seen in the media when catastrophes occur, it is not always your local police or fire departments that get there first. It may be a responder from

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the township next door or perhaps a passing state trooper on the way to work. Having all building floor plans on the state website allows any first responder to immediately react to the situation, and not wait until another responder shows up. Time is not a luxury in these situations. Another point raised in our conversation was that while OAG is currently clarifying guidelines as to what needs to be submitted, currently it is receiving all types of plans, some more useful than others. When submitting a plan, keep in mind the purpose it is supposed to fulfill. The plan is to allow a first responder to quickly look at and determine a course of action depending on the type of emergency. Actual blueprints, while detailed, are overly complicated, confusing and not very user-friendly. However, simple line drawings of a floor plan that do not identify important features such as electrical boxes, on/off valves, windows and doors are equally useless.

Keep in mind that the submitted plans will need to be turned into an electronic format. If you can’t do that, it is a safe bet OAG might not be able to either. The main emphasis of my meeting was on what might be done to reach 100% compliance with submitting safety plans. Apart from fining non-compliant districts, the idea of publicizing them was raised, with the intent of embarrassing or creating additional pressure on them. In theory, since we are talking about student and employee safety, if a school is not doing everything it can possibly do, the public should be aware of that. But, in our representation of school boards, it also is unclear how many of the offending school districts’ boards of education were notified and provided an opportunity to respond. Developing and submitting safety plans is an administrative responsibility; however, boards of education are ultimately the responsible body in this situation, so they need to maintain some

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involvement and awareness of school safety plans. By the meeting’s end, it became apparent, and not unexpected, that OAG wants some enforcement ability in requiring districts to submit safety plans. Current law does not provide that, and it is embarrassing to note that 150 school buildings have not yet

complied. At the recent Ohio School Safety Summit, Chardon Local (Geauga) discussed how and why its safety plan worked, demonstrating that safety plans are necessary and do save lives. So, develop and submit your school safety plans. They can be submitted by email to: SchoolPlans@ OhioAttorneyGeneral.gov or hard

copies may be mailed to OAG at: School Digitization Project
 Ohio Attorney General’s Office
 150 E. Gay St., 18th Floor
 Columbus, OH 43215 Remember — it is the law and perhaps the most important thing you can do for your employees’ and students’ lives.

Conducting emergency drills by Kenna Haycox policy consultant Just when the beginning of the school year “to-do” list seems to be getting shorter, something else is added. Hopefully, one of the responsibilities on your to-do list is to ensure the appropriate emergency drills are in place and practiced as required by law. Let’s take a look at the required drills and some helpful resources available to districts. Ohio Revised Code Section (RC) 3737.73 outlines the requirements for fire drills, tornado safety precautions and safety drills. The times and frequency of these drills are prescribed in rules adopted by the state fire marshal. Three types of drills must be conducted in each school building: emergency evacuation drills, tornado drills and school safety drills.

Emergency evacuation drills

Staff and students are most familiar with emergency evacuation drills such as fire drills. These drills ensure that children can leave a building in a sudden emergency in the shortest amount of time possible, without confusion. It is important to have your evacuation plans and routes posted, and communicate this information to staff to review with students. The Ohio Fire Code (OFC) requires an emergency evacuation drill to be conducted during the first 10 days of the new school year. Throughout the school year, a minimum of nine emergency evacuation drills must be

September 2012

conducted. If you have a fire alarm system, the drill must be initiated by activating the fire alarm. Efforts also must be made to determine if all occupants were evacuated and accounted for. Your building may choose to do this by having the classroom teachers take attendance when their class is assembled. While it may be tempting to conduct all drills near the end of a day with good weather, it is important to note that OFC requires drills to be held at unexpected times and under varying conditions. Building administrators responsible for drills should plan for this, and understand that it’s possible that students and staff may have to stand in the rain or snow for a few minutes one day. After conducting a drill, the following must be documented: the person conducting the evacuation; the date, time and notification method used; staff members on duty; number of occupants evacuated; special conditions simulated; problems encountered; weather conditions; and how long the evacuation took.

Tornado drills

Tornadoes present a very real danger in Ohio. Schools are required to have building plans for precautions to be taken in case of a tornado alert or warning, including designated locations to be used to shelter pupils. Building administrators should clearly communicate this information to staff, and information should be posted that shows where shelter areas are located.

OFC requires tornado drills to be conducted at least once a month, whenever school is in session, during the tornado season (April 1–July 31). After conducting the drill, documentation must be made of the date, hour, time, number evacuated and weather conditions.

School safety drills

School safety drills ensure students know the procedure to follow in situations where they must be secured in the school building. These situations could include a threat to the school involving an act of terrorism, a person possessing a deadly weapon or dangerous ordnance on school property, or other act of violence. A school safety drill must be conducted annually on or before Dec. 1. One important distinction for school safety drills is the staff training requirement. RC 3737.73(D)(3) requires the principal to hold annual training sessions for school employees on how to conduct school safety drills. This training could be integrated into the beginning of the year in-service meetings for staff. Another important distinction is that the school must provide advance written notice to the local police chief, or other similar chief law enforcement officer or sheriff no later that 72 hours prior to the time the drill will be conducted. The notice must include the date and time of the drill and the address of the school. As with all drills addressed in RC 3737.73, documentation must be made of the

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safety drill, including the month, date, time and length of the drill.

Record keeping

The state fire marshal has provided a form that districts must submit twice a year, at the middle and end of the school year. This form is available at http://com.ohio.gov/fire/Forms. aspx#CodeEnforce. The form outlines the information that must be recorded

for each drill and how frequently each must be conducted. School safety is important. By having plans and procedures in place, schools can be better prepared to address emergency situations. Make sure you are taking the steps necessary for the safety of your students and staff during a fire, tornado or school safety situation. In addition to the required drills, it is important that you are compliant with

other policies and procedures required for staff and student safety. OSBA policy service subscribers have general language that you may want to review as a refresher in ECB, Emergency and Safety Plans. School safety issues are not going away, and being prepared to address them is critical for the learning environment and to help protect a district from litigation.

The role of the security officer/school resource officer in your schools by Dr. Richard J. Castor senior school board services consultant The 1999 Columbine tragedy spurred much activity in the area of protecting students from lethal violence. The federal government responded with money from the Community Oriented Policing Service (COPS) office. This money was used to place security personnel, both private and sworn law enforcement officers, in schools. The threat is every bit as real today as it was in 1999. In fact, it has escalated, considering the potential for domestic and international terrorism. Given these concerns, what is the best way to use school security personnel? What are the expectations for their performance and how do they fit into the overall school organization? Without doubt, a job description needs to be developed for these officers. In addition to the job description, a memorandum of understanding (MOU) is imperative when sworn law

enforcement personnel are assigned to a school, because it addresses essential issues that come from an “outside” person working in the school. Does the workday start when the officer leaves home or when he or she arrives at school? To whom does he or she report? What will the school district provide in terms of support (office, computer, telephone, administrative support, etc.)? Copies of the job description and/or MOU must be in the hands of the building administration and the officer. The officer should meet with building administrators and discuss mutual expectations; this should be a very thorough and detailed conversation that helps the administration and officer know and understand duties, expectations and limits. Best practice dictates that security personnel are not to be used in place of teaching staff. Security personnel must remain mobile as much as possible to enable them to respond immediately to an incident. For example, they should be visible in the cafeteria during lunch,

but not assigned to lunchroom duty. Often the security officer’s job turns into hall monitor or study hall supervision; be cautious of putting these individuals in roles that they may not be able to perform legally. Remember, there was a specific reason the district chose to hire a security or law enforcement officer. Keep that reason in focus when you are assigning duties and working with your security personnel. Ohio schools have seen an escalation in potential threats to students and staff. Besides the threat of a disgruntled student, employee or spouse assaulting a school, domestic and international terrorism are always a possibility. Schools hiring security officers should place them in a work environment where they are best able to do their jobs. Make sure you give them clear expectations and support them in meeting those expectations. In the end, everyone’s goal is the same: a safe learning environment where kids can flourish.

School district contract settlements Certified contracts

District: Beachwood City Settlement date: July 2012 Contract term: three years

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Contract particulars: 0% base salary increase in year one, 1.75% base salary increase in year two, 2% base salary increase in year three; employee share of

health insurance premiums increased from 6% to 10%; insurance deductibles increased from $200 to $800 for single insurance and from $400 to $1,600 for

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family insurance; creation of a 16-member committee to establish new teacher evaluation procedures in compliance with the new teacher evaluation system.

increase and no step increase; one-time $250 ratification bonus; re-opener related to teacher evaluations.

District: Hopewell-Loudon Local (Seneca) Settlement date: July 2012 Contract term: three years Contract particulars: 2% base salary increase in year one, 1.5% base salary increase in year two, 1% base salary increase in year three; increase in employee health insurance deductibles.

District: Galion City Settlement date: June 2012 Contract term: one year Contract particulars: 0% base salary increase and no step increase; employees’ share of health insurance premiums increased to 10%.

District: Norwayne Local (Wayne) Settlement date: July 2012 Contract term: three years Contract particulars: 0% base salary increase in year one, 1.5% stipend based on employee’s base salary in year two, wage re-opener in year three. District: Ottawa-Glandorf Local (Putnam) Settlement date: July 2012 Contract term: three years Contract particulars: 0.75% base salary increase in year one, 0.5% base salary increases in years two and three; the addition of two health insurance plans; teacher pay for after-school program reduced from $25 to $20. District: River View Local (Coshocton) Settlement date: July 2012 Contract term: three years Contract particulars: 1% base salary increase in year one, 0.5% base salary increases in years two and three. District: Sylvania City Settlement date: June 2012 Contract term: two years Contract particulars: 0% base salary increases in both years; employee share of health insurance premiums will increase from 6% to 10% effective Sept. 1, 2012. District: Triad Local (Champaign) Settlement date: July 2012 Contract term: one year Contract particulars: 0% base salary

September 2012

Classified contracts

District: Westerville City Settlement date: June 2012 Union: Westerville Educational Support Staff Association Contract term: two years Contract particulars: 0% base salary increases and no step increases in both years; district share of its contribution to employees’ HSAs decreased by 50% on Jan. 1, 2013, and eliminated on Jan. 1, 2014. District: Big Walnut Local (Delaware) Settlement date: July 2012 Contract term: three years Contract particulars: 2.8% base salary increase in all three years; health insurance deductibles doubled. District: Columbiana County Career & Technical Center Settlement date: July 2012 Contract term: three years Contract particulars: 1.5% base salary increases in all three years. District: Delaware City Settlement date: July 2012 Contract term: three years Contract particulars: 1.25% base salary increase in year one, 0.75% base salary increase in year two with the possibility of an additional 0.25% if total revenue projections exceed $45 million in 2013-14; salary and benefits re-opener in year three; mandatory direct deposit; district-paid life insurance benefit increased from $25,000 to $30,000. District: Hopewell-Loudon Local (Seneca)

Settlement date: July 2012 Contract term: three years Contract particulars: 2% base salary increase in year one, 1.5% base salary increase in year two, 1% base salary increase in year three; increase in employee health insurance deductibles.

Other salary news

Administrators at Hopewell-Loudon Local (Seneca) will receive between 2% and 5% salary increase following a pay freeze. Confidential employees and administrative staff at West Branch Local (Mahoning) will have a wage freeze in the 2012-13 school year and will participate in a new vision plan. Confidential employees’ health insurance costs will be consistent with those negotiated in the labor agreement with the classified staff; administrative employees’ health insurance costs will be consistent with those negotiated in the labor agreement for certified staff. Brunswick City administrators, board office secretaries and technology staff will receive 0% base salary increases the next two years. They also will pay more toward their health insurance premiums, have increased deductibles and be consolidated onto one insurance provider. Rossford EV administrators and supervisors volunteered to freeze their wages and pay more of their health insurance costs in the 2012-13 school year. In addition, administrators waived incentive bonuses to which they were entitled. Source: Newspaperclips.com If your school has recently settled a contract and you would like School Management News to report the settlement information, please contact Renee L. Fambro at rfambro@ ohioschoolboards.org or (614) 540-4000, ext. 243.

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Working well with your board of education: A workshop for administrative assistants and professionals OSBA is pleased to announce a new workshop, part of a series of activities developed for administrative assistants and professionals working with school board members and superintendents. The first workshop, scheduled for Wednesday, Oct. 10, will be held at the OSBA office from 10 a.m. to 2 p.m and will include lunch. The registration fee is $85. “When it comes to the central office in any school district, the superintendent’s administrative assistant, as well as any other staff who work with the superintendent and board of education, are key to

maintaining a smooth and positive relationship with its community,” said Cheryl W. Ryan, OSBA deputy director of school board services and the workshop’s lead facilitator. “What we’ve found, however, is that often these staff members receive little or no professional development in areas like parliamentary procedure, student privacy laws, understanding the board’s key responsibilities or public records laws and the best ways to work with the media.” The workshop agenda includes information on these areas, as well as strategies and tools to build trust and

enable open communication among staff and the board of education. “We think this new series of workshops will enable us to facilitate strengthening an important network of administrative professionals in school districts throughout Ohio,” said Ryan. “If we can provide professional development in areas of interest, as well as help them connect with and learn from one another, all OSBA members benefit.” For more information or to register for the workshop, please contact Laurie Miller, OSBA senior events manager, at (614) 540-4000 or (800) 589-OSBA.