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CORRECTIVE ACTIONS PROGRESS Report

This webpage features updates on Corrective Actions undertaken by Montgomery County Public Schools as a result of the investigative work of the Montgomery County Office of the Inspector General, the Communities of Practice workgroup, and the policy work of the Board of Education. The Corrective Actions Updates reflect our dedication to addressing any instances of misconduct swiftly and effectively. It is essential to cultivate a workplace and school environment that is free from bullying, harassment, and sexual misconduct.

By implementing robust policies, providing ongoing training, and fostering a culture of accountability, we strive to create a workplace and school atmosphere where everyone feels respected, valued, and safe.

Important Note: This website will be updated as the status of identified corrective actions change or new information is added.

(Website last updated on June 20, 2024)

Key: Progress of Corrective Actions

Under Review / Not Yet Started

 

In Progress

 

Completed

 

office of inspector general recommendations

The following section features the findings and recommendations following investigations conducted by the Montgomery County Office of the Inspector General.

Office of Inspector General Report, MCPS Complaint Processing / Jan. 24, 2024, (OIG Publication # OIG-24-08)—Office of Inspector General Report, Investigation of Misconduct by Senior MCPS Officials / Jan. 10, 2024

Findings/Recommendations

MCPS Complaint Processing / Jan. 24, 2024, (OIG Publication # OIG-24-08)—Office of Inspector General Report

Actions

Status

*report-MCPS Complaint Processing

Finding 1: MCPS does not have a comprehensive written policy addressing the receipt, evaluation, tracking and disposition of complaints.

Recommendation 1: We recommend the BOE draft and implement a comprehensive policy, and MCPS issue aligned regulations and procedures, regarding the receipt and processing of employee misconduct complaints, to include a requirement to maintain a centralized, searchable database of all complaints with enough detail to enable the identification of patterns of misconduct and repeat offenders.
  • To implement a database with a searchable function that identifies patterns of behavior and repeat offenders
      • New System: Guardian by Campus Kaizen – ready to launch by June 30, 2024
  • Revision of DCI Internal Manual to specifically outline process for receipt of cases, how they will be handled, final outcomes by August 26, 2024 (first day of school)
  • Regulation from Superintendent of Schools that addresses the process for all employees by August 26, 2024
  • Creation of Board of Education policy that addresses the receipt, evaluation, tracking and disposition of all cases by January 2025

In Progress

 

In Progress

*report-MCPS Complaint Processing

Finding 2: Department of Compliance and Investigations does not follow defined criteria when determining what actions to take with complaints.

Recommendation 2: We recommend Department of Compliance and Investigations formalize procedures and specific criteria to be used when assessing complaints and making disposition decisions.
  • Implementing weekly Director/Coordinator committee review of Workplace Bullying, Harassment, & Discrimination complaints against criteria defined by Board Policies ACH & ACI
  • Draft and implement “step by step” written procedures around assessing complaints and decision-making process found in DCI Internal Manual by August 26, 2024
  • Appropriate updates to the MCPS Employee Code of Conduct detailing how complaints are received, evaluated, and tracked

In Progress

*report-MCPS Complaint Processing

Finding 3: Department of Compliance and Investigations does not have formal comprehensive policies for conducting and documenting investigations. 

Recommendation 3: We recommend the BOE draft and implement a comprehensive policy, and MCPS issue aligned regulations and procedures, that address how investigations should be conducted, and results documented by Department of Compliance and Investigations.
  • Draft and implement written procedures through the DCI Internal Manual by August 26, 2024
  • Conduct trainings with school-based and central office leaders clearly communicating procedures for investigations occurring within schools and offices AND the criteria for referring incidents to DCI for investigation and reporting by August 26, 2024.
  • Draft Board policy around conducting and documenting investigations by January 2025

In Progress

 

In Progress

 

In Progress

*report-MCPS Complaint Processing

Finding 4: DCI does not have formal comprehensive policies for conducting and documenting investigations. 

Recommendation 4: We recommend MCPS undertake an effort to evaluate DCI’s role in the organization, assess staffing and training needs, and implement stricter oversight of DCI’s investigations.
  • DCI Acting Directors have begun an internal review of current investigative practices and reports in collaboration with the Office of General Counsel to create greater structure, alignment, and standardization
  • DCI is reaching out to colleagues in neighboring districts for best practice sharing opportunities
  • MCPS will provide external training for all DCI staff in September 2024
  • DCI will work with the Superintendent of Schools to draft/implement an MCPS regulation around training, investigation process/procedures for all DCI staff
 These measures will be informed by recommendations from the “Investigations Community of Practice Workgroup” (COPW), the Policy Writing Group, and technical guidance provided by the HR firm awarded the Office of Human Resources and Development Request For Proposal. These tasks are projected to continue through summer 2024.

*report-MCPS Complaint Processing

Finding 5: Previously identified deficiencies regarding DCI management and operations have not been addressed. 

Recommendation 5: MCPS should revisit and evaluate the previous findings and recommendations related to the Department of Compliance and Investigation and implement solutions to resolve those impacting MCPS’s ability to properly receive, evaluate, and track complaints. They should also implement policy and practices that improve the consistency of investigations, management oversight, and documentation requirements.
  • DCI staffing changes include four additional staff to manage caseloads
  • Addition to staff of a Director I position with legal and investigative background to coordinate/manage the caseloads and provide oversight of the department
  • Review and revision of processes associated with Workplace Bullying, Harassment and Discrimination through external training have been prioritized

In Progress

 

 

In Progress

Findings/Recommendations

Investigation of Misconduct by Senior MCPS Officials / Jan. 10, 2024

Actions

Status

*report-Investigation of Misconduct by MCPS Officials

Finding 1: MCPS policy does not require supervisors to disclose prior romantic and sexual relationships with employees in their supervisory chain.

Recommendation 1: We recommend that MCPS establish requirements mandating that anyone serving in a leadership position disclose to their supervisor any previous romantic and/or sexual relationships with employees within their supervisory chain.
  • MCPS will include language to address disclosure in the 2024-2025 Employee Code of Conduct by August 26,2024

In Progress

*report-Investigation of Misconduct by MCPS Officials

Finding 2: MCPS’s Employee Code of Conduct (Code of Conduct) requires that employees “respond honestly to a work-related inquiry by MCPS, law enforcement, or other authorized investigative officials.

Recommendation 2: We recommend that MCPS strengthen policy requirements to mandate employees fully cooperate and provide complete and truthful information when questioned as subjects and witnesses as part of an investigation.
  • A message was sent to all staff indicating support for the work of the OIG and the expectation of cooperation by all staff at all times (April 2024) Message link
  • Annual updates in the Employee Code of Conduct to all staff yearly as part of employee training and on-boarding

In Progress

 

 

 

Completed

 

 

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MCPS Independent Corrective Actions

The following section features corrective actions Montgomery County Public Schools leaders have put in place immediately prior to and during investigations conducted by the Montgomery County Office of the Inspector General. These actions were first reported in two separate Corrective Actions Updates sent to the MCPS Community.

1. MCPS Action Plan Update, Oct. 2023

2. MCPS Action Plan Update, Jan. 2024

Findings/Recommendations

Action

Status

Enhance Monitoring, Intake and Resolution of Complaints

  • Create new structures to ensure the thorough investigation of all anonymous complaints, which includes logging anonymous reports into compliance software, a shared drive, and case-tracking system.

  • Streamline monitoring, tracking, and resolution of all named and anonymous reporting.

  • Standardize the intake response process, ensuring immediate acknowledgment via email of all complaints submitted to the Department of Compliance and Investigation.

  

 

Completed

Completed

Completed

Facilitate Stronger Coordination Across MCPS to Manage Complaints

  • Establish channels for active collaboration between the Department of Compliance and Investigation, the Office of the Chief Operating Officer, and the Board of Education (BOE) to manage complaints submitted through the Lighthouse Reporting Hotline. This hotline allows for anonymous reporting and also supports anonymous uploading of documents

  

 

Completed

Institute Leadership Changes and Staff Expansion

  • Evaluation and placement of new staff and acting director for the Department of Compliance and Investigation.

  • Bolster the investigations team by bringing in additional staff with legal and investigative experience, expanding both the office’s expertise and capacity to thoroughly examine and investigate incoming complaints

  

 

In Progress

 

In Progress

Institute Standardized Filing Process

  • Standardize electronic files to ensure consistent saving of relevant information for investigation.

  

 

Completed and Reconciling

Develop Focused Professional Learning

  • Create in-person staff development and document resources to support the work of Department of Compliance and Investigation staff.

  

 

In Progress

Mandate Training on Sexual Harassment, Misconduct and Bullying

  

 

In Progress

Additional Staff Training on Reporting and Management of Complaints

  • Require staff training on reporting processes (who, how, what, when, why)for instances of sexual misconduct, sexual harassment, and workplace bullying.

  • Require staff training to ensure supervisors have the required knowledge and skills to support the investigation of a claim of sexual misconduct, sexual harassment, and/or workplace bullying in schools or offices using appropriate MCPS processes.

  

 

In Progress

 

In Progress

Request Additional Resources in Fiscal Year (FY) 2025

  • Allocate an additional $500,000 in the FY 2025 operating budget to hire experts in investigations and compliance.

  

Awaiting FY 2025 operating budget passage by County Executive and County Council

Review

Strengthen Eligibility Requirements

  • Establish that no MCPS employee under active investigation is eligible for promotion. 

  

 

Completed

Enhance & Expand Background Checks and Screening for All Candidates

  • Institute a more thorough and rigorous vetting of candidates from a number of sources including personal references, online databases (searches conducted through Google, Maryland Judiciary, and Maryland Sex Offender Registry), personnel files, any open investigations, current and past disciplinary actions (for internal and returning MCPS candidates), and filed complaints (including anonymous complaints made through the Maryland Safe Tip Line as well as Lighthouse).

  

 

 

Completed

Establish More Rigorous Interview Process

  • Revamped the promotions process to ensure higher levels of transparency and accountability, including requiring more stringent record keeping and documentation protocols, more exhaustive screening of background and certifications of candidates, and longer timeframes for more robust internal review of candidate materials, among other requirements. 

  

 

Completed

Require Ongoing Training for Appointments Committee

  • Mandate, ongoing trainings for members of the Appointments Committee to ensure integrity of processes designed to identify highly-effective and qualified candidates and to ensure alignment on expectations and requirements around disclosing evidence-based information and knowledge of candidates. 

  

 

Completed

Update & Strengthen Email Retention Policy

  • Update MCPS email retention policy requiring emails be stored and saved for three years, significantly expanding the timeframe for email records to be accessed and reviewed, ensuring more accountability throughout the investigation of complaints. Three year retention of email will begin on February 12, 2024 

  

 

Completed

ADDITIONAL INTERNAL RECOMMENDATIONS

Documents referenced in an addendum to the Office of Inspector General report of January 24, 2024, titled MCPS Complaint Processing in which MCPS had previous identified deficiencies needing review and action.  Those items have been aggregated here and are being considered and reviewed for action. Some of these recommendations are similar to items already posted on this page.

Recommendation

Status

Assess and identify perceived areas of deficiencies and OHRD concerns, which may include:

  • DCI handling of  matters of employee misconduct, EEO, accommodations, disabilities

  • Underqualified leadership, poor decision-making

  • Excessive number or rise in number of misconduct incidents or noncompliance (with law/policy)

  • Inadequate prevention measures/efforts

  • Department of Compliance and Investigations team members lack skills; specific members or as a whole

  • Public relations, communication (internal/external staff, partners such as police dpt, Child Protective Services)

  • Lacking collaborative approach with principals/schools, OGC, OHRD

  • Inconsistent or inadequate tracking, reporting, accountability

  • Implementing inappropriate or inconsistent employee discipline

  • Investigation practices/results, timeliness of results

  •  General process issues, efficiency and/or dubious investigation outcomes

Review

Address urgent concerns and deficiencies by confronting and communicating with director/coordinator and:

§  Virginia Commonwealth University (VCU) current compliance program

§  VCU’s 2019 review

§   2021 United States Sentencing Commission Guidelines Manual (see pp 517-522);

§  Pasco Co.;

§  COSMOS, Navigate the Compliance Universe (Complete Compliance and Ethics Manual 2021)

  • Hire an outside consultant to review and make recommendations for short-term improvements in processes, training, tracking and communication (limited to current functions of department)

 In Process as part of overall recommendations

In Progress

Create a new position and hire a compliance officer (assistant chief?) that would lead the work of the office, implement urgent changes in practices and supervise the current director II and coordinator;

 Alternatively, maintain current structure and:

  • Conduct immediate review of work, identifying urgent areas of concerns and address through additional training.

  • Review the qualifications of the Director II position.

  • Once reassigned, revise Director II job description, incorporating additional qualifications/training/experience such as legal background, risk management, criminal investigations, effective compliance program creation/implementation.

  • Hire a new director II that meets the qualifications set forth in the revised job description.

 In Process as part of overall recommendations

In Progress

Convene a workgroup comprised of Office of General Counsel representative(s); Office of Human Resources and Development; Department of Compliance and Investigation and outside counsel other stakeholders as appropriate to:

  • Review current structure and staffing, and determine areas of deficiencies and challenges.

  • Draft and present to executive leadership the scope and outline of “compliance program” utilizing best practices and Federal Sentencing Guidelines.

  • Consider Prince Georges County Public School's structure, staffing and integration of risk management as a part of the compliance program

 In Process as part of overall recommendations

In Progress

Revise and create new positions (e.g., compliance officer) to oversee and implement changes, compliance program

 Under Review as part of Examination of Office Structure

Review

Create a compliance manual based on external resources.

Review

Consider new software for case management for tracking and accountability purposes and to assist in meeting deadlines.

 Completed as part of overall recommendations

Completed

Consider outside consultant review of workgroup results, compliance manual or outside counsel. Input should be gathered from experts in employee conduct and discipline, Equal Employment Opportunity Commision, Title IX, employee accommodations, compliance and/or risk management

 In Progress as outlined in overall recommendations

In Progress

In accordance with recommendations, hire qualified/expert in risk management (officer/assistant chief) and other qualified leadership to oversee districtwide measures, incorporating best practices, tracking, communication and collaborative efforts involving all departments

In Progress

Based on findings reorganize office/reporting structure and hire qualified staff to create, implement and maintain risk management program. 

 Under Review as part of Examination of Office Structure

Review
  • Ensure systemwide accountability through tracking (software for compliance).

     

  • Software will enable regular reporting to the Board

     

Software selection completed

Completed

Under consideration

Review

Board of Education Policy Work

New Appointments Policy to be created and in place by the end of the school year.

The Writing Team will prepare a preliminary draft policy for consideration by District Leaders who will recommend a draft to the Board of Education Policy Management Committee. The draft will substantially re-envision and rename former Board Policy GEA, Appointment of Professional Personnel, that was rescinded in 2005.

The draft will guide the Board’s role in the appointment of key leaders in MCPS; identify personnel positions subject to Board appointment upon the recommendation of the superintendent of schools; and establish timelines and criteria for information to be included in the superintendent of schools’ recommendations for Board appointment.

  • The MCPS multistakeholder writing team is researching and engaging stakeholders.

  • Office of Human Resources and Development, supported by the Office of the General Counsel is managing the process.

  • New policy (title yet to be determined) It will address the board’s role in the appointment process.

  • This is all subject to Board of Education member interest.

A Proposed Timeline

  • January 23 Policy Management Committee, process update on research and stakeholder engagement on what should be in a new policy.

  • February 28 Policy Management Committee, discussion of Draft 1 may be ready.

  • March 19 Board (subject to PMC approval), Tentative Action on Draft 1

  • March 25-April 19, public comment period (subject to BOE approval)

  • May 16, Policy Management Committee, review of public comments

  • June 11, Board (subject to PMC approval), Final Action on response to public comments

Community of Practice Updates

You can learn more about the Community of Practice work group at this website. www.montgomeryschoolsmd.org/superintendent/cop

Corrective actions or recommendations from this workgroup are currently being considered and expected to finish later in spring of 2024.

Recommendations thus far