The Creighton Elementary District policy review committee on Oct. 31 reviewed proposed revisions to student concerns, complaints and grievance policies (JII and draft 201) and agreed to keep the new policy's narrower grievance framework while adding a separate district-level procedure for lower-level complaints and concerns.

Committee chair Adriana described the distinction under discussion: "a grievance is, like, for, like, anti discrimination or is it something that goes against policy and law," and members said the new draft appeared to narrow grievances to allegations that implicate law or district policy while omitting the lower-level complaint language that had appeared in the older policy (JII). Committee members said they wanted a separate, standardized process for lower-level concerns that could live as a district procedure or regulation rather than in the core policy.

Members debated whether the policy should use "may" or "shall" when assigning responsibility. James said he bristled at discretionary "may" language and asked that key duties be specified as "shall." The group proposed revising the sentence that currently reads "the superintendent may develop separate grievance procedures and designate a compliance officer" to clarify that the superintendent would provide or authorize a standardized complaint/concern procedure for sites (with the option to delegate to a site administrator or designee).

On forms and access, members agreed that lower-level complaint/concern forms should be standardized and treated as regulations or exhibits rather than lengthy policy text. They discussed posting requirements, with some members saying forms need only be readily accessible (for example via the district website or handbook) rather than physically posted in every building.

Committee members noted the new draft omitted explicit withdrawal and timeline language. They discussed possible time limits for filing or for barring resubmission after withdrawal (proposals ranged from 30 school days to 180 calendar days) and raised concerns that Title IX and other federal rules might prohibit limiting withdrawal or resubmission in certain cases. The committee voted to add a written comment asking the district's legal counsel to confirm whether any proposed timeline language would conflict with Title IX or other statutes and to return with recommended wording.

No policy vote was taken at this meeting. Instead the committee recorded action items: (1) add a district procedure and standardized forms for "concerns/complaints" (separate from grievance procedures); (2) revise discretionary language where appropriate from "may" to "shall" as the committee identifies mandatory duties; and (3) request legal review on withdrawal/timeline language for Title IX compliance.

Members said the regulations (R JIIR / 1201.a) appeared to cover much of the detailed process but recommended copying any explicit withdrawal language into the regulations/procedures if retained. Adriana said she would track insertion points and that staff would present a cleaned draft and the proposed forms at the next meeting for final comment.

The committee set as homework that members review the drafted complaint procedure, the proposed forms, and any legal guidance before the next meeting.