Summaries of, and commentaries on, selected court and administrative decisions and related matters affecting public employers and employees in New York State in particular and possibly in other jurisdictions in general.
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On January 22, 2026, New York State Comptroller Thomas P. DiNapoli’s Fiscal Stress Monitoring System reported that tirty-one school districts were designated in some level of fiscal stress under the New York State Comptroller's Fiscal Stress Monitoring System for the school fiscal year (SY) ending June 30, 2025, up from 22 districts in fiscal stress so designated in the previous school fiscal year.
“In recent years, pandemic-related federal funding as well as increases in state aid have provided districts with significant financial support,” DiNapoli said. “With much of the relief funding having been spent, the number of school districts in fiscal stress has returned to pre-pandemic levels this year. As districts continue to adjust to these conditions, officials should make every effort to ensure budgets are structurally balanced to avoid fiscal problems going forward.”
From SY 2019-20 to 2024-25, school districts spent $4 billion of the nearly $4.6 billion in available federal pandemic relief funding. With this funding dwindling, in SY 2024-25, districts reported spending only $317 million in combined federal pandemic relief funding, a decrease of over 70% from SY 2023-24.
Of the 669 school districts that filed their financial reports in time to be scored in SY 2025, 4.6% have been designated as being in a level of fiscal stress, compared to 3.3% in SY 2024.
DiNapoli’s Fiscal Stress Monitoring System was designed to identify school districts, counties, cities, towns and villages that are having difficulties with budgetary solvency, or the ability to generate enough revenue to meet expenses. School districts receive a fiscal stress score that is based on several factors: year-end fund balance, operating deficits, cash position, and reliance on short-term debt for cashflow. The higher the score, the more severe the level of stress.
This release of scores, which excludes New York City and the “Big Four” City School Districts of Buffalo, Rochester, Syracuse and Yonkers, designated two school districts in “significant fiscal stress,” the highest category – Harrisville Central School District in Lewis County and Mount Vernon School District in Westchester County. Four districts were designated as being in “moderate fiscal stress” and 25 districts were designated as “susceptible to fiscal stress.”
Regionally, the Mohawk Valley had the highest percentage of school districts with a stress designation (10.9%), followed by Central New York (10.4%) and the North County (7%).
In addition, DiNapoli’s report identified 24 chronically stressed school districts which have been designated in a category of stress for five or more years since SY 2012-13, although they may not currently be designated in a level of stress.
DiNapoli urges district officials to take advantage of the resources available to them to monitor factors affecting fiscal stress. These include the Comptroller’s self-assessment tool and financial toolkit, which offer guidance, resources, training and reports, to help officials manage through complex fiscal circumstances.
Lists
School Districts in Stress for Fiscal Year Ending 2025
Complete List of School District Fiscal Stress Scores
Report
Fiscal Stress Monitoring System: School Districts Fiscal Year 2024-25 Results
In reviewing a determination of an administrative agency not made after a quasi-judicial hearing, the Appellate Division noted that the reviewing court's inquiry is limited to determining whether the administrative decision:
1. Is arbitrary and capricious;
2. Without a rational basis in the record; and
3. Has a reasonable basis in law.
The Appellate Division observed that "An agency's interpretation of the statutes and regulations that it administers is entitled to deference, and must be upheld if reasonable".
Further, the court opined that "The agency's determination need only be supported by a rational basis", noting that "An administrative determination is arbitrary and capricious when it exceeds the agency's statutory authority or is made in violation of the Constitution or laws of this State".
In the words of the Appellate Division: "If the agency's determination is rationally based, a reviewing court may not substitute its judgment for that of the agency even if the court might have decided the matter differently" as it is not "for a reviewing court to weigh the evidence or reject the choice made by the agency where the evidence conflicts and room for choice exists ."
Click HERE access the Appellate Division's decision posted on the Internet.
The New York State Workers’ Compensation Board is hosting a Paid Family Leave (PFL) webinar specifically for "employers and HR professionals" to share What’s New for 2026", including:
Each one-hour, online session, will also provide an overview of New York State’s landmark PFL benefits, including:
The sessions are free and there will be time at the end for questions. Each session covers the same content, and interested individuals are invited to choose the date that works best for them.
PFL for employers and HR professionals are schedule to be held on:
In this appeal to the Commissioner of Education the Respondent [School District] contended that the appeal must be dismissed as untimely, among other reasons.
The Commissioner agreed, explaining that an appeal to the Commissioner of Education must be commenced within 30 days from the administrative decision or act complained of, "unless any delay is excused by the Commissioner for good cause shown" and it is the actual knowledge of the facts underlying a claim that begins the running of the 30-day period in which the aggrieved party may bring the proceeding.
In this instance the Commissioner noted that the Petitioners had received actual notice of the School District's decision on June 27, 2025 but did not commence their appeal until August 25, 2025, more than 30 days after had knowledge of the School District's ruling.
Although Petitioners had requested the School District reconsider its decision, the Commissioner noted that such a request does not extend the time limits within which a petitioner may file an appeal to the Commissioner.
As Petitioners did not offer any explanation for the delay in their submitting their appeal to the Commissioner, the Commissioner held that Petitioner's appeal must be dismissed as untimely.
Click HERE to access the Commissioner's decision posted on the Internet.