Determining if the disciplinary penalty imposed on the employee shocks the court's sense of fairness

A tenured New York City school teacher [Educator] employed by the New York City Department of Education [DOE] challenged her being terminated from her position after being found guilty of certain disciplinary charges including allegations that she had directed a racially charged insult at an individual in the course of an incident which had occurred off school grounds. 

DOE's investigation of this event had led to its discovery of additional alleged discriminatory conduct by Educator that was claimed to have been directed at Educator's students in her classroom. 

Supreme Court denied Educator's application brought pursuant to CPLR Article 75 seeking to vacate the arbitration award rendered after an Education Law §3020-a disciplinary hearing. The Appellate Division unanimously affirmed the Supreme Court ruling.

Click HERE to access the Appellate Division's decision posted on the Internet.

A Reasonable Disciplinary Penalty Under the Circumstances - This 442-page e-book focuses on determining the appropriate disciplinary penalty to be imposed on an employee in the public service in instances where the employee has been found guilty of misconduct or incompetence. For additional information concerning this e-book click on http://booklocker.com/books/7401.html.

Agency's timely response defeats plaintiff's claim that his Freedom of Information request was constructively denied

The New York City Department of Social Services [Department] denied Plaintiff's [Petitioner] administrative appeal challenging the denial of his Freedom of Information Law [FOIL] request. Petitioner then appealed the Department's action by filing a CPLR Article 78 appeal in Supreme Court challenging the Department's decision. Supreme Court dismissed Petitioner's Article 78 action.

The Appellate Division unanimously affirmed the Supreme Court's ruling, finding that the Department did not constructively deny* [Petitioner's] FOIL request as it had mailed the Department's response to Petitioner within five days of its the receipt of the FOIL request and, in addition, the Department had notified Petitioner by email that same day "that it had mailed the response".

Further, the Appellate Division's decision notes that the Department's mailing to the Petitioner "was postmarked April 1, 2024" and advised the Petitioner that Petitioner had 30 days from receipt of the letter to appeal. 

As the postal service first attempted to deliver the Department's denial letter on April 9, 2024, and Petitioner mailed his appeal on May 8, 29 days later, the Appellate Division ruled that Petitioner's administrative appeal was timely.

* "Constructive denial" is a concept pursuant to which an agency's failure to respond to a timely FOIL  request within the timeframe otherwise required is deemed to have been a denial of the FOIL request by the agency.

Click HERE to access the Appellate Division's decision posted on the Internet.

The failure to raise a raise a public policy argument in the party's answer without good cause bars appellate review of the issue

An employee organization [Union] representing certain employee of a Board of Education [Petitioner] for the purposed collective bargaining pursuant to Article 14 of the Civil Service Law [the so-called Taylor Law] filed an improper practice charge with Public Employment Relations Board [PERB], alleging that Petitioner had unilaterally transferred bargaining unit work of certain of its members to the County's social workers in violation of certain terms set out in a collective bargaining agreement between the Petitioner and the Union.

Petitioner did not assert a public policy issue in its answer to the Union's charge until the final day of the hearing before the PERB hearing officer when it attempted to raise that argument. Although the hearing officer allowed Petitioner to move to amend to answer to include the public policy issue, Petitioner was unsuccessful as it failed to demonstrate "good cause", a finding that Petitioner has not disputed.

Upon administrative appeal, PERB adopted the ALJ's findings and upheld the decision, issuing a remedial order in favor of the Union.

Petitioner then commenced a CPLR Article 78 proceeding seeking to annul PERB's determination because, among other reasons advanced, "it was not based upon substantial evidence".

Ultimately the Appellate Division affirmed PERB's determination, noting that as Petitioner's "public policy claim was never properly presented to the ALJ for consideration, it is unpreserved for appellate review".

The Appellate Division's decision is set out below:

Matter of Board of Educ. of the Newburgh Enlarged City Sch. Dist. v Public Empl. Relations Bd. of the State of N.Y.

2025 NY Slip Op 06579

Decided on November 26, 2025

Appellate Division, Third Department

Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.

This opinion is uncorrected and subject to revision before publication in the Official Reports.

Decided and Entered: November 26, 2025

CV-24-1839

[*1]In the Matter of Board of Education of the Newburgh Enlarged City School District, Petitioner,
v
Public Employment Relations Board of the State of New York et al., Respondents.

Before:Aarons, J.P., Reynolds Fitzgerald, Ceresia, Fisher and McShan, JJ.

Shaw, Perelson, May & Lambert, LLP, Poughkeepsie (Mark C. Rushfield of counsel), for petitioner.

Laura H. Delaney, Public Employment Relations Board, Albany (Ellen M. Mitchell of counsel), for Public Employment Relations Board of the State of New York, respondent.

Robert T. Reilly, New York State United Teachers, Latham (Jose L. Manjarrez of counsel), for The Newburgh Teachers' Association, respondent.

Ceresia, J.

Proceeding pursuant to CPLR article 78 (transferred to this Court by order of the Supreme Court, entered in Albany County) to review a determination of respondent Public Employment Relations Board finding that petitioner had committed an improper employer practice.

Respondent Newburgh Teachers' Association (hereinafter NTA) is a public employee organization that represents, among others, school social workers and school psychologists (hereinafter collectively referred to as the school providers) employed by petitioner. The school providers offer mental health counseling to students, in addition to other duties. In 2013, petitioner obtained a grant to establish a pilot program for the operation of "satellite" mental health clinics at three of its schools, in partnership with the Orange County Department of Mental Health (hereinafter OCDMH). The purpose of the pilot program was to provide mental health services to non-mandated students ^[FN1] and their families on school grounds, where such services might be more easily accessed than in other county locations. The clinics were staffed by clinical social workers employed by OCDMH (hereinafter the County social workers). 

In 2014, petitioner and NTA signed memoranda of agreement allowing the County social workers to be employed within the schools, with the caveat that the County social workers would not replace the school providers, nor would NTA be waiving its exclusive right to bargain concerning the work of the school providers. 

In 2016, NTA advised petitioner that it would no longer consent to the continued employment of the County social workers within the schools upon expiration of the grant. Nonetheless, after the grant expired in 2017, petitioner and OCDMH continued to operate the satellite clinics on school property, albeit under a different funding arrangement.

Thereafter, NTA filed an improper practice charge with respondent Public Employment Relations Board (hereinafter PERB), alleging that petitioner had unilaterally transferred bargaining unit work to the County social workers in violation of Civil Service Law article 14 (hereinafter the Taylor Law) (see Civil Service Law § 209-a [1] [d]). 

Petitioner answered, and a hearing was held before an Administrative Law Judge (hereinafter ALJ). On the final day of the hearing, petitioner attempted to raise a public policy argument, essentially claiming that it was not required to bargain with NTA due to the strong public policy interest in supporting students' mental health. The ALJ observed that this defense was not contained in petitioner's answer and, accordingly, allowed petitioner to move to amend its answer to raise the defense. 

Petitioner filed such a motion, but it was denied for lack of good cause. Ultimately, the ALJ found that petitioner had engaged in an improper employer practice by transferring bargaining unit work to non-unit employees without first negotiating with NTA. Upon administrative appeal, PERB adopted the ALJ's findings and [*2]upheld the decision, issuing a remedial order requiring that the work of counseling non-mandated students be returned to NTA's bargaining unit.

Petitioner then commenced this CPLR article 78 proceeding seeking to annul PERB's determination because, among other reasons, it was not based upon substantial evidence (see CPLR 7803 [4]). NTA answered, and PERB moved pre-answer to dismiss the petition. Supreme Court transferred the proceeding to this Court. Upon review, this Court denied PERB's motion to dismiss the petition on the basis that PERB was improperly seeking a merits-based determination of the petition in the context of a pre-answer motion and remitted the matter to Supreme Court to allow PERB to file an answer (213 AD3d 1186 [3d Dept 2023]). PERB subsequently filed an answer, which included a counterclaim for enforcement of its remedial order, and the proceeding was transferred back to this Court.

We confirm. In determining whether there was a transfer of unit work that violated the Taylor Law, the issue, as relevant here, is "whether the work in question had been performed by unit employees exclusively and whether the reassigned tasks are substantially similar to those previously performed by unit employees" (Matter of Sliker v New York State Pub. Empl. Relations Bd., 42 AD3d 653, 653-654 [3d Dept 2007] [internal quotation marks, brackets and citations omitted]; see Civil Service Law § 209-a [1] [d]; Matter of Lawrence Union Free Sch. Dist. v New York State Pub. Empl. Relations Bd.,200 AD3d 886, 888 [2d Dept 2021]; Matter of Romaine v Cuevas, 305 AD2d 968, 969 [3d Dept 2003]). Our review of a decision by PERB following a hearing on an improper practice charge is limited to whether PERB's conclusion is supported by substantial evidence, "which, in turn, depends upon whether there exists a rational basis in the record as a whole to support the findings upon which such determination is based" (Matter of Romaine v Cuevas, 305 AD2d at 969; see Matter of Town of Islip v New York State Pub. Empl. Relations Bd., 23 NY3d 482, 492 [2014]; Matter of State of New York v New York State Pub. Empl. Relations Bd., 183 AD3d 1172, 1177 [3d Dept 2020]; Matter of Sliker v New York State Pub. Empl. Relations Bd., 42 AD3d at 653).^[FN2]

Turning first to the question of exclusivity, petitioner contends that the work of counseling non-mandated students was not exclusively performed by the school providers prior to implementation of the pilot program because the school providers would, at times, refer students to outside agencies. We disagree. The hearing testimony reflected that these referrals were for services that fell beyond the scope of the school providers' job duties, inasmuch as certain students required additional supports such as counseling outside of school hours or psychiatric interventions. As PERB noted, the referrals did not take away work that otherwise would have been performed by the school providers and, indeed, all of the in-school counseling work [*3]was undisputedly performed by them. Thus, there is substantial evidence supporting PERB's conclusion that the school providers exclusively performed the bargaining unit work at issue before it was transferred to the County social workers (see Matter of Manhasset Union Free School Dist. v New York State Pub. Empl. Relations Bd., 61 AD3d 1231, 1234 [3d Dept 2009]).

As for whether the work performed by the County social workers was substantially similar to that done by the school providers, the evidence showed that both groups provided counseling to non-mandated students by receiving referrals, performing intakes, making mental health diagnoses, setting treatment goals, developing treatment plans, implementing those plans in individual and group settings for the students and their families using a variety of treatment modalities and referring students and families to outside agencies as needed. Therefore, substantial evidence supports PERB's finding regarding substantial similarity (see Matter of Lawrence Union Free School Dist. v New York State Pub. Empl. Relations Bd.,200 AD3d at 889), notwithstanding the fact that there was some evidence in the record indicating that the County social workers offered certain limited additional services not delivered by the school providers, some of which occurred outside of school hours.

With respect to petitioner's public policy argument, petitioner did not assert such an argument in its answer. When given the opportunity to move to amend the answer, petitioner was unsuccessful for failure to demonstrate good cause, a finding that petitioner has not disputed. Accordingly, since this public policy claim was never properly presented to the ALJ for consideration, it is unpreserved for appellate review (see Matter of Lane Constr. Corp. v Cahill, 270 AD2d 609, 611 [3d Dept 2000], lv denied 95 NY2d 765 [2000]).

Finally, in light of all of the above, PERB's counterclaim for enforcement of its remedial order is granted (see Civil Service Law § 213 [d]; Matter of County of Rockland v New York State Pub. Empl. Relations Bd., 225 AD3d 944, 948 [3d Dept 2024]). To the extent not explicitly addressed herein, petitioner's remaining contentions have been considered and found to be without merit.

Aarons, J.P., Reynolds Fitzgerald, Fisher and McShan, JJ., concur.

ADJUDGED that the determination is confirmed, without costs, petition dismissed, and respondent Public Employment Relations Board is entitled to a judgment of enforcement of its remedial order.

Footnotes

Footnote 1: "Mandated" students are those who must be provided mental health services as part of an individualized education plan (IEP) or an individualized accommodation plan (also known as a 504 plan). These services have always been delivered by the school providers. "Non-mandated" students are those who do not receive mental health services through an IEP or 504 plan.

Footnote 2: In its motion to dismiss the petition and in its answer, PERB argued that its hearings are discretionary in nature rather than required by law and, in such instances, the correct standard of review is not whether the determination is supported by substantial evidence but, rather, whether it is arbitrary and capricious (see e.g. Matter of Lippman v Pub. Empl. Relations Bd., 263 AD2d 891, 894 [3d Dept 1999]). PERB does not pursue this argument in its brief before this Court, and we therefore deem it abandoned (see Matter of Portmore v New York State Comptroller, 152 AD3d 945, 946 n [3d Dept 2017]).

Click HERE to access the Appellate Division's decision posted on the Internet.

New York State Comptroller posted audits of New York State agencies, municipalities and school district on the Internet

On January 30, 2026 New York State Comptroller Thomas P. DiNapoli announced the following audits were posted on the Internet.

Click on the text highlighted in COLOR to access the audit.

Department of Financial Services – Virtual Currency Licensing (Follow-Up) (2022-S-18) The Department of Financial Services (DFS) supervises and regulates the activities of more than 3,200 financial institutions with nearly $10 trillion in assets as of December 31, 2024, including 22 virtual currency licenses with assets totaling more than $404 billion. New York Codes, Rules and Regulations Title 23, Part 200 – Virtual Currencies requires businesses to obtain a license (BitLicense) to engage in virtual currency business activities in New York State, with some exceptions. A prior audit, issued in January 2024, found that DFS was not adequately performing its oversight responsibilities related to the application for and supervision of BitLicenses. Specifically, DFS did not ensure compliance with the Department of Taxation and Finance’s tax obligations and might use outdated anti-money laundering risk assessments to approve licenses, and DFS Bit Licensees were not in compliance with DFS’ cybersecurity regulations, although in some cases they self-certified that they were. DFS officials made some progress in addressing the issues identified in the initial report; of the initial report’s six recommendations, three were implemented and three were partially implemented.

Department of Health, New York City Department of Health and Mental Hygiene – Oversight of the Practice of Funeral Directing (2022-S-47) The Department of Health (DOH) is responsible for governing and regulating the business and practice of funeral directing, undertaking, and embalming in New York State. DOH’s Bureau of Vital Records is responsible for administering the Electronic Death Registration System used to electronically register deaths that occur in New York State but outside of New York City. For deaths that occur within New York City, the New York City Department of Health and Mental Hygiene (DOHMH) administers eVital. Auditors found that some funeral directors were not using the tests prescribed by the regulations to verify death, some preparation rooms did not meet standards, some deaths were being registered before disposition of bodies, and some death certificates were duplicated or had no Social Security numbers in the DOH and DOHMH systems. In addition, auditors found that DOH and DOHMH should improve their interagency data sharing and other communication to better identify and address risks of unauthorized funeral directing activity.

Workers’ Compensation Board – Assessment of Costs to Administer the Workers’ Compensation Program for the State Fiscal Year Ended March 31, 2024 (2025-M-1) The purpose of this report was to ascertain the total expenses that the Workers’ Compensation Board (Board) incurred in administering the Workers’ Compensation Program (Program) for the State Fiscal Year ended March 31, 2024. The Office of the New York State Comptroller performed certain procedures, which were agreed to by the Board, to ascertain the Board’s expenses. Annual expenses to administer the Program totaled $215.3 million.

Office of Mental Health – Controls Over the Empire State Supportive Housing Initiative (Follow-Up) (2025-F-11) The Empire State Supportive Housing Initiative’s (ESSHI) goal is to develop 20,000 units of supportive housing over a 15-year period ending in 2031. The Office of Mental Health (OMH) serves as the lead procurement agency for ESSHI, which provides up to $34,000 annually per individual toward supportive housing for vulnerable populations experiencing homelessness. A prior audit, issued in December 2023, found significant deficiencies in OMH’s oversight of the ESSHI program: a review of selected residents’ progress notes identified a lack of face-to-face meetings or in-home visits, delays in developing support plans, and annual income not being verified in all cases. Furthermore, two residents were missing for extended periods of time; four of six providers that auditors inspected had critical issues with housing units (e.g., water leaks and mold); and contract work plans lacked attainable, measurable objectives to allow providers to track their progress toward stated objectives. OMH officials made some progress in addressing the problems identified in the initial audit report, partially implementing three of the initial report’s five audit recommendations and not implementing two.

New York City Department of Transportation – New York City Bike Share Program: Oversight of Revenue Collection and Monitoring (2023-N-5) In 2013, the New York City Department of Transportation (DOT) launched the New York City Bike Share program. DOT contracts with a vendor, and the program generates revenues from rides, sponsorship and advertising, liquidated damages assessed for non-compliance with the terms of the agreement with the vendor, and revenue lost due to replacing parking meters with bike stations, which is fixed at $1 million per year. Auditors found DOT was not enforcing all the terms of the agreement or ensuring that the city and its residents were getting the maximum benefit from the program. DOT could not demonstrate that all revenue sources were received and included in the calculation of DOT’s share of the revenues, the vendor complied with all terms of the service level agreements, or the liquidated damages assessed were accurate.

New York Power Authority – Selected Management and Operations Practices – BuildSmart NY/Executive Order 88 (Follow-Up) (2024-F-37)
Executive Order (EO 88), issued on December 28, 2012, mandated a 20% reduction in the average source Energy Usage Intensity (EUI) of State government buildings by April 2020. The organizations subject to EO 88—Affected State Entities—were required to work with the New York Power Authority (NYPA) to achieve their allotted portion of the overall savings. An initial audit, issued September 2023, found NYPA did not reach its goal by April 2020; the actual EUI reduction reported was 14.4%, and when committed (incomplete) projects were added, the reduction in EUI was 22.6%. NYPA officials made progress in addressing the problems identified in the initial audit report. Of the initial report’s five audit recommendations, two were implemented, two were partially implemented, and one was no longer applicable.

State University of New York – Oversight of Study Abroad Programs (2024-S-36) State University of New York (SUNY) Study Abroad Programs (SAPs) include exchange, non-exchange, and faculty-led programs that allow SUNY students the opportunity to participate in educational opportunities globally. The SUNY Office of Global Affairs (SUNY OGA) is responsible for the oversight of SAPs across the SUNY network and each SUNY campus is responsible for administering and monitoring its own SAPs. The audit determined that SUNY OGA could improve its oversight of SAPs in certain areas. Agreements were not consistently submitted by one campus and automated reminders from SUNY OGA to campuses about partnership agreements approaching expiration were not received by officials at one campus. Campuses sent 258 students abroad during the audit scope under the lapsed agreements.

Department of Health: Medicaid Program – Improper Payments for Drugs Without a Federal Drug Rebate Agreement (Follow-Up) (2025-F-20) The Medicaid Drug Rebate Program requires drug manufacturers to enter into a National Drug Rebate Agreement (NDRA) with the Department of Health and Human Services in exchange for state Medicaid coverage of most of the manufacturer’s drugs. The Manufacturers then pay states rebates on those drugs for which Medicaid payments were made. A prior audit, issued in February 2024, found the Department of Health (DOH) lacked adequate oversight of Medicaid managed care payments for drugs, which led to improper managed care organization (MCO) payments for drugs from manufacturers without an NDRA at the time of service. Additionally, auditors found flaws in DOH’s managed care capitation rate adjustment methodology that resulted in nearly $50.3 million in improper MCO payments for drugs from manufacturers without NDRAs at the time of service that were not included in the rate adjustments. DOH officials made some progress in addressing the problems identified in the initial audit report. Of the initial report’s four audit recommendations, one was implemented, one was partially implemented, and two were not implemented.

Primary Hall Preparatory Charter School – Debit Cards (Erie County) Some debit card purchases were not properly approved or adequately supported and lacked documentation to demonstrate that the charges were for a valid school purpose. Debit cards pose significant risks because individuals using them have direct access to a school’s bank account and unauthorized use may not be readily detected. Of the 186 debit card purchases totaling $170,941 that auditors reviewed, 138 totaling $130,295 were not properly approved or adequately supported and 76 totaling $39,398 lacked documentation to demonstrate that the charges were for a valid school purpose. In addition, none of the 186 purchases had evidence of preapproval by the executive director or the board treasurer as required by school policy

Scarborough Fire District – Board Oversight (Westchester County) The board did not provide adequate oversight of the district’s financial operations. Specifically, the board did not adopt written financial policies to establish a system of internal controls that ensure oversight of financial operations, including a code of ethics, investment policy or procurement policy, as required by state law. They did not develop and adopt written multiyear financial and capital plans. The board also did not ensure all commissioners completed the mandatory fiscal oversight training in a timely manner or ensure that the treasurer filed the district’s 2018 through 2024 annual financial reports (AFRs). The 2024 AFR was also 244 days late as of Oct. 31, 2025.

Arkport Joint Fire District – Treasurer’s Records and Reports (Steuben County) The current and former treasurers did not record and report district receipts and disbursements accurately and in a timely manner. The former treasurer inaccurately recorded or did not record 13 receipts totaling $93,978 and 20 disbursements totaling $24,502, among other issues. The former treasurer also did not file the required AFR for the last five fiscal years and the current year is overdue. The current treasurer, appointed in April 2025, did not prepare any records or reports for nine receipts totaling $26,324 or six disbursements totaling $1,878 since their appointment through June 30, 2025. Because the treasurers did not prepare bank reconciliations and the board did not review monthly bank statements or perform an annual audit, these errors and inaccuracies went undetected and uncorrected.

Nichols Joint Fire District – Procurement (Tioga County) The board and district officials did not always use a competitive process to procure goods and services in accordance with statutory requirements. Officials did not adhere to the piggybacking exception or obtain competitive bids for two purchases totaling $319,945 or issue requests for proposals or use any other competitive process before procuring professional services from two vendors totaling $38,873. Officials did not obtain quotes for seven purchases totaling $27,810 or seek competition for fuel purchases, which may have saved the district $3,626 over the audit period.

Hillsdale-Copake Fire District – Cash Disbursements (Columbia County)

The board generally provided adequate oversight of disbursements. Auditors determined that all disbursements were properly authorized, adequately supported, and made for appropriate district purposes. However, the board did not always ensure that its adopted written disbursement policies were followed. Ten checks totaling $249,004, had only the treasurer’s signature. One check for $4,267 payable to the treasurer was not signed by the chairman, but instead by the treasurer herself. In addition, periodic comparisons were not made between canceled check images to the list of approved checks by someone without the check-signing authority.

Ouaquaga Fire Company, Inc. – Company Operations (Broome County) Auditors found the treasurer oversaw all financial operations of the company without any oversight. Given this lack of oversight, the treasurer also paid claims before approval by the board or membership, did not maintain accurate and complete accounting records, and did not submit required reports. Of the 172 claims totaling $185,900 paid by the treasurer before approval, 40 claims, totaling $43,100, did not have adequate supporting documentation to verify that each disbursement was for a proper company purpose. Auditors also identified one claim, totaling $11,800, which was paid twice for the same piece of equipment without a refund issued. The treasurer’s cash balances in the accounting records were not accurate or complete. The treasurer also did not file the required  annual report with OSC on the receipt and use of FFI tax proceeds for the 2023 and 2024 fiscal years.

Village of Washingtonville – Budget Review (Orange County) When a village is authorized by a special or general law to incur debt to liquidate an operating deficit, it must submit the village’s tentative budget for the next fiscal year to the State Comptroller’s office (OSC) for review. The scope of this review was significantly limited by the lack of complete, accurate and current accounting records maintained by the village. Further, village officials have not complied with some of the requirements of the law and certain significant revenue and expenditure projections in the proposed budget appear unreasonable. In addition, the village fully implemented only one of the seven recommendations from OSC’s January 2025 budget review letter. The 2026-27 tentative budget includes a tax levy of $5.6 million. It appears the village may be over the tax cap by as much as $60,300. However, officials provided a proposed local law to override the limit. The village will need $1.1 million to service its debt obligations during 2026-27, which represents about 10% of its annual budget.

Upper Jay Fire District – Audit Follow-Up (Essex County) The purpose of the review was to assess the Upper Jay Fire District’s progress in implementing recommendations in the audit report Upper Jay Fire District – Board Oversight, released in May 2023. The audit determined that district officials did not provide adequate oversight of district financial activities, which hindered their ability to monitor financial activities and increased the risk that improper claims could be paid. Of seven recommendations in the audit, the district fully implemented five, partially implemented one and did not implement one recommendation. Until all recommendations are implemented, the board cannot ensure district assets are fully safeguarded.

Crown Point Fire District – Audit Follow-Up (Essex County) The purpose of this review was to assess the Crown Point Fire District’s progress in implementing the recommendations in the audit report Crown Point Fire District – Board Oversight, released in May 2024. The audit determined that the board did not ensure required annual audits were completed and annual financial reports were filed in a timely manner. To help the board adequately oversee the district’s financial operations, the audit report contained three recommendations. The district implemented one recommendation and partially implemented two recommendations.

###

 

Posted on the Internet during the week ending January 30, 2026

From the Trenches: Why Every Government City Manager Needs Better Meeting Documentation Poor documentation erodes trust and slows government action; modern tools help preserve institutional memory. READ NOW

Building and Evaluating an RFP for Digital Grants Software This guide gives public sector professionals the clarity they need to craft and evaluate a digital grants software RFP. Learn how to set expectations, streamline responses, and select a solution that fits your mission and your budget. DOWNLOAD

See the Future of AI Control Real-time visibility and control over every AI tool running across your organization. See it Live

Get Ahead of AI Compliance Now Create AI policies fast and stay aligned with evolving federal and state AI laws. Build Free Policy 

The 2026 State of Online Payments This sixth annual report delivers essential insights into how, when, and why Americans are paying their bills digitally. DOWNLOAD

Combating Fraud with Data-Driven Insight This thought leadership paper explores how state and local governments can use data analytics and AI to detect emerging risks, reduce improper payments and protect public funds, even amid shrinking budgets and staffing shortages. DOWNLOAD

Navigating Dash Cams: A Guide for Union Engagement Navigating union concerns around dash cams? This guide shows public sector leaders how to build trust, address privacy head-on, and create fair policies that support both safety and morale. DOWNLOAD

Fighting AI with AI: How State and Local Governments Can Stop Fraud This thought leadership paper covers common misconceptions about AI in identity verification and the technology components agencies need to combat to prevent AI-driven fraud. Read more to learn how your agency can enhance its approach to identity verification. DOWNLOAD

A Roadmap for Modernizing Government from the Inside Out State and local government CIOs are leading through rapid change. Their remit is expanding as AI, data and cybersecurity reshape government. This paper discusses the four core priorities CIOs must focus on to meet this moment: modernizing legacy systems, advancing data and AI maturity, leading enterprise security and driving operational efficiency. DOWNLOAD

Public Safety Investment Priorities for 2026 New data highlights efficiency gaps, cybersecurity risk, and funding priorities shaping public safety budgets. Read 

How Leaders Are Preparing for Public Safety in 2026 Insights from agencies nationwide on AI, cybersecurity, and public safety modernization. Download the Report 

Building Government Visibility and Resilience with Autonomous Tech Explore how autonomous technologies strengthen operations, resilience and situational awareness across government. READ NOW 

4 Ways SLED Organizations Are Driving Efficiency Government and education organizations are under growing pressure to do more with fewer resources. This thought leadership white paper explores four proven ways SLED organizations are driving efficiency through modernization, from process mapping and AI-powered automation to cloud adoption and improved constituent experiences. DOWNLOAD