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Baltimore County schools claims “one time” clerical error responsible for destroyed financial disclosure statements for key personnel
Posted by Ann Costantino on 19th June 2018

—– By: Ann Costantino —–

Baltimore County schools is claiming a clerical error was responsible for the destruction of original financial disclosure statements belonging to a key member of the system’s central office staff, Ryan Imbriale, the executive director of the Department of Innovative Learning.

Citing a one-time mistake, Andrew Nussbaum, an attorney that advises the school system’s ethics panel said, “The employee who collects and files the Statements was of the mistaken belief that when an employee files an amended FDS, the earlier document should be discarded.  Unfortunately, when Mr. Imbriale filed his amended Statement, the initial filing was destroyed. Fortunately, the employee was quickly advised that it was an error to destroy the previously filed Statement and I was told that this one was the only FDS that was discarded.”

However, as reported in March, a review of financial documents by The Baltimore Post found that two years’ worth of Mr. Imbriale’s financial records were actually destroyed after originals were replaced with new versions — in one case 19 months after the original document was filed. 

Moreover, the statements for three other employees were left intact, although they too were amended to disclose previously undisclosed positions or payments around the time Mr. Imbriale amended his forms.

To put it into perspective, even former Superintendent S. Dallas Dance’s disclosure documents were left intact despite amendments – albeit incomplete – that he made to four years’ worth of disclosures.  But the school system says Mr. Imbriale’s destroyed files were an error, nonetheless. 

Dance is currently serving time in a Virginia jail for lying on those financial disclosure statements, despite amending his forms.

  • On November 14, 2017, Mr. Imbriale replaced his original disclosure statement for the 2015 reporting period, 19 months after the original filing period deadline.
  • On December 4, 2017, Mr. Imbraile replaced his financial disclosure statement for the 2016 reporting period, while amending it again one month later, on January 18, 2018, eight months after the original 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 the company. Mayo has worked for the school system since 2012.
  • In 2016, after former Superintendent Dance was found in violation by an independent ethics review that he failed to disclose an adjunct teaching position and a consulting company, he amended his 2013, 2014, 2015 and 2016 financial disclosure statements. But all original statements remained intact.

In February, The Baltimore Post requested the financial disclosure documents for eight school employees.  While reviewing the records for Mr. Imbriale, The Post noticed disparate signing dates relative to dates the forms were originally due.  In other words, the dates the documents were signed did not line up with their filing deadlines.

The Post inquired with the system’s ethics department multiple times about the forms and was told they had been amended.  But when the original forms were requested, an employee stated that Mr. Imbriale’s original documents had been “destroyed” after he amended them electronically. 

The ethics department stated that the software filing system was responsible for overriding Mr. Imbriale’s old filings with new versions. The school system’s law office told The Baltimore Post that the software for the filing system was created “in house” by school system employees.  Mr. Imbriale’s wife, Jeanne Imbriale, works in the department that created and maintains the software.

But hardcopies that Mr. Imbriale filed with the ethics department were also destroyed when he amended his forms electronically.  It is unclear, however, how those forms were destroyed.  Questions about the process have not been answered.

Financial disclosure statements are required to be filed annually by school system employees who have the authority to make a final decision to commit the school system to the spending of public funds.  

Along with the superintendent, community superintendents, cabinet members, executive directors, managers, purchasing agents, principals, and legal counsel, even school board members must file annually to report income and relationships with any company doing business with the school system.

Baltimore County schools’ policy states that financial disclosure statements must be retained for four years before discarding them.  The policy mirrors state law.

But according to Michael W. Lord, the media director for Maryland’s State Ethics Commission, it is up to local agencies, like Baltimore County schools, to oversee themselves.  And it is up to the Ethics Board to regulate itself and its compliance with rules, policies and regulations as well as to interpret and align their policies with state laws.

The Baltimore Post asked the ethics department in March if it violated its own ethics policy by destroying Mr. Imbriale’s forms.  Late last week, the department’s attorney responded, stating he was told it was a one-time clerical error.

But when pressed for clarification about other employees’ forms remaining intact despite amendments to them, Mr. Nussbaum did not respond.  The Baltimore Post also requested clarification since Mr. Imbriale’s forms were apparently destroyed – not once as Mr. Nussbaum stated – but twice.  The Post did not receive a response.

The school system has been beset by issues surrounding financial nondisclosure. In addition to former Superintendent Dance, interim Superintendent Verletta White has also been criticized for failing to disclose income on her financial disclosure statements.

Ms. White amended her forms in February to reflect a consulting job and adjunct teaching position after an ethics complaint revealed that she violated two ethics policies for failing to disclose the work.  One of the jobs was a consultant position with education consulting firm, The Education Research and Development Institute – or ERDI.

The New York Times reported in November that Ms. White worked as a consultant for ERDI.

Unlike Dance, however, White has not been accused of any crime. The interim superintendent told Maryland State Delegates in January that, also unlike Dance, her intention was not to mislead. 

When The Post requested Mr. Imbriale’s original financial documents in February, it was originally regarding nondisclosure of an adjunct teaching position he has with Johns Hopkins University.

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.  But the two following years, he disclosed the position again.

Baltimore County schools contracted with a department at the university in 2014 to evaluate its laptop-for-every-student, STAT program, the year Mr. Imbriale did not disclose the position.

STAT, which Mr. Imbriale and former Superintendent Dance spearheaded, stands for Students and Teachers Accessing Tomorrow.  The program will extend to all Baltimore County high schools in the 2018-2019 school year, completing former Superintendent Dance’s vision to convert the entire school system to all digital curriculum for all students and teachers.

Mr. Imbriale has taught technology-related courses at the university as an adjunct professor.  The department evaluating STAT is the Center for Research and Reform in Education at the university.  The lead researchers evaluating STAT also study education technology and educational software programs, including DreamBox, a Baltimore County school system vendor.  DreamBox is a mathematical game-based computer program used by the district’s elementary students as part of its STAT program.

The Baltimore Post asked Mr. Imbriale in March about the disappearance of his original financial disclosure forms.  He did not respond to the inquiry, nor to questions regarding his disclosure of the Johns Hopkins teaching position. 

Requests for other copies of his 2015 and 2016 financial disclosure statements – that may still exist – also did not yield a response.


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