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Baltimore County schools purportedly “destroyed” financial disclosure docs for key personnel
Posted by Ann Costantino on 26th March 2018

—– By: Ann Costantino —–

Baltimore County Public Schools may have violated its own ethics policy when it discarded two years of original financial disclosure statements for Ryan Imbriale, the executive director of the Department of Innovative Learning who spearheaded, along with former Superintendent S. Dallas Dance, the school system’s education technology initiative called STAT, for Students and Teachers Accessing Tomorrow.

Stating the district cannot produce his original documents for reporting years 2015 and 2016, an official from Baltimore County schools’ own Ethics Department told The Baltimore Post that when Mr. Imbriale amended the two financial disclosure documents recently, after reports of Mr. Dance’s criminal investigation emerged last fall, the originals were then “destroyed.”

But when pressed for the reason why those forms were discarded, the official said it was due to an electronic filing system which replaces original versions of the forms when an employee makes a change in the system.

Yet, despite the apparent peculiarity, The Baltimore Post found that other employees’ original disclosure statements have remained intact, in hardcopy form.

In February, The Baltimore Post requested permission to inspect financial disclosure statements for seven Baltimore County Public Schools employees.  Records for an eighth employee were requested earlier this month.

The statements are required to be filed annually by members of the board of education, the superintendent, community superintendents, cabinet members, executive directors, managers, purchasing agents, principals, legal counsel and any other employees who have the authority to make a final decision to commit the school system to the spending of public funds. Employees are also responsible for reporting relationships with any company doing business with the school system.

While The Post found that three of the eight employees amended their financial disclosure documents, Mr. Imbriale was the only employee without original disclosure statements in his file for the two years he amended them. In fact, not only were the original documents missing, but they were completely replaced by new ones 19 months after his 2015 financial disclosure filing deadline, and seven months after the filing deadline for 2016.  The deadline for each filing year is April 30th of the year following a reporting period.

Despite multiple requests for Mr. Imbriale’s original disclosure documents from the school system’s Ethics Department, an official from the department told The Post multiple times that Mr. Imbriale’s original documents were simply not available because they no longer exist.

But according to the district’s own ethics policy, which is modeled after State law, the school system’s retention policy for financial disclosure statements requires the district to hold on to the documents for a specified amount of time.

The school system’s policy states, “The Panel or the office designated by the Board shall retain financial disclosure statements for four (4) years from the date of receipt.”

However, Andrew Nussbaum, an attorney and advisor for the school system’s Ethics Panel, told The Baltimore Post that it’s something the Ethics Panel will need to discuss.

“It is my understanding that in the past, the administrative staff had discarded Financial Disclosure Statements that had been amended.  The Panel will discuss this issue at a future meeting,” Mr. Nussbaum said in email response today.

Although school system employees have been required to file their financial disclosure forms electronically since February of 2016, it is unclear what the Ethics Department’s procedure is for disposing of paper copies.

After an official at the system’s Ethics Board told The Baltimore Post that Mr. Imbriale’s original filings had been destroyed through the process of revising them electronically many months after filing the originals, The Post reached out to the district’s law office for the software manual for the electronic filing program used by system employees to file their financial disclosure forms.

In response to a request for the manual, an attorney for the district said it was school system employees who created the software system used by employees to file their financial disclosure forms.  “The online financial disclosure statement filing system was designed and built ‘in-house’ by BCPS,” the law office stated in a response to The Baltimore Post’s records request.

In short: school system employees wrote the software that, officials say, overrides previous versions of financial disclosure forms, making it impossible, they say, to view original forms filed months or years before, on a system employees were only required to use since 2016.

Last April, former Superintendent Dance resigned citing unsustainable 18-hour days.  The young education leader would leave the school system in June.

Although not known at the time Mr. Dance made the announcement, The Baltimore Sun reported in September that the former superintendent had been under criminal investigation at the time he resigned.

Mr. Dance, who pleaded guilty this month to charges stemming from that investigation, was indicted in January on four counts of perjury for lying on his financial disclosure forms.

Despite his legal troubles, all of Mr. Dance’s financial disclosure statements are in their original form, with amendments stapled to the end of each statement, for each reporting year.

Mr. Dance will be sentenced on April 20.  Prosecutors are asking that he serve 18 months of a recommended five-year prison sentence.  Each of the four perjury counts could have yielded a 10 year prison sentence.

Within two and a half months of media reports that Mr. Dance was under criminal investigation, two of the eight employees investigated by The Baltimore Post made changes to their financial filings. Another employee amended his forms the year prior.

  • On November 14, 2017, Mr. Imbriale replaced his original disclosure filing for the 2015 reporting period, 19 months after the filing period deadline.
  • On December 4, 2017, Mr. Imbraile replaced his financial disclosure form for the 2016 reporting period, while amending it again one month later, on January 18, 2018, eight months after the filing period deadline.
  • On December 15, 2017, Jeanne Imbriale, the school system’s director of Enterprise Applications, and also Mr. Imbriale’s wife, amended her disclosure form for the 2016 reporting period, adding an unpaid position that she had in which she served on the National Council for Digital Convergence. However, unlike Mr. Imbriale, Ms. Imbriale’s original financial disclosure forms were among the documents available for public inspection.
  • On June 2, 2016, John Mayo, the system’s director of Human Resources, replaced his disclosure form a few months after originally filing for the 2015 reporting period. Like Ms. Imbriale, Mr. Mayo’s original financial disclosure statement was among the documents available for public inspection. Mr. Mayo also declared his educational consulting company, Commonwealth Educational Consulting Services –or CECS.  He did not, however, declare any income earned through his company.

Although not among the employees The Baltimore Post investigated, interim Superintendent Verletta White amended her forms last month after an ethics complaint revealed that she violated two ethics policies for failing to disclose outside consulting and teaching work.

Unlike Dance, however, Ms. White is not accused of any crimes. The interim superintendent told Maryland State Delegates in January that, also unlike Dance, her intention was not to mislead.  Ms. White has promised not to do any more consulting work and has apologized.

When The Post requested Mr. Imbriale’s original financial documents last month, it was originally to confirm whether he failed to disclose an adjunct teaching position he has with Johns Hopkins University.  The Post requested four years of Mr. Imbriale’s financial disclosure forms.

When Mr. Imbriale filed his forms in 2014 for the 2013 reporting period, he declared working for the university.  When he filed in 2015 for the 2014 reporting period, he did not. Because the two subsequent years were replaced with completely new versions of Mr. Imbriale’s financial disclosure statements, it is not possible to know what changed roughly 19 months and seven months after the original filing deadlines.

For both of those years, Mr. Imbriale declares teaching at the university, according to the replaced 2016 and 2017 financial filings for reporting years, 2015 and 2016.

Baltimore County schools contracted with a department at the university in 2014, to evaluate its STAT program.

Mr. Imbriale also stated on his 2017 filing for the 2016 reporting period, that he was a paid consultant for the Santa Cruz County Office of Education.  Additionally, like Ms. Imbriale, Mr. Imbriale also amended his form that year to include that he served on the National Council for Digital Convergence.

Mr. Imbriale did not respond to a request for comment regarding the disappearance of his original financial disclosure forms, nor his disclosure of the Johns Hopkins teaching position.

Michael W. Lord, the media director for Maryland’s State Ethics Commission, told The Baltimore Post that it is up to local agencies, like Baltimore County schools, to oversee themselves.  It is up to the Ethics Board to regulate itself and its compliance with rules, policies and regulations, he said.

Mr. Lord also said it is up to local districts to interpret and align their policies with State laws.

While he said the Commission does not oversee local districts and there is no State-level consequence for being out of alignment with the State ethics laws, Mr. Lord said that if a district’s policies are out of alignment with the law, “we tell them why and what they need to do to fix it.”

A formal request has been made to Baltimore County Public Schools’ Audit Department to look into the matter.




6/19/18 Correction – An earlier version of this story indicated that John Mayo, the school system’s HR Director worked for Baltimore County schools for three years.  Mr. Mayo has actually worked for the district since 2012.

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